We think that before reading our reactions to the focal article, readers should be aware of the history of the Licensure of Consulting and I-O Psychologists (LCIOP) Joint Task Force. The Association of State and Provincial Psychology Boards (ASPPB) initiated the LCIOP, and the objectives of the task force were developed without input from Society for Industrial and Organizational Psychology (SIOP). In June 2013, Don Crowder informed Mark Nagy (SIOP Chair of State Affairs) that the ASPPB approved the establishment of a joint task force related to licensure of consulting and industrial and organizational (I-O) psychologists. The membership composition of the task force was determined by ASPPB, and SIOP was allotted one member. By including a member of SIOP, ASPPB can describe the task force as a cooperative effort and SIOP ostensibly has the opportunity to help shape recommendations made with regard to the licensure of I-O psychologists. Don Crowder now serves as the president of ASPPB. In Crowder's October 2016 ASPPB meeting address, he encouraged jurisdictions to review their statutes, and, if permitted, require licensure for both health service providers (HSPs) and general applied psychologists (GAPs).
In the remainder of this commentary we discuss three issues that pertain to the Licensure of Consulting and I-O Psychologists (LCIOP) Joint Task Force (2017) recommendations: (1) Who stands to gain by implementing the recommendations? (2) What are the implications of the recommendations for the standing of I-O in psychology departments? (3)What are the implications for the nature of our field?
For the Public or for Profit?
Who stands to gain by imposing regulations on I-O psychology? The LCIOP Joint Task Force (2017) suggests that the stated sole objective of licensure is to protect the public. Protection of the public as the motivation for regulation of I-O psychology does not hold water. No evidence is presented to support the notion that the absence of a requirement that I-O psychologists be licensed jeopardizes the health, safety, or well-being of the public. Research in general finds little indication that a relationship between occupational licensing and service quality exists (McLaughlin, Ellig, & Shamoun, Reference McLaughlin, Ellig and Shamoun2014). Moreover, if one did assume that protection of the public was needed, requiring I-O psychologists to be licensed would not result in public protection given that individuals not trained in I-O provide the same services without restriction.
What there is evidence of, however, is that ASPPB stands to financially gain from expanding licensure requirements. Expanded licensure requirements create an additional market for selling exams, selling courses for continuing education, charging annual membership fees, and so forth. ASPPB is registered as a 501c(6) organization. Public records show that as of December 31, 2014, it holds over $8 million in assets. The majority of revenue comes from its licensing exam, known as the Examination for Professional Practice in Psychology (EPPP). Licensing laws require a written exam, and ASPPB sells that exam. The ASPPB has recently come under fire by a group known as Modern Psychologist (Modernpsychologist.com, 2017). The group charges that the ASPPB has created a system that profits from those whom they license and does not protect the public. In addition, the group has revealed that state psychology board officials across multiple states have received compensation from ASPPB, creating a conflict of interest (Modernpsychologist.com, 2016). Make no mistake, ASPPB stands to gain financially by expanding licensing requirements for psychologists. I-O psychology has been identified as a market ripe for exploitation.
The theme of the ASPPB's October 2016 meeting was “Sailing in Rough Waters: Promoting Public Protection in an Anti-Regulatory Climate.” Presentations focused on concerns with regard to losing regulatory power of the practice of psychology. This is because cases are being filed and won against regulatory boards over restrictions of the use of the title of psychologist (e.g., Rosemond v. Markham, 2015). Such restrictions are recognized as a violation of the First Amendment. Legislators across multiple states are suggesting with greater frequency that regulatory boards are harming individuals rather than serving the public by limiting competition (e.g., Caulder, Reference Caulder2016; Sweigart, Reference Sweigart2016). ASPPB is concerned that it could lose its power to restrict the practice of psychology. This may provide further motivation for extending its reach to I-O psychologists.
We recognize that there are also those within our profession who champion the licensure of I-O psychologists. Economists have long recognized that guilds and licensing restrictions are often about protecting the interests of the members of the profession, in that they give incumbents the opportunity to restrict supply, protect the exclusivity of the profession, and maximize incomes (Friedman, Reference Friedman1962). We support disclosure of financial stakes in licensure among those in a position to make decisions with regard to the licensing status of I-O psychologists.
