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ASARC Policies & Procedures

 

APPIC Standards and Review Committee (ASARC) Policies & Procedures

Updated November 8, 2023

ASARC Purpose, Composition, Jurisdiction & General Responsibilities

Purpose of ASARC

ASARC provides a vital information-gathering function that assists the APPIC Board in evaluating alleged departures from APPIC Membership Criteria or nonadherence to APPIC policies by APPIC-member programs that are raised by non-APPIC personnel (e.g., a concern identified by a trainee or DCT, as distinguished from a concern identified by the APPIC Board of Directors, Executive Director, Match Coordinator, or other authorized designee of the APPIC Board of Directors). After conducting an investigation of a formal complaint deemed within ASARC’s jurisdiction, ASARC presents the APPIC Board with a description of investigation findings and recommended determination(s). All ASARC findings and recommended determination(s) are advisory to the APPIC Board of Directors; the APPIC Board is the determining body with respect to APPIC’s final decision and response to an alleged membership criteria/policy violation, including any resulting Board actions or sanctions (see APPIC Policies and Procedures for Responding to Training Program Nonadherence).  

Composition of ASARC and Terms of Office

  • ASARC is typically comprised of at least five members: typically at least three members from the APPIC constituency (i.e., an individual affiliated with an APPIC-member training program), who are appointed by the Board of Directors, a liaison from the APPIC Board of Directors, and the Public Member of the APPIC Board of Directors. If there is a need to appoint more than three constituency members to ASARC, an odd number of these members must be appointed to ensure there are no tie-votes on recommended determinations related to cases. The APPIC Board member serving as the ASARC liaison is appointed at the will of the Board and is usually relatively “senior” in terms of board tenure. The APPIC Board member liaison does not conduct ASARC investigations and is not a voting member of ASARC for the purposes of recommended determinations to the APPIC Board; this individual participates in Committee discussions and presents ASARC findings and recommended determination(s) to APPIC Board officers/the APPIC Board. The APPIC Board of Directors Public Member serves in an advisory role to represent a non-psychologist perspective during ASARC proceedings. The Public Member takes part in Committee discussions but does not conduct ASARC investigations and is not a voting member of ASARC for the purposes of recommended determinations to the APPIC Board. As APPIC Board members, both the APPIC Board liaison and the Public Member are eligible to vote on ASARC cases at the time they are considered by and voted upon by the APPIC Board.
  • ASARC term length for the APPIC Board liaison member can vary, with term lengths typically extending from one to three years. The term of each APPIC constituency ASARC member ordinarily will be three years. ASARC member terms may be staggered to provide continuity on the committee. APPIC constituent service on ASARC is ordinarily no more than two consecutive terms, which must be followed by a three-year interval before a Committee member is eligible to serve another term. Terms of members who are appointed to fill vacancies or who are serving in an ad hoc capacity are not counted towards the above-mentioned term limits. The APPIC Board of Directors may vote to except an individual appointment from this routine practice.
  • The Board of Directors will appoint one or more of the constituency members to serve as Chairperson(s) of ASARC, with a one-year, renewable ASARC Chair or ASARC Co-Chair term (January-December).
  • In this policy, the use of the term “ASARC Chair” refers to either the ASARC Chair or ASARC Co-Chairs.
  • Any disagreements or discrepancies between Co-Chairs will be resolved by the APPIC Board.
     

ASARC Jurisdiction & Authority

  • ASARC may accept complaints filed by an internship or postdoctoral applicant, a current or former intern or postdoctoral resident, a director of clinical training in a doctoral program, internship or postdoctoral staff/faculty, or other interested party.
  • ASARC reviews complaints about APPIC-member training programs in alleged violation of:
    • APPIC Membership criteria
    • APPIC Match Policies or the Match Agreement
    • Other APPIC Policies and Procedures
  • ASARC reviews the written information filed by the complainant to evaluate if the complaint falls within ASARC’s jurisdiction and to identify relevant parties to query in the investigation. ASARC may require a complainant to provide additional information as necessary for ASARC to investigate or process a complaint.
  • Where ASARC perceives it has no jurisdiction, it may recommend to the Board that the case be closed without investigation. In addition, ASARC, the APPIC Executive Director, or the APPIC Chair may refer the complainant to another entity as appropriate.
  • For a complaint that proceeds to ASARC investigation, ASARC may investigate any potential violations of APPIC membership criteria or policies that arise during the course of its investigation, even if such potential violations were not identified in the original complaint. The APPIC Board of Directors may take actions or impose sanctions in response to such violations.
  • The APPIC Board reserves the right to suspend or close an ASARC case if there are active legal or regulatory proceedings (e.g., cases referred to courts or other state/provincial/territorial/federal/credentialing/accrediting bodies). The case may be re-opened at the discretion of the APPIC Board.
     

