Education Standards
of
Profess
ion
Should Serve as Foundation for
State Regulation
of
Professi onal Training
.1
0 Linder-Crow, Ph.D. and Charles
A.
Faltz,
PhD.
California Psychologi
cal
Association
In/h
e position stateme
nt
outlined below CPA discusses our continuing
co
ncern ahout recent credc
I11
ialing decisions
mad
e
by
th
e Board
of
Psychology
slaffto
r
equ
ire individuals to repeat
an
entire Supervised
Prof
essional Experience because
of
a Supervision Agreement
Form
deficiency.
Th
ese decisions have been bas
ed
on
the
conclusion/hal a
discrepancy in the Supervision Agrecmcnl
Form
is sufficient evidence
10
conclude thaI the train
ee's
over
all
SPE
pCI/ormQnce, notwithstanding other,
much
stronger ev
id
ence
of
acceptable
pCljormance,
has
1101
mel
the
necessQly minimal
pelformance standard
of
the
pr
ofession
and
thaI the
trainee would reasonably
be
considered
to
r
ep
rese
nt
a danger to the
public
unless the entire training experience was repeated.
Back
gr
'o und
Professions su
ch
as psychology establish and maintai n the credentialing criter
ia
for
practice and the professional standards for ethically practic
in
g the profession. When the
State determines th
at
th
e practice
of
the profession affects the health, saf
et
y and welfare
of
the public, the State asserts the lawful authority
to
license people
who
have
l11et
the
credentialing standards
of
the
pr
ofessional
co
mmunity as well as to oversee the licensed
practice
of
psychology pursuant to the profession
al
standards
of
the profession.
The
point
we make here
is
that the State does not set its
OW
I1
i
nd
epe
ndent standar
ds
for professional
training but establishes
it
s regulatory oversight to
be
consiste
nt
with
th
e
prof
ession
's
standards
for
crcdcntialing and ethical practice.
III
its regulatory oversight
of
credcntialin
g,
the State, by definition, uses the standards
of
the profession
to
determine which persons have, reasonably, satisfied
the
minimum
standards
of
the multidimensional, overall training guidelines
of
the professi
on
so they
are qualified to practice without endangering the
pu
blic.
There are a great llla
ll
Y elements
of
a training program.
The
professioll, logically,
assumes that some clements
of
the training program arc strongly pr
ed
ictive
of
sat
isf
ac
tory
performance as a psychologist. The Board
of
Psychology has identified the overall
perrormance ratings
of
the tra
in
ee by
th
e supervisor as the primary predictor
of
minimally
satisfactory perrormance
by
the trainee
and
the corresponding safety
orthe
public. That
policy
of
th
e Board
is
consistent wi
th
a professional standard
of
the profession and was
accepted
by
the Board after a determinati
on
thaI
the post-training, cross-sectional
assessment
of
performance by oral examiners was less useful as a global predic
to
r
of
performance.
It
fo
ll
ows that each
of
the many other, individu
al
clements
of
training
is
likely to be
assigned a
di
fferent,
Je
sser weight by the profession
in
predicting the overall acceptable
level
of
performance by a trainee
wh
o had completed the training program. It is
in
this
co
ntext
th
at CPA, representing the profession
of
psycholog
y,
argues that the BOP and the
Board st
aff
, must be
ab
le to demonstrate that the failure to timely compl
ete
the
Supervision Agreement f o
rm
,
in
it
se
l
f,
overrides
all
other predictors used by the
profession and the su
pe
r
vi
sor
's
judgmellts before conclud
in
g that the trainee reasonably
represents a threat to the public
and
that only a repeat of the same or
si
milar training
program is required
as
a remedy.
Prob
lem
It
has
co
me to the attention
of
CPA that
in
recent months the Boa
rd
staff has been
mi
si
nterpreting established Board policy
in
its response to situations
in
volving a
1051
Supervision Agreement Form or a failure to timely com
pl
ete
th
e Form
in
a training
program.
In
these cases,
th
e training programs have otherwise met their
ob
ligation to
prepare its graduates to perform at a level m
in
ima
ll
y acceptable for consum
er
protection,
and have provided documenta
ti
on
to
demonstrate thi
s.
in these cases, despite the ample
documentation provided
to
the BOP, the staff has de
ni
ed the hours and noti
fi
ed the
individual and the program that a repeat
of
the full SPE is required. It is our contention
that
to
take a position that a mistake in the use
of
the SPE
fo
rm
is, by itself. reasonably
predicti
ve
of
a danger to the pub
li
c is fully inconsistent with t
he
trai
ni
ng
standards
of
the
profession.
We
be
li
eve that as non-psychologists, the Board staff needs to rely heavi
ly
on
Board professional members in discerning how training
perf
ormance is to be evaluated.
In
tum, the Boa
rd
pr
ofessional staff may wish to consult closely with training experts
in
the professi
on
to
determ
in
e the relationsh
ip
such a deficiency
ha
s to the a
ssess
ment
of
ev
era!! p
erforrmm-:::e
of
the trai!1ee. This
is
p~rti
ct
!!
a
!"!
y
true when the decis
ion
s
~
e
ing
handed down have
suc
h an enormous impact on individuals
and
the or
ga
ni
za
ti
ons where
they work as service
pr
oviders.
It is
re
levant that
th
e Supervision Agreement Form is a fairly rece
nt
development in
psychology training. The Form
is
a use
ful
de
vice
in
the training process and its use is
recommended today by
th
e profession. But to put the Form into perspec
ti
ve, the lack
of
t
hi
s Fonn
in
the
recent past did not result
in
danger to the publi
c.
The Board staff has no
basis for deciding that the fa
il
ure to complete the Form, in itsel
f,
is regarded by
th
e
professi
on
as a deficiency so overwhelming that it should negate the overall training
experience or that a reasonable
ba
sis e
xi
sts for assuming a danger
to
the
pub
li
c.
Con
cl
usions and R
ecomme
nd
at
ions
The Board staff decisions to disallow the entire tra
in
ing experience based
pr
imarily
on
a
deficien
cy
in
completing
th
e Supervision Agreement Fo
rm
represents a misunderstanding
of
how tbe profession evaluates the rela
ti
ve
contributions
oflh
e elements
of
training
programs to a minimally acceptable training experience.
It is imperative
that
the Board's
non-psychologist st
aff
work more
cl
osely with the Board
's
Professi
on
al
M
em
bers in
2
implementing the policy the Board developed
in
this area.
1t
is recommended that
the
Board seek
expe11
education and training input from the profession should it believe
it
needs to determine the actual effect
on
minimal professional competency that might be
caused by a mistake in completing and retaining the Supervision Agreement Form.
It
is
also recommended that the Board consider
amending
its regulation which requires
supervisors to regularly complete a course
in
training.
It
may
be appropriate for the
Board
to include
in
its regulations that all introductory courses in supervision include the
relevant sections
of
state law and regulation and clear information about how to stay
updated with changes
in
law relevant to supervising psychologists in training.
Finally, we suggest again that the Board
staff
decisions to disallow an entire training
experience based on a deficiency concerning the
Supervis
i
on
Agreement Form is
an
action entirely disproportionate to the deficiency's effect
on
minimally acceptable
training. Such a decision delays the trainee's training for
nea
rl
y a year and results in the
trainee losing, in due course, an entire year
of
compensation as a licensed psychologist.
Such a monetary effect
is
much harsher than, and disproportionate to, those disciplinary
decisions the Board routinely
makes
where there is actual evidence
of
clear harm
to
the
public.
The requirement that the Supervision Agreement
Form
be used in training programs is
fully justified, and its use is consistent with the standards
of
profession.
When
the
Board
finds a deficiency
in
this area, along with
cl
ear evidence that the trainee's
performance
was also below a minimally acceptable level, the denial
of
hours may also
be
justifia
ble.
However, when
am
ple evidence is presented to the Board
of
Psychology
demonstrating
a
well-conceived and executed training program, but
where
a deficiency in the use
of
the
SPE
Form is discovered, we contend that
it
is not
reasonable
to necessarily conclude
that
the trainee's performance was below standard.
Ra
t
her
than
requiring the trainee
to
stmi
again at the
begil111ing
of
their training, we believe that a
more
appropriate response is
to
carefully consider and weigh the rest
of
the documentation
of
the training, require
both
the trainee and Supervisor to acknowledge the mistake in the use
of
the
form
,
explain
it,
and take steps to educate themselves about the training requirements in statute and.
regulation.
We
believe this approach will provide a
more
balanced assessment
of
the
trainee's experience.
3
Board
of
P
syc
hology
2005 Evergreen Street. Suite 1400, Sacramento,
CA
95815
P
(9
16J 263-2699 F [916) 263-2308 1 www.psychboard.ca
.g
ov
CALIFORNIA BOA
RD
OF
PSYCHOLOGY
SUPERVISION AGREEMENT FOR SUPERVISED PROFESSIONAL EXPERIENCE
(PURSUANT
TO
SECTION 1387 OF TITLE
16
, CALIFORNIA CODE OF REGULATIONS
(CCR))
(All
CCR
or California Code
of
Regulations section refer to Title
16
)
The
purpose
of
an
agreement is to ensure that both
th
e supervisor and supervisee understand
and have a plan
to
comply with the laws and regulations related to the accrual of supervised
professional experience (SPEl, Please
re
view CCR sections 1387
et
seq. prior to developing
your plan for SPE. This agreement is to be reviewed, completed, and signed
by
both the
primary supervisor and supervisee prior to the commencement
of
t
he
supervised professional
experience. Experience
prior
to
preparation
of
a
plan
may
not
count
toward
qualifying
the
supervisee
for
licensure
, The
primary
supervisor
agrees to
maintain
this
agreement
until
the trainee
completes
the
SPE
and
requests
the
primary
supervisor
to
rate and
verify
the
experience. The
primary
supervisor
is
responsible
for
submitting
this
agreement
directly
to the
Board
along
with
the
Verification
of
Experience
upon
completion
of
the
experience
outlined
in
this document. FOR PSYCHOLOGICAL ASSISTANTS
IN
PRIVATE
PRACTICE SETIING, THIS FORM MUST BE COMPLETED AND
SUBMITIED
TO
THE
BOARD
FOR
PRE-APPROVAL PRIOR TO THE ACCRUAL OF HOURS.
PRIMARYSUPERVISOR
:
________
__
~=c.~O<.~=o~""~~=o~------------------
(PM
t 011)'1'< : F
..
.
Nome,
M,d
dl
e
Ini
ha
l
an<l
Lo
st Nam
a)
License Type, _
________
__
License Number,
_________
__
DELEGATED
SUPERVISOR(S):'
______
--.==========
____________
_
-
pmlc
l Type:
F~
'
I
""am
e,
....
dd~
l
'li~
al
and
La.
t
Nam
_)
License Type"'
___
____
__
__
License Number:
_________
_
TRA
INEE:
_________
________
__
~~~~~"""""~~~~~,----------------
IPn
nlorType
: F
ir
st
Name
.
M,d
d"
I
llIlla
l
allo'
L .
..
Na
me)
Registration
Number
(if applicable):
_____________
__
INTRODUCTION
The
above
trainee
will
be
delivering
psychological
servi
ces
describ
ed
belo
w
under
one
of
the
following
c
ategories
un
der
the
California
Business
and
Professions
Code. (check appropriate category):
Business and Professions Code (8PC) Secti
on
2909
(d) - Registered Psychologist
BPe
Se
ct
ion 2910 - salaried employee
of
an exempt setting (Any government agency, public
schools or accredit
ed
or
state approved academic institutions)
BPC Section
291
1 - intern in a formal internship placement
o American Psychological Association (APA)
Q Association
fo
r Psychology Postdoctoral and Internship Centers
(APP
le
)
o California Psychology Internship Council (CAPIC)
BPC Section
2913 - registered psychological assistant (For accrual
of
hours
in
a private practice
setting, the plan for SPE
must
be
pre-approved
by
the Board before the accrual of hours)
Department of Mental Health Waiver (We
I.
&
tns
t.
Code
§ 5751 .2)
(Please provide a copy of the
DMH
Waiver)
Qut of State Experi
ence
What
is
th
e start and anticipated co
mp
letion dates
of
th
e above checked category?
Start Date:
__
____
_
Anti
ci
pated Completion
Date
:
____
__
_ _
What professional title is the trainee being assigned In this setting? (On
ly
use
titles that are co
nsistent
with
Sections
2909
(d),
2911, 2913
of
the Business and Professions Code)
Provide the address(es), location(s), and telephone number(s) where the supervisee
will perform
psychologica
l services.
On a separate page type
your
responses
to
the followi
ng
items:
1. Describe the specific duties the supervisee will perform as they engage
in
psychological
activities that directly serve to prepare the supervi
see
for the independent practice
of
psychology once licensed.
2. Summarize the goals and objectives
of
this plan for SPE, including how socialization into the
profession will
be
achieved.
When answering each
of
the above questions, describe how the plan will meet the requirements
of
SPE as:
• an organized program that consists
of
a planned, st
ru
ctured and administered sequence
of professionally supervised comprehens
iv
e clinical training
ex
periences. SPE shall have
a l
og
ical training sequence that builds up
on
the
sk
ill
s and competencies
of
the trainee
to
prepare him
or
her for
the
independent practice
of
psychology once he
or
she becomes
li
censed.
