In some cases, appropriate intern training may include a need to remediate or correct either training deficiencies, problematic intern behaviors, and/or problematic performance or conduct. NPTC encourages all sites to document interactions and keep in constant communication with members of the NPTC Administrative Office when intern issues arise so that the Consortium can provide additional resources and support as necessary to both the site and intern in question. This policy does not replace the NPTC Evaluation Process above, or the Intern Due Process Procedure, but rather is in addition to the listed processes and defines the policy when a site implements an Action Plan or Performance Improvement Plan (PIP) as a means to formalize a plan of action and/or correct problem behaviors and/or problematic performance or conduct. It is encouraged that the implementation of any Action Plans or PIPs happen by the mid-point of the internship year so that there are adequate opportunities for training, growth, and intern evaluation to demonstrate compliance with the plan. It is the goal of NPTC and all Member sites to support each intern through their year to reach competency in all required areas by graduation. If intern behaviors continue to be problematic or escalate despite site attempts to redirect and/or remediate concerns, the Regional Training Director may be asked to meet with the intern, with the Site Training Director, and/or supervisor(s); the following sanctions may be imposed as appropriate through the use of a Performance Improvement Plan:
1. Additional assignments and/or training activities.
2. Alterations in required psychology intern activities.
3. Repetition of all or part of the clinical training activity.
4. Implementation of a performance improvement plan to address the demonstrated deficits.
5. Remanding the psychology intern for more intensive supervision.
6. Service to the site and/or to the community.
7. Denial of privilege to represent the organization in any activity.
8. Suspension of clinical privileges and hours.
9. Suspension or expulsion from the Internship program.
Definitions
Action Plans or PIPs can be initiated by either the site or NPTC, but in either case, the plan is developed in coordination with members of the NPTC Administrative Office and the Training Site as appropriate. The following are definitions of the three plan options:
Action Plan
Action Plans are for situations where the concern is related to things not necessarily within the interns’ control (being behind in hours) and/or not directly related to intern performance. The Action Plan could also have a primary focus on the site’s responsibilities as appropriate. The intention of this plan is to determine the effectiveness of the steps put in place to remedy the concerns on a short-term basis. The formal oversight of the plan can be removed once the plan is established as effective. These areas include, but are not limited to, hour deficits needed to be addressed by the site.
LEVEL 1: Performance Improvement Plan
Level 1 PIPs indicate potential barriers to internship progress worthy of additional oversight and accountability. Such behaviors or performance would be areas of needed improvement but identified as substantially attainable and not related to significant deficits or concerns related to progress toward graduation. These areas include, but are not limited to, being behind in hours related to intern behavior, and paperwork/task timeliness.
LEVEL 2: Performance Improvement Plan
Level 2 PIPs indicate problematic performance and/or problematic conduct that pose more significant barriers to graduation progress due to their severity and/or repetitive nature. These areas include, but are not limited to, privacy violation, inappropriate behaviors, repeated failure to follow directives, and are considered more serious than Level 1 plans.
Depending on the nature, severity, or frequency of the incident(s) or circumstances, an intern may progress from a Level 1 plan to a Level 2 plan if it is not successfully completed. Action Plans could also progress into a Level 1 or Level 2 PIP if the concerns transition into intern behavior or performance concerns. Interns may also be placed directly on a Level 2 PIP at the sole discretion of the NPTC Administrative Office and Training Site depending on the severity of the concern.
Action Plans and PIPs need to completed using the NPTC online form and, at minimum, need to include the following:
● level of concern
● identification of the issues
● detailed attempts to address the issues
● listed identifiable and measurable expectations of the intern (i.e. without the use undefined or vague terminology)
● a deadline to meet expectations
The process for all plans should also include regular review of the Action Plan or PIP during the set time frame to determine whether or not the intern is progressing appropriately toward successful completion of the plan. If new issues arise during the course of the Action Plan or PIP process, a new process should be initiated rather than changing/revising the pre-existing Action Plan or PIP. The process is completed under the sole discretion of NPTC and the Training Site and they reserve the right to deviate from the stated policy as needed.
Timeline
While there may be some variations to this timeline as needed from time to time, the following provides the basic timeline expectations for Action Plans and PIPs.
Action Plan
Typically an Action Plan is completed by request of an NPTC Staff member during an hour audit. If the Action Plan is site/supervisor initiated, then they should reach out to Operations Support for the link and resource materials.
Supervisor is provided with a link to the form. Action Plan should be created/submitted within two weeks of the request.
Action Plan should include date for follow-up meeting (typically one month out from initial submission).
Operations Support will provide links to the follow-up survey ahead of the scheduled follow-up meeting.
Process will continue until it is determined that the plan put into place is effective (hours do not have to be completely caught up at that time).
Level 1 or 2 PIPs
Typically Level 1 or Level 2 PIP’s are site initiated. Site supervisors should discuss PIP’s with the Site Training Director prior to implementing any PIPs. If a Level 2 PIP is necessary, the Site Training Director must contact the Regional Training Director to discuss concerns prior to starting this process.
● Supervisor or Site Training Director contacts Operations Support informing NPTC of desire to start a PIP process.
● Operations Support sends link and PIP resources.
● Supervisor/Site Training Director complete draft of PIP by using the save and continue later feature in FormPlus and contacts Operations Support to send draft to Regional Training Director and President/CEO for review.
● Please note: Date for review meeting should be no sooner than 7 days after the submission of the draft PIP for review.
● Interns are allowed to be part of the drafting process so long as a) NPTC staff AND the Regional Training Director are in support of implementation of the PIP and b) the intern is aware that the draft is not finalized and there may be changes made based on feedback from NPTC.
● No one should sign the document until it has been formally approved.
● PIPs should also include date for follow-up meeting after implementation (typically one month out from initial submission).
● Regional Training Director and President/CEO will review and provide feedback on the draft within 72 hours of submission.
● If edits are needed, the intern review meeting may need to be postponed until the plan is finalized and approved.
● Once approved, Operations Support will notify the supervisor/Site Training Director that the form is approved for signatures and final submission.
● A meeting will be scheduled between the intern and the supervisor/Site Training Director to review the document and this will be considered the intern’s hearing of concern. The intern will be given the opportunity to respond to concerns as well as request an appeal if they disagree with the plan.
● If an intern elects to implement their right to appeal the process, they will provide their comments on the form and select a request for appeal.
● The implementation of the PIP in question will be put on hold until the appeal process has completed and the PIP is either approved to continue or will be closed out as unnecessary if the appeal is upheld.
● Operations Support will provide links to the follow-up survey ahead of the scheduled follow-up meeting.
● The purpose of the follow-up survey is to provide updates on progress and effectiveness of the plan including either completion of the plan or continuation of the plan with a next review date if necessary.
● If new issues arise, they should not be added to the follow-up form, but rather a start to a new PIP process if deemed necessary.
● Process will continue until it is determined that the intern has met the requirements of the plan.
In the event the intern issues become increasingly problematic or it is determined that the site needs additional support completing the PIP, NPTC may assign an additional licensed psychologist from outside the site organization to assist in the supervision and performance improvement process. If it is determined that the site evaluation process and/or procedures are not in alignment with the NPTC mission, aims, goals, or objectives, or that through additional supervision and training the NPTC special reviewer does not find the same training concerns and/or deficits indicated by the site, NPTC reserves the right to alter any scores on the intern’s quarterly evaluation as applicable, and/or change the PIP. This action would only take place with direct communication with the Regional Training Director, Site Training Director, and any other appropriate people, and would include documentation of how the intern is meeting core competencies as required by the NPTC aims, goals, and objectives.