Lawrence S. Chalfin, in an article in the last issue of TAP, has praised the recent report of the BOPS Committee on External Credentialing as “comprehensive and sophisticated.”
Unfortunately it is riddled with incorrect information, and was extensively criticized when it was presented last December at the BOPS meeting. It is clearly designed to bolster the opposition to a joint external credentialing effort, and thus Chalfin repeats its errors.
Among the more egregious misstatements of fact in the BOPS Committee report are the following:
Claim: Division 39 representatives “cannot agree to the establishment of any numerical minimum standard frequency for the conduct of training analyses or control cases”.
Fact: This is false and has been refuted by a letter from Division 39 representatives to Marvin Margolis.
Claim: The Consortium wants to “establish a core set of requirements with each individual component organization having its own floor. According to this plan, training facilities could choose which floor they requested accreditation under, depending on the Consortium member organization with which they identify.”
Fact: The Consortium plan is for a single set of standards, but with a requirement that institutes that are members of a national organization, such as ours, must meet the standards of their own organization to be eligible to apply. There would be only one floor, not multiple ones, and such an arrangement was cleared with DOE.
Claim: The Joint Committee was incorrect in stating in its 1995 report to Council and Board that “the Consortium member organizations can agree to set essentially the same standards as are written in the APsaA Manual of Training Standards.”
Fact: The Joint Committee never made such a statement. This allegation is a clear distortion accomplished by deleting the rest of the quotation. The following is the complete quotation from that report:
“The other Consortium representatives agreed on essentially the same standards as are written in the APsaA Manual of Training Standards, except for the frequency of three times per week for training analyses and supervised analyses [instead of four] and the requirement of only two supervised cases instead of three (the standards of the IPA require only two). In fact, specifying a minimum number of training analysis and supervisory hours is not in our Manual, One other deviation is that our Manual says the duration of curriculum is ‘usually four years’, and these standards [proposed by the Consortium Committee] require only three years.”
One of the many false claims of the BOPS Committee, repeated by Chalfin in his TAP article, is that a joint external credentialing effort will take at least ten years to reach fruition. Although the report claims credibility by asserting the vouchsafed accuracy of summaries of interviews with CORPA and DOE officials, these summaries contain no such estimate. This extrapolation of the authors of the report contradicts previous estimates from DOE officials, which have set the time from establishment of such an external accrediting agency until its readiness for recognition at three to five years. An outside estimate of seven years from now seems achievable, unless the new agency replacing CORPA proposes unanticipated standards. (It should be noted here that CORPA ceased to exist as of February 1 and is being replaced by the Council on Higher Education Accreditation, CHEA. New standards for recognition will be made available in the next year.) During the years before recognition, the joint accrediting agency would be functioning and accrediting institutes. It would serve as a blockade against any application for recognition by a NAAP or NAAP-like organization with totally inadequate standards. It would also be a presence that encouraged motivated institutes to develop and maintain standards, while those that did not meet the standards and the accompanying competition from accredited institutes would be more likely to fall by the wayside. This is important, since there are now almost 60 self-designated “psychoanalytic institutes” in New York State alone. Recall the effects of the Flexner Commission on substandard medical schools early in this century.
The BOPS Committee and Chalfin now claim that only minor modifications of BOPS would be required to qualify it for recognition as an accrediting organization. This represents some progress from a year ago, when it was maintained that no changes would be required. However, they still fail to inform the membership of the more extensive changes that would be required by DOE to obtain recognition for student loans and research funds.
These changes would include relinquishing at least some of the current activities of BOPS to conform to the requirements that accreditation be its primary purpose, and making public all proceedings and reports to the Council.
It is also alleged by BOPS and Chalfin that BOPS could be recognized on its own, as one of several accrediting organizations in psychoanalysis; the other members in the Consortium could apply separately as another accrediting organization and would not oppose us. Karen Kershenstein, director of accreditation of DOE, has recently authorized a statement in response to this claim. She has stated, “The Secretary of the Department of Education would question how can there be two reliable authorities when there are different standards?” This statement by Kershenstein casts serious doubt on, if not discredits, any assertions of the acceptability to DOE of multiple accrediting organizations with differing standards.
Moreover, while CORPA might have been willing to consider two or more accrediting boards, it may well be that the new nongovernmental agency that will replace it will be wary of promulgating a policy contradicting DOE's. The plan for a jointly sponsored accrediting agency would present only one set of standards.
