Voluntary Certifications

Beyond the forms of government-directed regulatory oversight described previously, another form of credentialing involves voluntary certification such as the designations offered by the Society for Human Resource Management (SHRM) or the American Board of Professional Psychology (ABPP). Voluntary certifications may be advanced, specialist designations beyond a basic license to practice or serve as an alternative form of minimum competence credentialing in fields where no license to practice is required (Shimberg, Reference Shimberg, Schoon and Smith2000). Voluntary certification can benefit the public by signaling that a certified service provider has met the qualification standards set by a professional society. This potential benefit seems most likely in cases where the voluntary certification is developed and administered using assessment practices that comply with professional standards (see American Educational Research Association, American Psychological Association, & National Council on Measurement in Education, 2014). However, there is considerable variability in the quality of voluntary certifications. For example, Goldacre (Reference Goldacre2010, p. 122) described how he signed up his dead cat as a “certified professional member” of the American Association of Nutritional Consultants.

The “‘alphabet soup’ of acronyms” is a source of confusion and skepticism among members of the public and others (e.g., employers; client organizations) about voluntary certifications (Hamm, Reference Hamm, Schoon and Smith2000, p. 31). Professional societies need to convince their practitioner communities, potential employers or organizational clients, and the broader public of a voluntary certification's value (Hamm, Reference Hamm, Schoon and Smith2000). Reaching the public, in particular, is a “massive marketing challenge” (Hamm, Reference Hamm, Schoon and Smith2000, p. 32), and even if the public is made aware of and develops trust in a voluntary certification, that form of credential offers little recourse in case of practitioner malpractice or misconduct. Although a professional society may revoke a voluntary certification, unlike a licensing board, it cannot issue an order for a practitioner to cease and desist practice activities or use of a title. For example, someone who is certified by an organization and violates its ethics code can only lose his or her certification; there is no way for the certifying body to limit or revoke the individual's right to practice or use an unregulated title.

Governments recognize that professional societies and the voluntary certifications they offer can benefit the public. Consequently, governments may indirectly support such efforts by affording exemptions from taxation to private-sector, nonprofit societies (Atkinson, Reference Atkinson, Schoon and Smith2000; Hopkins, Reference Hopkins, Schoon and Smith2000; Schoon & Smith, Reference Schoon, Smith, Schoon and Smith2000a). Professional societies may also use legal mechanisms provided by governments (e.g., copyright and trademark laws) to restrict the use of their voluntary certification to those who have met their standards (Shimberg, Reference Shimberg, Schoon and Smith2000), but a government does not regulate a voluntary certification per se. Although the public may benefit from voluntary certifications, public protection is ancillary to the primary aims of the professional societies and associations that offer them. The U.S. Internal Revenue Service has established a position that the primary purpose of voluntary certification is to promote the business interests of those certified (Hopkins, Reference Hopkins, Schoon and Smith2000; Schoon & Smith, Reference Schoon, Smith, Schoon and Smith2000a, Reference Schoon, Smith, Schoon and Smith2000b).

Concerns About Licensure of I-O and Consulting Psychologists

Key barriers and issues concerning the licensure of I-O and consulting psychologists will be discussed in a subsequent section. In this section, we want to review some underlying concerns about licensure raised by I-O and consulting psychologists.

Sackett (Reference Sackett1986) provided converging evidence from job analyses, archival literature, and continuing education (CE) offerings that I-O psychology is more concerned with “the design and evaluation of systems” (p. 22) for organizational clients and much less likely to involve one-on-one work with individuals. Sackett's description remains a useful source to orient stakeholders about the I-O community and help explain why licensure requirements designed for one-on-one helping professionals can present challenges for those whose practices are at the organization or systems level. A one-size-fits-all model does not work well with the realities of I-O and consulting practice. Nevertheless, a sizable portion of I-O psychologists (and perhaps larger portion of consulting psychologists) conduct individual psychological assessments and coach individual managers and executives. A need exists to expand research and practice on these core competencies (Silzer & Jeanneret, Reference Silzer and Jeanneret2011). Silzer and Jeanneret argued that licensure is relevant in this practice domain.

The SIOP Task Force that recommended changing the SIOP “Policy on Licensure” in 1995 did so with two key constraints—no additional administrative bureaucracy and no blanket endorsement of licensure (vs. identifying aspects of practice that might reasonably be subject to licensure; Sackett et al., Reference Sackett, Thomas, Borman and Campion1995). As noted previously, respondents to recent member surveys have recognized the potential for harm from unqualified people trying to do their work (Axton et al., Reference Axton, Porr, Dumani and Ferro2016; Shen, Reference Shen2016; Silzer et al., Reference Silzer, Erickson and Cober2009; SIOP, 2011). Unfortunately, those sources provide little guidance about the riskier activities that might appropriately be subject to licensure. The nature and severity of potential harms that could be inflicted by I-O and consulting psychologists are subject to debate and are likely different from potential harms related to health service provision. Howard and Lowman (Reference Howard and Lowman1985) identified nine (out of 172) task statements from a job analysis of the I-O psychologist's job that might put individuals at risk (e.g., tasks dealing with employee counselling). Howard and Lowman (Reference Howard and Lowman1985) argued that the risks posed to individuals by I-O practice seem much less obvious than is the case for clinical, counselling, and school psychology.