General Responsibilities of ASARC

  • Evaluate whether a complaint is within ASARC's jurisdiction.
  • Investigate alleged violations and/or any potential violations identified in the course of an investigation concerning APPIC membership criteria and APPIC policies as per the ASARC procedures described below.
  • Create a written report of its investigation, findings, and recommended determination(s).
  • Advise the APPIC Board of Directors as to the evidence suggesting whether a policy violation has or has not occurred.

 
Procedures for Formal Complaint

Relevant Definitions

  • APPIC Informal Problem Consultation (IPC) process. The Informal Problem Consultation (IPC) process is an APPIC service intended to provide guidance, consultation, and assistance in navigating or attempting to resolve the broad array of challenges that may be encountered by concerned parties involved in psychology training. IPC involves discussion of the consultation question with an APPIC IPC consultant, which may include the APPIC Executive Director, a member of the APPIC Board of Directors, or any other designated individual as determined by the APPIC Board of Directors.
  • Formal complaint. Written allegations of a violation of APPIC membership criteria/policies.
  • Complainant. Person(s) or organization(s) who files a formal complaint alleging violation of APPIC membership criteria/policies.
  • Alleged violator. Individual(s) or organization(s) against whom a complaint is directed.
     

Procedures & Time Limits for Filing a Complaint

  • Prior to filing a formal complaint, allegations of a violation of APPIC membership criteria/policy should first be filed via the APPIC Informal Problem Consultation (IPC) process (https://www.appic.org/Problem-Consultation), and the complainant should engage with the person designated by APPIC to handle the consultation request. In keeping with IPC confidentiality expectations, APPIC does not provide ASARC with information from the Informal Problem Consultation; the APPIC Board of Directors is privy to this information and may incorporate it in decisions about an ASARC Case.
  • Formal complaints should be submitted as promptly as possible, and no later than 60 days after the date of the alleged violation or after the complainant knew or should have known of the alleged violation, whichever is later, unless the complainant, in writing, shows good cause for submitting a complaint after that date. Where the complainant shows they have a reasonable fear of retaliation for filing a complaint relating to the Match, internship, or postdoctoral program, the complainant may file such a complaint within 60 days after separation from the internship program or postdoctoral program. The complainant should describe in the formal complaint the basis for their reasonable fear of retaliation.
  • Should the complainant wish to request an extension to the above-described timelines, the complainant may file a written request for an extension with accompanying justification to the Chair of the APPIC Board of Directors. Granting or declining a timeline extension is at the discretion of the APPIC Chair. Should a timeline extension be granted, the ASARC Formal Complaint Form must then be submitted within 30 days. After this time, a petition for further timeline extension would be required and would be at the discretion of the APPIC Chair.
  • To initiate the formal complaint process, the complainant must fully complete the ASARC Formal Complaint Form (available from the APPIC website or from the APPIC Central Office). A complainant's failure to provide adequate information may preclude ASARC investigation and processing of a complaint or may result in dismissal of the complaint.
  • The complainant should describe the complaint as completely and specifically as possible, in narrative form, specifying the APPIC membership criterion(a)/policy(ies) allegedly violated.
     