It has also been claimed that application to DOE is unimportant, because the process of obtaining loans for our students is too complex and impractical. (These loans could cover the costs of tuition, supervision, and personal analysis up to $25,000.) No documentation is provided for these unsupported allegations. Money is now in short supply, but such budgetary restrictions run in cycles. When Congress restores funding in the future for loans and grants, we should be positioned so our students can apply for and use such loan availability, rather than belatedly scrambling for such recognition.
Much is made of the fact that the three other organizations in the Consortium do not accredit institutes and that some of the institutes that are loosely affiliated with them may have lower standards and quality of training than
those accredited by The American. Of course, this is precisely why we and those in the Consortium who support a joint credentialing effort believe that a joint enterprise is so desirable. Placing a national floor on training standards and encouraging the development of institutes to meet those standards would serve to elevate the status of psychoanalysis in this country.
There is no formal relationship in any of the other three Consortium members with any institutes. They play no role in the governance or decision-making of these organizations, which are membership organizations. The decision to engage in a joint accreditation agency would be made by the boards of directors of the organizations, with institutes having no voice in that decision, except indirectly through affiliations of individual members. Nor would any institutes have any voice in the setting of minimum standards of training. Therefore, the current standards of any institutes are irrelevant to consideration of forming an accrediting board, whose standards would be determined by the governing board.
Neither would any institutes have a voice in the envisioned operation of such an external accreditation agency. Once the minimum standards are agreed upon—by the boards of the four Consortium organizations, they could only be modified (in the proposed draft plan) by a unanimous vote of the governing board of that agency, which would be composed of representatives from each Consortium organization, not from any institutes, per se. The IPS, therefore, can find representation on the accrediting board through its faculty members' affiliation with any of the four organizations. The governance of an external accrediting agency would be independent of institutes and of Consortium organizations. Any institute, therefore, including those of the IPS, could apply for accreditation.
The gatekeeping accrediting function of such an agency would in no way interfere with the enabling and educational activities of BOPS. There is no reason why site visits could not be integrated with BOPS site visits for our institutes, and thus not compromise in any way those valuable educational activities of BOPS that promote institute development.
An external accrediting body will not only secure national standards for training psychoanalysts but also make possible a national body to certify individuals (independent of any accrediting body) by establishing training criteria to determine who would be eligible for certification. Such a body could be set up by any group of individuals that does not engage in training evaluation and would not be dependent on Consortium participation.
As long as it was fairly administered, the Consortium organizations would have no cause to object, as it would be no threat to them.
However, the other members of the Consortium have repeatedly and explicitly stated that they would regard any attempt by The American to obtain recognition on its own as a betrayal and a threat, even if CORPA allowed multiple accrediting bodies. One of their stated concerns is that The American would have a head start because of its accrediting experience, and would then for some time be able to drain off candidates who would otherwise apply to their institutes.
We would not only pay a heavy price, including the likely disruption of the Consortium, but the other members of the Consortium would certainly form their own credentialing organization, if permitted by the regulations. (The BOPS report even speaks of helping them do it.) Should two accrediting organizations be in place with differing standards, it is almost certain that NAAP or a successor will successfully seek recognition on the basis that, since there is no established single national standard, their standards are entitled to the same recognition.
The public perception of psychoanalysis will then undoubtedly be formed by the lowest common denominator, with psychoanalysis defined as a once-weekly treatment, practiced by individuals with hardly a college degree and little, if any, clinical training. The opposition can dismiss these predictions as unlikely. But if they are wrong, the damage will be irreparable.
Chalfin and the BOPS Committee make dire and vague predictions that somehow a joint endeavor will end or damage our own internal accreditation procedures. Yet, not one credible scenario has been presented that would eventuate in any dilution of or interference with our accreditation processes and standards for our institutes. On the contrary, a joint accreditation body would rely upon BOPS and its cadre of experienced educators and site visitors to lead the way in teaching the other less experienced representatives, raising standards for all.
BOPS, far from losing influence, would become the bellwether in developing supporting data and educating the rest of the psychoanalytic community toward their acceptance. In these respects, the Board on Professional Standards could provide vital leadership and expand its influence beyond The American to the entire national psychoanalytic community.