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Addressing Problems in Professional Competency - Clinical Psychology/RCP
This document provides policies and procedures for managing student conduct or performance that are reflective of problems in professional competence (“PPC”). These policies are consistent with accreditation standards of the American Psychological Association (“APA”) and incorporate human resources policies of the Fielding Graduate University. This policy applies to clinical psychology PhD and respecialization students.
The APA Ethical Principles of Psychologists and Code of Conduct (2002/2010/2017) requires that psychologists meet certain standards of competence and that they be free of personal issues that could impair professional performance based on generally accepted standards of care. It further requires that training programs have the obligation to apply these standards of performance to students, taking remedial action when possible, and dismissing students when such efforts fail to improve performance to the required levels or when remediation is not deemed possible
For purposes of this document, PPC are defined broadly as an interference in professional functioning which is reflected in one or more of the following ways: 1) an inability and/or unwillingness to acquire and integrate professional standards and knowledge into one’s repertoire of professional behavior, 2) an inability and/or unwillingness to acquire professional skills in order to reach an acceptable level of competence, and/or 3) an inability to control personal stress, psychological problems, and/or excessive emotional reactions which interfere with professional functioning. PPC can arise when the skills necessary for adequate professional performance are lacking or there is an impairment (physical or mental) that diminishes professional functioning. PPC can be associated with a health or mental health condition. More specifically, such health or mental health conditions often include, but are not limited to, physical and emotional hardships, chemical dependency, stress, burnout, extreme personal/relationship difficulties, emotional and mental disorders, and/or cognitive impairment due to injury or illness or other causes.
While it is a professional judgment as to when a student’s behavior becomes more serious or problematic rather than just of “concern,” for purposes of this document a “concern” refers to a students’ behaviors, attitudes, or characteristics which, while they may require remediation, are not determined to be unexpected or excessive for professionals in training.
Student behaviors become identified as PPC when they include one or more of the following characteristics:
- the student does not acknowledge, understand, or address the problem when it is identified;
- the problem is not merely a reflection of a skill deficit which can be rectified by academic or didactic training;
- the quality of academic or clinical work delivered by the student is sufficiently negatively affected;
- a disproportionate amount of attention by faculty is required;
- the student’s behavior does not materially change as a function of feedback, remediation efforts, and/or time;
- the problematic behavior has had or has the potential for ethical or legal ramifications if not addressed;
- the student’s behavior negatively impacts the public’s perception of the Fielding Graduate University; or
- the problematic behavior negatively impacts the student population.
General Responsibilities of the Clinical Psychology Program
A major focus of this program is to assist students in integrating their personal values, attitudes and functioning as individuals with their professional functioning. We are committed to providing the type of learning environment in which a student can acquire professional knowledge and skills necessary for entry into the profession. The responsibilities correspond to the general expectations described here:
Professional Standards and Competency
The program will provide students with information regarding relevant professional standards and guidelines and relevant legal regulations which govern the practice of psychology. The program will also provide appropriate avenues (e.g., coursework, Practicum Case Seminars, etc) to discuss the implementations of such standards.
The program will further provide students with information regarding academic standards as well as information regarding academic policies of the university (e.g, during the New Student Orientation, relevant course work, and in faculty advising sessions). Students will be reminded of these and to review laws and regulations which govern the practice of psychology in their state or province.
Process for addressing PPC
PPC, whether the identified problem occurs within the program (e.g., class work, training days, case presentations, etc.) or is brought to the program from a person, agency, or body outside the University, will be addressed through the following review process. This process is intended to protect student due process rights as well as the obligation of faculty to uphold the academic and professional standards of the Clinical Psychology PhD program and the profession of clinical psychology.
- Notification of the complaint will be provided to the Director of Clinical Training (DCT) regarding the event(s) or circumstance(s) that identifies a potential PPC or a violation of University, legal, ethical, or professional codes (other than possible academic dishonesty which is addressed by a separate policy). The DCT will inform the student in writing of the complaint (referred to as ‘the document’) that initiates the PPC process. This will be done in a timely manner sufficient for the DCT to gather and organize the necessary information. A link to this PPC policy also will be provided to the student.