Reducing Barriers While Putting Up Walls
The LCIOP frames its charge as one of reducing barriers to licensure for I-O psychologists. The recommendations that it provides for reducing barriers will effectively put up a wall between I-O psychology and the rest of psychological science, as well as a wall between I-O science and practice.
The LCIOP Joint Task Force (2017) recommends the “identification of a limited nucleus of essential curriculum areas that any I-O and/or consulting program must address” (emphasis added). The focus on course requirements sets the stage for the development of an accreditation/certification system of I-O programs. As stated in Campbell, Levy, Murphy, Schmitt, and Weiss (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009), a “focus on educational recommendations will be seen as a substantial step toward an accreditation process that could easily lead to the death of I-O programs in comprehensive psychology departments.”
Although Jelly et al. (2017) refer to the arguments by Campbell et al. (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009), they do not describe them or address them. The main point of the letter by Campbell et al. (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009) was that the imposition of course requirements works against the survival of I-O psychology training programs within comprehensive psychology departments. The authors, all department chairs or former chairs, used experience with clinical accreditation as their model. They noted that the accreditation of clinical programs places great demands on the resources of psychology departments while limiting departmental strategic flexibility. Such demands frequently cause resentment and conflict within departments, but the historical standing of clinical psychology in the field leads departments to accommodate accreditation requirements.
Unfortunately, I-O psychology cannot count on such standing. Historically, I-O faculty members have had limited access to grant funding relative to other areas of psychological science, and few of the most prestigious departments in psychology include I-O. Moreover, I-O psychology is often not included in Introduction to Psychology textbooks or courses, as it is not yet viewed as an essential aspect of psychology (Allen, Reference Allen2015). In sum, there is little motivation for psychology departments to invest the extra resources into I-O programs that would be needed to comply with accreditation/certification systems. Essentially, continued efforts to develop a system of professional accreditation/certification will lead to the balkanization of science and practice and further disconnection of I-O psychology from the rest of psychology.
In addition, the acceptance of the LCIOP Joint Task Force (2017) recommendations is the acceptance of the point of view that training in I-O psychology should be guided by practice and by legal issues rather than by science. Noting the variety of topic coverage across I-O programs, the LCIOP Joint Task Force suggests, “It is difficult to justify the term ‘I-O psychology education’ if there is so much variety in the curriculum.” Our lack of a common curriculum is not a problem to be corrected or a barrier to be removed. It is our strength and the sign of a healthy science. As noted by Reynolds (Reference Reynolds2013), “Our membership includes university professors, corporate human resources executives, management consultants, and scientists in research labs, among other varied roles. The topics we study include nearly any aspect of how people behave at work and their reactions to work characteristics, and our practice areas are equally broad.” Program content that is driven by licensing requirements inhibits the cultivation of a diverse and cutting-edge science that meets the needs of our varied members. Moreover, there will be less room for trying new courses that address emerging topics.
Regulation of I-O psychology should be particularly alarming to individuals in organizations who hire I-O psychologists for their science-based skills and training. Red individuals in organizations who hire I-O psychologists for their science-based skills and training. Reduction of I-O psychology programs in comprehensive psychology departments would likely result in increasing numbers of organizational consultants who receive limited science-based training. A license does not ensure a highly qualified consultant, nor does a specific course curriculum.
Who Do We Want to Be?
SIOP members were outraged in 2014 when the Washington Post described I-O psychologists as “government therapists” (Wax-Thibodeaux, Reference Wax-Thibodeaux2014; see also SIOP Administrative Office, 2014). We suggest the current effort should provoke similar outrage, as any requirement to license I-O psychologists will contribute to further blurring of the distinction between clinical and I-O psychology among the public. Moreover, as noted before any move toward accreditation puts us in the same category as clinical.
