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Intern Evaluation Procedures

Introduction

The Intern Training Staff (ITS), composed of all CCCPS staff providing supervision to interns on any given year, is asked as part of their commitment to supervision to provide ongoing feedback to interns regarding their progress toward completion of the internship, and to do so in accordance to the CCCPS intern evaluation procedures described below.

The CCCPS  intern evaluation system includes both informal and formal evaluation procedures, as well as procedures for addressing concerns and grievances that may arise regarding intern performance and/or behavior and its evaluation during internship.   

Due Process: General Guidelines

Due process ensures that decisions made by ITS and CCCPS staff about interns are not arbitrary or unfair.  It requires that programs such as CCCPS identify specific evaluative procedures which are applied to all trainees and have appropriate appeal procedures available to the intern so they may challenge the program’s actions if needed.  General due process guidelines described in this handbook include:

  1. Presenting interns, in writing, CCCPS's expectations related to professional functioning.
  2. Stipulating the procedures for evaluation, including when and how evaluations will be conducted.
  3. Articulating in writing the various procedures and actions involved in making decisions regarding intern impairment.
  4. Communicating with graduate programs of origin about any significant difficulties with interns and seeking input from these academic programs about how to address such difficulties.
  5. Instituting, with the input and knowledge of the graduate program of origin when needed, a remediation plan for significant intern inadequacies, including a timeframe for expected remediation and consequences of not rectifying the inadequacies.
  6. Providing the Intern Handbook at the outset of the training year to interns, including the policies and procedures and, more specifically, a description of Due Process and Grievance mechanisms.
  7. Ensuring that interns have sufficient time to respond to any action taken by CCCPS.
  8. Using input from multiple professional sources when making decisions or recommendations regarding the intern’s performance.
  9. Documenting, in writing and to all relevant parties, the action taken by CCCPS and its rationale. 

The Evaluation Process 

At CCCPS interns are evaluated and given feedback by individual and area supervisors, as well as by other CCCPS staff involved in their training, in various ways throughout the internship year. This feedback serves to facilitate growth by highlighting ongoing areas of strength and areas for growth that can serve as foci during training at CCCPS and beyond.

Although formative evaluation and feedback is ongoing during internship year, there are four key moments in the regular evaluation process during the year, two informal and two formal (summative):

1) In the middle of the first term (or approximately November 1) interns and supervisors informally discuss interns’ performance over the first 7 weeks of internship.  This informal meeting is designed to review the progress of interns and discuss any ongoing concerns or challenges as they are being addressed by supervisors in their respective areas. This initial meeting also provides an opportunity for:

      a. early intervention if significant concerns are raised about performance with the training director       and other supervising staff (see Procedures for Addressing Staff Concerns Regarding Intern Behaviors and Skills below)

      b. increasing supervising staff awareness of intern performance across professional wide       competencies to tailor training over next few weeks in various supervised areas as needed.

Supervising staff are encouraged to discuss any concerns they have regarding intern performance with their supervisee throughout the semester and in a formative manner.

2)  In late-January , the first formal evaluation occurs. Primary and Secondary supervisors, as well as Assessment, Multicultural, Supervision of Supervision and Outreach supervisors fill out formal evaluation forms for their areas, which are then reviewed and signed by each area supervisor and each intern. Primary and Secondary supervisors meet prior to completing their evaluation to insure broad congruence in their ratings, and/or discuss lack thereof and possible rationale when there is lack of congruence. In the case of the latter, these differences are then explained to the intern by each supervisor. Evaluations are also provided to the intern’s graduate program along with a letter regarding the overall intern’s progress in the internship program.

3) In mid-April, supervising psychologists again informally discuss with interns progress over the second half of the year. Feedback from this discussion is shared with the primary supervisors and training director as is relevant.

4) In early to mid-July, final formal evaluations are completed by  primary and secondary supervisors, as well as Assessment, Multicultural, Supervision of Supervision and Outreach supervisors, which are then reviewed and signed by each area supervisor and intern. Copies of all six final evaluations are provided to interns’ graduate programs along with a letter indicating successful completion of the internship program. 

The original copies of formal evaluations become a permanent part of the intern’s internship file.