Within 10 business days of receipt of the document, the DCT will follow up and attempt to obtain information from the person/body making the complaint to the extent such information is available without violating any right of privacy of any person involved in the PPC allegations. To the extent a consent or consents are necessary to obtain such information, the DCT will make a good faith effort to obtain that consent including any consent that must be obtained from the subject of the PPC. If the person submitting the document does not have direct knowledge of the facts, then a good faith effort will be made by the DCT to contact and interview the person who does have that knowledge. Should the student, who is the subject of a PPC allegation reflected in the document, refuse to provide any necessary or legally required consent to obtain or release information may be grounds in itself for dismissal of the student from Fielding Graduate University.
Within 15 business days of receiving the document, the DCT, in consultation with the Program Director (“PD”), will determine if evidence indicates that a PPC may have occurred and that the program needs to take further action.
If it is decided by the DCT and PD that the issue does not require further action by the program or that the information is insufficient to make such a decision, the student who is the subject of the document and the party/ies who submitted the document will be so informed in writing within 3 business days of this decision.
If further action by the program is deemed warranted by the DCT and PD, the student, the student’s faculty advisor, and other identified parties will be notified within 3 business days that the student’s status in the program is being reviewed and that a formal meeting of the PPC Committee will be necessary to evaluate the nature of the problem and to decide on a course of action.
- When further action by the program is deemed warranted, the student will be provided with all materials/information obtained to date that support the allegations. This must occur within 5 business days of the above decision. The student will have 10 business days to write up his/her response to the allegations and provide any supporting documentation. During this time period, the DCT and PD will follow up with any needed information gathering from the student and other parties whose input is determined by the DCT and PD to be necessary to understand and accurately evaluate the complaint.
Once further action by the program is deemed warranted, the DCT, within 5 business days, will assemble a PPC Committee comprised of three faculty in the clinical program, at least two of whom have relevant expertise in the area of the complaint. The Committee will not include the faculty advisor or anyone with a potential conflict of interest. The DCT will provide the PPC Committee with all written materials that have been provided about the potential violations, including all materials provided by the student who is the subject of the complaint.
The PPC Committee process is as follows:
- The Committee will issue its written outcome based on the written documents provided by the DCT, including all materials provided by the student who is the subject of the complaint. If additional information is needed, the Committee may at its sole discretion invite any persons (including the student) judged to have relevant additional information to submit such information either in-person, by conference/telephone call, or in writing by mail or e-mail. Once the PPC Committee receives the student’s response, the Committee must complete its work, including issuing a written outcome and transmitting that written outcome to the DCT and PD within 15 business days. At least two of three committee members must agree. When the Committee decision is not unanimous, all viewpoints will be included in the report.
- As part of their written outcome noted above, the Committee decides if and how the student violated professional competency expectations and makes a written recommendation to the DCT and PD regarding the student’s standing in the program. The DCT and PD have the responsibility of reviewing and approving or rejecting in whole or in part, the Committee’s written outcome and recommendation. In order to make this decision the DCT and PD may approach the PPC committee or student with requests for clarification or further information if such is needed to make a decision. If the DCT and PD conclude that revisions of the Committee’s written outcome and recommendation is appropriate, the incorporation of these revisions will be discussed with the Committee. The work of the DCT and PD to review, approve, reject or revise the written outcome and recommendation of the Committee must be completed in 7 business days after the PPC Committee renders its written outcome and recommendation.
Once the DCT and PD’s work noted above is complete, the student will be notified of the program’s decision by the DCT and PD within 3 business days. The final decision may result in (a) retention of the student in good standing, (b) allowing the student to continue in the program but without receiving credit for completed work (e.g., internship, practicum, course), (c) allowing the student to continue in the program on probationary status until specified conditions* as outlined in a remediation plan are met, and/ or (d) immediate dismissal of the student from the program. In the case of a remediation, each required step and timeline for completion will be provided.
Although the student may consult an attorney about the PPC process, an attorney may not appear on behalf of the student during the PPC process.
