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Policies and Procedures for Responding to Training Program Nonadherence

APPIC Policies and Procedures for Responding to Training Program Nonadherence

Revised February 9, 2022


For this policy, unless otherwise specified, the term "program" refers to APPIC-member internship and postdoctoral programs, academic programs that are Doctoral Program Associates (DPA), non-member internship and postdoctoral programs that use APPIC's services, and non-DPA academic programs that use APPIC's services.

APPIC Membership and Doctoral Program Associate statuses, along with the use of APPIC services by non-member/non-DPA programs, are contingent upon adherence to APPIC membership criteria and APPIC policies. If a program is deemed noncompliant with APPIC membership criteria or other APPIC policies, APPIC may utilize a range of efforts to facilitate program adherence to these criteria/policies and/or may invoke a range of sanctions. Alternatively, a program may elect to discontinue APPIC membership or DPA status, with accompanied discontinuation of APPIC membership benefits and services, at any time. APPIC processes for investigating and responding to concerns about nonadherence and potential actions and sanctions are described below.


Process for Managing Concerns about a Training Program 


Concerns Identified by APPIC Personnel

In the event that APPIC Personnel (defined as a member of the APPIC Board of Directors, the APPIC Executive Director, the APPIC Match Coordinator, or another authorized designee of the APPIC Board of Directors) learn that a program is nonadherent to APPIC membership criteria or policies, these individuals may issue an Educative Directive (further described in the APPIC Actions & Sanctions section). APPIC understands that lapses in adherence to membership criteria/policies may be inadvertent; the Educative Directive is a mechanism to educate and advise programs about established criteria/policies, to specify any needed program changes to ensure adherence, and to provide support/consultation to programs in making changes to come into alignment with the relevant criteria/policies.

If a program wishes to express concern about, or request review of, an Educative Directive, the program may do so by addressing this request in writing to the APPIC Executive Director (or the Chair of the APPIC Board of Directors if the Executive Director issued the Educative Directive). The Executive Director or Chair will gather information as needed and present the matter to the APPIC Board of Directors, who will determine the final response (i.e., whether the Directive is upheld or modified).

If a program is deemed by APPIC to be non-responsive to an Educative Directive, if the response or actions taken by the program are deemed by APPIC to be insufficient or unsatisfactory, or if the nature of the program’s conduct (both current and historical) is believed by APPIC to warrant a more substantial response than an Educative Directive, the matter may be referred to the APPIC Board officers (i.e., Chair, Vice Chair, Treasurer & Secretary) for review. Board officers will review information pertaining to the concern and will recommend to the Board of Directors any APPIC action(s) or sanction (see potential actions and sanctions below). Officer recommendations are advisory to the full APPIC Board of Directors; the Board retains authority to make the final decision regarding any APPIC action or sanction against a program.

When APPIC Board officers recommend to the Board of Directors an action or sanction beyond an Educative Directive, in ordinary cases the program will be advised in writing of the specific concerns and anticipated APPIC action(s)/sanction(s), and the program will be offered opportunity to submit to the APPIC Chair within 30 days a written response for correction of facts prior to implementation of any action(s)/sanction(s). 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 and is not intended to invite general expressions of disagreement or as an opportunity for the program to provide information for the first time that they were asked to provide earlier but chose not to. If, in the Board’s discretion, circumstances warrant more emergent action, the Board has discretion and authority to impose immediately effective action(s)/sanction(s) without first offering the 30-day opportunity to respond but will consider a program’s written response within 30 days after implementation. Upon consideration of any written response for correction of facts, Board officers may make a recommendation to the APPIC Board of Directors as to modifications deemed advisable to the anticipated (or already-imposed) APPIC action(s) or sanction(s). The APPIC Board of Directors makes the final decision regarding whether a violation occurred and any Board actions/sanctions that may be imposed. The APPIC Board of Directors will vote on any board action or sanction against a program, as per usual voting procedure, which includes the option for individual recusals as deemed appropriate by an individual Board member. Programs will be advised of any APPIC action(s)/sanction(s) in writing.