Minimum Level of Achievement

Intern evaluation is operationalized according to a full-year perspective with progression toward independent, autonomous practice. Our minimal level of achievement (MLA) is a "4" on our 1-5 scale by end of year, with this indicating that the intern is performing at the minimum level to be expected for post-internship, entry-level practice. See the Evaluation of Intern Performance Definitions for more information on this scale. Average scores in each competency area are tabulated across evaluations (Primary Supervisor, Supervision of Supervision, Supervision of Assessment, Multicultural Seminar, and Outreach Seminar). The passage criterion at end of internship is an average rating of 4 (our MLA) or greater for each competency area, successful passing of two case presentations, and completion of 500 direct service hours within a full 2000-hour internship experience.

Intern Training Staff Concerns Regarding Intern Behavior and Skills: Definitions

There are three broad types of concerns regarding intern behaviors and skills, described below in order of severity from low to high.

Intern performance below the expected level of competency

Defined as a skill deficit in any one given supervised area or -more broadly- professional wide competency. It is typically identified by supervising staff in the course of their regular supervision/work with interns and leads to the development of an informal remediation plan to address the skill deficiency. This initial informal plan is developed in collaboration with the intern and may include the training director, upon the request of either party.

In instances in which the skill deficiency is still present by the time of the first formal evaluation, intern performance below the expected level of competency is defined as any rating below “3” in any single element of a written intern evaluation. Ratings of “1” in any single element mid-year automatically trigger a formal remediation plan (see below). Ratings of “2” mid-year may simply reflect ongoing work to improve in an area at the time of the evaluation, although clearly identify areas of concern, and consequently require a plan, formal or informal, to address them. By the end of the year, interns are expected to achieve ratings of “4” or above in all elements of their written final evaluation.

Intern unprofessional and/or problematic behavior

For purposes of this document, unprofessional and/or problematic behavior is defined broadly as behavior causing a significant interference in professional functioning that is reflected in one or more of the following ways:  

  • An inability and/or unwillingness to acquire and integrate professional standards into one’s repertoire of professional behavior;
  • An inability and/or unwillingness to acquire professional skills in order to reach an acceptable level of competency, and/or,
  • An inability and/or unwillingness to manage personal stress, psychological difficulties, and/or excessive emotional reactions which interfere with professional relationship and functioning. 

Problems typically become identified as problematic and unprofessional when they include one or more of the following characteristics:

  • The intern does not acknowledge, understand, or address the problem when it is identified;
  • The problem is not merely a reflection of a skill deficit which can be rectified by academic or didactic training;
  • The quality of services delivered by the intern is negatively affected;
  • The problem is not restricted to one area of professional functioning;
  • A disproportionate amount of attention by training staff is required; and/or
  • The trainee’s behavior does not change as a function of feedback, remediation efforts, and/or time.

Intern violations of policy

Intern violations of policy, be it APA’s code of ethics, CCCPS policies and procedures, West Virginia University’s code of conduct and/or other state laws and regulations that may be severe enough (committing a felony, sexual/romantic contact with a client, etc.) to warrant immediate suspension or dismissal from the program. 

Procedures for Addressing Staff Concerns Regarding Intern Behaviors and Skills

Most discussions regarding intern performance begin with individual and area supervisors. It is their responsibility to bring to the intern’s attention skills, behavior and other actions which are perceived to be problematic or below the expected level of competency for an intern at any point during the internship year, and to offer and discuss strategies at that time to address these difficulties.

At times, the concerns over an intern behavior or skills may come from a CCCPS staff member not involved in the intern’s supervision. In these instances, CCCPS staff members are asked to address their concerns first directly with the intern. If they are unsure how to address them, have attempted to do so but have been unable to, or have not received an appropriate response from the intern, they are asked to consult with the primary supervisor or Training Director (TD) for guidance on how to proceed. For serious concerns, please check Grievance Procedures for Staff Complaints Concerning a Psychology Intern below for detailed grievance procedures for staff complaints.

When concerns are perceived by ITS members to be significant enough to warrant additional action, the following procedures may be initiated:

Informal Remediation

Informal Remediation can be started by any intern supervisor in consultation with the TD. It defines a relationship where a supervisor works closely with an intern to remediate perceived performance below the expected level of competency in any one given supervised area. Informal remediation acknowledges through the TD and supervisor that: 

  • the supervisor is aware of and concerned with the intern’s skill deficit or problematic behavior;
  • the skill deficit or behavior in question has been brought to the attention of the intern
  • the supervisor in question will work with the intern to rectify the behavior or skill deficits identified, as needed (see Schedule Modification below) and,
  • the skill deficit or behaviors associated with the concern are not significant enough to warrant more serious action.

