International Journal for the Advancement of Counselling, Vol. 27, No.

3, September 2005 (
C
2005)
DOI: 10.1007/s10447-005-8202-z
Enhancing Counseling Gatekeeping with
Performance Appraisal Protocols
Christine Suniti Bhat
1,2
Academic and site supervisors of counselors-in-training perform the important
function of serving as gatekeepers to the counseling profession. Their endorsement
of a trainee implies that the trainee is capable of carrying out the role of a counselor
in an ethical and effective manner, without endangering clients. Limited guidelines
and training in the gatekeeping function pose a problem for supervisors. In the
quest for improved gatekeeping processes, the counseling profession may achieve
greater clarity and fairness by incorporating performance appraisal protocols
from the business and management elds.
KEY WORDS: gatekeeping; counselor training; counselor supervision; counselor evaluation;
counselors-in-training.
The moral, ethical, and legal mandate for academic and site supervisors of
counselors-in-training to be gatekeepers for the profession is well established.
Effective supervisors to some degree control the access of impaired, unethical or
incompetent counselors to clients, thereby protecting clients who are likely to be
at a highly vulnerable stage of their lives. Clients of trainees are in a temporary
position of subordination due to the counselor-client power differential, and are
therefore often in need of protection (Vasquez, 1999). The public relies on the
professions gatekeeping mechanisms, and presumes that those who graduate from
counseling training programs are fully able to provide service that is effective and
safe (Schoener, 1999).
In countries where counseling is a regulated professions such as the United
States of America, Canada and the United Kingdom, professional codes of ethics
1
Department of Educational Psychology, Administration, & Counseling; California State University,
Long Beach, California.
2
Correspondence should be directed to Christine Suniti Bhat, EDPAC, CSULB, 1250 Bellower
Boulevard, Long Beach, CA 90804; e-mail: cbhat@csulb.edu.
399
0165-0653/05/0900-0399/0
C
2005 Springer Science+Business Media, Inc.
400 Bhat
address the need for supervisors to protect from harm both current and future
clients of trainees. The Code of Ethics and Standards of Practice of the American
Counseling Association (ACA, 1995) is unequivocal in spelling out the gatekeep-
ing responsibilities of supervisors. Ongoing evaluation and appraisal are recom-
mended to identify both academic and personal limitations of trainees that may
impede performance. Supervisors are required to institute remedial assistance,
and if necessary, dismiss trainees from counselor preparation programs. Ethical
guidelines fromthe Association for Counselor Education and Supervision (ACES,
1993) similarly warn that supervisors should not endorse a supervisee for cer-
tication, licensure, completion of an academic training program, or continued
employment if the supervisor believes the supervisee is impaired in any way that
would interfere with the performance of counseling duties (Section 2.13). The
Ethical Framework for Good Practice in Counselling and Psychotherapy put
forward by the British Association of Counselling and Psychotherapy (BACP)
notes that one of the responsibilities of a supervisor is to protect clients from poor
practice, and the code of ethics developed by the Canadian Counselling Associa-
tion (2000) cautions that supervisors have an obligation to take steps to ensure the
welfare of clients, and to intervene when their welfare is threatened.
Professional literature is replete with exhortations to supervisors to protect
the public from incompetent or impaired practitioners (Bernard & Goodyear,
1998; Carroll & Right, 1997; Corey, Corey, & Callanan, 1998; Gould & Bradley,
2001; Pope & Vasquez, 1998). Yet the evaluative component of supervision may
be a source of discomfort for both supervisors and supervisees. This discomfort
with evaluative responsibilities may be a result of a lack of specic evaluation
training received by supervisors and their greater comfort in the non-evaluative
role of counselor (Bernard & Goodyear, 1998). Some supervisors appear to be
uncomfortable with the responsibility of assessing the professional development
of supervisees (Pope &Vasquez, 1998), and others feel strongly enough to express
the view that evaluation is antithetical to the helping professions (Cohen, 1987).
The counselor educators preference for having positive relationships with
students in academic settings may be one reason for the stress that accompanies
having to address trainee impairment (Forrest, Elman, Gizara, & Vacha-Haase,
1999). Awareness of reluctance to assume the gatekeeping role within academic
programs has led to calls for further study to understand faculty concerns and
possible resistance to assuming the role of gatekeeper (Gaubatz & Vera, 2002;
Lumadue & Duffey, 1999). The increased litigious nature of practice may con-
tribute to feelings of unease toward the role of assessing competence of trainees,
and may lead to a sense of reluctance to make pass-or-fail decisions on what makes
a good enough counselor (Wheeler, 1996).