I-O and consulting activities directed at higher levels of analysis (e.g., organizational policies) could pose serious indirect risks to large numbers of individuals (Vandaveer, Reference Vandaveer1991). However, Howard and Lowman (Reference Howard and Lowman1985) pointed out that organizations’ employment practices can be and often are regulated directly (e.g., via employment laws) and that such laws and regulations provide better protection to the public than does “licensing those few advisors who may be labeled psychologists” (Howard & Lowman, Reference Howard and Lowman1985, p. 45). SIOP's “Policy on Licensure” recognizes that jurisdictions may require some aspects of I-O practice to be licensed yet maintains that “many of the work and research activities of I/O psychologists are not unique to this discipline, do not pose a threat of harm to the public, and are not subject to licensure” (Campion, Reference Campion1996, para. 2). The practice activities that should be licensed have not yet been made clear nor has the issue of how to deal with related disciplines (e.g., human resources) doing similar work.

In addition to concerns from a practice perspective, there are also concerns about potential implications of licensure raised by academics. Academic psychologists initially opposed licensure of psychologists because they were concerned about potentially restrictive curricula requirements and threats to academic freedom (Reaves, Reference Reaves and Vaughn2006). Some I-O psychologists have also objected to licensure on the grounds of the need for freedom and flexibility (e.g., Campbell, Levy, Murphy, Schmitt, & Weiss, Reference Campbell, Levy, Murphy, Schmitt and Weiss2009; Howell, Reference Howell1986; Thayer & Goldstein, Reference Thayer and Goldstein1991). For example, Howell (Reference Howell1986, pp. 37–38) argued,

Howell's (Reference Howell1986) article, especially the above quote, has been useful to the LCIOP Joint Task Force. It, along with other sources (e.g., Byrne et al., Reference Byrne, Hayes, McPhail, Hakel, Cortina and McHenry2014; Campbell et al., Reference Campbell, Levy, Murphy, Schmitt and Weiss2009; Howard & Lowman, Reference Howard and Lowman1985; Sackett, Reference Sackett1986), has helped some of our members articulate the cultural opposition to licensure and program accreditation in I-O psychology. Conversely, the Howell quote above allowed regulators on the Joint Task Force to argue that licensure is not about “uniformity” but about ensuring minimum standards for public protection. Those minimum standards provide a common foundation for evidence-based practice, scientifically informed innovation, and renewal of professional competence to provide both existing and emerging services. The LCIOP Joint Task Force has discussed ideas about how best to respect freedom for creativity and innovation with the practical reality that psychology is a regulated profession. Licensure systems are not fixed entities. We see opportunities for change.

Mounting Pressure on Licensing Boards

Recently, occupational and professional regulations have received increased scrutiny by judicial, legislative, and executive branches of government. Anticompetitive concerns about licensure are not new, but a jurisdiction's right to regulate occupations and professions has traditionally provided great deference to licensing boards. However, the U.S. Supreme Court's decision in the case of the North Carolina State Board of Dental Examiners v. Federal Trade Commission (2015) has amended the assumption that a state's licensing boards, controlled by market participants (i.e., members of the regulated profession), can engage in anticompetitive behavior without fear of antitrust scrutiny. The U.S. Senate held a 2016 hearing, License to Compete: Occupational Licensing and the State Action Doctrine, to examine related issues. A significant case from Texas will be discussed later in the section about the scope of practice.

Canadian governments revised the Labour Mobility chapter of the Agreement on Internal Trade (AIT) in 2009, stipulating mutual recognition of licenses in other jurisdictions as the default to facilitate interjurisdictional movement among professions and skilled trades (Knox, Reference Knox2010). The revised AIT has impacted the regulation of professional psychology in Canada, prompting regulators to move toward a National Standard for Entry to Practice (Association of Canadian Psychology Regulatory Organizations [ACPRO], 2014). Incidentally, there are positive features of the ACPRO model but also concerns that the LCIOP Joint Task Force has expressed formally to ACPRO (i.e., CPA accreditation, predoctoral supervision requirement).

Kleiner (Reference Kleiner2015) noted several recent examples of governors vetoing occupational licensing legislation, even from legislatures dominated by their own parties. Also, legislators have become more demanding of justification for licensing (Kleiner, Reference Jelley, Bonaccio and Chiocchio2006). The White House (2015) provided a review of licensure-related issues and presented a best practices framework for reform, along with $15 million in new discretionary funding in the 2016 budget. Those best practices reflect three key themes that are instructive for our purposes, as well for consideration by legislators and licensing boards:

• • “Ensure that licensing restrictions are closely targeted to protecting public health and safety, and are not overly broad or burdensome”;

• • “Facilitate a careful consideration of licensure's costs and benefits”; and

• • “Work to reduce licensing's barriers to mobility” (White House, 2015, pp. 42–43).