Once an Informal remediation plan is implemented, it is expected that the status of the plan will be reviewed no later than the next evaluation period. Failure to improve by that time may lead to a Formal Remediation plan. Informal remediation actions are documented in supervisor notes and with the training director.

Formal Remediation

Formal Remediation results from a decision made by a majority of supervising staff in consultation with the TD, and occurs typically after the first formal evaluation, although it may be started at any point in the year. It defines a relationship such that the supervising staff actively and systematically monitor, for a specific length of time, the degree to which the intern addresses, changes, and/or otherwise improves the behavior associated with performance below the expected level of competency or unprofessional and/or problematic behavior .  Formal Remediation requires a written statement to the intern that includes:

  • The actual behaviors associated with the formal remediation plan
  • The specific recommendations for addressing the problem (see Schedule Modification and Suspension of Direct Service Activity below)
  • The time frame during which the problem is expected to be ameliorated and,
  • The procedures designed to ascertain whether the problem has been appropriately rectified.

If a formal remediation plan is implemented, the TD will inform the intern’s doctoral program, indicating the nature of the inadequate rating, the rationale for the ITS action and the plan as outlined by the ITS. The intern shall receive a copy of the letter to their doctoral program.

Once a Formal Remediation plan is implemented, it is expected that the status of the plan will be reviewed no later than the time frame identified in the written statement. If the concern has been addressed to the satisfaction of the ITS, the intern, doctoral program of origin and other appropriate individuals will be informed, and no further action will be taken. 

Interventions used in Remediation Plans

Two types of interventions are typically used in informal or formal remediation plans, with the nature of the intervention varying depending on the specific concern:

Schedule Modification

A time-limited intervention designed to help an intern address a skill deficit, and professional and/or problematic behavior in the context of an informal or formal remediation plan. The length of a schedule modification period will be determined by the TD in consultation with the intern’s primary supervisor, the Clinical Director, and the Director. The termination of the schedule modification period will be determined, after discussions with the intern, by the TD in consultation with the primary supervisor and the Director. Several possible and perhaps concurrent courses of action may be included in modifying a schedule. These might include:

  • Increasing supervision time, either with the same or other supervisors,
  • Change in the format, emphasis, and/or focus of supervision,
  • Recommending personal therapy (a list of community practitioners and other options will be provided),
  • Reducing the intern’s workload,
  • Requiring specific didactics or academic coursework.

Suspension of Direct Service Activity (Partial or Complete) 

Suspension of direct service activity (partial or complete)  requires a determination, made by the TD in consultation with ITS that the welfare of an intern’s client/s or consultee/s has been jeopardized or is at significant risk of being jeopardized, and that partial or complete suspension of the intern’s direct service activity is needed to prevent further injury. 

In this instance, direct service activities will be suspended for a specified period as determined by the TD in consultation with the primary supervisor, Director and Clinical Director. At the end of the suspension period, the intern’s supervisor in consultation with the TD will assess the intern’s capacity for effective functioning and determine when direct service can be resumed.

When formal remediation plans fail to improve intern’s performance or change problematic or unprofessional behavior, the ITS will communicate in writing to the intern that the conditions of the remediation plan have not been met. Any of the following actions may then be taken and reflected in the written communication to the intern:

  • An extension of the remediation plan (as stated in the original written document or modified by the ITS) for a specified added time period.

  • A recommendation to the Director of CCCPS for intern dismissal from the Training Program (see below)

Recommendation to the Director for Dismissal

It results from either the informal and formal remediation process (see above), or as a direct consequence of a severe intern violation of policy (see Grievance Procedures for Staff Complaints Concerning a Psychology Intern, below). 

Procedures for Intern Appeal

If the intern challenges any of the actions taken by the ITS as described above, they must inform the TD in writing of such a challenge within 10 days of receipt of the ITS’s decision.

The TD will then convene a Review Panel consisting of two staff members selected by the TD and two staff members selected by the intern.  The intern retains the right to hear all facts with the opportunity to dispute or explain their behavior.