There appears to be little doubt as to what counseling supervisors have to
dothat is, be effective gatekeepers for the sake of the profession and the good
of clients. The question of how to carry out this function is less clear. A recent
survey of training directors of academic psychology programs accredited by the
Enhancing Counsling Gatekeeping 401
American Psychological Society found that 54%of the programs did not have writ-
ten guidelines for intervening with problematic students (Vacha-Haase, Davenport,
& Kerewsky, 2004). Another recent study of counseling programs reported that
when programs have formalized gatekeeping processes faculty members are able
to follow through more effectively with concerns regarding students (Gaubatz &
Vera, 2002).
Models of gatekeeping have been presented in the literature (Baldo, Softas-
Nall, & Shaw, 1997; Bemak, Epp, & Keys, 1999; Frame & Stevens-Smith, 1995;
Lamb et al., 1987; Lumadue & Duffey, 1999), but with limited or on-going em-
pirical validation of these models, their efcacy has not been established in a
denitive manner. It is possible that the counseling profession could gain addi-
tional insight into gatekeeping processes by looking beyond the boundaries of
the profession. In the realms of business and management, various forms of per-
formance appraisal systems to assess job performance of employees have been
consistently utilized. These formalized systems of appraising on-the-job perfor-
mance may provide counseling supervisors with a guide to develop workable and
legally defensible gatekeeping mechanisms.
Before examining possible parallels between performance appraisal systems
and counseling gatekeeping, challenges to carrying out this function will be ad-
dressed. These include a lack of consensus on the denition of behaviors war-
ranting concern and the increasing threat of legal action. This will be followed
by a brief review of ve gatekeeping models from counseling literature. Finally,
suggestions to develop gatekeeping protocols drawn from performance appraisal
systems will be presented.
CHALLENGES TO GATEKEEPING
Existing gatekeeping models alert us to the issue of trainee impairment, but
achieving denitional clarity and consensus on this termremains elusive. Unethical
and incompetent professional behavior is sometimes described as impairment
(Forrest, Elman, Gizara, & Vacha-Haase, 1999). The American Counseling As-
sociation (ACA) uses the umbrella term of personal limitations of supervisees
that may impede performance (Code of Ethics and Standards of Practice, F.3,
1995). The ambiguity inherent in this term is not conducive to clear-cut evaluation
processes. Personal limitations could include psychological limitations, unethical
behavior, and/or incompetence.
There is the view that current denitions of impairment are too narrowly
focused on DSM-IV Axis I descriptors, and do not consider the more subtle,
but ominous personality disorders associated with impairment (Bemak, Epp, &
Keys, 1999). These authors warn that impaired graduate students may incorpo-
rate personal agendas into their counseling philosophy involving dogmatic reli-
gious teachings, harmful directive techniques, or antipathy towards members of a
402 Bhat
different gender, ethnicity, race, sexual orientation, or age group (Bemak, Epp, &
Keys, 1999).
Attempts have been made to classify types of impairment, the rst type
being more obvious, and easy to identify (Sussman, 1992). Examples of this type
include substance abuse, pronounced personality disorders, and/or prejudicial
attitudes and values. When behaviors that are clearly inappropriate or damaging
to clients are displayed by trainees, it may be easier for supervisors to take a
rm stand and refuse to endorse these trainees. The second type of impairment
is less obvious, and therefore more difcult to identify. Indicators of this type
could include interpersonal insensitivity, the need for narcissistic idealization, a
pathological desire to parent, fantasies about being a rescuer, or the need be in
complete control over another (Sussman, 1992).
Another approach has dened impairment as being reected in (1) inability
and/or unwillingness to acquire and integrate professional standards; (2) inability
to acquire acceptable levels of professional skills; and (3) inability to control
personal stress, psychological dysfunction, or emotional reactions (Lamb et al.,
1987). This denition of impairment includes issues of attitudinal mind-set, skills
decit, as well as psychological factors.