Later we will examine aspects of these themes as they apply to I-O and consulting psychology (see “Barriers, Issues, and Recent Developments”). Regardless of your perspective on licensure of consulting and I-O psychologists, it is important to recognize both the popularity of occupational regulation as well as pressures for and possibility of reform.

Reflecting on the Side Effects of Licensure

In addition to its specific goal of protecting the public, licensure has a number of other outcomes, which may be positive or negative, depending on one's perspective. We have already described some negative side effects, but it is important to recognize that licensed professionals can also gain certain benefits from licensure. Among the benefits are increasing credibility with potential clients, use in branding and marketing, and providing greater access to professional liability insurance (Scontrino, Gormanous, & Blanton, Reference Schoon, Smith, Schoon and Smith2010). Courts may be more likely to recognize a licensed professional as an expert witness (Byrne et al., Reference Byrne, Hayes, McPhail, Hakel, Cortina and McHenry2014; Howard & Lowman, Reference Howard and Lowman1985). In addition, it may be beneficial to be able to identify openly as a psychologist (Scontrino et al., Reference Schoon, Smith, Schoon and Smith2010). Having I-O and consulting psychologists’ good work clearly linked to psychology seems a bigger benefit for the visibility of the profession than it is for those individual psychologists. Providing a viable credentialing option within professional psychology may help build a professional identity as psychologists. Otherwise, people trained in I-O or consulting psychology may seek alternative credentials such as human resources certifications that currently seem more accessible and relevant to some I-O and consulting professionals than is licensure as a psychologist (Jelley, Bonaccio, & Chiocchio, Reference Jelley, Bonaccio and Chiocchio2014). The I-O and consulting communities might consider using existing administrative infrastructures (e.g., licensing boards, ASPPB, ABPP, APA Practice Organization) to help build visibility and brand recognition, especially if there are concerns about additional administrative bureaucracy (Sackett et al., Reference Sackett, Thomas, Borman and Campion1995).

Thinking critically about licensure serves to remind all stakeholders that, to foster public protection, governments and their delegated authorities should implement standards that provide adequate protection from the incompetent or unscrupulous while also providing consumers the choice to access competent, cost-effective services. This can include providing consumers with the freedom to use unregulated services or less restrictively regulated (e.g., statutory certification) services when the risks are low or when other mechanisms (e.g., lawsuits, regulation of organizations) exist to manage risks.

Scope of Practice

The ASPPB (2010, p. 7–8) MLA contains an expansive scope of practice statement (see also APA, 2010, p. 2), as do many jurisdiction's statutes. In part, the ASSPB MLA specifies,

I-O and consulting psychologists have raised concerns about this and similar scope of practice statements because they define the practice of psychology very broadly (seemingly exhaustively), and the ensuing laws typically specify that it is illegal for any unlicensed person (with a few exemptions) to engage in activities constituting the practice of psychology (e.g., ASPPB, 2010, p. 3). This creates a situation where strict interpretation would prohibit unlicensed people from lawfully engaging in activities that many other individuals (e.g., GAPs, human resource professionals, managers) are competent to perform and who commonly do this work. Such practice restrictions are particularly problematic for GAPs when licensure requirements are difficult or impossible for them to meet (i.e., education and supervision) or are perceived as being unrealistic given interjurisdictional demands of their practices.

Beyond challenges for GAPs to identify as psychologists or practice psychological activities, the LCIOP Joint Task Force has also discussed the issue of balancing public protection through licensure of professional practice with the noble idea of “giving psychology away” (Miller, Reference Miller1969, p. 1071). By giving psychology away, the field can have an even larger positive impact through more widespread application of evidence-informed principles. I-O and consulting psychologists promote such use of psychological principles by, for example, providing knowledge translations meant for broad consumption and application (e.g., Latham, Reference Latham2009). During its deliberations, the Joint Task Force has considered some members’ contention that there should be no prohibition in law for members of the public (e.g., parents, managers, and consultants operating outside a regulated profession) to apply psychological principles in a responsible, ethical manner to improve the human condition, their families, and organizations.