ASARC Investigations & Privacy/Confidentiality

  • An ASARC investigation requires that the alleged violator have the opportunity to address each accusation levied by the complainant. Unlike Informal Problem Consultation (IPC), inherent in electing to file a formal complaint is an agreement by the complainant that their information and complaint will be shared with the alleged violator. There is no confidentiality or anonymity afforded between the complainant and alleged violator once an ASARC investigation is initiated. When advised of a complaint and the initiation of an ASARC investigation, an alleged violator will also be advised that retaliation is expressly prohibited and that actions deemed by APPIC as retaliatory may be associated with consequences from APPIC.
  • When conducting an investigation, in some instances ASARC will only need to interact with the complainant and alleged violator; in other cases, ASARC will find it pertinent to communicate with additional individuals (e.g., supervisors, direct report of the training director, institutional leadership, DCT) in an effort to be complete and accurate in gathering relevant facts. Both complainant and alleged violator may choose to identify specific individuals thought to possess specific knowledge regarding the facts of the complaint, though ASARC is not limited in its investigation to witnesses identified by the parties.
  • In the course of an ASARC investigation, no information about a formal complainant is shared outside of APPIC personnel, ASARC personnel, and the additional individuals described above. Once an ASARC investigation is complete, any APPIC actions/sanctions imposed may be communicated in accordance with APPIC Policies and Procedures for Responding to Training Program Nonadherence.

 

ASARC Procedures for Investigation of a Formal Complaint

  • Upon receipt of the ASARC Formal Complaint Form, the ASARC Chair shall:
    • Acknowledge receipt of the complaint to the complainant within 15 days.
    • Review the complaint prior to investigation and, if necessary or appropriate to evaluate suitability relative to ASARC jurisdiction, request additional information from the complainant.
    • After consultation with ASARC Committee members, the ASARC Chair may recommend to the Board that it reject a complaint that is untimely, without good cause shown, not within ASARC's jurisdiction, incomplete, or without merit or frivolous.
    • Assign a Case Coordinator for any complaint if the ASARC Chair does not recommend that the Board reject the complaint. The Case Coordinator is one of the APPIC constituency members of ASARC; the ASARC Chair may also serve as Case Coordinator.
  • An ASARC Committee member may recuse themselves or be recused by the APPIC Board from a case if there is deemed to be a perceived conflict of interest. In such a case, the APPIC Chair may appoint an ad-hoc Committee member from the APPIC constituency (i.e., an individual affiliated with an APPIC-member training program) or a past ASARC Committee member, to allow for a full Committee to conduct ASARC investigations, deliberate, and generate/vote on recommended determinations on a case.
  • The complainant may be asked to provide clarifying information or additional documentation. Response must occur in writing within 30 days of the date of an ASARC request for such information, unless the complainant, prior to the end of the 30-day period, requests and is granted up to an additional 30-day extension in writing, showing good cause for such an extension. If no response or if insufficient information is received, ASARC may determine to continue with the investigation or to recommend to the APPIC Board that the case be closed.
  • Upon assignment, a Case Coordinator shall gather pertinent information about the complaint from the complainant, the alleged violator, and any other parties deemed by ASARC to be pertinent to the investigation, as described below. As needed, the Case Coordinator may delegate information-gathering activities to another APPIC constituency member of ASARC, including the ASARC Chair.
  • For a complaint proceeding to an investigation, the Case Coordinator reviews the formal complaint submission, identifies relevant APPIC membership criteria/policies, and considers what specific information may be helpful to solicit from the complainant, alleged violator, and/or any other parties. The Case Coordinator reviews this information with other ASARC members and recommends a plan for investigation (e.g., parties to contact, information or documentation to request). Other ASARC members may make additional observations and recommendations to inform the plan for investigation.
  • After this deliberation and formation of a plan for investigation, the Case Coordinator (with assistance as needed from APPIC Central Office) generates a letter addressed to the alleged violator notifying them of the complaint, describing its allegations, identifying APPIC membership criteria/policies relevant to the matter, and advising as to the required written response within 30 days including any specific requested information or documentation. The alleged violator is also advised in the letter that retaliation is expressly prohibited and that actions deemed by APPIC as retaliatory may be associated with consequences from APPIC.
  • ASARC requires an alleged violator to provide acknowledgment of the letter and to respond to the allegation(s) and/or any potential violations identified in the course of an investigation concerning APPIC membership criteria and APPIC policies. Response to the contents of the letter must occur in writing within 30 days of the date of an ASARC letter requesting such a response. The alleged violator, prior to the end of the 30-day period, may request in writing a reasonable extension for good cause. If granted by ASARC, this extension is usually no more than 30 days. If no acknowledgment of the letter is provided, ASARC may contact another identified leader at the program/institution to request a response from that individual. Lack of cooperation by an alleged violator will not delay ASARC's deliberations and, even without establishing a violation, non-responsiveness may result in Board action/sanction of the alleged violator solely for such lack of cooperation. ASARC investigations may continue independent of an alleged violator's request for a delay or for further information or clarification.
  • The Case Coordinator reviews the alleged violator’s written response and any accompanying documentation. The Case Coordinator reviews this information with other ASARC members and may make recommendations to update the plan for investigation (e.g., any additional parties to contact, additional information or documentation to request).
  • After review of the written materials provided by both the complainant and the alleged violator (via the required written response), the Case Coordinator may invite or request the complainant and/or alleged violator each to a separate phone/video call to discuss the complaint with the Case Coordinator for the purpose of clarification of identified facts of the case. The Case Coordinator will advise as to the expected duration of the phone/video call and is responsible for determining the necessary time based on the information needed for the conduct of the investigation. The Case Coordinator will briefly summarize current understanding of the complaint and key facts and will identify any requests for specific points of clarification or additional information. The complainant or alleged violator will be offered an opportunity during this call to provide any corrective information regarding the summarized understanding.
  • If one or more phone/video calls occur as described above, the Case Coordinator reviews the content of any phone/video calls with other ASARC members and makes any recommendations to update the plan for investigation (e.g., parties to contact, additional information or documentation to request), or recommends to conclude the investigation. The ASARC Case Coordinator oversees any remaining investigation components and continues to inform ASARC of such components until the committee determines to conclude the investigation or is so advised by the APPIC Board of Directors. It is expected that this phase lasts no more than 30 days.
  • The Case Coordinator will present the information, along with their comments to ASARC. ASARC will discuss the investigation findings and generate recommended determination(s) (described below) concerning any evidence of violation or lack thereof. The ASARC constituency members vote on the recommended determinations; the APPIC Board liaison member and the Public Member are not voting members of ASARC.
  • Based on the above discussion, the Case Coordinator will submit a draft of the ASARC case report to ASARC, within 30 days from the date the investigation is complete. This ASARC case report contains a description of the complaint and relevant parties involved, a summary of the investigation process, a summary of findings of facts/evidence, and ASARC’s recommended determination(s) with respect to each alleged violation (i.e., no violation, insufficient information for a determination, or evidence of violation).
  • ASARC will review the draft case report, discuss any recommended modifications, and generate a final ASARC case report. The ASARC case report should be completed within 30 days of ASARC’s vote on the recommended determinations.
     