A review hearing will be conducted, chaired by the TD, in which the challenge is heard, and the evidence presented.  Within 5 days of the completion of the review hearing, the Review Panel submits a report to the Director, including any recommendations for further action.  Decisions made by the Review Panel will be made by majority vote.  The intern is informed of the recommendation.

Within 5 days of receipt of the recommendation, the Director of the CCCPS will either accept the Review Panel’s action, reject the Review Panel’s action and provide an alternative, or refer the matter back to the Review Panel for further deliberation.  The Panel then reports back to the Director within 10 days of the receipt of the Director’s request for further deliberation. The Director then makes a final decision regarding the appeal.

Once a decision has been made, the intern, sponsoring university, and other appropriate individuals are informed in writing of the action taken. 

Grievance Procedures for Intern Complaints Concerning a CCCPS Staff Member

In the event an intern encounters any difficulties or problems (e.g., poor supervision, personality clashes, inappropriate behavior, other staff conflict) during their training experiences, an intern is encouraged to:

  • Discuss the issue directly with the staff member(s) involved in an effort to informally resolve the problem
  • If the issue cannot be resolved informally, or if the intern is uncomfortable with directly approaching the persons involved, the intern may discuss the concern with their primary supervisor or, alternatively, the TD. If the primary supervisor and the Training Director are part of the complaint, the intern may speak with a different ITS member. The role of these individuals is to support, mentor and/or direct the intern in how best to proceed with the concern and to recommend appropriate resources for consultation. The ITS member may also consult with a member of the CCCPS leadership team on how to proceed.

  • If the Primary Supervisor, TD or ITS member cannot resolve the issue, the intern can present a formal complaint following this procedure:
    • The intern should file a formal complaint, in writing and all supporting documents, with the TD.  
    • If the formal complaint involves the TD, the Director will appoint a staff member from the counseling senior staff to fulfill the TD function with regard to the complaint.
    • Within 3 working days of a formal complaint, the TD or alternative designated staff member consults with the Director and implements Review Panel procedures as described in Procedures for Intern Appeal
Given that interns are staff members, they have access to the grievance procedures available to West Virginia University Employees available through Human Resources. 

For more information, see below:


WVU, Division of Talent and Culture, Employee Relations
1-304-293-5700 ext. 5
EmployeeRelations@mail.wvu.edu
Grievance Procedure and Process  

WVU, Division on Diversity, Equity and Inclusion
1-304-293-5600
diversity@mail.wvu.edu 

Ethics
1-304-293-5841
LegalAffairs@mail.wvu.edu
Ethics Line 
More information on Ethics Line

Interns can also reach out to APPIC and APA to seek consultation or file a complaint in order to seek resolution as a part of the above measures or if unable to satisfactorily do so via available WVU options.

APPIC Problem Consultation (Informal and Formal)

https://www.appic.org/Problem-Consultation

APA Commission on Accreditation Complaint Procedure

https://www.accreditation.apa.org/complaints-and-third-party-testimony

Grievance Procedures for Staff Complaints Concerning a Psychology Intern

Any staff member of the Carruth Center may file with the TD, in writing, a grievance against an intern for any of the following reasons: 

  • Unethical or legal violations of professional standards or laws
  • Serious professional incompetence or negligence, or;
  • Infringement on the rights, privileges or responsibilities of others
The TD will review the grievance with the primary supervisor of the intern and determine if there is reason to proceed.

If the TD and primary supervisor determine that the alleged behavior in the complaint, if proven, WOULD NOT constitute a serious violation, the TD shall inform the staff member who may be allowed to renew the complaint if additional information is provided.

If the TD and primary supervisor determined that the alleged behavior in the complaint, if proven, WOULD constitute a serious violation, the staff member will be notified and the TD and primary supervisor will meet with the intern to inform them of the grievance and seek their response.

If the intern wishes to challenge the grievance, a Review Panel (see in Procedures for Intern Appeal above) will be convened to examine the evidence and reach a decision.

If the intern confirms the concerns as described in the grievance, Procedures for Addressing Staff Concerns Regarding Intern Behaviors and Skills would apply.

Once a decision has been made, the intern, staff member, sponsoring university, and other appropriate individuals are informed in writing of the action taken.