At the time the decision of the DCT and PD is transmitted to the student, the student will also be advised that if he or she wishes to appeal that decision, he/she will be allowed to file a written appeal with the Provost that must be received by the Provost within 10 business days of the date on which the student is notified of the decision by the DCT and PD. Failure to file the written appeal with the Provost within 10 business days renders the decision of the Committee, and the DCT and PD, final. The letter can be e-mailed but must also be followed up with a mailed copy of the appeal. The appeal must state all of the reason(s) why the student believes the decisions of the Committee, DCT and PD are incorrect. The Provost will review the appeal papers and any other relevant information, including the decision of the DCT and PD, and will provide a decision to the student within 10 business days after the acknowledging receipt of the written appeal. The decision of the Provost will be final.
Overview of Time Line
- Within 5 business days of receipt of the complaint document, the DCT informs the student who is named in the document
- Within 10 business days of receipt of the complaint document, the DCT gathers initial information.
- Within 15 business days of receipt of complaint, the DCT consults with the PD to decide if further program action is warranted.
- The student must be informed within 3 business days of the decision of the DCT and PD as to whether further program action is warranted.
If further program action is warranted, then:
- Within 5 business days of being informed, the student receives, in writing, all the information obtained to date concerning the allegation relating to PPC and has 10 business days to respond.
- Within the 5 business days of determining that further action is warranted, the DCT assembles the three person PPC Committee and provides them with the materials generated to date. Once the PPC Committee receives all documentation including the student’s input, it has 15 business days to complete its work and produce a written outcome and recommendation which is provided to the DCT.
- Within 7 business days, the DCT and PD review the decision of the PPC Committee and either adopt the decision, reject the decision or make changes/edits to the decision of the PPC Committee.
- The determination by the DCT and PD is provided to the student in writing within 3 business days of the DCT and PD making their determination.
- Appeal to the Provost is possible within 10 business days. Provost’s final decision shall be transmitted to the student within 10 business days of Provost acknowledging receipt of a written request from the student appealing the decision of the DCT and PD.
- If any circumstances prevent following the above time lines, the student will be informed within a day of the delay being identified and a revised timeline will be provided.
Policy Revised 12/01/2019
APA Ethical Principles - Clinical Psychology/RCP
All Clinical Psychology and Respecialization students should be aware of Section 7.04, Student Disclosure of Personal Information, in the APA’s Ethical Principles of Psychologists and Code of Conduct (2002, 2010 revision). This section states:
Psychologists do not require students or supervisees to disclose personal information in course- or program-related activities, either orally or in writing, regarding sexual history, history of abuse and neglect, psychological treatment, and relationships with parents, peers, and spouses or significant others except if
- the program or training facility has clearly identified this requirement in its admissions and program materials or
- the information is necessary to evaluate or obtain assistance for students whose personal problems could reasonably be judged to be preventing them from performing their training- or professionally related activities in a competent manner or posing a threat to the students or others.
The Clinical Psychology PhD and Respecialization programs at Fielding Graduate University place considerable value on personal exploration, requiring students to self-reflect and to be self-aware. As a result, it is the expectation that students will disclose personal information as part of their participation in the doctoral and respecialization programs in Clinical Psychology. If you have any questions regarding this issue, please contact the Program Director for the Clinical Psychology PhD and RCP programs.
Policy Revised 01/01/2020
Student Informal Complaints Procedure - EdD and IECD
Pursuant to Fielding Policy
A student complaint/grievance is an allegation by a student that there has been, in an individual case, an arbitrary or discriminatory application of, or failure to act pursuant to, the policies of Fielding Graduate University (specifically within the EdD/IECD programs) in relation to students. To start this procedure, the student sends a formal written request to a designated academic or administrative officer for which specific remedies are requested.
The parties to a grievance are the student filing the grievance and the person(s) against whom the grievance is filed.
An academic complaint/grievance is one involving faculty members, the Program Director of a particular program, or the Department Chair for a particular program. Faculty evaluations and grading of student work are based upon the substantive judgment of the faculty and are not subject to a complaint/grievance.
An administrative complaint/grievance is one involving staff of Fielding Graduate University.
The informal complaint/grievance procedure within the EdD/IECD programs is the process a student initiates prior to filing a formal grievance with the University. The student initiating this process must be the individual against whom the alleged infraction has occurred.
