Interns are formally invited to provide feedback to the program through a number of outlets throughout the year. More information about each formal feedback process is available in the following section Intern Forms, specifically the Quarterly Site Feedback, Supervisor Feedback, Didactic Satisfaction surveys, and site visits. Using these forms, interns are able to provide regular feedback regarding the orientation, training, support, and communication provided by their placement sites, their supervisors, and NPTC. The didactic satisfaction survey also allows interns to provide immediate feedback to NPTC and their didactic presenters following each didactic training throughout the year.
In addition to these formal outlets, interns are informed of their rights and abilities to reach out to their Regional Training Director and any NPTC staff member at any point throughout the year to file any complaints or concerns. There is no deadline or formal requirement for how and when informal complaints are submitted. Interns may send email or other written forms of complaint or request a meeting to discuss their concerns. Once notified of the intern concerns, depending on the severity, the Regional Training Director may provide the intern with support and resources to appropriately and professionally bring up their concerns to their supervisor and/or site Training Director as appropriate.
While every effort should be made to handle conflicts directly and informally, NPTC recognizes there may be circumstances in which a Grievant may wish to discuss the matter with an administrator or file a formal complaint. In the event of a severe concern, the Regional Training Director and/or other executive staff of NPTC may initiate a meeting with the site Training Director to discuss the concerns and may initiate or request that the intern initiate a formal grievance review process into the stated concerns. NPTC would include the participation of the site HR department primarily in situations where the concerns are related to employment and/or discriminatory concerns at the site level. 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. The process for initiating a formal complaint and/or grievance is listed out below.
Definitions #
1. Days. In any instance where action is required to be taken by this policy, reference to the word “days” shall mean Monday through Friday, except for those days that the NPTC Administrative Office is closed as defined by the internship calendar.
2. Grievant. “Grievant” is the intern making the grievance or complaint claim.
3. Respondent. “Respondent” is the person or persons which are the subject of the grievance.
4. Review Officer. The “Review Officer” is a person appointed by the President/CEO for purposes of reviewing the appeal. This individual will be chosen based on their lack of involvement in the case at hand as well as a lack of conflict of interest to the situation/intern/site. Review Officers may be NPTC staff members, Board Members, or other Training Directors.
5. Notices. Any notices, requests or other communications required or permitted hereunder shall be in writing and shall be delivered by email to each party as follows:
a. To the Grievant: to the listed preferred email address currently on record with NPTC. Failure by any of the individuals to check that email or to update NPTC with a change of email or any other technical difficulties shall not be construed to invalidate such notice.
b. To the Respondent(s) or any other employee or member of NPTC: to the last email address currently on record with NPTC. Failure by the Respondent(s) or any other employee or member of NPTC to check their email or update a change of email on record with NPTC or any other technical difficulties shall not be construed to invalidate such notice.
Any such notice, request or other communication shall be considered given, delivered or received, as the case may be, on either the date indicated on the time stamp of the email or the day following if the email was time stamped after 5:00 pm local time of the sender. Rejection or other refusal to accept or inability to deliver because of a changed address of which no notice was given shall be deemed to be receipt of the notice, request, or other communication. By giving at least five (5) days prior written notice thereof, any party may, from time to time, at any time, change its email address hereunder.
6. Record of the Case. The phrase “Record of the Case” shall mean all documents considered by persons who have considered any complaint or grievance at any stage of the grievance process review, including, but not limited to: each and every written request for review submitted by the Grievant; each and every written decision on the appeal by any of these individuals; any evidentiary documentation submitted by any of these individuals or any other evaluator of the site’s compliance; and any evidence or documentation considered by the Review Officer or any member of a Review Committee.
Appeals Policy #
Appeal Documentation #
When submitting a formal complaint or grievance, the Grievant 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 Grievant. Names and roles of all individuals who are a part of the grievance.
- Document or process for which the complaint pertains (if applicable).
- Summary of the complaint with facts that support the Grievant’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 Grievant’s position as appropriate.
All Respondent(s) responses to an appeal should follow the following approved NPTC format (template provided on the resources page on the NPTC website):
- 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.
- All reports 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 (only for Review Officer report)
Review Process #
This procedure shall apply in all matters, including those related to academic integrity and professional conduct on both the part of the intern and/or supervisor. Any formal intern complaints and/or grievances that are unable to be addressed using informal processes as listed above are subject to the following criteria and processes.
