John Caccavale, PhD, MS
National Alliance of Professional Psychology Providers
P.O. Box 6263
Garden Grove, CA 92846

Dear Dr. Caccavale:

Thank you for your letter of July 14, 2006. I appreciate your candor in expressing your views about the issues surrounding appropriate training for psychologists in preparation for prescription privileges. I have indeed been very much in the information loop on this important issue that must be resolved. The very last thing we want to do is make life difficult for our practitioners. In fact, we work very hard to do just the opposite. From a staff perspective, we are all committed to reaching the best resolution of those issues for the profession as a whole, as well as for the public. We are also committed to assuring that no psychology constituency suffers at the hand of another.

There are several points that I believe bear underscoring as we move forward to address these issues within the profession.

First, it is critical for all of us involved in this discussion to recognize that the APA policy statement “Recommended Postdoctoral Training in Psychopharmacology for Prescription Privileges” (hereafter “Recommendations”) was adopted ten years ago at a time when prescription privileges for psychologists was a vision for the profession, not the reality that it is today. At that time there were few programs training psychologists to prescribe medication that could provide a base from which to build recommendations for all training programs. Instead, the Recommendations were one foundational part of a broad based plan established by APA’s Council of Representatives to realize the goal of making prescribing privileges a real option for psychologists who wished to enhance their practice with those skills. As prescription privileges have moved from a vision to a reality, it is not surprising that a few aspects of the Recommendations have been open to interpretation in more than one way. Two examples of this are the use of the terms “academic” and “accredited” which, as is clear from your letter as well as other materials, have been construed both narrowly and broadly by different readers. Neither APA staff nor APA governance groups other than the Council of Representatives have the authority to change APA policy such as the Recommendations.

For all these reasons---the age of the policy, the experience that has been gained since it was adopted, the language that has been the subject of debate, and the overall authority of Council--- there is only one way to appropriately address the issues NAPPP has raised, and that is to bring the policy back to APA Council. To inform that policy consideration, a Task Force with representatives from affected constituencies has already been established to reevaluate the Recommendations and consider changes or clarifications to the policy statement. Due to the urgency of the issue, APA is committed to expediting this process and I personally will be monitoring the work of the group. As an aside, I do think Dr. Belar has been unfairly singled out for criticism for merely for expressing the differences in interpretation of the policy among governance members. Again, staff do not have the power to either set the policy or change it. But we have taken expedited action to address this policy question with the creation of the appropriate task force.

Finally, it bears underscoring that both CAPP and the Practice Directorate took great efforts to encourage the National Register and ASPPB to develop their program in a way that would facilitate the development of the nascent RxP movement. In the end, of course, as independent organizations, the National Register and ASPPB made their own decision over which APA had no control.

Sincerely,

Norman B. Anderson

cc: Cynthia Belar
Russ Newman
Nathalie Gilfoyle

July 25, 2006

Norman Anderson, Ph.D.
CEO, American Psychological Association

Dear Dr. Anderson:

Thank you for your reply to my email. We appreciate that you understand NAPPP's intent and reasons for candor.

With respect to the substance of your response to NAPPP, I am somewhat perplexed with the continued reference to the words "accredited" and "academic", which Dr. Belar and others, and now you, point to when discussing those terms in the Recommendations. Maybe we are missing something but we do not see any issue of interpretation when it is clearly written in the Recommendations that training in psychopharmacology may be obtained by an approved provider of continuing education. There is no ambiguity or reference of
those words to approved providers. The terms you point to are used and attached to training in and by universities, only. In all candor, I do believe that tying these terms where they were never used is an attempt by BEA and others to anoint the NR to be the outside agency to "accredit" RxP training programs. Without discussing the merits of the desire of CAPP and the Practice Directorate to see this through an attempt was made to push this plan without any real thinking about the long term consequences and, worse, without any real consultation with the people who would be most affected by this new interpretation. We have letters from the training directors and Russ Newman that clearly show that many discussions with the NR were taking place as far back as the Hawaii convention and perhaps even earlier.

