On August 17, President of the Association of State and Provincial Psychology Boards (ASPPB), Sharon Lightfoot, PhD, announced that the ASPPB Board of Directors voted to rescind their 2017 decision, a decision which would have essentially mandated a second exam for those seeking a license in psychology.
“Based on your input this summer and our own priority-setting,” wrote Lightfoot, “the ASPPB Board of Directors on Sunday August 12, passed a motion to rescind our decision of August 2017 and announced to you in October that made the Enhanced EPPP (including both knowledge and skills portions) as the single licensure exam offered by the ASPPB.”
“We will continue toward launch of the Enhanced EPPP in 2020,” Lightfoot said, “and make it available to states and provinces interested in serving as early adopters. We are lifting the requirement for use of the Enhanced EPPP and are lifting the deadline for implementation.”
Lightfoot’s announcement came after a blistering critique of ASPPB’s methods, sent July 20 on behalf of the Louisiana State Board of Examiners of Psychologists (LSBEP) and signed by Executive Director Jaime Monic. The letter listed numerous criticisms and was addressed to the ASPPB Board of Directors, ASPPB members, and copied to the administrators at state psychology boards across the US and Canada.
“LSBEP does not believe that data exists demonstrating that psychologists are not already held to high standards of competence,” wrote Monic. “The data that exists in terms of complaints and disciplinary actions toward psychologists also does not support the theory that competency problems abound in the field of psychology. In fact, ASPPB’s own data regarding complaint patterns notes that ‘Incompetence’ is not even among the top 10 reasons psychologists were disciplined in 2016 (the most recent year of date reported). Moreover, reported disciplinary action (for any reason) has steadily decreased since 2013.”
“Nationwide, ASPPB reported that only 12 licenses were revoked in both 2015 and 2016,” Monic said. “These numbers are exceedingly low and do not suggests that public safety is in question. Therefore, LSBEP is not convinced that another exam is justified by the current data. Prior to instituting additional barriers to the process of licensure by the LSBEP, clear rationale must be presented for their necessity.”
The letter also noted that there is a strong anti-regulatory climate in the country and that Board members are concerned that additional barriers to practice would draw the attention of Louisiana legislators. They also criticized the idea put forth by the ASPPB that additional testing for psychologists would bring the professional psychology in line with medical training, saying that these two professions are inherently different.
Monic, on behalf of the Board, also pointed out concerns with validity and test construction. “Psychology has long held itself as the profession with the most expertise surrounding test design and construction. We are uniquely qualified to create and implement assessments. We are trained that tests are not used prior to establishing validity and reliability. Changing statutes and rules preemptively before we know that the test is necessary and valid is not prudent and would prevent us from choosing another, perhaps better, exam from another vendor.”
The authors also criticized ASPPB’s role and reminded them that they are not a regulating body and have no jurisdiction in Louisiana, and that the decision is “…an overstep.”
“We are concerned that ASPPB has lost sight of their original mission, which from this board’s understanding was limited to facilitating communication between various member jurisdictions,” Monic and the LSBEP pointed out, and that mandatory decisions on EPPP-2 do not fit this role but rather the role of a vendor providing a product.
The expansion of the current licensing exam, called the EPPP2, has been a source of controversy in Louisiana and for some other state boards.
In 2016, ASPPB CEO, Dr. Stephen DeMers, told the state boards that the ASPPB Board of Directors approved the development and implementation of a second examination to assess competency-based skills. Through 2016 and 2017 the new “skills” test was promoted as a voluntary addition to the Examination for Professional Practice in Psychology (EPPP).
Through 2016 and 2017 objections to the EPPP-2 mounted, mostly from student and early career psychologist organizations. In Louisiana, Dr. Amy Henke, then a Director on the Executive Council of the Louisiana Psychological Association (LPA) and Co-Chair of the LPA Early Career Psychologists Committee, put forth a Resolution to oppose the EPPP-2 for Louisiana. The Resolution passed unanimously.
However, then, in a surprise move, the ASPPB Board voted to make the new test mandatory. In late 2017 Dr. DeMers announced that the EPPP-2 was no longer going to be voluntary and that the price would increase from $600 to $1200 for the two sections.
Issues of need and statistical validity have been concerns for Dr. Henke, the state psychology board, and the state psychological association. She took up the banner for the young doctoral graduates, who will bear the financial and emotional burdens of the proposed new test. Other LPA members began looking closely at the scientific need for the new test and also the methodology.