Appeal to Review Officer:
In the event the informal conflict resolution process as listed previously in the Training Manual, does not address concerns or grievances by the Grievant, they may submit a formal appeal to a Review Officer. The formal appeal shall follow the format as listed in the Appeal Documentation section above and be delivered to the Vice President of Operations via email within ten (10) days of the occurrence of the matter giving rise to the grievance. The President/CEO or designee shall then appoint a Review Officer to examine all documentation submitted, including, but not limited to, the Record of the Case. The Vice President of Operations will forward the appeal documentation to the Review Officer and the Respondent(s) for review. The Respondent(s) will have the opportunity to respond to any accusations in writing following the guidelines listed in the Appeal Documentation section and their responses will be sent to the Review Officer as part of the Record of the Case. These individuals shall submit their responses to the appeal within ten (10) days from their receipt of the appeal documentation from the Vice President of Operations.
Once all of the case documents have been received, the Review Officer will meet separately with the Grievant, the Respondent(s) and other individuals deemed necessary in determining the facts of the matter at hand. The final determination of the Review Officer shall follow the guidelines listed in the Appeal Documentation section and sent via email to the Grievant, the Respondent(s), and NPTC within twenty (20) days following all interviews and final submission of any evidence to be considered.
Request for a Review Committee Proceeding:
If the Grievant feels there was an unfair ruling (such as conflict of interest or bias) with the decision of the Review Officer, the Grievant may submit a written appeal to the Vice President of Operations within ten (10) days from the date of receipt of notice of the Review Officer’s decision. Such notice should follow the guidelines listed in the Appeal Documentation section above and include a summary of their concern with the Review Officer’s determination and/or process. The Vice President of Operations will forward the Record of the Case to the Review Committee and any new Respondent(s) if necessary. The Review Officer will also be notified of the request for appeal and given the opportunity to respond. Any additional responses or documentation will need to be provided to the Vice President of Operations no later than ten (10) days after the notice of appeal. The Review Committee Chair or her/his designee will select the date, time, and place for the meeting and will make a reasonable attempt to accommodate the schedules for the Grievant, Respondent(s), and Review Officer. The Grievant, Respondent(s), Review Officer, and NPTC will be notified via email a minimum of ten (10) days prior to the meeting and will be provided with all necessary information.
1. Review Committee Composition
A Review Committee proceeding is conducted by three persons appointed by the President/CEO at the beginning of the training year to serve one year. In the event of the inability of any person so appointed to serve, the President/CEO may appoint either a temporary or a permanent replacement. Composition of the Review Committee shall consist of one board member, a site Training Director, and one Psychology Intern. In addition to the appointed members, the President/CEO or his/her designee shall serve as the Chair of the Review Committee and as a non-voting member. The role of the Chair is to exercise impartial control over the Review Committee Proceeding in order to achieve an equitable, orderly, timely, and efficient process. The Chair is authorized to make decisions and rulings as necessary and proper to achieve that end, including such decisions and rulings as pertains to scheduling.
2. Attendance During Review Committee Meeting
As Review Committee Proceedings are closed and are confidential investigations, no outside individuals are allowed. However, at the Grievant’s request, the Chair will permit a parent or legal guardian, spouse, or disabilities support person as appropriate to observe the proceedings in a support capacity only. If a documented disability prevents a party from speaking, a non-attorney advisor may speak on behalf of a party. This does not preclude a party from being directed to testify and to reply to questions directed to him or her.
If the Grievant who initiated a Review Committee proceeding has been properly notified of the proceeding, but fails to appear, the proceeding may take place in his or her absence and the decision of the Review Committee will be binding. Only under exceptional circumstances (to be determined by the Chair of the Review Committee) will a new proceeding be granted on the basis of absence.
All of the individuals listed below, with the exception of witnesses, have the right to be present during all stages of the Review Committee Proceeding except during the deliberations of the Review Committee. Witnesses will only participate in the meeting during their individual testimony and through any Review Committee questions.
Those in attendance may include:
- Review Committee Chair Review Committee
- Psychology Intern
- One designated support person (as needed)
- Respondent(s)
- Review Officer
- Any other individual named in the appeal as appropriate
- Witnesses for the Psychology Intern and/or Respondent(s) as approved by the Review Committee
A Review Committee Proceeding will not, as a general practice, be delayed due to the unavailability of a witness or support person, except for any support persons required due to documented disabilities.
It is the responsibility of the persons desiring the testimony of a witness before a Review Committee Proceeding to ensure that the witness appears or that a written statement is made available. Any written statement must be dated, signed by the person making it, shall contain the name, address and telephone number of the person making the statement, and contain a statement of the reasons that the witness cannot, or reasonably should not, be expected to appear. Written statements shall be witnessed by a notary, delivered to the Vice President of Operations, and received by the Chair and any other interested party at least five (5) days prior to the time the proceeding will commence. Written statements become part of the “Record of the Case” distributed to interested parties prior to the proceeding.
The Chair may remove from the Review Committee hearing any person who disrupts or impedes the investigation or who fails to adhere to the rulings of the Chair. The Chair may direct that persons, other than a party, who are to be called upon to provide information be excluded from the Review Committee Proceeding except for the purpose of providing information.