• a plan that includes socialization into the profession
of
psychology and how this
socialization will be augmented by integrated modalities including mentoring, didactic
exposure,
ro
le modeling, enactment, observational! vicarious learning, supervision and
consu1tative guidance.
• planned activities that address the integration
of
current
and
evolving psychological
knowledge, principles,
and
theories to the professional delivery
of
psychological services
to the consumer public.
-----mm-Supervision Requirements----
m
--
----
IN
ADDIT
IDN
TO
THE
ABOVE
PROVISIONS,
THE
FOLLOWING PROVISI
ONS
OF
THIS
AG
REEMENT
ARE
TO
BE COMPLETED
BY
BOTH THE PRIMARY
SUPERV
ISOR AND
THE
TRAINEE AND
REVIEWED
BY
ALL SUPERV
ISORS
:
In any supervised professional experience,
the
primary supervisor assumes professional and ethical
responsibility for the psychological functions performed by the trainee. The supervisor
is
also responsible
for ensuring that t
he
supervised professional experience meets all
re
quirements set forth
in
CCR
section
1387 and, in the case of registered psychological aSSistants,
in
CCR section
1391
.
Su
pervised professional experience under Section 1387 stat
es
:
SP
E is defined
as
on orga
ni
zed
program t
ha
t consists
of
a planned, structur
ed
and a
dmini
st
rative sequence
of
pr
of
eSS
i
ona
l
supervised comprehensive
trainin
g experiences.
The
supervisor(s)
and
trainee
agree
as
follows:
(Please
check
yes
or
no
as
it
is
reviewed).
SUPERV
ISION
REQUIREMENTS
: (California Code
of
Regulations Section 1387)
Yes No
1.
The trainee will be provided with at least 1
hour
of face·to·face, direct, individual
supervision by the primary supervisor each
week
.
2.
The trainee will be provided with supervision
for
10% of the total time worked each week.
3.
A maximum
of
forty· four (44) hours per
week
, including the required 10% superv
isi
on will
be
credited toward meeting the supervised professional experience requirement.
4.
The trainee shall have no proprietary interest in the business of the primary
or
delegated
supervisor(s) and shall not serve
in
any capacity whi
ch
would hold influence
over
the
primary or delegated supervisor(s)' judgment in providing supervision.
5.
Ne
ither the primary supervisor nor any delegated supervisors will receive
payment
,
monetary or otherwise, from Ihe trainee for
the
purpose of providing supervision.
6.
The trainee will not function under any other license to accrue SPE.
7.
The supervisor{s) will maintain a clear and accurate record of trainee supervision. Th
is
record may be in the form of
the
SPE log required to be maintained by the trainee
pursuant
10
section 1387.5 of Title 16, of the Code of Regulations .
. ,
QUA
LI
FI
CAT
IONS AND RESPONSIBILITI
ES
OF
PR
IMARY SUPERVISORS: (CCR Section
1387
.1)
THE PRIMARY SUPERVISOR:
1. Must
be
a licensed psychologist, except Board certified psychiatrists may be
primary
supervisors
of
thei
r own registered psycholog
ic
al assistants.
2.
Sha
ll possess and maintain a valid, active license free
of
any formal discipl
in
ary
action,
and will notify
the
trainee of any disciplinary action that affects his or her ability
or
qualifications to supervise.
3.
Shall be employed by the same work setting as the trainee.
4. Shall be
aVOlilabJe
to the trainee 100% of the time the trainee
is
working. This availability
may be
in
person or through telephone, beeper or other appropriate technologi
es
.
5.
Shall complete a minimum of six hours of supervision coursework every two
years
as
described
in
section 1387.1(b).
6.
Shall
be
in
compliance at all times with the provisions of the Psychology Licensing
LOIw
or
the Medical Practice
Act
, whichever might apply, and the regulations adopted pursuant to
these
Jaws.
7.
____
&
Sha
ll be responsible for ensu
ri
ng
that the trainee
is
in
compliance at
aU
times with the
provisions of the Psychology Licensing
law
or the Medical Practice Act, whichever might
apply, and the regulations adopted pursuant to these laws.
8. _
& Shall ensure that all SPE and record keeping is conducted
in
compliance with the Eth
ic
al
Principles and Code of Conduct of the American Psychological Association.
9.
_ Shall monitor
the
welfare
of
the trainee's assigned clients.
10. Prior to rendering services shall ensure that the trainee inform each client or patient is
unlicensed and is functioning under the direction and supervision of the supervisor and
that
any
fees paid for the services
of
the trainee must
be
paid directly to the primary
supervisor or employer.
