What does it mean if a test is classified by the Professional Board for Psychology as a psychological test?
Health Professions Council of South Africa’s (HPCSA) revised mandate:
During June 2019, the Professional Board for Psychology of the HPCSA released a revised mandate of its Psychometrics Committee, indicating that the committee would be focussing on test classification and not test certification. The registration of a test with the HPCSA and its classification as a psychological test, as published and gazetted by the HPCSA, is not a certification of the compliance of the test with the Employment Equity Act or any other evaluative certification.
Through the registration process, the HPCSA will be indicating whether the test measures a psychological construct or not and if it does, it will be classified as a psychological test that must be controlled and used by a HPCSA registered psychologist and psychometrist as indicated.
The Psychometrics Committee is now mandated:
- To classify any device, instrument, questionnaire, apparatus, method, technique or test aimed at the evaluation of emotional, behavioural and cognitive processes or adjustment of personality of individuals or groups of persons, or for the determination of intellectual abilities, psychopathology, personality make-up, personality functioning, aptitude or interests by the usage and interpretation of questionnaires, tests projections or other techniques or any apparatus, whether of SA origin or imported, and to report thereon to the Professional Board.
- The annual publication of a list of psychological tests/psychometric instruments classified by the Professional Board
- Develop training guidelines/standards related to psychometrics and psychological assessment that can inform and be used in the accreditation of qualifications, universities and internship programmes, when setting the national Board examinations, and for continuing professional development purposes
- Develop guidelines for ethical practice related to test use and psychological assessment and how to assess whether a psychological test meets the required standards
- Develop minimum requirements/standards for psychological tests
- Classification will entail verifying whether a test was psychological or not. To this end, practitioners and publishers should submit the full test manual that states the construct(s) tapped by the test, evidence of psychometric properties, an indication as to whether the item content was culturally appropriate. No costs would be attached to test classification by the Professional Board.
Aspects of human behaviour that may only be assessed by psychology professionals:
The following constructs are specifically mentioned in regulation 993:
- Intellectual abilities
- Aptitude
- Interests
- Personality make-up or personality functioning
- Temperament
- Emotional functions
- Psychophysiological functioning
- Neuropsychological disorders
- Mental functioning deficiencies
For what purpose would these assessments be done, that makes it a “psychological act”?
Within Form 208, there is reference to what constitutes a psychological act. Within Regulation 993, there is reference to the purpose of the assessments. Specifically mentioned are: The evaluation of emotional, behavioural and cognitive processes or adjustment of personality. Specific reference is also made to “personnel career selection”.
The regulation on the scope of the profession is written with the intent to be comprehensive:
The domains of assessment that define an assessment as psychological in nature are specified comprehensively and repeatedly, and there is repeated reference to different techniques of assessment – not only tests, but other techniques and apparatus as well. There is a clear effort to cover all possible ways of doing assessment. By the way this regulation is written, it is clear that the intent of the legislators was to regulate psychological assessment in all its aspects and applications, and to reserve it for the profession of psychology.
Currently tests are classified only as being psychological tests or not. There is provision in the current classification system for tests to be classified as psychological tests that may also be used by other professions (for example remedial teachers or occupational therapists), but to our knowledge no tests have been classified as such.
Tests that have not been submitted for classification:
It is possible that a test may measure one of the constructs reserved for the profession of psychology, but that it may not have been submitted for classification. Indeed it is very likely – the level of compliance among the people who distribute and sell tests has been disturbingly low. If a test measures personality, its use results in a psychological act whether it has been classified or not. If the test has also been classified, there is no doubt that using it constitutes a psychological act, and it has also been scrutinised for psychometric quality.
Who may administer psychological tests?
A certificate used to be issued when a test is classified, and that certificate specifies what different categories of assessment practitioner may do with respect to the test in question – for instance: administer it, interpret it, write reports on it etc. Currently, assessments that are submitted to the HPCSA for evaluation as a psychological assessment or not, receive a letter from the Professional Board of Psychology.
Psychologists may administer any psychological tests in which they have been trained.
Psychometrists may administer any psychological test in which they have been trained. It must be noted that there are some types of assessment that psychometrists may not use – these are tests designed to diagnose pathology, neuropsychological tests and also projective tests.
Registered Counsellors have a more limited range of tests that they may use – there is a specific list of tests that have been approved for the use of registered counsellors. The assessments registered counsellors do are also supposed to be for basic screening purposes – if comprehensive assessment is needed, registered counsellors are expected to refer the client to a psychologist or psychometrist.
The register for psychotechnicians was closed several years ago but there are still some persons registered in that category. No new psychotechnicians are being trained or registered. Psychotechnicians may administer and score some tests where the classification certificate of the test specifically allows it.
There is currently no specific category of “test administrator” recognised by the Professional Board for Psychology, other than the professional categories mentioned above.
It is important to take note though, that according to the current scope of practice for professionals in psychology, psychometrists constitute the professional category specifically trained to administer and interpret tests of a non-clinical and non-diagnostic nature. A set of competencies has been outlined for psychometrists to guide training institutions, and a lot of attention is paid to the skills involved in actually administering testing.
HPCSA Scopes of the practice of different categories of psychology professionals
It is therefore our contention that for many tests and in our multicultural context, the administration of tests can be reduced to simple reading out the instructions and watching respondents fill in the answer sheet.
What about tests where the administration is totally standardised and routine, or even automated?