Recent case law has served to reinforce that position and heighten the attention of the LCIOP Joint Task Force and, one hopes, others (e.g., ASPPB, psychological associations, and licensing boards) to related issues of title law, free speech, and appropriate scope of practice. In the case of Serafine v. Branaman (Reference Branaman2016) the U.S. Court of Appeals for the Fifth Circuit reversed aspects of a lower court's decision in favor of Dr. Serafine who, despite being neither licensed nor eligible for licensure as a psychologist in Texas, had identified herself as an “Austin attorney and psychologist” (p. 2) on her political campaign website. Subsequently, Dr. Serafine was ordered by the Texas State Board of Examiners of Psychologists “to stop using the title of ‘psychologist’ and to desist from offering or providing psychological services” (Serafine v. Branaman, Reference Branaman2016, p. 1). Serafine sued and, eventually, won important clarifications. The Serafine case includes nuances that must be considered more completely before its full implications for practice are made clear (e.g., political free speech vs. soliciting clients). For our present discussion, the Serafine case highlights that (model and actual) legislation should be crafted carefully to respect free speech, avoid overly broad scope of practice definitions,Footnote ¹ and limit the discretion of a licensing board to determine what constitutes the practice of psychology.

The LCIOP Joint Task Force has also considered the constructive advice offered by Gary Latham in his comment from the audience at one of our symposia (Jelley, Reference Jelley2014). Specifically, Latham advised that it would be wise to avoid language that may be perceived to infringe on and, consequently, provoke large, well-funded societies that do similar work to I-O and consulting psychologists (e.g., human resources). We suggest that ASPPB should have no interest in model legislation/regulations that its member jurisdictions will encounter deep resistance to adopt or that is unlikely to survive a legal challenge, if adopted. We have debated whether and how to provide a relevant exemption for nonlicensed people such as management consultants. South Carolina (Professions and Occupations–Psychologists–Exemptions, 1998) has provided an example that the LCIOP Joint Task Force conveyed to MARC for its consideration.

The LCIOP Joint Task Force shared other, related considerations with MARC. In particular, it is possible to define the scope of practice broadly in terms of activities in which a given professional may engage yet only restrict to designated, licensed professions certain high-risk activities that are of greatest concern from a public protection perspective. The latter are sometimes referred to as “controlled,” “authorized,” “reserved,” or “restricted” acts. A license may contain a “specific endorsement” to engage in one or more particular controlled act(s). Communicating a diagnosis and engaging in psychosocial treatment interventions are the common examples among Canadian ASPPB member jurisdictions that take this approach, often under general health professions legislation. Similarly, accountants engage in a variety of practice activities only a subset of which are restricted to licensed public accountants. A broad scope of practice need not be restricted in its entirety to one or more licensed profession(s).

It appears that ASPPB may consider shifting from its traditional approach of generic licensure to one that continues generic licensure but recognizes two different pathways to licensure: one for HSPs and another for GAPs. MARC requested that we provide greater clarity in terms of the definitions of HSP and GAP as part of its examination of that possibility (building on APA, 2010). The GAP category is meant to include I-O and consulting psychologists as well as a variety of others such as military psychologists, police psychologists, forensic psychologists, and sports psychologists. We have presented language similar to what follows for MARC's consideration (except for a few changes herein), based largely on the APA (2010) MLA as well as numerous other sources (e.g., jurisdiction's statutes). We present that (draft) language below for readers’ consideration. Which subcategories of GAP-related practice activities should be regulated has been the subject of some of the LCIOP Joint Task Force's most lively debates. In particular, should any, some, or all of the GAP subcategories be subject to licensure? This question has been debated constructively yet not settled within the LCIOP Joint Task Force.

Toward Greater Clarity in the Definitions of HSP and GAP (Adapted From APA, 2010)

“Applied psychologist.” An “applied psychologist” is a person who provides professional services to individuals, groups, organizations, and/or policymakers based on the evidence-informed application of psychological methods and principles. Within this broad category there are two major groupings: those who provide health-related services to individuals and those who provide other professional services to individuals, groups, and/or organizations. Rules and regulations adopted by the board/college shall account for variations in relevant training, supervision, and practice. All applied psychologists are permitted and expected to practice in their area(s) of competence in a manner that promotes human welfare and well-being. An applied psychologist, duly qualified under relevant rules and regulations, may engage in activities described below with respect to either or both of the two major groupings. The groupings are not mutually exclusive (e.g., a forensic psychologist may be qualified to engage in diagnosis and treatment of individuals as well as consult on correctional rehabilitation programs and policies) nor do the groupings provide exhaustive lists of fields of psychology or tasks in which an applied psychologist may engage.

A. “Health service provider” (HSP) in psychology. An HSP in psychology means an individual licensed under this act who is duly trained and experienced (i.e., meets defined criteria of training and experience adopted by the board/college in rules and regulations) in the delivery of promotion, preventive, assessment, diagnostic, therapeutic intervention, and management services relative to the psychological and physical health of consumers. An HSP in psychology is authorized, subject to the terms, conditions, endorsements, and limitations imposed on his or her license, to perform the following [authorized, controlled, reserved, or restricted] acts:

1. 1. To (a) make a diagnosis identifying, as the cause of a person's symptoms, a neuropsychological disorder or psychologically based psychotic or personality disorder that is within the psychologist's scope of clinical training and competence; and (b) communicate a diagnosis to an individual; his or her personal representative; or court, authority, or other official body in circumstances in which it is reasonably foreseeable that the individual, representative, or authority will rely on the diagnosis to make a decision about the individual and their health care.

