Final report to SSA: No board certification requirement for psychological consultants
Government Relations and Communications Staff
March 29, 2007 — A final report from the Institute of Medicine (IOM) about making improvements in the U.S. Social Security Administration’s (SSA) disability determination process does not include a recommendation from the interim report requiring board certification for psychologists working in the SSA system. APA had advocated that IOM should not make the board certification requirement mandatory for psychologists.
Psychological consultants for SSA function as employees in state disability determination offices or as independent contractors in making determinations about disability applicants’ mental impairments. Psychologists represent the largest specialty among all SSA consultants and are found in every state office, giving SSA beneficiaries and applicants access to psychological consultants throughout the United States.
In 2004, SSA asked IOM to develop recommendations related to strengthening the disability determination process. The federal agency asked IOM to focus on two areas: improvements in the criteria for determining severity of impairments and the use of “medical expertise” (including psychological expertise) in the disability determination process.
The IOM interim report, released in December 2005, included a recommendation that SSA should make board certification mandatory for physicians as well as psychologists working in its system. Psychologists who wished to continue in their positions as SSA consultants would have been required to attain board certification within five years.
APA took issue with this recommendation in a letter to the IOM director. APA Executive Director for Professional Practice Russ Newman, PhD, JD, argued that existing SSA standards for a psychological consultant ensure that psychologists selected for this position are fully qualified. Federal regulation requires that SSA psychological consultants hold a doctoral degree in clinical psychology and be licensed or certified by a state at the independent practice level of psychology.
“While board certification may be a common credential in the field of medicine, it is not so in psychology,” Newman explained in his letter. “For psychologists, the doctoral degree and state licensure are the appropriate benchmarks for establishing their qualifications.”
APA cautioned that if SSA required board certification for psychologists it would quickly fail to meet the agency’s needs because there simply are not enough psychologists who hold this designation. Dr. Newman’s letter warned that individuals with mental health impairments would face long delays if experienced psychologists were lost from the disability determination process simply because they lacked board certification. This is at odds, he said, with SSA’s goal of making the current system more efficient and reducing the time it takes for a disability determination.
The IOM released its final report, “Improving the Social Security Disability Decision Process,” in February. The preface to the report explained, “The committee has reviewed and affirmed 13 recommendations in the interim report, except for a revision in...recommendations that [would] require board certification of physicians and psychologists who serve as medical consultants for the state disability determination service agencies . . . . Implementing a board certification requirement for psychologists in the near term could seriously limit SSA’s ability to obtain enough qualified experts in psychology. The committee therefore has modified its position.”
The preface also noted that while SSA should continue the current requirements for psychologists participating as medical consultants, the agency should establish a long-term goal requiring that psychologists be board certified. However, this recommendation was not reflected in the body of the report, including the final recommendations. Further, there was no indication as to when the IOM considers it appropriate for SSA to revisit the issue of board certification for psychologists.