Concerns Identified by Non-APPIC Personnel

Formal complaints about a program filed with APPIC by non-APPIC personnel (e.g., a trainee, DCT, etc.) are investigated by the APPIC Standards & Review Committee (ASARC). Prior to filing a formal complaint, the concerned party must have utilized the APPIC Informal Problem Consultation process in an effort to address the matter. ASARC utilizes a standard process (see ASARC Procedures) to investigate these complaints and composes a written report of the committee's findings and recommended determination(s). The ASARC report is provided to the APPIC Board officers, who then review the information and issue a recommendation to the Board of Directors about any APPIC action or sanction (see potential actions and sanctions below). ASARC findings and conclusions and APPIC Board officer recommendations are advisory to the full APPIC Board of Directors; the APPIC Board determines APPIC’s final decision and response to any alleged membership criterion/policy violation, including any APPIC actions or sanctions.



APPIC Actions & Sanctions


APPIC may use a range of potential approaches to facilitate program adherence to APPIC membership criteria/policies or may invoke a range of sanctions on a program. As described above, an Educative Directive can be issued by APPIC Personnel (i.e., member of the Board of Directors, Executive Director, Match Coordinator, or other designee authorized by the APPIC Board). Decisions about implementation of other actions or sanctions are made by the APPIC Board of Directors using routine voting procedures consistent with APPIC’s bylaws. Such actions and sanctions are determined by the APPIC Board and may occur in response to Board officer recommendations following review of either a concern identified by APPIC personnel or an ASARC investigation. APPIC may impose actions or sanctions individually or in combination in any appropriate order, and has broad discretion to impose any action or sanction (or combination of actions and sanctions) that it determines is warranted by the underlying conduct. Factors the APPIC Board may consider when determining which action(s) or sanction(s) to invoke may include but are not limited to intent, consequences or potential consequences to individuals or the profession, single or multiple occurrences at present or over time, patterns of conduct, frequency of prior complaints, and nature and degree of program responsiveness to identified concerns.

Potential APPIC Actions & Sanctions in Response to Non-Adherence to Membership Criteria or APPIC Policy

  1. Educative Directive – an oral or written statement to the Training Director, DCT, or other relevant identified person specifying the conduct of concern or potential nonadherence. This statement may consist of one or more of the following: a) advising the Training Director, DCT, or other party of the relevant APPIC membership criterion or policy, b) issuing a directive that specific corrective action is needed to come into adherence with the identified criterion/policy and where failure to adhere may result in more serious actions or sanctions, c) offering guidance about methods to foster such adherence, d) requesting a response of acknowledgement and affirmation of the program’s agreement to adhere to the identified criteria/policy, and/or e) requesting an articulated plan for rectifying the identified problem within a specified time frame to ensure future adherence to the identified criteria/policy. This APPIC action is most likely when APPIC has determined an inadvertent, technical, or otherwise relatively minor violation of APPIC membership criteria/policy occurred that does not warrant a more severe action or sanction.

  2. Required Review by a Relevant APPIC Committee – required review by an appropriate APPIC committee (e.g., Internship Membership and Review Committee, Postdoctoral Membership and Review Committee, APPIC Doctoral Program Associate Review Committee) with the purpose of evaluating adherence to APPIC membership criteria/policies. Programs may be required to undergo full review or targeted review pertaining to specific criteria. Programs identified as nonadherent with membership criteria or APPIC policies will be required to implement changes necessary to ensure subsequent adherence and may incur additional APPIC actions or sanctions following review.

  3. Reprimand - a private written statement to the Training Director or DCT identifying the conduct of concern and that may specify specific corrective action with a copy to that individual's immediate supervisor, chief psychologist, and/or and other appropriate institutional leadership. A reprimand is often accompanied by requirement of a program’s written response of acknowledgement and articulated plan for rectifying the identified problem within a specified time frame. A reprimand may also require provision of additional written documentation demonstrating rectification of the identified concern(s) (e.g., documentation of revised policies and procedures, documentation demonstrating subsequent adherence to a membership criterion or policy). This APPIC action may be more likely invoked following insufficient response to an Educative Directive or when APPIC has determined a policy violation has occurred in repeated fashion or with more potentially serious or far-reaching ramifications.

