About PsychologyClick to copy link. Show The College of Psychologists of Ontario regulates the profession of psychology in Ontario. Members of the College are regulated professionals and are the only persons authorized to practice psychology in the province. Psychologists and Psychological Associates are members of the College. The College is not a university, community college, or school. Instead, its mandate is to protect the interests of the public by ensuring that consumers receive competent and ethical professional psychological services from qualified providers. What is a Regulated Professional? Click to copy link. Regulated professionals are required by law to deliver professional services competently and ethically. They are accountable to the public, through their professional regulatory body, for their professional behaviour and activities. As members of the College of Psychologists of Ontario, Psychologists and Psychological Associates must meet rigorous professional entry requirements, adhere to prescribed standards, guidelines, and ethical principles and participate in quality assurance activities to continually update and improve their knowledge and skill. In contrast, the College has no authority over unregulated service providers. There is no regulatory body with the legal authority to set minimum levels of education, training, and competence or to establish and monitor professional and ethical standards of conduct. There is no professional regulatory body responsible to protect your interests and hold unregulated providers accountable for the services you receive. What do Psychologists and Psychological Associates do? Click to copy link. Only members of the College of Psychologists of Ontario may use the title ‘Psychologist’ or ‘Psychological Associate’; use the terms ‘psychology’ or ‘psychological’ in any description of services offered or provided, or hold themselves out to be a Psychologist or Psychological Associate. Psychologists and psychological associates respectively may also identify themselves with the designation C.Psych. or C.Psych.Assoc. after their names. To qualify for professional registration to practise psychology requires successful completion of graduate education and training in professional psychology, supervised professional experience, and examinations. A member of the College is required to practise in accordance with applicable legislation, regulations, standards of conduct, professional guidelines, and professional codes of ethics. Psychologists and Psychological Associates are trained in the assessment, treatment, and prevention of behavioural and mental conditions. They diagnose neuropsychological disorders and dysfunctions as well as psychotic, neurotic and personality disorders and dysfunctions. In addition, Psychologists and Psychological Associates use a variety of approaches directed toward the maintenance and enhancement of physical, intellectual, emotional, social and interpersonal functioning. Psychologists and Psychological Associates usually focus their practice in specific areas such as clinical psychology, counselling psychology, clinical neuropsychology; school psychology; correctional/forensic psychology; health psychology; rehabilitation psychology; or industrial/organizational psychology. Within these areas, a Psychologist or Psychological Associate may work with a variety of individual client populations such as children, adolescents, adults or seniors, or may focus their attention on families, couples, or organizations. They work in a range of settings including schools, hospitals, industry, social service agencies, rehabilitation facilities, and correctional facilities. Many Psychologists and Psychological Associates have their own private practice. A Psychologist or Psychological Associate who holds a certificate of registration authorizing autonomous practice may provide services without supervision, within his or her area of competence, and may charge a fee for these services. While most members of the College have no explicit term, condition, or limitation on their certificates of registration, some do and must practice in accordance with any such restriction. The College maintains a register of all current members. Information about an individual Psychologist or Psychological Associate may be found in the searchable Public Register or obtained from the College by telephone 416-961-8817or by e-mail: . Occasionally clients of Psychologists and Psychological Associates need to have forms completed and signed by their treating professional in order to obtain insurance reimbursement for psychological services or to qualify for some other benefit or service from an insurer or government agency. Normally both Psychologists and Psychological Associates may complete and sign such forms. If there are any questions or difficulties in having such forms accepted, please contact the College for guidance. What is the difference between Psychologists and Psychological Associates? Click to copy link. The difference is in how they are trained. Both have completed an undergraduate degree and have gone on to complete a graduate degree in psychology. Psychological Associates have completed a masters level degree in psychology (e.g. M.A., M.Sc., M.Ps., M.Ed.), which is then followed by four years of experience working in the scope of practice of psychology. Psychologists have completed a doctoral level degree in psychology (Ph.D., Psy.D., Ed.D., D.Psy.) which typically includes a one-year internship. Both Psychologists and Psychological Associates have then completed at least one additional year of formal supervised experience approved by the College and passed the three examinations required by the College. The profession of psychology in Ontario has a single scope of practice. There is no distinction made in the legislation or in the regulations between Psychologists and Psychological Associates with respect to scope of practice or with respect to controlled/authorized acts. All members must have knowledge and skills respecting interpersonal relationships, assessment and evaluation, intervention and consultation, understanding and applying research to professional practice and knowing and applying professional ethics, standards and relevant legislation to professional practice. Every member of the College, with the exception of individuals whose practice is limited to Industrial/Organizational Psychology, must be competent to formulate and communicate a psychological diagnosis. *Note: In June 2009, the Federal/Provincial Agreement on Internal Trade was signed and in December 2009, the Ontario Labour Mobility Act (2009) was enacted. As a result of this legislation, the College must offer registration as a Psychologist to individuals who have been registered as Psychologists in other Canadian jurisdictions, regardless of the level of their graduate degree in psychology. There are some Canadian jurisdictions that award the title Psychologist to individuals at the Masters, rather than Doctoral level. The recent legislation requires that the College recognize this title for these individuals. Therefore, while the majority of psychologists and psychological associates in Ontario will have the differential training and experience described above, there are some Psychologists, who have come to Ontario from another Canadian jurisdiction, who may have a Masters degree. Members of the College are required to indicate their degree and title in any professional correspondence, report or promotional information. In summary, both Psychologists and Psychological Associates are members of the College and are qualified psychological practitioners in the province of Ontario. Questions? Questions regarding Psychologists and Psychological Associates or other inquiries related to the regulation and practice of psychology in Ontario may be directed to the College: The College of Psychologists of Ontario Applied Behaviour Analysis (ABA)What is Applied Behaviour Analysis (ABA)? Click to copy link. Applied Behavior Analysis (ABA) is the application of the science of learning to understand and improve behavior that is meaningful to the person and those around them. ABA considers how the environment impacts learning. The term behaviour refers to anything a person says or does, including skills and actions needed to talk, play, and live. Behavior can also be private (e.g., thoughts and feelings). ABA can help increase helpful or functional skills (e.g., communication) and/or decrease behaviours that are harmful or interfere with learning (e.g., self-injury). ABA intervention uses evidence-based procedures such as positive reinforcement to address a client’s concerns and needs and to reduce interfering behaviour and increase desirable behaviour. Behaviour Analysts practice in a variety of settings with many different client populations. Resources:
Why are Applied Behaviour Analysts being regulated? Click to copy link. In 2017, the Minister of Health and Long-Term Care asked the Health Professions Regulatory Advisory Council (HPRAC) to provide advice on:
In HPRAC’s January 2018 report to the Minister of Health and Long-Term Care, Applied Behaviour Analysis: Risk of Harm and Oversight, it concluded:
With respect to oversight, HPRAC recommended the following:
To protect the public from risk of harm, once regulated Behaviour Analysts who supervise and/or deliver ABA interventions will have to meet clearly defined standards. These standards will include having the necessary knowledge, skills, and judgement to meet practice requirements and to be allowed to use the regulated title “Behaviour Analyst”. What does it mean when a profession is regulated? Click to copy link. Anyone who wants to practise a regulated health profession in Ontario, i.e., psychologists, psychological associates, physicians, nurses, dentists, occupational therapists etc., and now, Behaviour Analysts, must be registered with, and be accountable to, a health regulatory College. A College is not a university, community college, or school. Instead, its mandate is to protect the interests of the public by ensuring that clients receive competent and ethical professional services from qualified providers. Ontario Health Regulators includes the 26 health regulatory Colleges in Ontario, including the College of Psychologists of Ontario. To learn more about how and why health professions are regulated in Ontario, visit their website. How does regulation of Behaviour Analysts protect you? Click to copy link. Regulated professionals are required, by law, to deliver professional services competently and ethically. They are accountable to the public, through their regulatory body, for their professional behaviour and activities. Once regulated, Behaviour Analysts will have to meet rigorous professional entry requirements, adhere to prescribed standards, guidelines and ethical principles and participate in quality assurance activities to continually update and improve their knowledge and skill. Complaints and discipline processes hold professionals accountable when a client, or other member of the public, believes that the standards may have been breached. In contrast, the College has no authority over unregulated service providers. There is no regulatory body with the authority to set minimum levels of education, training, and competence or to establish and monitor professional and ethical standards of conduct. There is no professional regulatory body responsible to protect your interests and hold unregulated providers accountable for the services you receive. What does the new legislation do? Click to copy link. On June 3, 2021, the enabling legislation to authorize the College of Psychologists of Ontario to regulate the profession of Applied Behaviour Analysis (ABA), Bill 283, Advancing Oversight and Planning in Ontario’s Health System Act, 2021 received Royal Assent. Included in Schedule 4 of this Bill is the legislative authority for the College to regulate the profession of Applied Behaviour Analysis. On a day to be named, this legislation will be proclaimed by the government and will repeal the Psychology Act, 1991 to replace it with the Psychology and Applied Behaviour Analysis Act, 2021. The new Act establishes the regulation of two separate and distinct professions, Psychology and Applied Behaviour Analysis within one College. The current College of Psychologists of Ontario will be the regulator for both professions and will be renamed the College of Psychologists and Behaviour Analysts of Ontario to reflect its expanded role. The legislation maintains the regulatory framework for current members, Psychologists and Psychological Associates, but additionally:
Why is ABA being regulated by the College of Psychologists of Ontario? Click to copy link. In 2017, the Health Professions Regulatory Advisory Council (HPRAC), at the request of the then Minister of Health and Long-Term Care, undertook to review Applied Behavioural Analysis; its potential for harm and need for regulation. In response to a request for information, the College submitted a letter which stated, in part, that, “Should ABA regulation proceed in Ontario, the Council of the College of Psychologists is prepared to undertake this process within its governance structure”. On September 19, 2019, the College received a letter from Minister Todd Smith of the Ministry of Children, Community and Social Services and Minister Christine Elliott of the Ministry of Health inviting the College to confirm its interest in undertaking the regulation of ABA as part of its governance structure. In their letter, the Ministers state that, “Strengthening the oversight of behavioural clinicians will protect vulnerable Ontarians from risk of harm and set standard expectations for professional standards and educational requirements for ABA providers across the province. It will also support families in finding qualified providers, and making complaints about providers, if necessary. Our ministries would like to begin with regulating those who are in a supervisory role, and we envision that this will be broadened to include front-line clinicians over time.” On September 27, 2019, the Council of the College of Psychologists passed a motion confirming the offer to undertake the regulation of ABA within its governance structure. Click to copy link. The College is drafting regulations to be made under the new Act as well as by-law and policy changes that will be necessary to support the regulation of Behaviour Analysts. This work must be completed before the Act can be fully proclaimed by the government. The new Act and any other legislative changes will come into force on a day to be named by proclamation of the Lieutenant Governor. Who will be registered with the College? Click to copy link. Initially, those who practise applied behaviour analysis providing clinical oversight of ABA interventions, or clinical supervisors, must register with the College. Clinical supervisors are those who provide clinical direction and supervision of ABA activities, which include behaviour assessment, designing an intervention plan, implementing intervention plans, and monitoring and evaluating the plans. On the day the new Act is proclaimed, and going forward, only those who have registered with the College will have access to the restricted title “Behaviour Analyst”. At this time, front line providers who deliver ABA interventions directly to a client or caregiver and are accountable to a Behaviour Analyst clinical supervisor are not proposed to be regulated. When will the College begin to accept applications? Click to copy link. The College does not yet have a definite date when it will begin to accept applications but expects it to be before the new Psychology and Applied Behaviour Analysis Act, 2021 is proclaimed. That is, pre-registration will begin when the registration requirements are finalized, and the regulation-making process nears completion. At that time, Behaviour Analysts currently in practice and new graduates who are completing a program in applied behaviour analysis, and who meet the registration requirements, will be able to apply to the College. The goal of the pre-registration period is to ensure that qualified Behaviour Analysts can continue to practice and provide services to their clients on the date of proclamation and after, ensuring continuity of care. Where can I get more information? Click to copy link. The College will update its website as more information becomes available. You can also subscribe to the College’s e-newsletter HeadLines to receive updates to your inbox. I am a Psychologist/Psychological Associate; how will adding a new profession to the College affect my College membership? Click to copy link. For most current members of the College, adding the profession of Applied Behaviour Analysis to the College will have little or no effect. The College will regulate the two professions separately, therefore Psychologists and Psychological Associates should not see any change in their interactions with the College with respect to their practice or expectations of the College. Behaviour Analysts will have their own standards of practice, quality assurance program and registration requirements. The current Professional Misconduct, Advertising and Quality Assurance Regulations will be revised so that they apply to the practice of Applied Behaviour Analysis as well as Psychology. The College Council will be enlarged and both Council and Committees will be made up of Psychologists, Psychological Associates, Behaviour Analysts and public members appointed by the government. Decisions made by the College’s statutory committees will rely on the expertise of members of both professions and the public members who participate on each Committee. There are members of the College who may also want to register as Behaviour Analysts in order to be able to use the restricted title “Behaviour Analyst”. They will hold two certificates of registration: one authorizing the practice of Psychology and one authorizing the practice of Applied Behaviour Analysis. These members will be expected to meet the College’s registration criteria and practice expectations with respect to both professions. Will the College be closing the Master’s level registration for psychology when it adds Behaviour Analysts? Click to copy link. There is no