There is another important distinction to be made—that between consulting psychology and I-O psychology. The current ASPPB efforts clearly conflate the two. The conflation of consulting psychology with I-O psychology works in favor of clinicians who wish to work with organizations. Organizational consulting is the way by which clinical psychologists expand their practice beyond individual health services (DeNisi, Reference DeNisi2000). Health service providers comprise the largest segment of membership within The Division of Consulting Psychology (Division 13) (APA, 2015). Language throughout Jelley et al. (2017) groups I-O psychology together with consulting psychology. The LCIOP Joint Task Force (2017) states, “Although there may be differences in education, roles, and current licensure status between I-O and consulting psychologists, we believe that many of the main licensure issues are similar and that these groups are relatively homogenous within the broader GAP category (e.g., APA, 2010).” Other indications of the attempt to group I-O psychology and consulting psychology is that the LCIOP Competency Project involves mapping the competencies for I-O psychology and consulting psychology into one. In addition, Division 13 recently released revised Education and Training Guidelines in which they specify training guidelines for organizational consulting psychology.
Where might this all lead us in terms of the future if licensure becomes mandatory? Organizational consulting will separate from the science and practice of I-O psychology. Those who wish to identify as consulting psychologists and seek licensure will be able to receive their education in professional programs eligible for accreditation and find a home in Division 13. I-O science will be taught in a select number of graduate programs that will train researchers and practitioners who desire robust, science-based training free from legislative interference. This may result in shrinkage of I-O psychology as currently construed. However, it may also provide the opportunity to expand our science and practice. Free of the need to monitor forces that wish to constrain what we teach and what we practice, we can focus energy on a science that strives to enhance our understanding of work, workers, and workplaces in an effort to improve the human condition. We can nurture a science that is distinct and distinctive, and one that is viewed as essential to the broader discipline of psychology and to society. We can move beyond application and shift our perspective toward a scientific understanding of working as an important aspect of human nature, recognizing that we better understand people when we understand them working.
Conclusion
The decision to obtain a license should be a personal one. SIOP has historically espoused that licensing should left to the discretion of the individual, and it is our position that SIOP should continue to do so. SIOP members who express favorability toward licensing often do so because they want to be able to use the title of I-O psychologist but believe they are prohibited in doing so based on title laws. The LCIOP Joint Task Force (2017) notes that “collaborative engagement can take advantage of the current environment in which occupational regulation is under scrutiny.” On that point we agree. It is in the best interest of I-O psychology to collaborate as a unified science and practice in an effort to remove overly restrictive title regulations rather than to bastardize the field in an effort to find ways to accommodate them.
We think that before reading our reactions to the focal article, readers should be aware of the history of the Licensure of Consulting and I-O Psychologists (LCIOP) Joint Task Force. The Association of State and Provincial Psychology Boards (ASPPB) initiated the LCIOP, and the objectives of the task force were developed without input from Society for Industrial and Organizational Psychology (SIOP). In June 2013, Don Crowder informed Mark Nagy (SIOP Chair of State Affairs) that the ASPPB approved the establishment of a joint task force related to licensure of consulting and industrial and organizational (I-O) psychologists. The membership composition of the task force was determined by ASPPB, and SIOP was allotted one member. By including a member of SIOP, ASPPB can describe the task force as a cooperative effort and SIOP ostensibly has the opportunity to help shape recommendations made with regard to the licensure of I-O psychologists. Don Crowder now serves as the president of ASPPB. In Crowder's October 2016 ASPPB meeting address, he encouraged jurisdictions to review their statutes, and, if permitted, require licensure for both health service providers (HSPs) and general applied psychologists (GAPs).
In the remainder of this commentary we discuss three issues that pertain to the Licensure of Consulting and I-O Psychologists (LCIOP) Joint Task Force (2017) recommendations: (1) Who stands to gain by implementing the recommendations? (2) What are the implications of the recommendations for the standing of I-O in psychology departments? (3)What are the implications for the nature of our field?
For the Public or for Profit?
Who stands to gain by imposing regulations on I-O psychology? The LCIOP Joint Task Force (2017) suggests that the stated sole objective of licensure is to protect the public. Protection of the public as the motivation for regulation of I-O psychology does not hold water. No evidence is presented to support the notion that the absence of a requirement that I-O psychologists be licensed jeopardizes the health, safety, or well-being of the public. Research in general finds little indication that a relationship between occupational licensing and service quality exists (McLaughlin, Ellig, & Shamoun, Reference McLaughlin, Ellig and Shamoun2014). Moreover, if one did assume that protection of the public was needed, requiring I-O psychologists to be licensed would not result in public protection given that individuals not trained in I-O provide the same services without restriction.