ASARC Findings & Recommended Determinations

  • Upon completion of an ASARC Formal Complaint investigation, ASARC may specify the following recommended determinations with respect to a complaint:
    • No violation - ASARC may find there is not sufficient evidence to suggest that the alleged behavior occurred or that the alleged behavior does not constitute a violation of APPIC membership criteria/policy.
    • Insufficient information for a determination - ASARC may find it has insufficient information to reasonably determine whether the alleged behavior occurred or if the alleged behavior reflects a violation of APPIC membership criteria/policy. ASARC may make note of any identified questions or concerns for consideration by the APPIC Board.
    • Evidence of violation – ASARC may find that based on its investigation, evidence exists that one or more APPIC membership criteria or APPIC policies have been violated.
  • The Case Coordinator will draft a written summary of findings and recommended determinations. This ASARC case report contains a description of the complaint and relevant parties involved, a summary of the investigation process, a summary of findings of facts/evidence, and ASARC’s recommended determination(s) with respect to each alleged violation (i.e., no violation, insufficient information for a determination, or evidence of violation).
  • All ASARC findings and recommended determinations are advisory to the APPIC Board of Directors.
     

Opportunity to Respond to ASARC Findings & Recommended Determinations

  • The ASARC case report including findings and recommended determination(s) will be provided to the complainant and alleged violator by the Case Coordinator. Following its provision, the complainant and/or alleged violator may submit a written response within 30 days for correction of facts to the ASARC Chair.
  • Submitting a written response for correction of facts is entirely optional. The opportunity is intended to offer a mechanism to provide corrective information to address any apparent factual misunderstandings that may have occurred during the ASARC investigation and is not intended to invite general expressions of agreement or disagreement with the ASARC findings and recommended determination(s).
  • In the event of receipt of a written response for correction of facts, the ASARC Chair will acknowledge receipt to the submitting individual within 15 days. ASARC will discuss the written response for correction of facts and will identify a planned response. Responses may include:
    • Requesting clarifying information from any individual participating in the ASARC investigation or determining that no such follow-up is indicated.
    • Amending the ASARC case report with updated or revised findings and recommended determination(s) or determining that no such amendment is indicated. The opportunity to respond to the report is for purposes of clarification and is not intended as an opportunity for an alleged violator to provide information for the first time that they were asked to provide during the investigation but chose not to. In such cases it shall be within the discretion of the ASARC Chair as to whether to accept such information or not.
       

Conclusion of ASARC Investigations and APPIC Board Response

  • Upon completion of an ASARC case report and expiration of the above-described 30-day opportunity to respond, the APPIC Board liaison member will share the ASARC case report(s) (i.e., original and any amended reports) and any written responses for correction of facts with the current officers of the APPIC Board of Directors. Board officers will deliberate about potential Board actions/sanctions that may be appropriate (see APPIC Policies and Procedures for Responding to Member Program Nonadherence for Board action and sanction options).
  • The APPIC Board officers or Board of Directors may instruct ASARC to gather additional information or conduct additional investigation if deemed necessary prior to making its final decision.
  • Upon consideration of the ASARC case report and any written responses for correction of facts, Board officers may recommend that the full board (a) adopt the findings and recommendations in full; (b) adopt the findings and recommendations with modification; or (c) reject the findings and recommendations in full. Board officers may also make a recommendation to the APPIC Board of Directors as to any board action(s) or sanction(s) deemed advisable.
  • The APPIC Board of Directors will vote on any board action or sanction against a member program, as per usual voting procedure, which includes the option for individual recusals as deemed appropriate by an individual Board member. If a Board member is an active and participating member of a training program that is subject to an ASARC investigation OR was an active and participating member of a training program during the period of time referenced in an ASARC complaint, the Board member will be recused from the entire process (including review of written materials, discussion, and voting).
  • In the event of required recusal due to a Board member being currently or formerly affiliated with a training program that is subject to an ASARC investigation, the remaining Board members will consider the case and develop proposed findings and any proposed sanctions/actions.  Prior to Board vote, these proposed findings and any proposed sanctions/actions will be sent to ASARC for review and feedback, specifically focused on whether there is any perception of leniency toward the program in either findings or sanctions/actions.  This feedback from ASARC is advisory only and not binding on the Board. Any feedback or recommendations from ASARC on the proposed findings and any sanctions/actions will then be reviewed by the Board, and final findings and actions/sanctions would be considered and voted upon.
  • The APPIC Board of Directors makes the final decision regarding whether a violation occurred and any Board actions/sanctions that may be imposed. APPIC actions and any sanctions of member programs deemed in violation of APPIC membership criteria/policies will occur in accordance with the APPIC Policies and Procedures for Responding to Training Program Nonadherence. The APPIC Board of Directors votes to close an ASARC case, regardless of whether a Board action/sanction is proposed or taken.

 

Closing an ASARC Case & Communication of Final Decision

  • When the APPIC Board votes to close a case, the APPIC Board Chair will inform the complainant, the alleged violator, and any other relevant persons of the Board’s final decision on the complaint. Any associated actions or sanctions will be communicated to the program deemed in violation. ASARC will also be advised as to the Board’s final decision and any actions or sanctions.

 

Logistics of ASARC Functioning

  • The majority of ASARC business is conducted by telephone conference, videoconference, e-mail, or written correspondence. ASARC may meet in-person if needed, but only if the press of ASARC business requires such in-person meetings and as approved by the APPIC Board of Directors.
  • ASARC generally sends all correspondence related to ASARC complaints by email.
     

Costs Associated with Complaint Processing

  • Any expenses incurred by ASARC members and/or the APPIC Board of Directors in the course of processing a complaint shall be borne by APPIC. ASARC members must comply with APPIC travel and expense policies and should contact APPIC Central Office for the APPIC Reimbursement Form.
  • Any expenses incurred by the complainant and/or alleged violator during the processing of a complaint (e.g., copying, travel, lodging) shall be borne by the parties, not by ASARC or APPIC.