The National Psychology Training Consortium (NPTC) has established due process procedures to ensure the rights of its interns to receive fair and impartial treatment. This procedure is reviewed during the psychology intern orientation and is provided to all supervisors during the annual supervisor orientation. This policy is reviewed by NPTC staff on an annual basis to ensure the processes remain efficient and effective across years.
First Steps
What is the first level of notice to the intern that the program has a concern?
Interns are provided notice of behaviors of concern informally via documented supervision meetings.
What would be the next step?
If behaviors of concern are not reasonably addressed informally, Site Training Directors and supervisors will provide formal notice of the intent to implement a Performance Improvement Plan (PIP) during a documented supervision session, in order to more efficiently manage the behaviors/issues of concern. This meeting will constitute the hearing process. During this meeting the intern will be provided information of the areas of concerns, and expectations of acceptable performance, and the actions to be taken by the site, supervisors, and intern. The intern will have the opportunity to ask any questions they may have about the documented concerns and the PIP. The intern will be provided with an electronic copy of the PIP. They will then have the ability to respond to the concerns by entering their response in writing within the PIP. They also have the ability to either agree to and sign the PIP or decline to sign and request initiation of the appeal process. The Performance Improvement section below details the steps involved in establishing, reviewing, and completing a PIP. More details regarding the performance improvement process is provided in the C.5.25 – Performance Improvement Policy.
Performance Improvement
How is a performance improvement plan determined?
Site supervisors should discuss the behaviors of concern and/or PIPs with the Site Training Director prior to taking any formal action. A PIP is considered when other informal attempts at resolving concerns have been unsuccessful or when a severe concern threatening successful completion of internship arises. 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. 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 two types of PIPs:
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, and/or repeated failure to follow directives and are considered more serious than Level 1 plans.
Is the graduate program informed?
As stated in the Communications Policy, the DCT of the intern’s sponsoring school will be notified of all Level 2 PIPs and/or concerns which cast doubt on an intern’s ability to successfully complete the internship program.
How often is the plan reviewed?
PIPs are informally reviewed regularly during supervision, but should have a formal progress update submitted to NPTC approximately one month from the initial submission.
What is the process for review?
Supervisors and Training Directors will discuss progress and areas of concern during weekly supervision sessions or more frequently as necessary. The PIP will be updated via the PIP Follow Up form in order to provide updates on progress and effectiveness of the plan including, either completion of all or parts of the plan, or continuation of the plan with a next review date if necessary.
How do you know if the performance improvement plan is working or not?
The PIP form contains an Expectation for Acceptable Performance section which includes measurable goals with specific timelines. Progress will be evaluated via achievement of these goals.
How does a student exit the performance improvement program?
The intern exits the Performance Improvement Plan by successfully completing all of the documented goals and objectives within the agreed upon timeline.
What would be the next step if a performance improvement plan is not working?
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. 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. Intern suspension of clinical duties and/or suspension or expulsion from the internship program are last-case scenarios for actions or behaviors that have been determined to be untrainable and/or all other training efforts have failed.
Clinical or Program Suspension
How is suspension from clinical work and/or the program determined?
Suspension from clinical work is determined through consultation with supervisors, the Site Training Director, the Regional Training Director, DCT, and NPTC Executive Leadership. Program suspensions are considered more severe, and may include concerns for the intern’s and/or client’s overall well-being. NPTC Executive Leadership also consults with APPIC leadership if the noted concerns are severe enough to warrant possible suspension from internship.
What are the time frames for suspension?
Time frames for clinical and/or program suspension will vary depending on the severity of the concerns and training expectations. They typically range between 2 – 4 weeks depending on the training and/or leave needs of the intern.
What are the time frames for re-evaluation?
The Performance Improvement Plans will include expected follow-up/evaluation of progress. Time frames may vary depending on the severity and complexity of the concerns and the interventions needed to address the documented concerns. The PIP Follow Up Form will be completed to document progress.
Is the graduate program informed?
If suspension from clinical duties is suspected, consultation with supervisors, the Site Training Director, the Regional Training Director, DCT, and NPTC Executive Leadership will occur. If suspension is deemed necessary, the DCT will be regularly updated regarding the intern status.
Is the Site HR Department involved in the process?
The site HR department would be involved in all internship suspensions as interns are considered employees of the agency and HR would need to be included in any discussions involving removal from client contact or temporary program suspension. HR would also be included in any cases involving violations to any agency compliance guidelines such as HIPAA.
What, if any, documentation is completed during suspension?
NPTC Administrative Staff will maintain written summaries of the events that lead to the suspension, the suspension plan, as well as the plan for promoting the successful completion of the suspension. The Level 2 PIP will also be formally documented as well as any necessary updates to the plan progression during the plan review stages.
How do you know when the suspension plan is over?
When the intern has successfully completed the goals and objectives of the Level 2 PIP and any concerns regarding intern and/or client safety have been addressed as appropriate.
What would be the next step if clinical or program suspension is not working?
If necessary progress is not made during a clinical and/or program suspension, supervisors, the Site Training Director, the Regional Training Director, DCT and NPTC Executive Leadership will consult to determine appropriate options including termination of internship. NPTC Executive Leadership would also consult with APPIC in this event.
Program Termination
How is termination from the program determined?