2. 2. To treat, by (a) means of psychotherapy technique delivered through a therapeutic relationship, (b) applying or ordering the application of a form of energy, and/or (c) where authorized by statute, prescribing a drug, an individual's serious disorder of thought, cognition, mood, emotional regulation, perception, or memory that may seriously impair the client/patient's judgement, insight, growth, adjustment, behavior, communication, or social functioning.

B. “General applied psychologist.” GAPs provide psychological services to individuals, groups, organizations, and/or policy makers aligned with their specific training and competence in particular fields and contexts (e.g., industrial–organizational, human factors and ergonomics, sport and exercise, legal and correctional). GAPs may conduct assessments; offer consultation; and/or design, deliver, administer, manage, and/or evaluate interventions related to cognition, affect, and/or behavior, all for the purpose of enhancing the performance, effectiveness, and well-being of individuals, groups/teams, organizations, and/or society. They may offer expert opinions and testimony in their area(s) of expertise. GAPs provide psychological services outside of the health and mental health fields that may include services such as

1. 1. the provision of direct services to individual clients, or to an individual on behalf of another client (e.g., organization), using psychological principles, methods, and/or procedures. Direct services to individuals include services such as

   1. a) assessment and evaluation on personal abilities and characteristics for individual development, behavior change, performance enhancement (e.g., at work, in sport competition), and/or for making decisions by or about the specific individual (e.g., vocational choice, selection or deselection, individual development, promotion, reassignment);

   2. b) providing feedback, consulting, and/or coaching individuals (e.g., athletes, business executives) for individual development, behavior change, and/or performance enhancement; and

   3. c) recognizing signs of potential mental health disorders and making referrals to a qualified HSP for assessment, diagnosis, and treatment, as applicable;

2. 2. the provision of services related to groups/teams such as composition, communication, goals, interpersonal relations and conflict management, role clarification, cohesion, development, norms, and/or decision-making dynamics to enhance performance and member satisfaction; and

3. 3. the provision of services to organizations that are provided for the benefit of the organization and do not involve direct services to individuals, such as job analysis, attitude/opinion surveys, selection testing (i.e., administration of standardized tests or interviews in which responses are mechanically scored and interpreted as part of a competitive process involving multiple individuals), selection validation, program evaluation studies, designing performance appraisal systems, training, organization design, advising management on human behavior in organizations, organizational assessment, diagnosis and intervention of organizational problems, and related services.

Providing input to MARC into the possible future direction of ASPPB's model act and model regulations was a specific charge given to the LCIOP Joint Task Force. Work on that charge also relates to other charges such as identifying and addressing licensure barriers.

Educational Requirements

A number of jurisdictions (14) require an applicant for licensure to have graduated from an APA- or CPA- accredited program (see Appendix). Many current educational requirements pose problems for GAPs because neither APA nor CPA currently accredit programs in GAP-related areas like I-O or consulting psychology. That is not to say that APA or CPA are unwilling to consider expanding accreditation (e.g., see the editor's note to O'Neill & Jelley, Reference O'Neill and Jelley2012), but that does not seem likely to happen anytime soon. ASPPB (2013) has recommended that graduation from an APA- or CPA- accredited program should be required specifically for licensure of HSPs. This reflects heightened pressures from insurance companies and other groups in health-related fields for licensed professionals to have graduated from accredited programs. Jurisdictions that require graduation from an APA- or CPA-accredited program as a prerequisite for licensure cause problems for GAPs regarding meeting the education requirement for licensure.

The LCIOP Joint Task Force recognizes that accreditation of graduate programs is a contentious issue in I-O psychology. Some I-O academic leaders have cautioned strongly against accreditation or even quasi-accreditation, arguing that comprehensive psychology departments are unlikely to tolerate additional accrediting requirements (Campbell et al., Reference Campbell, Levy, Murphy, Schmitt and Weiss2009). Although Jeanneret (Reference Jeanneret2009) argued that licensure is appropriate for his type of I-O practice and asked for the support of academic colleagues with respect to preparing I-O students for licensure, he also offered to help academics battle program accreditation. Opposition to accreditation may reflect a concern about its possible effects on the culture of intellectual diversity that has been central to I-O psychology (Howell, Reference Howell1986) as well as potentially heavy financial and time burdens. Byrne et al. (Reference Byrne, Hayes, McPhail, Hakel, Cortina and McHenry2014) recognized potential value in helping students meet licensure requirements but captured a common concern about having criteria dictated by non-I-O psychologists along with more substantive concerns of displacing research and I-O topics with non-I-O practica and coursework. Program accreditation is commonly perceived as onerous.

