Soon you will be voting on a proposed comprehensive bylaw change for our Association known as the Plan to Renew the American. In this column, I will outline the parts of the proposed bylaws that deal with functions of the Board on Professional Standards (BOPS) in order to help inform you before you vote.
The Council of American Psychoanalytic Institutes (Institute Council)
This body will be heir to institute representation within the Association. The Institute Council will have representatives from each institute, as does the present BOPS, enabling it to perform the present BOPS functions of nurturing institutes and helping to maintain the quality of education and clinical training in psychoanalysis. Two current BOPS functions will be specifically placed outside the Institute Council, the accreditation of institutes and certification of individuals. These functions require relative autonomy from the membership organization to ensure the integrity of those processes. Therefore, they will be carried out by the American Psychoanalytic Board for Accreditation and Certification (the APsaA-BAC), a subsidiary corporation for accreditation and certification (described below). The Council of American Psychoanalytic Institutes will be responsible for revising principles and standards for psychoanalytic education, subject to the approval of the Association's Board of Directors (BOD). Such standards will be the standards of the Association and must conform to the accreditation standards of the APsaA-BAC.
The Institute Council will also recommend new training facilities (NTF), changing the status of an NTF to a provisional institute (PI), and changing the status of a PI to an approved institute. Full approval and periodic re-approval of institutes by the Institute Council and the Association will require accreditation and re-accreditation by the APsaA-BAC. The Institute Council and its Committee on Institutes (COI) will help institutes prepare for the accreditation site visits and recommend periodic approval and re-approval of institutes to the Association's BOD. If the APsaA-BAC accreditation standards allow waivers of standards in specific circumstances, the Institute Council will also recommend waivers of eligibility criteria for training and waivers of standards for TA/SA appointments, and recommend the appointments of training and/or supervising psychoanalysts. Because the Institute Council will be a committee of the corporation (APsaA), all of its actions will be subject to the approval of the Association's BOD.
Soon you will be voting on a proposed comprehensive bylaw change for our Association known as the Plan to Renew the American. In this column, I will outline the parts of the proposed bylaws that deal with functions of the Board on Professional Standards (BOPS) in order to help inform you before you vote.
The American Psychoanalytic Association Board for Accreditation and Certification (APsaA-BAC)
This is a new structure for the Association. This structure ensures the functional autonomy of credentialing (accrediting and certifying) functions. The APsaA-BAC will be a limited liability company (LLC) owned by the Association.
On the advice of our attorney, an expert in New York not-for-profit corporate law, the APsaA-BAC (the LLC) will be incorporated in Delaware. The laws of New York permit a not-for-profit corporation in New York (such as the Association) to own a subsidiary incorporated in New York as a for-profit enterprise, like a gift shop in a museum. It is a peculiarity of New York law that it would be difficult, perhaps impossible, for a New York not-for-profit corporation to have a not-for-profit subsidiary corporation in New York. However, a New York not-for-profit corporation (like the Association) may own a not-for-profit subsidiary LLC incorporated in Delaware. There are many New York not-for-profit corporations with not-for-profit subsidiaries incorporated in Delaware. The IRS would regard the LLC as an activity of the Association, eliminating the need for a separate tax filing. This will save the Association money.
The APsaA-BAC will be a broadly representative stakeholder board for accreditation and certification made up of equal numbers of members from institutes and from the general membership. Six members will be selected from nominees of the Institute Council, four members will be selected from nominees of the Society Council, one member will be selected from nominees of the Council for Research and Scholarship, one member will be selected from nominees of the Affiliate Council, and there will be one public member. The conceptual model for the structure of the APsaA-BAC is based on the structure of the Liaison Committee for Medical Education (LCME) which accredits medical schools.
Eric J. Nuetzel, M.D., is chair of the Board on Professional Standards.
The LCME is made up of an equal number of representatives from the Association of American Medical Colleges and the American Medical Association (with public, student, and Canadian members as well).
The APsaA-BAC will have four major responsibilities: the development of accreditation standards, the development of certification standards, administering the accreditation (and re-accreditation) of institutes, and administering a certification examination. Institutes must meet the accreditation standards as a prerequisite to being fully approved and re-approved. Accreditation is a necessary but not sufficient condition (paying affiliation fees could be another) for approval and re-approval of institutes by the Association.
The APsaA-BAC will function like an external credentialing body, but will also be under the Association's umbrella. Thus, it will have its own accreditation standards. The Association's educational standards must conform to the accreditation standards of the APsaA-BAC. As with any organization with an educational mission, the Association (and any component institute) may have educational standards that exceed the accreditation standards. However, the institutes of the Association must meet the accreditation standards to be fully approved and re-approved by the Association.
Accreditation will take place through site visits, with teams appointed by the APsaA-BAC. The APsaA-BAC will be asked to accredit an institute before the Institute Council recommends approval or re-approval of the institute to the Association's BOD. Accreditation site visits involve a review of the institute's standards, policies, and procedures, and documentation of adherence to those standards, policies, and procedures. These could be conducted in conjunction with the site visits of the Committee on Institutes, or separately.
For graduate members seeking certification, the APsaA-BAC will conduct an examination and simply certify, or not. Certified members will be eligible for the designation Clinical Fellow of the American Psychoanalytic Association (FAPsaA). Many have wondered whether certification will be required for training and/or supervising analyst (TA/SA) status. Certification will not be a bylaw requirement for TA/SA status. Educational standards do not belong in bylaws. The Association may continue to grapple with its uses of certification, but minimally, removing certification from the bylaws will enable a more flexible system either through granting waivers and/or by creating flexible pathways to TA/SA appointment. The membership has spoken on certification and its tie to TA/SA status in the last bylaw vote, and the educational components need to listen.
Valuable and essential activities of the BOPS will continue within the Association through the Plan to Renew the American. Supporting and nurturing institutes and psychoanalytic education will be the responsibility of the Institute Council. The accreditation of institutes and the certification of graduate members will be the responsibility of the APsaA-BAC. These structures ensure our continuing commitment to high quality psychoanalytic education by creating a strong, flexible, and adaptable national system. Consider your vote carefully. The future of the Association is in your hands.