  4. Monitoring - a required monitoring period with specific documentation/reports required from the program, as deemed appropriate by the Board. This may be more likely invoked when APPIC has determined a policy violation has occurred in a repeated fashion or with more potentially serious or far-reaching ramifications.

  5. Restriction of Access to the Match and/or Post-Match Vacancy Service (PMVS) – restriction of, or removal from, participation in the APPIC Match or PMVS. This may be more likely to occur in the event of failure to adhere to APPIC Match policies. Duration of the restriction is at the Board’s discretion and may occur with or without specified required conditions for re-entry.

  6. Hiding Program Listing in the APPIC Directory and/or APPIC Universal Psychology Postdoctoral Directory (applicable only to APPIC-member internship and postdoctoral programs)– rendering a training program’s Directory listing as invisible to students or other individuals referencing the Directory. This may be more likely to occur when programs are non-responsive to APPIC requests to update their Directory listing or are restricted from Match/PMVS access. Hiding a program listing in and of itself does not affect current membership.

  7. Specified Conditions for Continuance as a Member or a Doctoral Program Associate – required changes upon which a program’s continued APPIC membership or DPA status is contingent (e.g., program policy and/or procedure revisions, personnel changes). The program will be required to provide evidence of adherence to the specified conditions.

  8. Referral to Other Relevant Body - Provision of information to relevant state, provincial, or national associations/agencies, accrediting bodies, boards, or other appropriate bodies. This may be more likely to occur in response to evidence of egregious conduct (e.g., evidence of fraudulent or unethical activities or evidence of nonadherence to the standards of the above-named bodies).

  9. Probation with Censure - a written statement to the Training Director or DCT, along with other appropriate institutional leadership, with indication of probation, as well as potential public notification of probationary status. This may be more likely invoked when APPIC has determined a membership criterion or policy violation has occurred that warrants a more significant response than solely one or more APPIC actions as described above. The effective date of the probation will be the date of the APPIC Board of Directors’ vote to issue this sanction. Probationary status will be in effect for a specified time frame as determined by the APPIC Board, with a review occurring prior to the end of the probationary period. The probationary period may incorporate additional APPIC actions (e.g., monitoring, required documentation/written reports to articulate methods of remediating the problem and/or evidence of outcome of those efforts). The APPIC Board of Directors determines any specific requirements for a program’s restoration to good standing; prior to the end of the specified probationary period, the APPIC Board will evaluate and determine whether stated requirements have or have not been met and will vote to either conclude or extend the probationary period. APPIC may inform relevant parties of the probation, including but not limited to APPIC Member and non-member internship and postdoctoral programs, DPA and non-DPA academic programs, current or potential applicants, accrediting bodies and/or other relevant bodies, and may make public notification through APPIC’s website, newsletter, or other means. Probation with censure does not affect current membership or DPA status.

  10. Expulsion – removal from membership / DPA status with associated discontinuation of all rights and benefits. Expelled member programs are placed in Inactive status in eMembership (see Policy for APPIC-Member Programs Requesting Program Withdrawing Status or Deemed Inactive), are no longer visible in the APPIC Directory Online, and are not permitted to use any APPIC services without the approval of the APPIC Board of Directors. APPIC may inform relevant parties of the expulsion, including but not limited to APPIC Member and non-member internship and postdoctoral programs, DPA and non-DPA academic programs, current or potential applicants, accrediting bodies, and/or other relevant bodies, and may make public notification through APPIC’s website, newsletter, or other means. Any program that was previously an APPIC Member or DPA may re-apply for APPIC membership or DPA status at any time. In such cases, the program will undergo routine new member/DPA application procedures; the APPIC Board may also require additional information prior to the Board vote that determines if a program is admitted to membership/DPA status. In addition to the routine membership/DPA application review and any additional requested information, the Board’s decision about re-admittance may also consider circumstances of the prior departure from membership/DPA status and any program changes since that time. The APPIC Board also has authority and discretion to apply specific contingencies required for re-admittance of a previously expelled or otherwise re-applicant program to membership/DPA status.

  11. Other Action or Sanction as May be Appropriate Under the Specific Facts – The APPIC Board of Directors has the discretion to craft other appropriate remedies as dictated by the facts of a specific situation, and may accordingly identify that an action or sanction other than those specified above is the most appropriate response to a specific case.