The LCIOP Joint Task Force has recommended that licensing boards specify clearly that any law or regulation requiring APA- or CPA-accreditation applies only to HSPs and that GAPs be afforded alternative ways to demonstrate knowledge of required psychological domains (LCIOP Joint Task Force, 2016b). Further, the LCIOP Joint Task Force has explored ways to ease the additional work for licensing boards if they would need to adjudicate candidates from nonaccredited GAP programs. For example, Joint Task Force members (LCIOP Joint Task Force, 2016a) mapped course titles from the SIOP (1999) doctoral education and training (E&T) guidelines, and other frameworks, to the ASPPB coursework content areas (psychological knowledge domains often used for licensure adjudication). A recent update to the SIOP E&T guidelines (SIOP, 2016) did not have any material effect on that work as the categories were similar. LCIOP's Coursework Reference List for I-O (LCIOP Joint Task Force, 2016a) has been approved by ASPPB's Board of Directors for dissemination to member jurisdictions and has been posted on the ASPPB Members Only website. The effort reveals that most I-O programs have coursework or could provide access to appropriate courses in the domains of psychological knowledge typically required for licensure through other psychology programs/areas in their respective academic settings.

Three LCIOP Joint Task Force sponsors—ASPPB, SIOP, and SCP—also jointly funded an I-O student to categorize course information from 63 doctoral I-O programs against the SIOP (1999) E&T Guidelines. SIOP's (2016) E&T Guidelines are now available, but the 1999 version was more appropriate for our purpose because programs have not yet had time to reflect on implications of the new version for their curricula. The chair of the LCIOP Joint Task Force invited program directors to review the accuracy of the information about their programs, and the updated information is being integrated into the database. Based on the preliminary information available at this point, it appears the only commonalities among I-O programs in terms of required courses are for research methods (92% of programs) and statistics (97%), both of which involve course content not exclusive to I-O psychology. This finding is consistent with Sackett's (Reference Sackett1986) analysis and conclusion that “the possession and everyday use of an arsenal of research skills is central to functioning as an effective I/O psychologist” (p. 22). The variation of substantive topic coverage across programs likely reflects the high value placed on intellectual diversity in the field as well as the broad range of topics that relate to psychology applied to work. However, some would argue that it is difficult to justify the term “I-O psychology education” if there is so much variety in the curriculum.

Consideration of the current SIOP “Policy on Licensure” (Campion, Reference Campion1996) reveals categories relevant to I-O for licensing boards’ consideration. These include basic fields of psychology, research fields, and I-O fields. Whereas the research field seems relatively consistent among I-O programs in terms of required courses, based on our study the requirements for both the basic fields of psychology and the I-O fields are quite heterogeneous across programs. The SIOP (1999, 2016) E&T Guidelines are comprehensive and aspirational. However, it would be useful to identify a complementary, smaller nucleus of essential I-O fields that represent the fundamental body of knowledge that defines I-O psychology. This set of essential I-O fields would enable common-foundation alignment among programs and clarify minimum competence domains. Exhaustive specification of program requirements beyond a small nucleus seems ill-advised given the breadth of substantive topics programs, faculty, and students might like to pursue. It would be inappropriate for us to comment on what the essential I-O fields should be, but we suggest that SIOP/CSIOP should consider doing so. Likewise, SCP could engage in a similar process for consulting psychology programs.

Supervised Professional Experience Requirements

It is common for licensing boards to require licensure candidates to accumulate a certain number of hours of practical experience through a formal program that is supervised by licensed psychologists. The LCIOP Joint Task Force (2016b) has reminded regulators that outside HSP domains, such as in consulting and I-O, very few programs include APA- or CPA-structured pre-doctoral internships. Likewise, postdoctoral internships for GAPs are typically informal (Blanton, Reference Blanton2014), and it is difficult for candidates to find licensed supervisors and opportunities that would satisfy licensure requirements. Even HSPs have struggled to find required internship experience, and leaders have needed to come up with creative solutions (Hogg & Olvey, Reference Hogg and Olvey2007) and multimillion dollar investments (Walton, Reference Walton2013) to tackle the internship matching challenge. Requiring large numbers of I-O and consulting candidates for licensure to obtain supervision from licensed psychologists would further strain the system for HSPs. In many cases, it could also result in a poor match between a supervisor's scope of competence and the candidates’ desired area of practice.

Barriers in supervision can make it difficult or impossible for a GAP to become licensed. Consequently, the LCIOP Joint Task Force (2016b) has recommended that licensing boards (continue to) provide an option that all supervised professional experience can be acquired post-doctorate, in contrast to pressures in health domains for required predoctoral supervised experiences. Further, requirements that supervisors be licensed pose problems for finding appropriately qualified supervisors (i.e., a licensed I-O psychologist vs. a licensed clinician). We have recommended alternative supervision plans to meet supervision requirements for GAP fields when there is a lack of licensed practitioners available to provide supervision (LCIOP Joint Task Force, 2016b). Preliminary work in California suggests this is a difficult issue to address given current laws. The I-O and consulting communities can help by providing licensed supervisors, where possible, or advocating for, supporting the development of, and participating in alternative supervision plans that might utilize well-trained, nonlicenced professionals as part of the supervision process.