connection between the regulation of Behaviour Analysts and the closure of master’s level registration for the practice of psychology. Any activity related to the closure of master’s level registration will be done separate and apart from activities undertaken to begin the regulation of Behaviour Analysts. What will be restricted; the title “Behaviour Analyst” or the activities related to Applied Behaviour Analysis? Click to copy link. The scope of practice or activities that a Behaviour Analyst performs when providing services to a client are not Controlled Acts or restricted activities. They are therefore, in the public domain. If one is not registered with the College, one must be aware of the restrictions within the Act regarding how one refers to the services being offered (refer to the following question for more information about Controlled Acts). Once the Psychology and Applied Behaviour Analysis Act, 2021 is proclaimed, the title “Behaviour Analyst” will be a restricted title that can only be used by individuals registered with the College as Behaviour Analysts. Members registered as Behaviour Analysts may also refer to any earned certification they may have that would assist the public in understanding their qualifications as a regulated health provider registered with the College. Non-members using the title “Behaviour Analyst” or indicate any certification or designation or communicate in any way that could be considered as holding oneself out as a person who is qualified to practice as a Behaviour Analyst, could be in violation of the Act. What are Controlled Acts? Click to copy link. Controlled Acts are health care activities or interventions that are considered to be potentially harmful if performed by unqualified persons. Some examples of Controlled Acts are administering a substance by injection, setting a broken bone, dispensing a drug, prescribing glasses, performing a surgical procedure, managing the delivery of a baby, and applying a form of energy. The full list of the 14 Controlled Acts may be found in section 27 of the Regulated Health Professions Act, 1991 (RHPA). Due to the potential for harm, a Controlled Act may only be performed by a regulated health professional who is authorized, in legislation, to do so. Not all regulated health professions are authorized to perform Controlled Acts. Each profession specific act, e.g., the Medicine Act, 1991, Pharmacy Act, 1991, Psychology Act, 1991, or Nursing Act, 1991, etc., prescribes which, if any, Controlled Acts may be performed by members of that profession. Will Behaviour Analysts be authorized to perform any of the Controlled Acts, including #7, applying or ordering the application of a form of energy? Click to copy link. No. Behaviour Analysts will not be authorized to perform any of the Controlled Acts, including the application of energy in the form of electricity for aversive conditioning. As noted, a Controlled Act may only be performed by those professions with the authority specified in legislation. The yet to be proclaimed profession specific act related to Applied Behaviour Analysis; the Psychology and Applied Behaviour Analysis Act, 2021, does not authorize Behaviour Analysts to perform any Controlled Acts. Note: This prohibition on performing any of the Controlled Acts is currently in place for individuals practicing Applied Behaviour Analysis or any form of behaviour therapy and will continue with the proclamation of the new Act. I am a practitioner registered with another College (e.g.,College of Audiologists and Speech-Language Pathologists, College of Occupational Therapists of Ontario, College of Nurses of Ontario), and I also practise Applied Behaviour Analysis. Will I have to register with the College of Psychologists and Behaviour Analysts? Click to copy link. Many professionals registered with other regulatory colleges, including nurses, social workers, occupational therapists, speech language pathologists, educators, and others, may use behavioural techniques in their practice. As noted above, these will remain in the public domain and are not restricted activities. If, however, a practitioner wishes to use the title “Behaviour Analyst” or indicate any certification or designation or communicate in any way that could be considered as holding themself out as a person who is qualified to practice as a Behaviour Analyst, they will be required to also register with the College of Psychologists and Behaviour Analysts of Ontario. Dual registration occurs often in many sectors as professionals may hold certificates of registration with more than one regulator to practice multiple professions. It is permissible, and may be necessary, for a Behaviour Analyst to be registered with more than one regulatory College. In this same vein, Psychologists and Psychological Associates, that want to be able to use the restricted title “Behaviour Analyst”, must meet the registration requirements to obtain a second certificate of registration authorizing practice as a Behaviour Analyst. Will Behaviour Analysts be required to carry professional liability insurance? Click to copy link. Professional liability insurance coverage is required for all regulated health professionals. Behaviour Analysts will be required to hold or otherwise be covered by professional liability insurance in all settings in which they practise. Insurance must be in place upon registration and confirmed annually with the College during the annual renewal process. A Behaviour Analyst who is employed by an organization may be insured under their employer’s professional liability insurance policy so long as it meets the minimum requirements to be set by the College. It is important to know however, that one’s insurance through the workplace covers only the services provided while working for that employer. If an employed Behaviour Analyst also provides services to clients outside of their employment, they must also obtain individual professional liability insurance. Professional liability insurance can be obtained through associations, insurance companies and other organizations and coverage must be in accordance with the College By-laws. Becoming a MemberCan you provide me with an overview of College’s registration process? When is the deadline to submit my application for registration with the College? Click to copy link. There isn’t a deadline for receipt of Supervised Practice or Interim Autonomous Practice applications. Applications are reviewed on an on-going basis throughout the year. Once the College has received your completed application form, the application fee, and all supporting documentation, your application is ready for review. The review process is usually completed in four to six weeks. How long does the application process take? Click to copy link. Once the College has received your completed application form, the application fee, and all supporting documentation, your application is ready for review. The review process is usually completed in four to six weeks. After the review, if the Registrar has any doubts or concerns about your meeting the academic or good character requirements, or about your training in your proposed area(s) of practice, your application is referred to the Registration Committee for further review. You will be notified of this referral and given 30 days to submit any further information to assist the Registration Committee in its review. The Registration Committee meets about every six weeks throughout the year. The application review will be scheduled for the next available meeting after the 30-day notice period. Once the review of your application is complete, you will receive a letter confirming the outcome. How will I know when my application is complete and ready for review? Click to copy link. Applicants are encouraged to submit their completed application form and supporting documentation as soon as possible. You can track the status of your application using the Checklist feature in your on-line application. This Checklist will tell you which documents have been received and which are outstanding. If you have questions about the status of your application, you can email your questions using the same on-line application portal. I’ve already requested that my academic transcripts and supervisor’s agreement forms be submitted to the College. What if the College receives these supporting documents before my application? Click to copy link. Any supporting documentation that arrives at the College before your application will be filed according to your name. Once your application arrives, the supporting documentation will be included with it. How long will the College keep my application? Click to copy link. Once the College receives your application and fee, you have 24 months to submit all the supporting documentation. The application will expire after 24 months unless a certificate of registration or a confirmation of eligibility has been issued. At this point, the application and all supporting documents will be destroyed. The application fee is non-refundable. I’ve completed my degree requirements and would like to apply for registration, but my convocation is not scheduled to take