A calendar day is any day of the week. For purposes of computing the time periods specified under steps 1 - 3 below, if the last day of this time period falls on a Saturday or Sunday, the last day will be construed as the Monday following that Saturday or Sunday. If the last day falls on a holiday, the last day will be construed as the next regular calendar day following the end of the holiday time period. If the next regular calendar day falls on a Saturday or Sunday, the last day will be the following Monday.
EdD/IECD Informal Procedure for Filing Academic and Administrative Complaints
This procedure is designed for dealing with issues relating to courses; comprehensive assessments; dissertations and dissertation committees; regional or online meetings; mentor relationships; satisfactory academic progress; sessions; and related organizational work.
- The student raises the issue of concern with the faculty, administrator, student or other person(s) involved. This should be done within 14 calendar days after the student becomes aware there allegedly has been an arbitrary or discriminatory application of, or failure to act pursuant to, the policies of Fielding Graduate University (specifically within the EdD/IECD programs).
- If the issue is not resolved between the parties within 14 calendar days, the student may contact, in writing or email, the appropriate Program Director.
- The Program Director will mediate the dispute, within 14 calendar days after being contacted by the student, with the purpose of finding a resolution. During this process, the student may select another person (no faculty, staff or administrator) to assist them in preparing for and presenting their position at the mediation.
- If the issue is not resolved, the student may take the matter to the University’s formal grievance procedure within 14 calendar days after the mediation.
Policy Revised 09/01/2019
Student Informal Complaints Procedure - Clinical Psychology/RCP
Students are to follow an informal complaint procedure prior to filing a formal academic grievance involving a faculty member. If a student has difficulty with one or more faculty members over an academic matter, these informal procedures can assist the student in resolving the difficulty without the need to file a formal grievance.
- The student should discuss the problem directly with the faculty member(s) with whom the student has a problem and/or ask the student’s faculty advisor to intercede. If the problem is with the student’s faculty advisor, then the student can contact the student representative to or chair of the Clinical Psychology Personnel Committee who will work with the student to find a member of the committee who can intercede. Such student requests for assistance should be responded to within five business days. It is recommended that any written correspondence between parties be saved.
- If the student is not satisfied with the results of initial attempts to resolve the grievance, the student should contact a faculty or student member of the Clinical Psychology Personnel Committee. This next step in the informal grievance process member must be made within 45 days of the incident. The committee member contacted must inform the Personnel Committee as a whole within five days of being notified.
- If an unresolved dispute is with a member of the Personnel Committee, that member will not be included in the discussion by the committee as a whole and will be treated as any other non-committee faculty member in the complaint process. The faculty member who is the subject of the complaint will have an opportunity to respond to the complaint before any action is taken by the Personnel Committee.
- The Personnel Committee may assign one or more of its members to serve as mediator(s) with the student and faculty member(s). If the mediator(s) are unable to resolve the problem, the student may file a formal grievance.
- The Personnel Committee must resolve the matter satisfactorily with the student within 75 days of the original incident, so the student can still file a formal complaint within the 90 day time limit required by the formal grievance procedure.
Policy Revised 09/01/2020
Timely Response: Expectations of School of Psychology Students
This policy is a companion to the faculty timely response policy. Just as students can contact faculty, staff, and administrators with the expectation of receiving a timely response, it is the student’s responsibility to attend to communications from the institutional personnel that request a response. Student timely communication is necessary for effective institutional functioning and to provide appropriate educational supports.
As a distributed learning environment, faculty, staff, and administrators may send students a communication that requires a response by email, postal mail, or by phone. It is the student’s responsibility to respond in a timely manner to those communications. The expectation is that a student will respond within ten calendar days. If there is no response, the sender should make a second attempt. If there is no response within ten calendar days, the sender should notify the Program Director immediately.
The Program Director will attempt to contact the student via registered letter to the student’s address on record requesting a response to the last communication in question. Lack of response to the registered letter after two weeks will result in an immediate suspension of 30 days. The Program Director’s office will continue to make a good faith attempt to contact the student to determine if there are mitigating circumstances that are preventing a response from the student. If circumstances warrant it, the Program Director may simply reinstate the student from suspension. If unable to make this determination within 30 days or circumstances do not warrant non-response, the Program Director will dismiss the student. Dismissal under these conditions requires an application for re-enrollment.
Policy Effective 01/01/2020