The SIOP “Policy on Licensure” recognizes the value of supervised professional experience and outlines considerations for such experiences (Campion, Reference Campion1996). Contributors to the March 2014 issue of this journal (see Byrne et al., Reference Byrne, Hayes, McPhail, Hakel, Cortina and McHenry2014, and related commentaries) have examined proposals for SIOP-certified internships and postdocs. Improving the status quo (see Blanton, Reference Blanton2014) of preparation for professional practice is laudable even if the means through which this is accomplished requires further examination. The LCIOP Joint Task Force considered the possibility of “certification” or “accreditation” by SIOP or other groups outside of APA to approve programs to qualify for supervised experience. However, commentaries from I-O practitioners have cautioned against formal certification of internships arguing that such requirements could threaten the very experiences the certification program would seek to foster (Gibby, McCance, Pusilo, Ducey, & Biga, Reference Gibby, McCance, Pusilo, Ducey and Biga2014; Mueller-Hanson, Reference Mueller-Hanson2014; Pratt & Massman, Reference Pratt and Massman2014; Sund et al., Reference Sund, Smith, Bastos, Small, Mills and Chaudhuri2014). For example, organizations would likely hire interns from allied fields instead of subjecting themselves to a bureaucratic I-O internship certification process.

The LCIOP Joint Task Force has agreed that there are legitimate differences between the supervised professional experiences for GAPS and those of HSPs. We support the development of regulations that provide for alternate supervision plans for GAPs. Nevertheless, the I-O and consulting communities may consider adapting some lessons for preparing professionals for evidence-based practice from existing models in HSP (Catano, Reference Catano2011). Efforts to improve the opportunities for supervised professional experience should consider the demands faced by licensing boards to vet appropriate training and how the I-O and consulting communities can facilitate GAP candidates’ adjudication by licensing boards. For example, ASPPB has established supervision guidelines for HSP. The LCIOP Joint Task Force has taken preliminary steps toward modifying those guidelines for GAPs.

Scope of Competence

The scope of practice for psychologists is often defined broadly. Furthermore, 89% of U.S. jurisdictions use a generic license. The LCIOP Joint Task Force (2016b) affirmed the ethical principle that psychologists provide services within their respective scopes of competence. For example, a consulting or I-O psychologist would require additional training and/or supervision before offering mental-health services. Equally, an HSP who wishes to offer I-O services could pose a risk without supplementary training in organizationally-relevant areas.

Continuing Education/Maintenance of Competence Requirements

One of the prime shortcomings of licensure systems pertains to ongoing demonstration of professional competence (Shimberg, Reference Shimberg, Schoon and Smith2000). Historically, CE courses were more acceptable to medical societies and their members than was the idea of periodic reexamination (Shimberg, Reference Shimberg, Schoon and Smith2000). However, it is doubtful that simply sitting through a series of CE courses assures continued competence or professional conduct (Neimeyer, Taylor, & Orwig, Reference Neimeyer, Taylor and Orwig2013; Shimberg, Reference Shimberg, Schoon and Smith2000). In particular, critics of mandatory CE have flagged the weak relationship between CE courses taken and licensees’ practice-related weaknesses (Shimberg, Reference Shimberg, Schoon and Smith2000).

The LCIOP Joint Task Force (2016b) has recommended to licensing boards that CE or maintenance of competence requirements be aligned with a psychologist's area of practice and client interests. Jurisdictions should be hesitant to require specific courses for license renewal that would be irrelevant to certain types of practice (e.g., mandating a “medical errors” course for a GAP). We recognize that legislators, not licensing boards, sometimes order the completion of CE courses that seem poorly tailored to professionals’ learning needs or client interests. We suggest psychological associations and other groups monitor this practice and urge decision makers to allow practitioners to focus CE on relevant topics. SIOP and SCP conferences already offer relevant CE credits for members. Making practice-relevant CE courses available to GAPs helps those who need to maintain licenses.

ASPPB (2014) has recommended that licensing boards transition from CE courses and workshops to continuing professional development (CPD), which is a broader concept that recognizes many ways psychologists can maintain their professional competence, such as through journal reading groups, independent study, publishing research, and so on. The consulting and I-O communities should also be aware that there is now a competence assessment movement in professional psychology (e.g., Fouad & Grus, Reference Fouad, Grus, Johnson and Kaslow2014; Rubin et al., Reference Rubin, Bebeau, Leigh, Lichtenberg, Nelson, Portnoy and Kaslow2007) that could have implications for entry-level licensing as well as maintenance of competence requirements. ASPPB is exploring competence assessments as an additional step in the licensing process that now focuses on testing academic knowledge (i.e., the Examination for Professional Practice in Psychology).

The I-O and consulting communities should consider ways of supporting continued professional development for GAPs through offering relevant programs and researching methods of maintaining and growing competence throughout one's career.