The broad spectrum of denitions creates signicant challenges in identi-
fying and isolating criteria for impairment and for exercising the gatekeeping
function. This lack of clarity combined with the threat of legal liability makes
gatekeeping an unwelcome task for many supervisors of counselors-in-training.
Legal precedents indicate that effective gatekeeping is as much a legal as an ethical
issue.
Two legal cases of particular relevance to the eld of counseling indicate that
the threat of legal liability is indeed real. In the case of Harris v. Blake and the
Board of Trustees of the University of Northern Colorado (1986), Harris a graduate
student, received an unfavorable evaluation from Blake, his practicum instructor,
and was not permitted to enroll in a second practicum. He was subsequently termi-
nated from the program, after which he joined another university, and successfully
obtained a Masters degree in Counseling. Armed with this degree, Harris sued
Blake and the University for discriminating against him unfairly. Given that he
had been dismissed on the evaluation of one faculty member, the need for a re-
view and retention policy that involved more than one member of the faculty was
underscored. Although in the end, Blakes professional judgment was upheld, this
case served as a warning to counselor educators and highlighted the necessity for
justiable and well-designed counselor education evaluation programs.
A second instance of legal liability came about with a case against Louisiana
Tech University (Frame & Stevens-Smith, 1995) for failure to adequately train a
therapist. Initially, a suit was led against a counselor and the clinic for which
the counselor worked. The case further expanded when the institute at which the
counselor had trained was sued. The rationale for this case was that a university
Enhancing Counsling Gatekeeping 403
has an obligation to the public to ensure that a person graduating with a degree is
competent in the area in which the degree is bestowed (Custer, 1994).
Growing concerns regarding the gatekeeping function in the past two decades
have led to various gatekeeping models being presented in counseling and psy-
chology literature. Five of these models will be reviewed next.
BRIEF REVIEW OF FIVE GATEKEEPING MODELS
Dealing with Professional Impairment During Internship
Consistent with their denition of impairment (Lamb et al., 1987; Lamb,
Cochran, & Jackson, 1991), these authors focus on concentrating on behaviors
demonstrated in three areas of professional functioning: professional standards,
skills competency, and personal functioning. Lamb et al. (1987) recommend four
processes in the identication and response to trainee impairment:
1. Reconnaissance and Identication. Supervisors identify areas of concern,
and distinguish between problematic behaviors and impairment. Problem-
atic behaviors could include behaviors demonstrating performance anxi-
ety, or discomfort with clients of diverse ethnic backgrounds. If trainees are
amenable to remediation, such behaviors are not considered impairment.
The authors note eight characteristics of impairment, and an awareness
of these characteristics is helpful in this rst process of the model. These
characteristics are: (a) trainee cannot acknowledge, or understand, or ad-
dress a problematic behavior; (b) the problematic behavior is not a skill
decit and will not improve with further training; (c) the quality of service
offered by the trainee is consistently negatively affected; (d) the prob-
lematic behavior is not restricted to one area of professional functioning;
(e) the problematic behavior has the potential for legal or ethical rami-
cations; (f) a disproportionate amount of attention by training personnel
is required; (g) the trainees behavior does not change despite feedback
and training interventions; (h) the trainees behavior negatively affects the
image of the agency (Lamb, Cochran, & Jackson, 1991, p. 292).
2. Discussion and Consultation. Once a problematic behavior has been iden-
tied, Lamb et al. recommend an explicit discussion of all possible inter-
ventions by all involved training personnel. The importance of decision-
making by a group rather than a single supervisor is emphasized.
3. Implementation and Review. All relevant training personnel meet to re-
view information from all sources. The degree of impairment must be
assessed and nally a specic course of action must be decided upon.
This could range from no further action being taken, to probation, to
404 Bhat
termination. If probation or termination is selected, Lamb and colleagues
caution that due process procedures available to the trainee be reiterated.
Five steps to be taken before a trainee is informed of a dismissal decision
are spelled out in their materials.
4. Anticipating and Responding to Organizational Reaction. The ripple ef-
fects of a dismissal decision are discussed in the fourth process of the
model. Strategies on dealing with the affected trainee, the involved train-
ing personnel, other interns, agency staff and clients are discussed.
Lamb et al.s (1987, 1991) four-process model provides valuable guidelines
to respond to issues of trainee impairment. Although specically focused on the
internship, this model is readily applicable to academic or practicum settings. This
model is one of the early attempts in the counseling profession to address trainee
impairment.