“There is no evidence that the public is facing some sort of previously unheard of crisis in terms of safety from currently practicing psychologists,” said Henke, who currently serves on the LSBEP.
This past April Dr. DeMers met with LSBEP members and representatives of LPA and others about the objections. After the meeting, Dr. Kim VanGeffen, LPA Past-President and current Chair of the Professional Affairs Committee for LPA, said, “Dr. DeMers acknowledged that, currently, there is not really any research on the validity of the EPPP-2.
“The EPPP2 committee believes that this exam has face validity and content validity,” VanGeffen said. “They are satisfied that these types of validity are acceptable for the EPPP2. There do not seem to be any plans to obtain predictive validity nor does the EPPP2 committee believe that establishing this type of validity is necessary,” she said.
Dr. Marc Zimmermann, past LSBEP board member and Chair of the LPA Medical Psychology Committee, also attended DeMers’ meeting. “I think the idea of measuring a professional’s skills before turning him/her lose on the public is a good idea. I do not think this attempt hits the mark,” Zimmermann said. “When the Board does oral examinations we come closer to this by allowing the
person to provide reasoning for their projected behaviors.”
“He [Dr. DeMers] stated that there is no predictive validity,” said Zimmermann. “He also threw in that none of the national tests had predictive validity. He reported that content validity was the accepted standard because a test with predictive validity could not be constructed.”
“He said several times that they were just a vendor, but they have put themselves in the position of being the only vendor,” said Dr. Zimmermann, and it impressed him that, “… DeMers had the
temerity to try to sell us something that does not meet the standard that psychological tests being published are expected to have.”
In Dr. Lightfoot’s announcement, she wrote, “our goal is to provide the best possible resource to you to evaluate your candidates. All jurisdictions will continue to receive detailed information about the nature, content, validity, and utility of the Enhanced EPPP as that information becomes available during 2020 and beyond.” The ASPPB is a private, nonprofit, 501(c) tax-exempt corporation located in Tyrone, Georgia. The company states its mission is to “Facilitate communication among member jurisdictions about licensure, certification, and mobility of professional psychologists.”
ASPPB’s main income producing product is the national exam for psychologists, which brings in about $5,000,000 in gross sales each year. They have a few other products, such as the Psychology Interjurisdictional Compact (PSYPACT), a service to coordinate psychologists working across state lines. In 2016 they listed assets of $8,954,240.
The “members” are about 65 representatives from regulatory boards from across the United States and Canada. The boards pay dues to be a member of ASPPB.
While many members are government officials, ASPPB does not follow open meetings laws. Deliberations and decisions are private. “If you are not a member or staff of an ASPPB Member Psychology Regulatory Board or an individual member, you are not eligible to access this section of our website,” they write. Their conferences are also members only.
The company it also owns the intellectual property rights to the EPPP and the data generated by the testing program, which they appear to have acquired in or around 2013 from PES.
ASPPB officials said that the change was “mutually beneficial because ASPPB can now provide a simplified agreement that is more specific to the needs of psychology licensure boards. In addition, the renewal of contracts is expected to be more efficient…” And, “Finally, as voting members of ASPPB, each jurisdiction exercises more oversight of this important examination service by contracting directly with ASPPB for examination services.”
Over the last two years, Henke and others have also pointed to multiple hurdles that candidatesalready must clear, including two years of supervision, a written exam, oral exam, background check, and jurisprudence exam. Additionally, the law allows the board to require additional physical and psychological assessments whenever needed, Henke has pointed out.
However, Dr. Emil Rodolfa, involved with test development at ASPPB, has said he questions if these standards are enough, saying that supervisors have “… difficulty providing accurate evaluations of their supervisees to others who may have to evaluate the supervisee’s competency.”
Dr. Henke has said, “I am particularly concerned about ASPPB Rescinds Decision Continued regulatory boards encroaching ownership of training standards. The goal of a regulatory board, in my personal opinion, is to provide the least restrictive amount of guidelines possible in order to protect the safety of the public.”
Dr. Rodolfa disagrees and said, “Licensing boards have a mandate to ensure that the professionals they license are competent. Competence is comprised of the integrated use of knowledge, skills, attitudes and values.”
[Editors Note: The Times has reported on this topic over a number of years. See reports in past issues, Vol 7, No. 6, No. 5, No. 8, and No. 9, and Vol. 8, No. 12, and Vol. 9, No. 5, available on our website.]