Mobility and Technology Issues

The realities of client work in I-O and consulting are different than those of HSPs. I-O and consulting psychologists often have practices that span multiple jurisdictions, travel to different locations, collect data, or otherwise engage with a client's employees in various jurisdictions in person or remotely (e.g., web surveys). For example, an anonymous reviewer posed the following questions that help illustrate the complexities relating to possible regulation of I-O and consulting psychologists. “If I deploy a survey for a client with employees in every state, where is the work being performed? In my office where I push the send button or in each location where an employee resides (as in the health care situation)? If I conduct an extensive test development and validation project for a client with a national footprint, am I going to need to track every time I go to a particular state for a job analysis interview or a focus group or a test administration session?” GAPs also frequently work with client representatives who travel among various jurisdictions and who use technology to connect with their service providers who are in a different jurisdiction. Interjurisdictional and remote practice activities pose serious challenges for those subject to occupational regulation.

Holding licenses in multiple jurisdictions or even meeting the requirements for advance notification to licensing boards to comply with short-term practice rules is impractical, represents a source of competitive disadvantage compared with nonlicensed professionals, and compromises best practices and client needs for timely responses. Multiple-jurisdiction licensure is also prohibitively expensive and complex. As an unusual example, Dr. Mark Cunningham is a clinical and forensic psychologist who maintains 19 licenses in different jurisdictions (Cunningham, Reference Cunningham2016). Obviously, that is an untenable and unrealistic situation for professionals, like GAPs, whose practices require work in multiple jurisdictions.

Another consideration is that some emerging requirements for the protection of individual health information (e.g., electronic health records) are likely inappropriate for GAPs consulting to organizations. Consequently, the LCIOP Joint Task Force (2016b) has advised regulators that laws and rules dealing with short-term, cross-state (or interprovincial) practice and technology-assisted practice must be updated to provide reasonable and practical ways to efficiently and effectively balance regulation with the realities of modern mobility and technology. Further, different regulations may be necessary for HSPs and GAPs.

ASPPB has several initiatives designed to facilitate temporary in-person practice, electronic practice, and mobility. There are existing tools that can be used and other promising options being developed (see the ASPPB Mobility Program web page). For example, the ASPPB Credentials Bank provides a central repository of one's licensing-related professional documents and results. This service is free and simplifies any application for jobs or licensure because materials are kept permanently in one place. Faculty and supervisors do not need to be contacted each time their sign off is required. The Psychology Licensure Universal System (PLUS) is an online system that provides a more convenient and streamlined method for a candidate for licensure to apply to a growing number of participating jurisdictions through ASPPB. ASPPB supplies the relevant licensing board(s) with the application information the jurisdiction needs to determine the candidates’ eligibility for licensure. The Interjurisdictional Practice Certificate (IPC) allows for up to 30 days of practice per year in a participating jurisdiction, upon proper notification, without the need for full licensure in the temporary-practice jurisdiction. The Certificate of Professional Qualification (CPQ) allows experienced psychologists with no disciplinary actions against them to more easily achieve full licensure in participating jurisdictions. The E.Passport is a new initiative designed to facilitate telepsychology practice among participating jurisdictions.

The Psychology Interjurisdictional Practice Compact (PSYPACT) developed by ASPPB is a recent and promising effort to address the mobility issues for in-person practice and practice via telephonic or electronic means. PSYPACT creates the E.Passport and extends the IPC. In May 2016, Arizona became the first state to adopt PSYPACT. Other state legislatures are considering adopting PSYPACT. The basic idea is that PSYPACT signatory jurisdictions would allow licensed professionals in other signatory jurisdictions the right to practice telepsychology as well as permitting temporary in-person practice for up to 30 days per calendar year. PSYPACT goes beyond compacts in some other professions (e.g., medicine) that are more about expedited licensure in a new state (similar to the CPQ). PSYPACT does not require a separate license in the receiving jurisdiction.

Although far from perfect, these various ASPPB mobility initiatives can help address mobility and technology challenges that limit psychologists’ practices and deprive clients of expertise and assistance that may happen to be located in a different jurisdiction. Jurisdictions must opt to participate in these initiatives for them to have full effect. Adopting mobility initiatives requires effort to amend legislation, but adopting a centralized initiative such as a compact is much more practical than is trying to enact bilateral agreements among all jurisdictions to achieve the same ends.

We recognize that SIOP would prefer a 60- vs. 30-day temporary practice period (Campion, Reference Campion1996); however, these political compromises were hammered out after a substantial debate and the PSYPACT must be accepted or rejected by each legislature as it stands, without tweaking. Despite remaining concerns, these efforts do address some of the challenges in mobility. The LCIOP Joint Task Force sees the development of PSYPACT as a promising possibility and encourages jurisdictions to consider its adoption. Likewise, it would be helpful for members of the I-O and consulting practice communities to bring PSYPACT and other ASPPB mobility initiatives to the attention of authorities in their jurisdictions.