3. Review Committee Procedure
It is the responsibility of the Review Committee to review the Record of the Case in advance of the Review Committee hearing. That being the case, in no testimony or summary should any individual read documents to the Committee that are already a part of the case. The Review Committee may request additional material or require additional witnesses to appear before the committee to present evidence in cases in which the committee deems it appropriate, both prior to and during the proceeding. The members of the Review Committee may also conduct private deliberations at such times and places as they deem proper.
The procedure for all Review Committee Proceedings shall be as follows:
a. The Chair will rule on all requests and points of order and shall preside at the hearing. Chair will call the hearing to order by:
i. Calling the roll of the committee in attendance
ii. Ascertaining the presence or absence of the individuals listed above
iii. Reading the notice of hearing and the reason for the appeal
b. First, the Grievant shall present to the Review Committee a summary of the incident and an analysis upon which the grievance is based.
c. If the Grievant has requested witness testimonies, each witness will then provide their feedback separately in support of the Grievant’s position.
d. Second, the Respondent(s) will present to the Review Committee a summary of the incident from their points of view.
e. If the Respondent(s) have requested witness testimonies, each witness will then provide their feedback separately in support of the Respondent’s position.
f. Finally, the Review Officer will present to the Review Committee a summary of their review process and the outcome of their determination.
g. The Review Committee will have the opportunity to ask clarifying questions following each summary and/or testimony. These questions may be in regard to the summary statements, any witness testimonies, or the Record of the Case.
h. Only the Grievant and Respondent(s) may make summary statements to close the proceeding for such period of time as permitted by the Chair.
i. After the close of the hearing, the Review Committee may meet privately to discuss the case. The committee’s finding will be by a simple majority vote and shall communicate its decision in writing to all parties via email within ten (10) days of the date of the Review Committee Proceeding.
j. Any request for continuance or extension of the time deadlines shall be made in writing to the Chair, who shall have the authority to continue the hearing or to extend a time deadline if the request is made prior to the passage of the time deadline and if made for good cause. The Chair shall notify all parties of the new date for the hearing or other new time deadline. Request for continuance or for extensions of any time deadline shall include all reasons for the request.
k. Any other procedural questions which arise during the hearing not covered by these general rules shall be determined by the Chair, whose rulings shall be final.
The standard of review is de novo. The determination of the Review Committee shall be made on the basis of a preponderance of the evidence (whether it is more likely than not). In cases such as this, the determination of the committee, as well as prior notices to and from the Psychology Intern that have been issued in the matter prior to appeal to the Review Committee, shall become the “Final Record of the Case” and shall be accessible at reasonable times and places to all parties as determined by the Chair.
Miscellaneous #
Maintenance of the Intern File
The Record of the Case including a copy of the Committee’s report will be maintained in the NPTC Administrative Office according to the NPTC Maintenance of Records policy. All documentation of grievance proceedings are maintained separately from the Intern’s Training File.
Grievant Status Pending Appeal
A Grievant who is appealing any matter has the right to continue to provide clinical services. However, when, in the opinion of the Review Officer or Review Committee, a Psychology Intern’s conduct presents a threat to the safety of other members of the institutional community, either may issue an immediate interim suspension from all or part of the program. Interim suspensions should be issued in writing, stating clearly the privileges that are being suspended (ability to see patients or access to some/all site facilities), and should inform the Psychology Intern of his or her grievance process rights. The Psychology Intern may appeal issuance of the interim suspension to the President/CEO. The President/CEO or Board of Directors may lift or modify the interim suspension during the appeal process. If a matter is pending at the end of a training year, the Psychology Intern will be allowed to extend their internship until the matter is resolved.
Grievance Process Appeals Involving Charges of Harassment or Discrimination
When any appeal makes allegations of harassment or discrimination, the Sr. Vice President of Clinical Operations shall be promptly informed of the allegations. The Sr. Vice President of Clinical Operations shall separately investigate the allegations concurrently with any grievance appeal process. The Sr. Vice President of Clinical Operations will report the results of the investigation to the President/CEO and the results of the investigation may be included in the Record of the Case for the grievance appeal process if appropriate. In the event the President/CEO is the one who is accused of having harassed or discriminated against the Psychology Intern, the Sr. Vice President of Clinical Operations will report to the Chairman of the Board of Directors.
Notifying the Site Training Director of Finding
The President/CEO will notify the intern’s Site Training Director when an appeal process begins and provide regular updates throughout the process. However, the formal Record of the Case including information obtained from the Review Officer and/or Review Committee will not be sent to the Site Training Director unless the Training Director is directly implicated in the appeal, the information is needed to facilitate intern training, and/or is beneficial to the site process.