What there is evidence of, however, is that ASPPB stands to financially gain from expanding licensure requirements. Expanded licensure requirements create an additional market for selling exams, selling courses for continuing education, charging annual membership fees, and so forth. ASPPB is registered as a 501c(6) organization. Public records show that as of December 31, 2014, it holds over $8 million in assets. The majority of revenue comes from its licensing exam, known as the Examination for Professional Practice in Psychology (EPPP). Licensing laws require a written exam, and ASPPB sells that exam. The ASPPB has recently come under fire by a group known as Modern Psychologist (Modernpsychologist.com, 2017). The group charges that the ASPPB has created a system that profits from those whom they license and does not protect the public. In addition, the group has revealed that state psychology board officials across multiple states have received compensation from ASPPB, creating a conflict of interest (Modernpsychologist.com, 2016). Make no mistake, ASPPB stands to gain financially by expanding licensing requirements for psychologists. I-O psychology has been identified as a market ripe for exploitation.
The theme of the ASPPB's October 2016 meeting was “Sailing in Rough Waters: Promoting Public Protection in an Anti-Regulatory Climate.” Presentations focused on concerns with regard to losing regulatory power of the practice of psychology. This is because cases are being filed and won against regulatory boards over restrictions of the use of the title of psychologist (e.g., Rosemond v. Markham, 2015). Such restrictions are recognized as a violation of the First Amendment. Legislators across multiple states are suggesting with greater frequency that regulatory boards are harming individuals rather than serving the public by limiting competition (e.g., Caulder, Reference Caulder2016; Sweigart, Reference Sweigart2016). ASPPB is concerned that it could lose its power to restrict the practice of psychology. This may provide further motivation for extending its reach to I-O psychologists.
We recognize that there are also those within our profession who champion the licensure of I-O psychologists. Economists have long recognized that guilds and licensing restrictions are often about protecting the interests of the members of the profession, in that they give incumbents the opportunity to restrict supply, protect the exclusivity of the profession, and maximize incomes (Friedman, Reference Friedman1962). We support disclosure of financial stakes in licensure among those in a position to make decisions with regard to the licensing status of I-O psychologists.
Reducing Barriers While Putting Up Walls
The LCIOP frames its charge as one of reducing barriers to licensure for I-O psychologists. The recommendations that it provides for reducing barriers will effectively put up a wall between I-O psychology and the rest of psychological science, as well as a wall between I-O science and practice.
The LCIOP Joint Task Force (2017) recommends the “identification of a limited nucleus of essential curriculum areas that any I-O and/or consulting program must address” (emphasis added). The focus on course requirements sets the stage for the development of an accreditation/certification system of I-O programs. As stated in Campbell, Levy, Murphy, Schmitt, and Weiss (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009), a “focus on educational recommendations will be seen as a substantial step toward an accreditation process that could easily lead to the death of I-O programs in comprehensive psychology departments.”
Although Jelly et al. (2017) refer to the arguments by Campbell et al. (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009), they do not describe them or address them. The main point of the letter by Campbell et al. (Reference Campbell, Levy, Murphy, Schmitt and Weiss2009) was that the imposition of course requirements works against the survival of I-O psychology training programs within comprehensive psychology departments. The authors, all department chairs or former chairs, used experience with clinical accreditation as their model. They noted that the accreditation of clinical programs places great demands on the resources of psychology departments while limiting departmental strategic flexibility. Such demands frequently cause resentment and conflict within departments, but the historical standing of clinical psychology in the field leads departments to accommodate accreditation requirements.
Unfortunately, I-O psychology cannot count on such standing. Historically, I-O faculty members have had limited access to grant funding relative to other areas of psychological science, and few of the most prestigious departments in psychology include I-O. Moreover, I-O psychology is often not included in Introduction to Psychology textbooks or courses, as it is not yet viewed as an essential aspect of psychology (Allen, Reference Allen2015). In sum, there is little motivation for psychology departments to invest the extra resources into I-O programs that would be needed to comply with accreditation/certification systems. Essentially, continued efforts to develop a system of professional accreditation/certification will lead to the balkanization of science and practice and further disconnection of I-O psychology from the rest of psychology.
