Devil in the Details: APA’s Problematic Footnote 4

Shara Sand

duh-magazine1Footnotes rarely make headlines. Typically, they reside at the bottom of a page; they often go unread. But footnotes also can wield considerable power with troubling consequences. This is the case for Footnote 4 of the American Psychological Association’s (APA) Guidelines and Principles for Accreditation of Programs in Professional Psychology.

In the context of doctoral, internship, and postdoctoral programs, the Guidelines states that “all accredited programs will articulate and implement a specific plan of learning with regard to diversity that is integrated throughout its didactic and experiential training, consistent with each program’s goals and objectives.” This diversity requirement in the training of psychologists is uncontroversial from both ethical and practical perspectives.

But Footnote 4 of the Guidelines (I provide the footnote in its entirety at the end of this essay, as is fitting) permits programs that have a religious affiliation to give preference in admissions and employment to “persons adhering to the religious purpose or affiliation of the program” as long as they do not preclude individuals on the basis of specific personal and demographic characteristics.

While this footnote serves to protect the integrity of academic religious institutions, it also allows such institutions to discriminate against lesbian, gay, bisexual, and transgendered persons. Indeed, this was the recent experience of a student who had to sign a “code of conduct” statement which included a provision that any homosexual activity would be grounds for dismissal. The student signed this statement, later came out, got married, and dared be honest about this action. He was subsequently threatened with dismissal from the program and only allowed to remain enrolled because he was nearing degree completion and departing for his internship.

The university is certainly entitled to have a code of conduct, but a key question remains: Is APA obligated to accredit an institution that can use its code to discriminate against openly LGBT people?

APA’s Committee on Accreditation (CoA) last addressed the issue of Footnote 4 during the Bush administration years. Attempts to tackle problems inherent in the footnote were met with threats that APA’s standing as a federally approved accrediting body would be jeopardized, negatively impacting the training of psychologists. Not surprisingly, Footnote 4 remained unchanged. Hopefully, the Obama administration will not exercise such a heavy hand.

Now is the right time to close the Footnote 4 loophole that can lead to discrimination. The CoA has announced a period of open public comment (through March 23rd) concerning proposed clarifications to the Guidelines in regard to “cultural and individual differences and diversity” as applied to doctoral, internship and postdoctoral programs. In response, Maryka Biaggio, Ph.D., co-chair of the Education and Training Committee of APA’s Division 44 (the Society for the Study of Gay, Lesbian & Bisexual Issues) has submitted detailed comments regarding Footnote 4. Her comments highlight the following questions:

• If a program does not endorse Footnote 4 and has a statement of creed or philosophy implying that LGBT persons are not welcome, is the program held accountable by the CoA for restricting admission and hiring?

• If a program endorses Footnote 4, is the program expected to make its hiring and admission policies clear to prospective applicants and hires? Does the CoA ascertain that these programs do not restrict admission and hiring for LGBT persons?

• Do site visitors or the CoA determine if LGBT students/interns/residents and faculty/staff/supervisors are treated with courtesy and respect in the program?

• Does the CoA accredit programs whose codes of conduct state that sexual orientation or sexual conduct may be cause for disciplinary action? Although many such codes refer to sexual conduct outside of a marriage, they disproportionately affect LGBT persons because few jurisdictions allow same-sex persons to marry.

• Are Footnote 4 programs expected to affirmatively address LGBT issues in their training programs? For example, is the CoA scrutinizing the syllabi to ensure that instruction conforms to the scientific understandings and official APA positions on sexual orientation?

I strongly encourage interested readers to add your own comments or endorse Division 44’s comments at It is time to bring Footnote 4 to center stage so that it can receive the long overdue critical review it deserves.

Footnote 4: “This requirement does not exclude programs from having a religious affiliation or purpose and adopting and applying admission and employment policies that directly relate to this affiliation or purpose so long as: (1) Public notice of these policies has been made to applicants, students, faculty, or staff before their application or affiliation with the program; and (2) the policies do not contravene the intent of other relevant portions of this document or the concept of academic freedom. These policies may provide a preference for persons adhering to the religious purpose or affiliation of the program, but they shall not be used to preclude the admission, hiring, or retention of individuals because of the personal and demographic characteristics described in Domain A, Section 5 of this document (and referred to as cultural and individual diversity). This footnote is intended to permit religious policies as to admission, retention, and employment only to the extent that they are protected by the United States Constitution. It will be administered as if the United States Constitution governed its application.”

PsySR member Shara Sand is an Assistant Professor of Psychology at LaGuardia Community College in Queens, NY and maintains a private practice in New York City. She can be reached at


5 Responses to “Devil in the Details: APA’s Problematic Footnote 4”

  1. Eric Says:

    Diversity of all kinds needs to be acknowledged and accepted by our society and profession. It is right for psychologists to receive specific training in working with the GLBT population. However, our profession must also acknowledge that individuals with conservative religious beliefs are also a part of this society and have mental health needs as well. Conservative universities are uniquely positioned to train psychologists for working with this segment of the population. If APA truly values diversity in society it will also value diversity in the profession and allow these institutions that are providing quality training to retain their accreditation.

  2. Shara Sand Says:


    I am not saying that conservative universities should not be accredited. I am saying there is a problem when such universities can use their policies to discriminate against GLBT persons. If such policies were used to discriminate against ethnic or racial populations, they would likely not be tolerated. All populations should be treated equally.


  3. Eric Says:

    I guess my hope is that each program will be evaluated fairly based on it’s merit and the quality of psychologists it produces and not be blacklisted because of perceptions about the university at large.

  4. Shara Sand Says:

    That would be my wish as well. There are many fine programs which do not discriminate housed at religiously based institutions (I taught at Yeshina University for many years). However, there are some programs where discriminations does occur and this is problematic.

  5. Vince Nocito Says:

    Universities that include anti-LGBT material in their curriculum should be denied accreditation – plain and simple. The field of psychology must have standards like the rest of the medical field, and if a religious university does not wish to adhere to the scientific method & empiricism, then it has no business offering education in any scientific field including psychology. Perhaps they should call their programs “religious counseling,” rather than psychology.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: