Enforcement of a requirement that psychology internships be approved by the California Board of Psychology prior to beginning supervision threatens thousands of pre and post doctoral graduate students as well as interns with a loss of supervised hours and possible charges of perjury.
Dawn Vo-Jutabha, Ph.D., director of the psychology internship program at Didi Hirsch Mental Services in Los Angeles, said officials of the California Psychological Association (CPA) intend to discuss the matter with the board but in the meantime recommend that anyone facing possible perjury charges should hire a lawyer.
“Unfortunately, it doesn’t look to be good in the short run,” Vo-Jutabha said.
A web search of board regulations shows that at least since 2005 the board’s regulation covering an agreement for a psychological assistant plan for supervised professional experience has included the following requirement:
“This agreement is to be reviewed, completed, and signed by both the undersigned primary supervisor and supervisee prior to the commencement of the supervised professional experience (SPE). Experience prior to preparation of this document may not count toward qualifying the supervisee for licensure.”
The board’s website directing users to sites for both the Supervision Agreement Form and the Verification of Supervision Form, also carries the following warning: “The board has the authority to deny any hours of supervised professional experience in which a Supervision Agreement was not properly completed prior to the accrual of hours after January 1, 2005.”
It was unclear why the issue has only arisen since a Sept. 24 revision of the regulations, which did not change the prior approval requirement nor the jeopardy of perjury.
Vo-Jutabha said many students and supervisors apparently began internships before formally signing agreements and backdated the forms.
She provided excerpts from CPA progress notes as advice for interns:
“Lawyers and the CPA identify several things you can do at this point, but what is abundantly clear is that supervisors should NOT backdate forms. CPA has been working diligently to advocate for those affected and at this time is recommending the following steps:”
The first recommended steps to both supervisors and supervisees stress that they should follow the letter of the regulation and sign a supervision agreement and have it approved before commencing a supervised internship.
The advice continues: “If you have already begun to accrue hours and have not completed the agreement form, contact the Board of Psychology to discuss options or consult with an attorney familiar with the situation.”
The notes encourage those who have been denied hours or those with mitigating circumstances to appeal and request reconsideration.
The notes close with advice to become active in state and local professional associations “to remain abreast of the issues and receive up-to-date information.”