11
.
Shall monitor the performance and professional development
of
the
trainee.
12
. Shall ensure that the supervisor has the education, training, and experience
in
the
area(s)
of
psychological practice supervised.
13. Shall have no familial, intimate or other relationship with the trainee that would
compromise the supervisor's effectiveness, and/or
would
violate the Ethical Principles
and Code
of
Conduct
of
the American Psychological Association.
14. Shall not supervise a trainee
who
is now or ever
has
been a psychotherapy client
of
the
supervisor.
15
.
Shall
not
exploit or engage
in
sexual relationships or any other sexual contact with t
he
trainee.
16.
Shall provide a copy of the pamphlet
'P
rofessional
Therapy
Never Includes Sex" to the
trainee.
17.
Shall monitor the supervision performance of all delegated supervisors.
PRIMARY SUPERVISOR'S SIGNATURE
I understand and accept this agreement, including, but not limited to
my
duties
as
a supervisor,
and
wi
ll
ensure to the best
of
my
abilities that the trainee
and
all delegated supervisors will comply with
the
terms
and
conditions
of
this agreement. All the foregoing is true and
correct
Name (Print or Type)
__
____________
_
License
#:
______
_
Signature
___________________
_
Email Address
__________________
_ Dale
_______
_
QUA
LIFICATIONS
AND
RESPONSIBI
LI
TIES OF DELEGATED
SUPERV
ISORS: (CCR Section 1387.2)
THE DELEGATED SUPERVISORI
S)
:
1. _ Must be a licensed psychologist or those other licensed mental health professionals listed
in
section 1387(c)(1).
2. _ Shall possess and maintain a valid, active license free
of
any
formal disciplinary action, and
will notify the trainee
and
primary supervisor of any disciplinary action or change
in
license
status that affects his or her ability
or
qualifications to supervise.
3. _ Shall be in compliance
at
all times with the provisions
of
the
Psychology Licensing
Law
and
the regulations adopted pursuant to this la
w.
4. _ Shall
be
responsible for ensuring compliance
at
all
times
by
the trainee with the provisions
of
the Psychology Licensing Law and the regulations adopted pursuant to this law.
5.
_ Shall ensure that all SPE and record keeping conducted under the supervision delegated to
them is in
comp
liance with the Ethical Principles and
Code
of
Conduct
of
the
American Psychological Association.
6. _
Shall monitor the welfare
of
the trainee's clients while
under
their delegated supervision.
7.
_ Shall be responsible for monitoring the performance and professional development
of
the
trainee and for reporting
th
is performance and development to the primary supervisor.
B.
_ Shall ensure that they have the education, training , and
exper
ience
in
the area(s)
of
psychological practice
to
be supervised.
9.
_ Shall have no familial, intimate, business or other relationship with the trainee which would
compromise the supervisor's effectiveness, andlor would violate the Ethical Principles and
Code
of
Conduct
of
the American Psychological Association.
10.
_
Shall
not supervise a trainee who is now or ever has been a psychotherapy client of the
supervisor.
".
_ Shall not exploit or engage
in
sexual relationships, or
any
other sexual contact with the
trainee.
DELEGATED SUPERVISOR(S) SIGNATURE(S)
I understand and accept
this
agreement, including, but not limited t
o,
my
duties
and
responsibilities as a
delegated supervisor
and
will ensure to the best
of
my
abilities that the trainee
and
' will comply with the
terms and conditions
of
this agreement. AI! the foregoing is true
and
correcl.
Name (Print or
Type)
_______________
_
Slgnalure
__________________
_
City
and
Slale
_________________
_ Date
_________
_
Name (Print or T
ype)
_______________
_
Signature
______
__
______
_
___
_
Cilyand State
_________________
_
Dilte
________
_
TRAINEE'S SIGNATURE
I understand and will
comply
with the terms
and
conditions
of
this agreement. I will cooperate with
my
supaNisor(s) to ensure
that
conditions
of
the supervision are fulfilled
and
will
provide
my
supervisor(s)
with all information necessary to supeNise
me
on matters involving professional, ethical or legal
concems. All
of
the foregoing is true and correct.
Name
(Print
Of
Type'cl
_
___
____
______
_
Signature
____
______
_______
_
Address:
___
__
___
_ _
__
____
__
_
City and State:
________________
_
Tetephone:
____
____
__
_______
_
EmaitAddress:
________________
_
Date
_________
_
FOR
BOARD
USE ONLY
Date
_____
_
Approved
Denied
:c:-==--
Reason
f
or
denial
Revised
01/2612011
