FACT Response to APA Task Force on Test User Qualifications

September 29, 1999
 
Dr. Heather Roberts Fox
APA Science Directorate
750 First Street, NE
Washington DC 20002-4242
Dear Dr. Roberts Fox:

We are writing to you in response to the draft report dated June 7, 1999, from the APA Task Force on Test User Qualifications (TFTUQ), on behalf of the 23 member organizations of our Fair Access Coalition on Testing (FACT). Our response should in no way be construed as indicating acceptance of the TFTUQ Report or as evidence that FACT was an active participant in the process of drafting this Report, as neither of these is the case.

Our primary quarrel with the TFTUQ Report is that it deviated from its original "charter" or mandate from APA. In your article in the Division 5 SCORE Newsletter (July 1999, pages 3-4), you stated that the "charge of the nine-member task force is ‘(1) to review and summarize results of previous efforts to develop guidelines on test user qualifications; (2) to extend this prior work to address issues of assessment context, purpose, and specific application as critical variables in the definition/description of test user qualifications, (3) to describe the set of knowledge and skills necessary for psychologists to administer, score, and interpret assessment instruments in a competent and responsible manner that best serves the interests of the public, and (4) to develop a set of guidelines to be adopted by APA in order to inform psychologists of the knowledge and skills required in the responsible conduct of assessment"’ (emphasis added). We believe that the TFTUQ Report deviated from this charge by attempting to prescribe test user qualifications for professionals who are not psychologists or APA members (reference Page 1-1 lines 4-12 and 1-3 lines 51-57 and 67-70).

We laud the Task Force’s successful efforts in points (1) and (2) above; the summary of past results was illuminating and constructive for moving forward with test user qualifications for APA members, and the organizational scheme that incorporated test use and context was superior to previous efforts to define qualifications for test users. Unfortunately, much of this laudable work was undermined by the Task Force’s deviation from its charge from APA to "describe the set of knowledge and skills necessary for "psychologists." Because the Task Force chose not to involve in this effort all the other professional organizations whose members use psychological and educational tests, it cannot dictate test user qualifications for professionals beyond their own organization’s members. The Task Force cites no evidence of research into test use in other disciplines. Had this been a Joint Committee report, it would have required the participation and input from other professional organizations; instead, it is solely an APA effort and, as a consequence, it overreaches its charter and APA’s authority.

FACT members traditionally have taken a much more collaborative approach to defining test user qualifications, and we should prepare our own standards. If APA through this Task Force Report attempts to dictate to our professional members what they should require in the form of test user qualifications, FACT members should ignore such efforts. The APA Report’s repetition of the statement "The qualifications described above are best obtained through doctoral training in psychology" is potentially self-serving. We respectfully disagree with that quoted supposition because of several contexts in which our professionals administer and interpret tests. For example, in the Education context, an advanced degree in special education with appropriate testing preparation might well be superior training to a doctorate in psychology, if the tests to be administered and interpreted are for special education purposes.

Consequently, we cannot support the recommendations of the Report for all test users; however, we have no argument with the use of this document for the stated purposes of test use by psychologists or APA members.

Sincerely,

Thomas W. Clawson, Ed.D.                   Lorin Letendre, M.A.

Co-Chair of FACT                                 Co-Chair of FACT

TWC/LL/mwf