A Model Enhancing Monitoring and Dismissal Processes
Frame and Steven-Smith (1995) outline a three-step monitoring and dismissal
process for counselor educators, implemented in the University of Colorado at
Denver. Prospective students are made aware of the policy through the Student
Handbook even though this may deter students from applying to the program. The
importance of informing students at the outset of review and dismissal procedures
is emphasized. The authors report that since its implementation, there have been
less confrontations or dismissals.
In this model, faculty members evaluate students using the Personal Charac-
teristics Evaluation form at midterm and at semester-end. The three steps relate to
degree of consensus amongst faculty on student impairment and the consequent
severity of the issue. Step 1 involves low evaluations on the form by one faculty
member and could lead to possible remediation. Step 2 involves low evaluations
by two staff members that would lead to denite discussions on remediation. Fi-
nally, low evaluations by three or more faculty members on a student within a
two semester time-frame would lead to review of the suitability of the student to
remain in the counselor education program.
A Student Review and Retention Model
As a consequence of the Harris v. Blake case (1986), a step-by-step student
review and retention policy for Counselor Education programs was introduced
at the University of Northern Colorado (Baldo, Softas-Nall, & Shaw, 1997). The
policy outlines the departments aim to evaluate the academic, professional and
personal development of students, and presents action to be taken if a students
behavior is assessed to be substandard by the faculty. Twenty probation and
Enhancing Counsling Gatekeeping 405
remediation steps are listed so that faculty members are well advised on how to
proceed with an impaired student.
The following advantages of the model are presented by the authors: (1) it
guarantees due process for both student and facultythis being implemented
through every stage of the process thereby preventing miscommunication and also
preventing students from claiming they were not given feedback; (2) it outlines
clear steps to follow and specic actions to takeranging from remediation to
dismissal; (3) it bases decisions on the judgment of the entire faculty; and (4) it
has been implemented with success on two occasions subsequent to the original
case (Baldo, Softas-Nall, & Shaw, 1997). The review and retention policy at the
University of Northern Colorado is given to every graduate counseling student
upon entrance into the program. Students are therefore well aware of the process
from their rst day in the program.
A Process Model
A review of counselor educators responses to impairment within the United
States was undertaken by Bemak, Epp, and Keys (1999), and formed the basis of
their subsequent process model for monitoring and intervening with psycholog-
ically impaired counseling students. Findings indicated that counselor education
programs tend to focus on three areas to evaluate students: (1) academic per-
formance, (2) skills demonstrated in applied classes, and (3) skills demonstrated
during internship/practicum. The rst area was regarded as easy to monitor, but
the second and third areas caused evaluators some concern. The role of evalu-
ator/gatekeeper becomes particularly difcult when students who perform well
academically and have basic counseling skills present with psychological difcul-
ties or personality decits.
Bemak, Epp, and Keys (1999) propose a ve-step process model, the aim
being to evaluate student progress and dismiss impaired students if necessary. The
ve steps are as follows: (1) Clarication and communication of expectations,
with this needing to begin prior to the application process. Departmental policies
on dismissing students for academic as well as non-academic reasons should be
clearly articulated in handbooks and other departmental resources. (2) Consen-
sual agreement on policies and procedures, with this involving the signing of a
contractual agreement by the student indicating acceptance and understanding of
evaluation procedures. The recommendation is that the agreement should cate-
gorically state that a student must be assessed as being free from psychological
impairment by qualied and experienced department assessors if he/she is to con-
tinue in the program. (3) Identication of concerns: once concerns are identied,
they are to be shared with the students faculty advisor and a prompt reviewshould
be undertaken. (4) Feedback and recommendation with the counselor trainee: this
consists of a meeting with the student, student advisor, and the faculty member
406 Bhat
who identied the concern in Step 3. Recommendations for remediation are made
at this step. (5) Monitoring and evaluating progress: the last step in the process
model calls for ongoing monitoring and feedback throughout the course of study.
In case progress is not made, dismissal is identied as a possible option at this
stage.
The authors have implemented this model at one university in the United
States, and while they acknowledge that the model takes time to implement and
requires commitment and cooperation from faculty and on-site and off-site super-
visors, they believe the benets outweigh the costs. The model has advantages
in terms of creating and promoting awareness and clear expectations for students
even before they apply to the program. The model also incorporates due process
into every stage, and formalizes this aspect with a contract.
