Public records and emails obtained from the state psychology board indicate that the Association of State and Provincial Psychology Boards (ASPPB) did not alert its members that a major change in policy was to be considered at the Board of Directors meeting, held on October 17 in Waikoloa, Hawaii. Furthermore, the policy change topic did not appear on the agenda for the members’ meeting that followed, held October 18 to 22, also in Hawaii.
The major policy change––the decision to mandate the Part 2 of the Examination for Professional Practice in Psychology (EPPP) by combining it with Part 1, and doubling the price from $600 to $1200, was announced to jurisdictional members by email on Saturday, October 21. Robin Pence, an assistant at ASPPB, notified members that the Part 2 would no longer be optional.
Email records and published agendas show no items that would alert members to a major change in policy. A “Business Session” was listed for Thursday, October 19, but the EPPP was not listed. Also, while a revised agenda was sent out, for the state board administrators, it included only an “Education Session” about the “EPPP 1 and 2.”
On Saturday, October 21, Robin Pence notified the Louisiana State Board of Examiners of Psychology (LSBEP), who did not send a delegate to Hawaii due to costs, by way of the ASPPB Listserv, of the change.
“I am writing to you to share with all ASPPB member jurisdictions some important new developments about the EPPP Part 1 and Part 2 that were announced today during the 2017 ASPPB Annual Meeting. These new developments represent an important change from the original thinking about how ASPPB would implement the EPPP Part 2. The ASPPB Board of Directors, based on a number of factors, including feedback from our member jurisdictions and input from our legal counsel, has determined that the EPPP Part 2 is a necessary enhancement, and therefore an essential component of the EPPP.” She said that both parts will “… be the licensing exam for psychologists in the U.S.”
In the Listserv discussion on October 21, Dr. Kathleen Doyle of the New York State regulatory board asked, “… was this determination made by a vote of the members at the annual meeting, or a determination by the Board of Directors?”
On October 27, Dr. DeMers answered, writing, “The determination was voted on by the Board of Directors and presented at the annual meeting we just had this month. After we made the announcement at the meeting, we discussed the rationale and other issues and answered questions posed by the membership. Based on the overwhelming reaction at the meeting, it seemed that our members were supportive of these decisions and more
than a few appreciated the vision that lead to them.”
Dr. Doyle also wrote, “… please provide the rationale for the determination how the legal defensibility for the examination would depend on both parts being seen as one examination?”
To Doyle’s question about rationale, Dr. DeMers wrote, “Our legal counsel has advised us that he has concerns for us and for our jurisdictions if we allow some jurisdictions to use a lesser exam when a better exam is available and in use in other jurisdictions. Candidates failing either Part 1 or Part 2 would have a basis for claiming that they were not given a comparable exam to that offered in other jurisdictions, regardless of which part of the EPPP was failed. These concerns about legal defensibility center on potential challenges to both ASPPB and the individual jurisdictions when the need to assess both knowledge and skills to adequately assess professional competence has been publicly advanced, and the validity of both Part 1 and Part 2 has been demonstrated empirically. […]”
Dr. Doyle responded, “We have several concerns with the examination as it is being presented and we will send these concerns to you soon,” and said the rational “does not appear to make sense.”
“ASPPB is a vendor,” Doyle wrote. “As an organization, it was created to develop some kind of an examination that jurisdictions might use to meet their licensing responsibility and to some extent enable an examination to be endorsed by other jurisdictions if they choose to do so.”
She wrote, “The scopes of practice of the jurisdictions differ; few are the same. The requirements for practice differ, as well as the authority to practice. Each jurisdiction is an independent entity which is fully responsible for determining what it citizens need. ASPPB cannot ‘allow’ any jurisdiction to take any action regarding their licensees and no jurisdiction can fall back on saying ‘ASPPB made me do it.’”
“It was formed to provide its members with products that they might need to carry out their duties, or to gather information for members who might need it. It was formed to enable some form of unity among the many jurisdictions, but not to make regulatory decisions for the members. Hopefully, the Board of Directors will undertake additional consideration of this determination,” Doyle noted.
On October 27, Dr. DeMers wrote, “… ASPPB’s position is this is a necessary enhancement and revision of an existing exam that is used as a licensure requirement in most jurisdictions. The enhanced EPPP is not an additional requirement but a change to an existing requirement. ASPPB is a vendor offering a product to jurisdictions and this product is being updated and improved…”
Other Listserv members asked questions about various problems with administration and scoring of the sections if a candidate was retaking part of the new exam.
Dr. Amy Henke emailed members of the psychology board about the issues, writing, “I’m not surprised and I’m not sure there is much we can do. I’m very disappointed in the psychology community for allowing this to happen.” In one message she said she would contact Dr. Doyle.
Current Chair of the state board, Dr. Phil Griffin, wrote to Executive Director Ms. Jaime Monic, saying, “The public (psychologists, current and future) are not liking this at all.” On October 23, in an email from past Chair, Dr. Marc Zimmermann noted his concerns to board members.
“Today I received a communication from ASPPB. I may be paranoid, but when I read between the lines it appears that the EPPP-2 idea is not going over well so they are going to force it upon the various jurisdictions. I have long had concerns that ASPPB wishes to become the credentialing agency for psychology. I believe the Board should consider options. With or without other Boards the LSBEP should consider an alternative to the EPPP.”
“This examination is a huge moneymaker for ASPPB and it empowers them to flex muscles in their interest and not the various jurisdictions they purport to represent. […]”
On October 23, Ms. Monic responded back to Zimmermann, saying, “I just finished reading that communication also. You’re thinking is along the same lines of current board members also.”
In 2016 ASPPB had announced the Step 2 exam and objections mounted, mostly from student and early career psychologist organizations.
Last year 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 in LPA, put forth a Resolution to oppose the Step 2 for Louisiana, which passed unanimously.
Objections, from Henke and others, involve technical and scientific issues, but also the criticism that there is no problem that the new test needs to solve. “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 Dr. Henke in 2016.