Thus, Dr. Anderson, while we have heard this familiar rationale for why Dr. Belar issued her infamous letters to the National Register, the only unfairness is to the psychologists who have made the RxP movement and given it sustenance and drive. Policy remains on paper, people give policy its dynamics. If, as you suggest, that a 10 year old document and policy needs to be reconsidered, then why not wait until it could be reviewed instead of issuing a statement by BEA that clearly shows what BEA considers appropriate training?.

The answer is inescapable: At the time that Dr. Belar wrote to the NR there was no plan to open the Recommendations for a review. That came as a response to those of us who spoke up and derailed, yes derailed, what the practice directorate, BEA, and CAPP had already decided to do. Russ Newman came up with that plan weeks after the confrontation at the town hall meeting at last year's convention in Chicago. In typical bureaucratic fashion, the buck was passed to a "committee." This allows those involved in this fiasco to hide behind a structural screen. We use candor out of respect for the people we are dealing with and quite, frankly, what we getting from APA is not respect or candor. We think that APA needs to stop using terms that only you feel are ambiguous to justify a policy blunder and problem that had not existed prior to APA designating the National Register to be the venue for accrediting RxP training.

You state that that both CAPP and the Practice Directorate took great efforts to encourage the National Register and ASPPB to develop their program in a way that would facilitate the development of the nascent RxP movement. In the end, you state, as independent organizations, the National Register and ASPPB made their own decision over which APA had no control. Was it not CAPP and the Practice Directorate who contacted the National Register and initiated this? It seems to us that is control. Didn't they know that the National Register, as a private organization would look for their best interests first? In the least, those responsible should be replaced for outright negligence for initiating a sequence that they knew, a priori, would take control from APA and give it to another private organization. To condone that action is inexcusable.

If you and any others in APA are truly interested in maintaining RxP and are committed to its future, then why not issue a policy restatement that training by approved continuing education providers is an appropriate venue to obtain the proficiency in psychopharmacology? Why not inform every board of psychology that APA does not recognize the NR's accrediting criteria? APA's failure to do these two simple things, which is nothing more than a statement supporting the status quo, demonstrates that the conclusions NAPPP is drawing are correct. We would be glad to be wrong on this issue but so far all the objective data proves us right. As long as APA goes down its chosen track, practitioners will respond by being proactive in protecting our rights and intellectual properties. This brings me to another point: Any discussion of policy or recommendations with respect to practice issues ought not to be under the control of the other directorates. When you say that you are committed to insuring that no psychology constituency suffers at the hands of another, as sincere as I do believe you are, we need to see action since words no longer are sufficient.

Practitioners have been treated unequally far too long to fall back on mere words. Your tenure has not been long enough for us to place blame on you. However, we have not seen any real improvement since you became CEO. Consider: academics, as a whole, pay less dues than clinicians. Academics, although fewer in number than clinicians, control most of the governance. APA 's budget is disproportionately devoted to activities that favor academicians. However, most importantly, clinicians are under the control of academics who have no real link to practice. The list can go on but we think you get the point. While we really accept that it is no easy task to please everyone, pleasing is not the issue. The Practice Directorate is not sufficient to respond to practitioner's needs when the other directorates can dictate how, what, when and where we practice. The RxP issue is only a part of the problem. We think APA needs to look at the "big picture".

Once again, we are offering a solution to the problem. Restate the status quo that RxP training by approved CE providers is an acceptable way to meet the curriculum guidelines. This is an expedient way to correct this fiasco. There is a saying that may be relevant here so forgive us if you have heard it: "The best way to ride a dead horse is to dismount." We truly hope that you take this as it is offered.

Sincerely yours,

Michael Baer, Ph.D.
Stephen E. Berger, Ph.D.,ABPP
John Caccavale, Ph.D., M.S.
James Childerston, Ph.D.
Nicholas Cummings, Ph.D., Sc.D.
Stanley Graham, Ph.D.
Matt Nessetti, Ph.D., M.D.
David Reinhardt, Ph.D., M.S.
Howard Rubin, Ph.D.
Lenore Walker, Ed.D, M.S.
Jack Wiggins, Ph.D., Psy.D., ABPP