The Site Training Director, the intern supervisor(s) as appropriate, the intern’s DCT, and NPTC Executive Leadership would participate in any discussion of possible termination from either the site or the internship program as a whole. NPTC also consults with APPIC leadership following the problem consultation process when intern issues result in possible termination from internship.
What would be the reasons for termination?
Termination from a site or internship program as a whole would be considered if it is determined that the intern is unable or unwilling to meet the goals and objectives stated in the Level 2 PIP or have severe violations which are determined to be beyond remediation.
Is the graduate program informed?
The DCT of the graduate program would be involved in any discussions involving the potential termination of internship as well as discussion of possible options.
What is the process for termination?
Termination from the site or program is considered as a last-resort after all other methods to train and remediate concerns have failed. Termination from a site placement would involve discussion and coordination with the intern, Site Training Director, site supervisor(s) as needed, NPTC Executive Leadership, the school’s DCT, and consultation and coordination with leadership within APPIC following the problem consultation process.
Before termination from the internship program is initiated, NPTC Executive Leadership would consider if placement at another site within the consortium is a reasonable option. A site transfer is only considered an option when the concerns are considered potentially site-specific and may be better remediated in a different environment. If no transfer is found to be viable, then NPTC would continue the process of full internship termination under the consultation of APPIC leadership.
Does the student need to complete all patient paperwork?
Depending on the nature of the termination, interns may be asked to complete any unfinished notes and paperwork. In the event that the intern is unable to complete the paperwork, or it is not in the best interest of the agency and/or patient(s) to have the intern complete the paperwork, the intern would be asked to provide whatever information they can to their supervisor and completion of paperwork would be left to the sites discretion on how it is completed.
Does the student get credit for any training hours?
If requested, NPTC is willing to provide documentation of all completed hours and internship completion documentation up to the point of suspension. These documents can be provided directly to the intern or a third party at the intern’s written request for record-keeping purposes.
Is the Site HR Department involved in the process?
The Site HR department would be involved in all internship terminations as it would end the intern’s employment with the site as well.
Appeals Process
Eligibility
What if an intern disagrees with any of the decisions listed above?
Interns have the ability to appeal (i.e. disagree) any site or NPTC decisions listed above.
Formal Appeal Submission
What is the process for submitting an appeal?
When submitting a formal appeal, the Intern must follow the approved NPTC appeal document format as provided on the resources page on the NPTC website and ensure the following information is included in the request:
● Name and preferred contact information for the Intern.
● Names and roles of all individuals who are a part of the decision being appealed.
● Document or process for which the appeal pertains (if applicable).
● Summary with facts that support the Intern’s position.
● Summary of specific concerns with the Review Officer’s determination (only when requesting a Review Committee).
● Description of the relief sought.
● Copies of any documents that support the Intern’s position as appropriate.
Who should receive the appeal paperwork and what is the timeline for submission?
The appeal paperwork should be submitted to the Vice President of Operations via email within ten (10) days of the decision being appealed.
Appeal Review Process
Who reviews the appeal and makes recommendations?
Regional Site Training Director Representatives on the NPTC Board of Directors are designated as the Review Officers for any appeal requests within the region. The Vice President of Operations will forward the appeal request and any applicable paperwork to the Review Officer for review.
What if there are conflicts with the Review Officer?
In the event that the designated representative has a conflict of interest with the appeal in question, a Board representative from a different region will be selected by the President/CEO or their delegate as a replacement Review Officer.
What is involved in the review process?
The individual(s) making the decision being appealed (Respondent(s)) will have 10 days to review and provide their justification for their decision. This response is submitted to the Vice President of Operations and should follow the approved NPTC template (provided on the resources page on the NPTC website) and include the following information:
● Name and preferred contact information for the individual.
● Summary of the situation with facts that support their position.
● Copies of any documents that support their position as appropriate.
Once all of the case documents have been received, the Review Officer will meet separately with the Intern, the Respondent(s) and other individuals deemed necessary in determining the facts of the matter at hand. The Review Officer then writes a report and determination recommendation. Their report of determination should include at least the following information:
● Name and preferred contact information for the individual writing the report.
● Listing of documents reviewed and interviews conducted throughout the investigation.
● Summary of the situation from all points of view.
● Recommendations for how to address listed concerns from all parties involved.
● Final determination.
● Intern and/or Respondent(s)’s right to appeal the determination.
This report will be sent to the NPTC President/CEO or their delegate for review and final approval.
Is the Site HR Department involved in the process?
NPTC would include the participation of the site HR department primarily in situations where the decision being appealed involves possible suspension, termination and/or the intern behavior leading to the decision under appeal included any site compliance violations.
Appeal Determination
What is the timeframe in which a decision is made and how are all parties informed?
The Review Officer is given twenty (20) days following all interviews and final submission of any evidence to be considered to submit their report of determination recommendation to NPTC. The NPTC President/CEO or their delegate will review the recommendation and make a final determination no more than seven (7) days following receipt of the Review Officer’s report. This final determination will be emailed to the intern, Respondent(s), and the Review Officer. The President/CEO or their delegate will notify the intern’s site Training Director when an appeal process begins and provide regular updates throughout the process if the site Training Director is not already directly involved in the decision being appealed.