Is it still necessary to submit a test to the HPCSA, and what is the difference between HPCSA and ASSA requirements?

The short answer is “Yes’’, if a test measures a psychological construct, it must be submitted to the HPCSA for classification.

Employers and/or psychologists and psychometrists need to comply with the provisions of the Employment Equity Act section 8 (a), (b) and (c) which state that the use of Psychological testing and other similar assessments of an employee is prohibited unless the test or assessment being used-

  • Has been scientifically shown to be valid and reliable;
  • Can be applied fairly to all employees;
  • Is not biased against any employee or group;

The Employment Equity Act stipulations hold true for all testing of employees, irrespective if it is a psychological test, or not, being used.

The Act was amended on 25 July 2014 to include that tests should also be certified by the HPCSA, but this was repealed on 14 April 2023. This is now official in the 2023 revision to the EEA: There is no requirement of certification by the HPCSA of psychological tests and similar assessments.

  • According to the Health Professions Act 56 of 1974, all tests measuring a Psychological construct must be submitted to the HPCSA for classification. Tests classified as measuring a psychological construct can only be used by a person registered with the HPCSA.
  • The Professional Practice committee of the Professional Board for Psychology at the HPCSA deals with all matters pertaining to test classification (not evaluation). To be clear, the HPCSA only classifies tests and does not certify tests.

ASSA provides for the voluntary submission of a test for certification. It is recommended that providers submit their test to the HPCSA for classification purposes, and to ASSA for certification. The process of classification (by the HPCSA) and certification (by ASSA) can run simultaneously or in any sequence.

How will composite assessments be dealt with, such as ability test batteries? Must those be submitted separately?

Tests that have been developed and are to be used as part of an assessment battery should be submitted together. If developed and used separately/independently, they can be submitted separately or together.

The review process: Is it a blind review?

The submitter will not know who the reviewers are. Reviewers will obviously know who the publisher is. Submitters can request that certain reviewers be excluded from the review process of a particular test, but can't request a particular reviewer.

Who will the reviewers typically be? How will the risk of conflict of interest be mitigated?

The reviewers are typically individuals who have experience in psychometrics and test evaluation. We also focus on training new reviewers to the required standard for test evaluation. The submitter will not know who the reviewers are. Reviewers will obviously know who the publisher is.

Submitters can request that certain reviewers be excluded from the review process of a particular test, but can't request a particular reviewer. Reviewers are required to sign a non-disclosure agreement. A list of reviewers is available on the ASSA website.

What factors should I keep in mind when intending to use an overseas instrument in the South African context?

  • The Employment Equity Act (EEA) requirements for the use of any measure in the SA context i.e.
    • reliability
    • validity
    • fairness
    • equivalence
    • appropriate norms,which should all be demonstrated with relevant and sufficient data for the SA context.
  • A voluntary, independent test review done on instruments by ASSA incorporates EFPA-based requirements, contained in our ratings documents, to ensure that the instruments meet minimum requirements on all aspects, including SA research or strong motivation in the absence thereof.
  • And, of course, if the construct measured is psychological, then it will have to be classified by the HPCSA.

Will ASSA certify tests that are not psychometric in nature?

The activities of ASSA will apply to all tests and testing, whether or not they are labeled as "psychological tests" or other similar assessments.

While it is understood why ASSA is using the EEA requirements, will this put off those who are working with assessments for use in other contexts? Would ASSA consider adding a sentence or two to indicate that the EEA standards are generally recognised as good and necessary requirements for tests nationally and internationally, so the ASSA requirements apply to all tests used in a range of contexts?

The initial drive and critical driving force behind the establishment of ASSA was to help organisations and practitioners navigate the legal context of testing in the world of work. The use of assessments in other contexts should be a logical next focus.

Is ASSA a statutory body? Do I have to submit my test to ASSA for it to be used in South Africa?

It is important to take note that ASSA is not a statutory body. It is a voluntary non-profit organisation similar to most other assessment evaluation bodies globally. Test submissions are voluntary, as it is in the UK, USA, and Norway, to mention just a few.

The Employment Equity Act (EEA) provides minimum requirements on the use of Psychometrics and other similar assessments in the workplace. ASSA provides for a voluntary evaluation and certification of assessments by ASSA to be EEA compliant. However, the onus still lies on assessment practitioners around best practices and the ethical use of people assessments in the workplace. South Africa has a very good legislative framework governing assessment and testing, and it is up to assessment practitioners, businesses, as well as the public to ensure that it works as intended.

What is an obsolete test?

The HPCSA provides a list of tests that are classified as "Psychological Tests". However, the HPCSA makes it very clear that:

"Psychology professionals should note that although the psychological tests contained in the list below have been classified, the onus rests on the psychology professional to use the tests in fair and ethical ways. According to Annexure 12 of the Ethical Rules of Conduct, ethical assessment practice includes ensuring that the tests used are appropriate for the purpose that they are applied, are psychometrically sound, and that their content, construct coverage, and norms are both appropriate for the target population and are up to date (i.e., the tests are not obsolete)." - [link]

In considering the ethical requirements involved in the assessment of individuals, it is important to ensure that decisions or recommendations that are based on test results are valid and not outdated for the purpose for which they are intended. An obsolete test may be a test where revisions in terms of reliability, validity, fairness, equivalence, and appropriate norms have not been done recently (i.e. in the last ~10 years), and the test may thus be outdated for the purpose for which it was intended. In the ASSA evaluation, norms between 10 and 19 years old are considered adequate – i.e. meet the minimum requirement. The onus lies on practitioners to evaluate if a test may or may not be obsolete, and the onus lies on test distributors to ensure that their test remains updated.

What steps must I take to register my test for an ASSA review?

The ground principle for developers and practitioners should be to adhere to the applicable EFPA (European Federation of Psychologists’ Associations) Guidelines, the ASSA (Assessment Standards South Africa) Test Review Form (rating items and options), and ASSA’s checklist of topics and content guiding documentation submission. Please also see the information on the Assessment Standards website, under the heading Test Review Process. A pre-submission checklist is also provided to guide the process.

The critical first step is for the applicant to use the ASTRA interface on ASSA’s website to lodge an application online. This entails registering as a user, completing ASSA’s checklist of information that needs to be submitted, uploading proof of payment, and uploading all submitted documentation.

Please refer to the document on the website titled Critical Steps for Test Submission for more detailed information on the test submission process.

Who can I contact at the HPCSA for more information on test classification?

The person to contact is Puleng Pela: PulengP@hpcsa.co.za and CC Portia Khati: PortiaK@hpcsa.co.za