A Professional Performance Fitness Evaluation Model
This model, developed and utilized at Southwest Texas State University
(SWT), and endorsed in principle by the Texas Association for Counselor Educa-
tion and Supervision (TACES), is presented as a systematic evaluation method
with a formal structure to address student impairment (Lumadue & Duffey,
1999). It features an instrument that was specically designed. based on com-
petencies articulated in the ACA Code of Ethics and Standards of Practice
(1995).
The instrument designed by SWT faculty for this purpose is the Profes-
sional Performance Fitness Evaluation (PPFE). The PPFE utilizes a four-point
rating (N = No opportunity to observe; 0 = does not meet criteria for pro-
gram level; 1 = meets criteria only minimally or inconsistently for program
level; and 2 = meets criteria consistently at program level). The ve major areas
assessed are counseling skills and abilities, professional responsibility, compe-
tence, maturity, and integrity. The instrument presents specic behavioral com-
ponents that dene the competencies expected of the student in each of the
ve areas. Counselor education faculty at SWT successfully addressed a le-
gal challenge to a dismissal in 1998, and attribute that success to their formal
evaluation and due process procedures (Kerl, Garcia, McCullough, & Maxwell,
2002).
The models presented in this section are an important step in the counseling
professions quest for fair and legally defensible methods of evaluating trainee
competence and impairment, and making decisions based on these evaluations.
Developers of gatekeeping models in the future may enhance their procedures by
drawing on resources and research in allied elds. Widening the net to examine
evaluation processes in other elds might provide input of value. Performance
appraisals from the management eld may be one such inter-disciplinary area to
consider.
Enhancing Counsling Gatekeeping 407
DRAWING ON PERFORMANCE APPRAISALS
FOR COUNSELING GATEKEEPING
Over the past fty years, performance appraisals have become rmly es-
tablished as personnel management tools in virtually every organization (Grote,
1996). Some suggest that the process of formally evaluating employees has ex-
isted for centuries (Murphy & Cleveland, 1995). Performance appraisals are well-
researched tools developed by management theorists and organizational psychol-
ogists. In the world of management, no appraisal system is immune to legal
challenges. Performance appraisals, by virtue of having been in the appraisal
business for a long period of time, have adopted strategies to minimize the risk
of legal challenge (Grote, 1996, 2002). Grote advocates seven basic good man-
agement practices to develop sound appraisal systems and minimize the risk of
legal difculties when utilizing performance appraisal systems. These strategies
are as follows:
1. Base the performance appraisal on an analysis of the job.
2. Dene your performance dimensions in behavioral terms and support
assessments with observable, objective evidence.
3. Keep things simple.
4. Monitor and audit for discrimination.
5. Train raters to assess performance accurately and to conduct effective
appraisal decisions.
6. Provide for upper-management review before the appraisal is reviewed
with the individual.
7. Provide some appeal mechanism (Grote, 2002, pp. 1314).
These seven strategies, adapted for use in the counseling profession, could
be of potential value in developing effective gatekeeping procedures in that con-
text. An adaptation of Grotes (2002) seven basic management strategies to the
counseling realm is presented below:
1. Base the counseling trainee evaluation (CTE) on an analysis of the job.
Developing evaluation instruments and processes that focus on standards
set by such professional bodies as the American Counseling Associa-
tion, the British Association for Counselling and Psychotherapy, or the
Canadian Counselling Association is recommended. Specic behaviors
and expected conduct are to be presented in formal evaluation documents
in unequivocal terms. Trait-based rating systems that are not directly re-
lated to specic job responsibilities and have the potential to be inuenced
by rater bias are best avoided (Grote, 1996).
2. Dene performance dimensions on the CTE in behavioral terms and
support assessments with observable, objective evidence. This strategy
minimizes difculties that might arise when abstract attributes are to be
408 Bhat
assessed and such attributes are not dened in behavioral terms. Inter-rater
reliability is also likely to be improved when raters are provided with ex-
amples of the kinds of actions and behavior to expect an individual who
possesses a certain attribute to demonstrate. The inclusion of specic be-
haviors is a feature of the gatekeeping model developed at Southwest Texas
State University (Lumadue &Duffey, 1999). Bernards (1998) Evaluation
of Counselor Trainee Skills Form provides another example of behav-
ioral statements. In the rst set of skills on this form (Relationship and
Attending Skills) supervisors are required to rate trainees on eleven spe-
cic behaviors (e.g., listens carefully and communicates understanding to
the client, is genuine and warm with the client, challenges the client when
appropriate).