In addition, the acceptance of the LCIOP Joint Task Force (2017) recommendations is the acceptance of the point of view that training in I-O psychology should be guided by practice and by legal issues rather than by science. Noting the variety of topic coverage across I-O programs, the LCIOP Joint Task Force suggests, “It is difficult to justify the term ‘I-O psychology education’ if there is so much variety in the curriculum.” Our lack of a common curriculum is not a problem to be corrected or a barrier to be removed. It is our strength and the sign of a healthy science. As noted by Reynolds (Reference Reynolds2013), “Our membership includes university professors, corporate human resources executives, management consultants, and scientists in research labs, among other varied roles. The topics we study include nearly any aspect of how people behave at work and their reactions to work characteristics, and our practice areas are equally broad.” Program content that is driven by licensing requirements inhibits the cultivation of a diverse and cutting-edge science that meets the needs of our varied members. Moreover, there will be less room for trying new courses that address emerging topics.
Regulation of I-O psychology should be particularly alarming to individuals in organizations who hire I-O psychologists for their science-based skills and training. Red individuals in organizations who hire I-O psychologists for their science-based skills and training. Reduction of I-O psychology programs in comprehensive psychology departments would likely result in increasing numbers of organizational consultants who receive limited science-based training. A license does not ensure a highly qualified consultant, nor does a specific course curriculum.
Who Do We Want to Be?
SIOP members were outraged in 2014 when the Washington Post described I-O psychologists as “government therapists” (Wax-Thibodeaux, Reference Wax-Thibodeaux2014; see also SIOP Administrative Office, 2014). We suggest the current effort should provoke similar outrage, as any requirement to license I-O psychologists will contribute to further blurring of the distinction between clinical and I-O psychology among the public. Moreover, as noted before any move toward accreditation puts us in the same category as clinical.
There is another important distinction to be made—that between consulting psychology and I-O psychology. The current ASPPB efforts clearly conflate the two. The conflation of consulting psychology with I-O psychology works in favor of clinicians who wish to work with organizations. Organizational consulting is the way by which clinical psychologists expand their practice beyond individual health services (DeNisi, Reference DeNisi2000). Health service providers comprise the largest segment of membership within The Division of Consulting Psychology (Division 13) (APA, 2015). Language throughout Jelley et al. (2017) groups I-O psychology together with consulting psychology. The LCIOP Joint Task Force (2017) states, “Although there may be differences in education, roles, and current licensure status between I-O and consulting psychologists, we believe that many of the main licensure issues are similar and that these groups are relatively homogenous within the broader GAP category (e.g., APA, 2010).” Other indications of the attempt to group I-O psychology and consulting psychology is that the LCIOP Competency Project involves mapping the competencies for I-O psychology and consulting psychology into one. In addition, Division 13 recently released revised Education and Training Guidelines in which they specify training guidelines for organizational consulting psychology.
Where might this all lead us in terms of the future if licensure becomes mandatory? Organizational consulting will separate from the science and practice of I-O psychology. Those who wish to identify as consulting psychologists and seek licensure will be able to receive their education in professional programs eligible for accreditation and find a home in Division 13. I-O science will be taught in a select number of graduate programs that will train researchers and practitioners who desire robust, science-based training free from legislative interference. This may result in shrinkage of I-O psychology as currently construed. However, it may also provide the opportunity to expand our science and practice. Free of the need to monitor forces that wish to constrain what we teach and what we practice, we can focus energy on a science that strives to enhance our understanding of work, workers, and workplaces in an effort to improve the human condition. We can nurture a science that is distinct and distinctive, and one that is viewed as essential to the broader discipline of psychology and to society. We can move beyond application and shift our perspective toward a scientific understanding of working as an important aspect of human nature, recognizing that we better understand people when we understand them working.
Conclusion
The decision to obtain a license should be a personal one. SIOP has historically espoused that licensing should left to the discretion of the individual, and it is our position that SIOP should continue to do so. SIOP members who express favorability toward licensing often do so because they want to be able to use the title of I-O psychologist but believe they are prohibited in doing so based on title laws. The LCIOP Joint Task Force (2017) notes that “collaborative engagement can take advantage of the current environment in which occupational regulation is under scrutiny.” On that point we agree. It is in the best interest of I-O psychology to collaborate as a unified science and practice in an effort to remove overly restrictive title regulations rather than to bastardize the field in an effort to find ways to accommodate them.