Regulation R717 annexure 12 allows for a psychologist to delegate work to an employee (item 8), and this could potentially apply to the case when an administrative worker administers a test that is administered in a mechanical, computerised or purely routine manner, and where the administration requires no psychological skill as such. The responsibility for the objectivity of the process and the procedurally proper administration of the test remains with the registered professional. This would fall under the category of delegated work, and it is the registered professional’s responsibility to ensure that the person who does the delegated work is properly trained for it.
Psytech has been reluctant to advise professionals to delegate the administration of tests to any person who is not a registered psychometrist – given that a professional category exists with a clearly defined role of administering tests, and that there are a great many psychometrists, many of whom struggle to find work. We believe that the administration of tests by unregistered persons (even if they have been trained) is a grey area. Even in the court case where the Association of Test Publishers and SHL took the HPCSA to court and attempted to get a court ruling that the administration of a test does not in itself constitute an act reserved for the profession of psychology, the judge did not grant this specific request.
Where the test administration is totally automated, it is difficult to justify the need for a registered professional purely to administer the test – however, this applies to administration only. In fact, our contention is that during the administration of a test, a lot of other important interactions take place. The process of gaining informed consent is one professional action that takes place during the testing process, and this is covered in detail in the professional conduct regulations. Another is the behavioural observation that takes place during testing – this is observation of a professional, psychological nature and goes way beyond a simple process that can be automated. If the test is automatically administered without supervision, the observational information cannot be obtained, and the professional in charge of the assessment process must take responsibility for doing the assessment in the absence of the additional information.
The rules of professional conduct clearly specify that assessment needs to be done in the context of a professional relationship. Only the registered professional can establish this relationship – that is not something you can delegate. How it must be done is not clearly defined, and nowadays technology allows us means of communication that were not even options a few years ago. There are the possibilities of Skype conversations, of a video call, videoconferencing, observation via webcam or video camera during testing, even the telephone. We believe that the establishing of a professional relationship is a necessary preliminary to the obtaining of informed consent for testing, the identification of special needs and circumstances, and especially to defining the limits of confidentiality. With rapidly changing technology and with the regulations that do not spell everything out in up-to-date detail, it is not possible for us to give people a hard and fast answer about all the ethical issues involved with automated testing. However, it is clear that there needs to be a professional relationship, and simply overlooking that aspect is not responsible professional behaviour.
We do not believe that sending a link in an email to a person with whom one has not otherwise interacted constitutes the establishment of a professional relationship.
For that reason, when professionals ask us for access to online testing and especially when they ask us to make a test available for unsupervised administration, we require them to sign a document where they personally take professional responsibility for the way in which they use this technology.
It is simply not possible to automate responsible professional behaviour.
The scoring of tests:
Regulation R717 annexure 12 allows for a psychologist to delegate work to an employee (item 8), and this would be the case when an administrative worker scores a test that can be scored in a mechanical, computerised or purely administrative way. The psychology professional is responsible for ensuring that objectivity is not compromised by multiple relationships, and for ensuring that only those responsibilities that such a person can be expected to perform competently on the basis of his or her education, training and experience are delegated. The psychology professional also must ensure that this person performs these services competently.
Regulation R717 also allows for automated scoring and interpretation systems (items 52, 53 and others). The responsibility for the use of these systems clearly rests with the psychology practitioner.
Thus, while delegation of certain actions that do not in themselves require psychological expertise are allowed, professional responsibility cannot be delegated to an unregistered person. The regulations also appear to require an active concern with quality control and direct supervision. The professional may not assume or trust that delegated activities are competently done, he or she must ensure it.
Interpretation, reporting and feedback:
Nowadays, computer systems can do a credible job of interpreting and reporting on psychological tests. However, only a registered professional can decide whether a specific report is appropriate for the purpose of the assessment, whether it is comprehensive enough, whether the report incorporates all relevant information, whether it is clear enough for the intended recipient or whether further elucidation is required. Often there are also several options in terms of computer-generated reports, and the decision on which particular report should be used is in our judgment one that needs to be made with professional discretion. Sometimes input from multiple reports needs to be combined. Feedback is a professional interaction that may also involve giving professional advice. In the case of a person who was assessed for selection or development in the context of a particular role, the feedback given to the management would not necessarily be the same as the feedback given to the respondent. These distinctions require professional judgment.
Thus, in our view, in the context of the current South African regulations, the giving of feedback on psychological tests requires a registered psychology professional. A professional may in fact decide that the computer-generated report is adequate as feedback for the purpose at hand and that no further interaction is required. In that case, the professional concerned must take personal professional responsibility for this decision and its consequences.
Unregistered persons who use tests:
Human resources practitioners and life coaches could also be registered psychology professionals and as such, they would be allowed to use psychological tests. It is their responsibility to remain within the scope of practice of their registered professional category. If they are not registered with the HPCSA as psychology professionals, HR practitioners and life coaches have no special status with regard to the use of psychological tests. They may only use them if they are registered as psychometrists or psychologists.
Some tests are not psychological – for instance, tests of knowledge or skill do not constitute psychological assessments. They may be used by unregistered persons.
However, if a test measures one of the constructs listed in the scope of practice of the profession (see above), it is a criminal offense for an unregistered person to use it. If they also presented themselves as being a registered psychology professional while being unregistered, the offense is even more serious and carries a heavier penalty. Unfortunately, the HPCSA does not have any jurisdiction over unregistered persons – it is a matter for the police.
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