Grote (2002) recommends writing a description of what a mas-
ter performer (skilled and effective counselor) in each of the rated
areas would do, and constructing a rating scale that reects how
often the individual being rated performs as a master would (e.g.,
rarely/sometimes/frequently/always).
3. Keep things simple. The rationale for inclusion of assessment categories is
vital and developers of CTE systems must ensure that only attributes that
constitute legitimate job requirements for counselors are included. For
example, leadership is an admirable attribute, but if a counseling trainees
job does not require high amounts of this trait, a trainee should not be
penalized for not demonstrating it.
4. Monitor and audit for discrimination. This is an area that warrants fur-
ther attention from developers of CTE systems. Monitoring and auditing
for discrimination can be achieved by conducting analyses determining
whether there are signicant differences in ratings given to minority group
members versus ratings given to groups as a whole. This process helps
identify any discriminatory evaluation processes in a proactive manner,
before challenges are levied against the CTE. Monitoring for discrimi-
nation in terms of race, ethnicity, culture, gender, age, ability level, and
sexual orientation may all be considered, depending on the demographics
of the group being assessed.
5. Train supervisors to assess performance accurately and conduct effective
evaluation discussions. Ideally, training should be comprehensive and
include topics such as a review of the CTE mechanism, an explanation
of the way ratings are to be assigned, common rating errors, frequently
asked questions by previous supervisors, and a list of red ag areas to
be checked before conducting the evaluation discussion. This is an area
that has not been elaborated in existing gatekeeping models, based on the
assumption that supervisors by virtue of their supervisory position are
capable of conducting evaluations. Increased inter-rater reliability could
Enhancing Counsling Gatekeeping 409
also be addressed through adequate training of supervisors in conducting
evaluations.
Grotes (2002) recommendation is that, in the absence of any compre-
hensive training program for evaluators, at a minimum, at least a one-hour
brieng of evaluators should take place. Evaluators should be reminded
that they are required to (a) be prepared to provide specic examples to
support ratings, and (b) maintain rapport during the discussion and explain
clearly reasons for a low rating. Grote also suggests that giving evaluators
some examples of well-completed forms would help them gain clarity
in what is expected of them. Conducting effective evaluation discussions
requires training as well. The discussion should involve coverage of the
problem behavior(s), and provide specic examples to support evalua-
tions. The trainee should be well informed of the process that follows
the evaluation during such a discussion. It is also advisable to obtain the
trainees signature to conrmthat the discussion and reviewdid take place
(Grote, 1996).
6. Provide for senior supervisor review of evaluations. This step may be of
particular importance to inexperienced supervisors and should be under-
taken before sharing any evaluation with the trainee. Provided a review
with a senior supervisor is not a mere rubber stamp, it could be invalu-
able in picking up evaluations that may have been made in an arbitrary,
capricious, or discriminatory fashion (Grote, 1996). While existing coun-
seling gatekeeping models emphasize the importance of having multiple
evaluators, they do not discuss protecting inexperienced supervisors.
7. Provide formal appeal mechanisms and make supervisees aware of them.
Provision of a formal means of appeal against an evaluation perceived as
unfair empowers the trainee to take action and to have their version of
events heard. It is recommended that CTE forms have a space for trainee
comments, and trainees be encouraged to use it. It is important that the
trainee be informed of the internal appeal process in a detailed manner,
so that any need to go outside of the training environment for redress is
reduced.
These seven strategies adapted from recommendations for legally defen-
sible performance appraisal systems in management (Grote, 1996, 2002) pro-
vide input for future developers of gatekeeping models. Widening the conceptual
net to incorporate appropriate systems from evaluation processes in other elds
could also be benecial. Robust dialogue on this topic amongst counselor edu-
cators, trainees and professional bodies is recommended. On-going research to
demonstrate the efcacy of gatekeeping models would help ensure that a CTE
mechanism is indeed serving to protect the public from impaired or incompetent
counselors.
410 Bhat
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