place until much later. My university transcript will not indicate that my degree has been awarded until after my convocation date, is this acceptable? Click to copy link. The College will accept a pre-convocation transcript in order to review your application if you have completed all requirements for your degree but have not yet convocated. The transcript must be accompanied by a signed letter from the Senate or Registrar of the University or an appropriate Department of Psychology designate such as the Director of Clinical Training. The letter must confirm the date that your degree requirements were successfully completed. The letter must be submitted to the College directly from the University. The College will not accept a student copy of the letter. Universities may send official electronic letters directly to . I have a sealed envelope containing my official academic transcript that my University issued directly to me. Will the College accept this transcript? Click to copy link. No. The College will only accept academic transcripts sent to the College directly from a University. It is your responsibility to contact the University and ask them to send a copy of the official academic transcript directly to the College. Universities may send official electronic transcripts directly to . Will the College give me credit for any supervised work that I began before my application was approved? Click to copy link. The College will approve the start date for supervised practice based upon the date that both your Primary and Alternate Supervisors confirm that their supervision of your work began, or the date that the last supporting document for your application was received, whichever date is later. I don’t yet have a job or supervisors. Do I need to be working before I can apply for registration? Click to copy link. No. You can apply for supervised practice, even if you are not yet working in Ontario. You should submit the application form, including the fee and supporting documentation. The College understands that you will not be able to complete the section titled “Authorized Supervised Practice” and the Primary and Alternate Supervisors’ Agreement Forms. The College will proceed to evaluate your academic credentials. If your application is found to be acceptable, the Registrar will wait to issue you the certificate for supervised practice until you have found an appropriate work setting and named two supervisors. In the meantime, if your application is approved, you can choose to take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE). Do I have to complete my period of authorized supervised practice in Ontario? Click to copy link. Yes. Supervised practice is intended to prepare you to practice psychology in Ontario. It must be completed here under the College’s Standards of Professional Conduct and Ontario legislation. The College’s mandate is to protect the public of Ontario. Psychological services provided in another province or state follow the rules of the regulatory board for psychology in that province or state only. Will the College help me to find a job and supervisors? Click to copy link. You are responsible for finding a suitable job as well as your Primary and Alternate Supervisors. Generally, once you find a job, your employer will have a member(s) of the College on site or who consults to the organization who can supervise your work. The College’s online Public Register (www.cpo.on.ca), may be of assistance in your search for supervisors. The Ontario Psychological Association (www.psych.on.ca) provides a listing of its members who may be available to provide supervision. What method of payment does the College accept for the application fee? Click to copy link. The application fee may be paid by credit card on the online application site. Can I fax or e-mail you my application form? Click to copy link. The College does not accept applications by email or fax. Please use the online application site. How can I get a copy of all of the documentation in my registration file? Click to copy link. You may receive a copy of all information and each document that the College has that is relevant to your application. Please note that the College does not return original documents however, you may ask for a copy of the documents in your registration file. To obtain a copy of your registration file you must makea written request to the College either in-person, by mail, or by e-mail. There is a charge of 20¢ per page for this. Upon receiving the written request, registration staff will determine the number of pages in the record and advise you of the cost before proceeding. I have my master’s degree, but I haven’t completed the required post-master’s work experience yet. Can I apply for registration as a Psychological Associate now? Click to copy link. Yes. You may submit an application along with all the supporting documentation, including the fee. At this time, you will not be able to complete the section of the application form titled “Authorized Supervised Practice” and the Primary and Alternate Supervisors’ Agreement Forms. Only your academic credentials will be reviewed until you have completed the required post-master’s work experience. In the meantime, if your academic credentials are approved, you may take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE). I meet with the parents/guardians of the children and adolescents I see; should I include families on my Declaration of Competence? Click to copy link. To include families on your Declaration of Competence, you must be engaged in family assessment and family intervention during your supervised practice period. In such cases, the family would be the primary client. If however, you will not be providing direct services to families, but instead will see parents or families in the context of your work with the children or adolescents within the family, then it is not appropriate to indicate families on your Declaration of Competence. The College recognizes that working with children and adolescents as declared client groups often involves meetings with parents or families. It is important to distinguish between families as a specific client group with whom one works, and family involvement in the context of working with the children or adolescents in the family. What is the Registration Committee? Click to copy link. The Registration Committee is a statutory committee under the Health Professions Procedural Code. In accordance with the By-laws, the Registration Committee is composed of at least three members of the Council who are members of the College, at least two public members of the Council, and at least two members of the College who are not members of the Council. Under the Code, if an applicant meets the qualifications and requirements, the Registrar may issue a certificate of registration. However, if the applicant does not meet the qualifications and requirements, the Registrar refers the application to the Registration Committee for a determination. It is then the duty of a panel of the Registration Committee to determine the eligibility of the applicant for a certificate of registration. In addition, applicants may be referred to the Registration Committee for advice and recommendations as to how they can bring themselves to meet the registration requirements and to acquire and demonstrate the knowledge and skills required for their declared area of competence. The Committee is divided into two panels. One Co-Chair of the Committee serves on each of the panels. The Registration Committee meets approximately every other month. For the convenience of applicants wishing to submit information to the Committee, meeting dates are posted on the College’s website. Submissions must be received 10 days in advance of a meeting. I disagree with a decision from the Registration Committee, what can I do? Click to copy link. Should you have any questions or concerns about a Registration Committee decision, you may contact the College directly to speak with a Registration Assistant, or you may e-mail the College at If you disagree with a decision of the Registration Committee you have the right to appeal the decision to the Health Professions Appeal and Review Board (HPARB). You must write directly to HPARB within 30 days of receiving the Registration Committee’s decision letter. HPARB may be contacted at the address below: Health Professions Appeal and Review Board Telephone: 416-327-8512 Ontario Regulation 74/15 - RegistrationWhat is the new Registration Regulation? Click to copy link. The new regulation (O. Reg. 74/15) replaces O. Reg. 533/98 and revises and updates the requirements for registration with the College. The new regulation reflects changes that were approved by Council and submitted to the Ontario government for approval in October 2013. When does the new Registration Regulation come into effect? Click to copy link. The revised Registration Regulation became effective on April 7, 2015. What changes are included in the new regulation? Click to copy link. The most significant changes are that:
How will applicants be affected by the changes to the Registration Regulation? Click to copy link.
Will the new regulation affect Psychologists and Psychological Associates already registered in another Canadian province who apply to register in Ontario (labour mobility applicants)? Click to copy link. Yes – such applicants will now be required to pass the College’s Jurisprudence and Ethics Examination (JEE) as a requirement for obtaining a Certificate of Registration for Autonomous Practice. Qualified applicants will initially be able to register for and hold a Certificate for Interim Autonomous Practice for up to 12 months, which will enable them to practise while they prepare for and write the JEE. For more information, please feel free to contact the College at if have any questions Registration ExaminationsWhen can I take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE)? Do I need to have a certificate to be able to take these exams? Click to copy link. Once your application for registration has been approved by the College, you will be provided with details on how to register to take the EPPP and the JEE. While you do not need to hold a certificate authorizing supervised practice in order to be eligible to take these examinations; your application for registration must have been approved by the College. The EPPP is a computer based multiple choice examination and is available throughout the year at various designated computer testing centres throughout Canada and the United States. The JEE is a multiple-choice examination offered on-line two times per year – each Spring and each Fall. Upcoming JEE
dates are posted on the College’s website here. Which exam do I take first? Click to copy link. You may take the EPPP and the JEE in any order that you prefer. The oral examination is the last step in the registration process. To be invited to attend an oral examination, you must have passed the EPPP and JEE and fulfilled all other requirements, including the period of authorized supervised practice. I recently took the JEE/EPPP, can I call or e-mail the College to receive my exam score? Click to copy link. No. College staff are not permitted to convey exam results over the telephone, fax or via e-mail. Exam results are only sent to candidates via mail. JEE results are mailed out approximately 6 weeks following the examination, and EPPP results are mailed out approximately 4 weeks following an examination. If you are concerned because you have not yet received your exam results, please contact the College to enquire whether your score has been mailed out to you yet. How do I sign up to take the EPPP, and the JEE? Click to copy link. Once your application for registration has been approved by the College, you will be provided with details on how to register to take the EPPP and the JEE. Where can I find information on how to study for the EPPP ? Click to copy link. The College does not recommend any particular method of preparation for the EPPP. Some candidates find materials published by commercial examination study companies to be helpful, but these commercial study materials are not endorsed by the College. Information on how to prepare for the EPPP, including a computer based practice exam, can be found on the website of the Association of State and Provincial Psychology Boards (ASPPB) at www.asppb.net. I have already passed the EPPP; do I need to re-take this examination as part of Ontario’s registration process? Click to copy link. Applicants who took the EPPP as part of the registration/licensure requirements in another jurisdiction, and who received a scaled score of at least 500 or a percentage score of at least 70% are not required to re-take this examination. Please arrange to have your EPPP results forwarded directly to the College of Psychologists of Ontario by contacting the Association of State and Provincial Psychology Boards (ASPPB) at the following link: http://www.asppb.net/?page=ScoreTransfer How do I prepare for the JEE? How well do candidates usually do on the JEE? Click to copy link. Candidates generally perform very well on the JEE. Ontario-educated candidates tend to do better than those candidates who did not receive their education in Ontario. The pass rate on the JEE over the past 11 years has been 89%. Only 6% of candidates have scored under 60%. The cut-score is generally about 66%, ranging from 62% to 69% for any one particular administration of the JEE. The highest score on each individual exam ranges from 86% to 98% and the lowest score ranges from 35% to 65%. The average score for the JEE over the past 11 years is 76%. Of particular note is that the pass rate observed on the JEE, both for Ontario educated and internationally educated candidates, is comparable to that of other high stakes professional licensing examinations. Why is the pass rate of the JEE lower for internationally educated candidates? Click to copy link. Internationally educated candidates are a very diverse group from many different countries. Many factors affect their success on the JEE, including language of education and language of clinical practice, years since graduation, and practice patterns in the country of education, that is, whether they are similar to Canada or different. Familiarity with the exam format may also affect the pass rate. In other words, candidates who have experienced multiple-choice exams during their education program may perform better than those candidates who have not experienced multiple-choice exams. Why doesn’t the College adjust the pass rate of the JEE so that the same percentage of candidates passes each time? Click to copy link. The leading psychometric standard-setting body, the American Educational Research Association (AERA), specifically recommends that professional licensing examinations not use a “norm-reference approach” – that is, adjusting an examination’s pass rate so that a specified percentage of candidates pass each time. Standard 11.16 says
How long will it take to receive my JEE result? Click to copy link. You can expect to receive your JEE score approximately 6 weeks after taking the examination. It takes approximately 1-2 weeks to record and verify all candidate’s scores. Then, the Jurisprudence and Ethics Examination Committee (JEEC) begins the process of psychometric analysis of items and setting the passpoint for that particular examination. The Registration Guidelines outline the procedure used by the JEEC to set the passpoint. This process takes approximately 1-2 weeks to be completed. Once the exam passpoint has been set and individual results have been verified, College staff prepare each candidate’s notification for mail out and this process takes approximately 1-2 weeks to be completed. College staff are not permitted to convey exam results over the telephone, fax, or via e-mail. Does the College provide feedback on performance within specific areas of the blueprint of the JEE? Click to copy link. The College does not provide feedback regarding a candidate’s performance within specific areas of the blueprint of the JEE or make recommendations for remediation. Only the total score that the candidate achieved is provided, along with the cut-score, mean, and standard deviation. The JEE is a professional licensing exam. Professional licensing exams are used to evaluate knowledge, skills, and abilities (i.e. competence) required to practise a profession at an entry-level, in the interest of the protection of the public. These types of examinations are not designed or intended to provide feedback to candidates. In this case, the JEE is used to evaluate knowledge of jurisprudence, ethics, and standards related to the practice of psychology in Ontario. The reliability of the results of any exam is strongly related to the number of items (questions) on the exam. Similarly, the reliability of any information provided to candidates related to scales within the exam is related to the number of items within that scale. Given the JEE Examination Blueprint (as outlined in the Registration Guidelines), some categories may have as few as four to seven items. When there is a small number of items in a scale the reliability and also validity of any report based on these scales would be questionable as feedback to the candidate. How do I prepare for the oral exam? How do I request an accommodation for taking the College’s examinations? Click to copy link. Candidates who have special requirements arising from documented impairments or disabilities may request accommodations in taking any of the College’s required examinations. The College’s Examination Accommodation Policy is found in the Registration Guidelines, and the forms required for requesting an accommodation are found in the application for registration. If you have a question about requesting an examination accommodation you may contact for assistance. Where can I find the examination accommodation request forms? Click to copy link. The forms required for requesting an examination accommodation are found in either the application for supervised practice or the application for interim autonomous practice. How to Apply If you have a question about completing the examination accommodation forms you may contact for assistance. When should I submit my request for an examination accommodation? Click to copy link. You may submit your request for an examination accommodation at the same time that you apply for registration with the College or you may submit your request later if necessary. In all cases, the College’s examination accommodation request form, and documentation, either from your regulated health care professional or the university from which you graduated, must be submitted to the College at least 60 calendar days in advance of an examination administration in order to allow sufficient time for your request to be reviewed and for accommodations to be arranged. When will the College let me know if my examination accommodation request has been approved? Click to copy link. Exam candidates requesting accommodation will be advised of the College’s decision within ten (10) business days of the submission date, unless more information is needed to effectively evaluate the accommodation request. Do I need to re-apply for an examination accommodation before I can re-take an examination? Click to copy link. A candidate who has applied and has been granted examination accommodation for a permanent or long-term disability will not be required to re-apply for accommodation for subsequent attempts but must confirm to the College that accommodations are still required. If the request was related to a temporary condition (e.g. recent injury or pregnancy-related conditions) or if five years have passed since the initial accommodation request, the College may request updated information confirming the continued need for accommodation. When re-applying to take the JEE, the College’s JEE Registration Form will require you to indicate whether you need accommodations, and if so to indicate whether you have already submitted the necessary accommodation request form. When re-applying to take the EPPP, the ASPPB’s candidate request form will require you to indicate whether you need accommodations. If the accommodation that you require has changed in any way from what was previously granted, you may be required to re-apply. Please contact for assistance. Applicants Educated Outside Canada or the USACan I begin the application process before I move to Canada? How do I go about having my credentials assessed? Click to copy link. If your degrees are from a university outside of Canada or the United States they must be evaluated to determine if they are comparable in level to a degree from a Canadian university. This evaluation may be arranged through either World Education Services (WES) www.wes.org/ca or Comparative Education Service (CES) https://learn.utoronto.ca/comparative-education-service. This evaluation must demonstrate that your highest degree in psychology is at either the masters or doctoral level. While the statement from WES or CES will indicate to the College whether the academic credentials are comparable in level to either a master’s or doctoral degree granted by a Canadian university, the College reserves the right to make a final determination of the level and will evaluate, in accordance with the guidelines to determine, whether the content of the degree(s) is primarily psychological in nature. Educated Outside of Canada/USA / Evaluation of Academic Credentials My university documents are not in English or French, what should I do? Click to copy link. If your transcript and official university documents are in a language other than English or French, you must arrange to have these documents translated by an official translator. Applicants are responsible for any fees associated with the translation of their documents. My university will not send an academic transcript, what should I do? Click to copy link. If a university outside Canada or the U.S. is unable to send a transcript directly to the College, the College may accept a certified copy of the transcript the university issued to the applicant. I haven’t found work in Ontario yet. Do I need to be working before I can apply for registration as either a Psychologist or Psychological Associate? Click to copy link. No. You may submit an application for supervised practice along with all the supporting documentation, including the application fee, with the exception of the section of the application form titled “Authorized Supervised Practice” and the primary and alternate supervisors’ agreement forms. Your academic credentials will be reviewed but further consideration of your application will be deferred until you have found suitable employment and supervisors. In the meantime, if your credentials are approved, you can take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE). I plan to apply for registration as a Psychological Associate. Do I need to complete my post-master’s work experience in Ontario? Click to copy link. No. It is acceptable for post-master’s work experience to be completed outside of Ontario or Canada. My degree(s) was obtained from outside of Canada and USA, what are the steps in Ontario’s registration process? Click to copy link. The steps in the registration process are outlined in detail in the Registration Guidelines, however, a flowchart illustrating the steps in the registration process for applicants whose degrees are from outside of Canada and USA is also available in the “Applicants” section of the College’s website. There is a flow chart for Psychological Associate applicants and a flow chart for Psychologist applicants. You can find the flowcharts here: Psychological Associate Registration Flowchart Psychologist Registration Flowchart Will the College help me to find a job and supervisors? Click to copy link. You are responsible for finding a suitable job as well as your Primary and Alternate Supervisors. Generally, once you find a job, your employer will have a member(s) of the College on site or who consults to the organization who can supervise your work. The College’s online Public Register (www.cpo.on.ca), may be of assistance in your search for supervisors. The Ontario Psychological Association (www.psych.on.ca) provides a listing of its members who may be available to provide supervision. How can I get a copy of all of the documentation in my registration file? Click to copy link. You may receive a copy of all information and each document that the College has that is relevant to your application. Please note that the College does not return original documents however, you may ask for a copy of the documents in your registration file. To obtain a copy of your registration file you must makea written request to the College either in-person, by mail, or by e-mail. There is a charge of 20¢ per page for this. Upon receiving the written request, registration staff will determine the number of pages in the record and advise you of the cost before proceeding. I have my master’s degree, but I haven’t completed the required post-master’s work experience yet. Can I apply for registration as a Psychological Associate now? Click to copy link. Yes. You may submit an application along with all the supporting documentation, including the fee. At this time, you will not be able to complete the section of the application form titled “Authorized Supervised Practice” and the Primary and Alternate Supervisors’ Agreement Forms. Only your academic credentials will be reviewed until you have completed the required post-master’s work experience. In the meantime, if your academic credentials are approved, you may take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE). Complaints & Reports - GeneralShould I file a complaint or a report? Click to copy link. Complaints and reports are different ways of letting the College know about your concerns. There are several key differences between a complaint and a report:
* with some limited exceptions. See additional FAQs below. Who can file a complaint or report with the College? Click to copy link. Anyone who has a concern about a psychologist or psychological associate can file a complaint or submit a report. This includes a client, a family member, or friend of the client, an employer, an insurer, a colleague, or a general member of the public. Do I have to report my concerns to the College? Click to copy link. Clients do not have to make a complaint or report. However, some people, in some situations, do have to make a Mandatory Report. For more information, please click here. If I make a complaint do I have to be involved in the process? What is I do not want to be involved? Click to copy link. You do not have to be involved in the College’s investigation. The College will still conduct a full investigation of your complaint and give you a copy of the decision. Do you have an alternative dispute resolution process? Is the information I provide to the College confidential? Click to copy link. The College has a strict duty of confidentiality. It will not share your information with anyone outside of the ICRC investigation. However, on some occasions, the information may become public: Referral to the Discipline Committee: Discipline hearings are public. However, the Discipline Committee can ban the publication of information that could identify you. HPARB review: The College must give its investigation record to HPARB. HPARB also holds public hearings. HPARB is independent of the College and has its own processes. You may contact HPARB directly should you have any questions. Do I need a lawyer for the complaint process? Click to copy link. Complainants may find it helpful to have a lawyer, but it is not necessary. Most complainants proceed without a lawyer. Members often do use lawyers when responding to complaints or reports. This is because the process may have a significant impact on the member’s practice and career. What kinds of allegations can the College investigate? Click to copy link. The role of the College is to protect the public from harm. The College does so by setting and upholding rules and Standardsfor its members. These rules and Standards address many different concerns, including:
The College’s standards and rules cover most of the concerns brought to the College’s attention. Please contact the College if you are not sure whether your concerns are covered. Can the College help me get a refund for psychological services? Click to copy link. No. The College cannot get involved in fee arrangements or make financial awards. Can I complain about a clinic or institution? Click to copy link. No. The College only has jurisdiction over individual members. Can I complain about someone who provides psychological services but is not a member of the College? Click to copy link. Yes. The College will investigate if you have concerns about services provided under the supervision of a psychologist or psychological associate. Psychological services provided under supervision are the supervising member’s responsibility. However, the investigation will focus on the College member, and not on the supervised. The College also investigates misuse of the titles “Doctor,” “psychologist” and “psychological associate.” The College also investigates non-members who imply that they can provide psychological services. What happens if the College cannot investigate? Click to copy link. The College will try to direct you to another body that may be able to address your concerns. Is it possible to make an anonymous complaint? Click to copy link. No, the College cannot process anonymous complaints. The College shares your name and concerns with the member as part of its investigation. However, the College can block out irrelevant information, such as personal contact information. If you want to provide information to the College without filing a complaint, you can make an anonymous report. However, depending on the information you provide, the College may be limited in its ability to investigate. Please see the FAQ about the difference between complaints and reports. Is there a limit for making a complaint or report? Click to copy link. No, there is no time limit for filing a complaint. However, the College recommends that you raise your concerns as soon as possible. The earlier a complaint or report is received, the fewer problems may arise with the investigation. For example, it is more likely that relevant documents will still exist and witnesses can be located. Mandatory reports have specific timelines attached. Please see the FAQs about mandatory reports. Will I get anything other than the member’s response to my complaint? Click to copy link. No. The College will only disclose a copy of the member’s first response. The College will not disclose any attachments to the response. These may include clinical records, the member’s CV, and other information. The College will contact you if it requires additional information. Complaints & Reports - Filing a Complaint or ReportHow do I file a complaint or report? Click to copy link. You can submit a complaint or report to the College through electronic forms. You may also submit a complaint or report in writing or other recorded format, including film and audio. These can be sent directly to the College by email, fax, or regular mail. What information should I provide with my complaint or report? Click to copy link. You should provide as many details about your concerns as possible. Supporting documents such as emails, reports or bills are also helpful. You may also provide the names of relevant witnesses. What if I don’t know the member’s full name or contact information?
Click to copy link. You may search for a member on the College’s Public Register. Please contact the College staff if you have trouble identifying the member. What happens if I change my mind after filing a complaint? Click to copy link. You can request to withdraw your complaint. The Registrar or the ICRC will review your complaint and request. If your concerns are serious, the Registrar or ICRC may still decide to continue with the investigation. Complaints & Reports - InvestigationsDoes the ICRC investigate every complaint? Click to copy link. The College must investigate every complaint, with limited exceptions. The College will not investigate a complaint that is “frivolous, vexatious, made in bad faith, moot or an abuse of process.” This can happen when the complaint is about something that happened before the professional was a member of the College. Another example is where the conduct is private and does not relate to the member’s professional practice. The College will notify you and the member if it decides not to investigate. You will have a chance to respond to that decision before it becomes final. Once it is final you may ask that HPARB review that decision. What happens after I file my complaint? Click to copy link. Your complaint will be assigned to a Case Manager, who will manage the complaint file. The Case Manager will be your contact person at the College and is available to answer your questions. The College will send your complaint to the member. The member will have a chance to review the complaint and respond. In most cases, the College will request that the member provide the clinical record. At the same time, the College will acknowledge your complaint in writing. The College will likely provide you with a copy of the member’s response. You will then have an opportunity to respond to the member’s response. The Case Manager will also conduct further investigation. This can include interviewing witnesses and getting other documents. When the investigation is complete, the complaint file will go to a panel of the ICRC. Why would I not get a copy of the member’s response to my complaint? Click to copy link. The College’s policy is to be as transparent as possible. In most cases, the complainant will get a copy of the member’s response. The College will not disclose the member’s response for reasons of confidentiality or public protection. For example, where the complainant is not the client, the College may not disclose the response. The response is still provided to the ICRC for their consideration. What if I want to give the College information but I don’t have access to it? Click to copy link. Let the case manager know which information you want to access. The College may be able to get that information by way of summons. How long does an investigation take? Click to copy link. The legislation requires the College to complete investigations within 150 days. However, this is not always possible. The legislation also allows the College to extend this timeline, with notification to the complainant and member. Some things that can cause an investigation to take longer than usual include:
What if I need more time to respond or get information? Click to copy link. The College understands that collecting information and writing a response take time and effort. However, the College must also respect the investigation timelines. By policy, College staff may give you an extension for up to 21 days. Any extension beyond 21 days must be supported by written reasons and approved by the ICRC. To ensure transparency of the College process, both parties are notified of any extensions granted. Who makes the decision about my complaint? Click to copy link. The Inquiries, Complaints and Reports Committee, or ICRC, is responsible for decisions about complaints. A panel of the ICRC will review your complaint and make a decision about how to proceed. Every panel includes one public and two professional members of the Committee. What does the ICRC consider when they review my complaint? Click to copy link. The ICRC is a screening committee. It cannot make findings of fact or credibility. The role of the ICRC is to decide how to best protect the public from possible harm. For every complaint, the ICRC considers the possible risks of the member’s conduct to the public. The ICRC considers both impact and recurrence risks. If the risks are low, the ICRC may decide not to take any action. If the risks are moderate or high, the ICRC is likely to take some kind of action. The ICRC has developed a table to help with its consideration of risks. This table is available here. How often does the ICRC meet? Click to copy link. The ICRC meets in person every month from September to May. The ICRC attempts to meet twice over the summer months. The ICRC also meets by teleconference throughout the year. Will the College keep me updated about my complaint? Click to copy link. The College will send you a formal acknowledgment of your complaint within 14 days of receiving your complaint. The Case Manager assigned to your complaint will be in touch with you directly if they need additional information. If the College is unable to meet the 150-day timeline, the College will let you know. The College will then set new timelines. The College will send you a copy of the ICRC’s decision once it is finalized. I know the ICRC met to consider my case. Why can’t you tell me their decision? Click to copy link. A panel of the ICRC might not come to a final decision when they consider a complaint. The panel may have some questions for one of the parties or may want more information. They will then need to meet again to reach a decision. The panel also needs some time to write the decision. College staff is not able to communicate any information about an unfinished decision. Click to copy link. No. The ICRC does not meet with either the complainant or the member. The ICRC reviews information contained in paper or electronic records. Complaints & Reports - ICRC DecisionsWill the ICRC tell me that the member did something wrong? Click to copy link. No. Only the Discipline Committee can make a finding of professional misconduct after a hearing. The ICRC can decide whether to refer allegations to the Discipline Committee. If it does not make a referral, the ICRC can still express concern about conduct and take some action. The action the ICRC takes will depend on the risks associated with the member’s conduct. Please see more information about the ICRC Risk Assessment Framework. What action can the ICRC take? Click to copy link. The ICRC may take a range of actions after an investigation:
In the last 5 years (January 2015 to March 2020), ICRC outcomes in relation to 416 cases were as follows:
*The Percentages add up to more than 100% due to multiple outcomes in some cases, i.e. caution and undertaking. The 437 outcomes here relate to 41 cases. † Frivolous, vexations, made in bad faith, moot, or an abuse of process. See the FAQs above. Will information about my complaint go on the Public Register? Click to copy link. The College is required to post specific information on the Public Register. The College will not post any information that could identify the complainant or client. Information posted on the Public Register includes:
What if I’m unhappy with the ICRC’s decision? Click to copy link. In most cases, you and the member can ask that the Health Professions Appeal and Review Board (HPARB) review the ICRC’s decision. HPARB cannot review referrals to the Discipline or Fitness to Practice Committees. There are not final decisions but rather involve other College processes. In a review, HPARB will consider whether the College’s investigation was adequate. It will also consider whether the decision was reasonable. The College sends instructions on how to ask for a review with your copy of the ICRC decision. Can I use the College decision in Court? Click to copy link. No. Section 36(3) of the Regulated Health Professions Act, 1991 does not allow information from a College proceeding to be used in civil court. Complaints & Reports - Mandatory ReportsWhen should I file a mandatory report? Click to copy link. The timelines are set out in the Health Professions Procedural Code, 1991, which is section two of the Regulated Health Professions Act, 1991 as follows: Timing of report (2) The report must be filed within 30 days after the obligation to report arises unless the person who is required to file the report has reasonable grounds to believe that the member will continue to sexually abuse the patient or will sexually abuse other patients, or that the incompetence or the incapacity of the member is likely to expose a patient to harm or injury and there is urgent need for intervention, in which case the report must be filed forthwith. 2007, c. 10, Sched. M, s. 62 (1). How should I file a mandatory report? Click to copy link. A report must be filed in writing. Please use the College’s mandatory report form available on the College’s website. You may also write to the College directly through fax, mail or email. What information do I need to provide when I make a mandatory report? Click to copy link. The mandatory reporting form will prompt you for the information necessary with respect to each report. If you have any additional questions about your report, please contact the College at 416-961-8817/1-800-489-8388; or What if the professional I need to make a report about is also my client? Click to copy link. It may be that your mandatory obligation to report sexual abuse arises in the course of providing psychotherapy to another regulated health professional. In this case, your report must also contain your opinion, if you are able to form one, as to whether this member is likely to sexually abuse patients in the future. The Inquiries, Complaints, and Reports Committee (ICRC) decides what to do in each case by thinking about the possible negative outcomes of the member’s conduct. The ICRC thinks about this in terms of “risk.” The ICRC considers both impact and recurrence risks. Impact risks include those to specific individuals, the general public, and the profession. Recurrence risks include concerns about the member’s conduct history, the practices, processes, or systems the member has in place, and the member’s awareness of the practice concerns identified. The ICRC uses the ICRC Risk Assessment Framework, below, to help categorize these risks. The Framework also helps the ICRC identify the range of appropriate outcomes in relation to the risks. The outcomes available to the ICRC after the investigation of a complaint or report include:
COVID-19Now that things are “opening up” in Ontario, may we return to in-person services in non-emergency and non-urgent circumstances and if so, may we require proof of vaccination? Click to copy link. Originally published in Volume 2 Issue 1 of HeadLines. Throughout the pandemic, members have been permitted to use their professional judgment to decide when it was necessary to see clients in-person. The College wishes to advise members that Ontario’s Chief Medical Officer of Health recently rescinded Directive #2 for Health Care Providers (Regulated Health Professionals or Persons who operate a Group Practice of Regulated Health Professionals).This Directive had been amended and re-issued in mid-April due to the increasing COVID-19 case counts, hospitalizations, and ICU admissions. Rescinding of Directive #2 means that non-urgent and non-emergent procedures may be gradually resumed by health care providers and health care entities who were subject to that Directive. This includes in-person services that are non-essential or non-emergent. In making this decision, the Chief Medical Officer of Health advised that all health care providers should continue to follow the guidance issued by the Ministry of Health in the COVID-19 Operational Requirements: Health Sector Restart. College members are advised to review this document to ensure an understanding of relevant requirements to return to in-person service provision appropriately and gradually. In returning to the provision of in-person services, the College urges members to take a conservative approach to minimize the risk of community spread as much as reasonably possible, particularly with the emergence of new variants of the virus and localized outbreaks. Proof of Vaccination: Some members have asked whether they may require clients wishing to receive in-person services to demonstrate that they have been vaccinated. The Ontario Human Rights Commission has published a document entitled COVID-19 and Ontario’s Human Rights Code – Questions and Answers to provide some guidance to individuals, practitioners and employers. The following section from this document may be of assistance. Please note that this is the published position of the Ontario Human Rights Commission and the College is not qualified or authorized to offer interpretation of the Ontario Human Rights Code. Members seeking specific guidance or further clarity on how to interpret their own responsibilities under the Code are encouraged to seek independent legal advice. Ontario Human Rights Commission 21. Can my employer or any service or housing provider require proof that I’ve received a COVID-19 vaccine?
The College will continue to provide updates to members as further information becomes available. I am a registered provider of psychological services in another jurisdiction but am not a member of the College of Psychologists of Ontario. May I provide services to someone located in Ontario temporarily exclusively because of the COVID-19 Pandemic? Click to copy link. The Psychology Act, 1991 limits the provision of psychological services in Ontario to members of the College of Psychologists of Ontario. In the absence of legislative amendments, the College is not able to authorize anyone other than members of the College to provide telepsychology services to clients located in Ontario. Under normal circumstances, the College views such activities by non-members as “unauthorized practice” and considers whether there is a need for appropriate action. The College has carefully considered the extreme circumstances in which we find ourselves. We recognize this must be taken into account with regard to duly registered/licensed practitioners from other jurisdictions who must provide telepsychology services into Ontario for their existing clients during the current emergency situation. Therefore, in response to the urgent COVID-19 situation, the College will not initiate an “unauthorized practice” action against an out of province practitioner provided the practitioner is:
– existing clients temporarily in Ontario due to the COVID-19 situation when it is clinically ill-advised to temporarily stop services and/or to transfer the service to a member of the College of Psychologists of Ontario; – clients who are temporarily located in Ontario due to the COVID-19 situation and are entitled to receive those services as a benefit of their registration with a University or College or other benefit program outside of Ontario, where the services will be provided by an out of province practitioner on behalf of the University or College counselling service or other benefit program; or – clients who are temporarily located in Ontario due to the COVID-19 situation, when it is reasonably expected that the clients will require continuing services with the same practitioner upon the client’s return to the jurisdiction in which the clinician is registered. Out of province practitioners are asked to confirm their understanding and acceptance of the requirements listed above by notifying the College of their intention to provide telepsychology service to existing clients in Ontario. Practitioners should email the College () providing their name, the jurisdiction in which they are registered/licensed, and their registration/license number. While the College will endeavour to acknowledge receipt of this information, practitioners need not wait for confirmation before initiating service.
May I require that clients provide proof of vaccination before providing in-person services? Click to copy link. Ontario has recently mandated that individuals must be vaccinated before entering specified high-risk settings. These settings are listed in O. Reg. 364/20: Rules for Areas at Step 3 and at the Roadmap Exit Step under the Reopening Ontario Act, 2020. It appears that this requirement does not apply with respect to entering a place for the purpose of health care. The Ontario Human Rights Commission recently published a policy statement which provides guidance with respect to COVID-19 vaccine mandates and proof of vaccine certificates. It states, among other important things, that: While receiving a COVID-19 vaccine remains voluntary, the OHRC takes the position that mandating and requiring proof of vaccination to protect people at work or when receiving services is generally permissible under the Human Rights Code (Code) as long as protections are put in place to make sure people who are unable to be vaccinated for Code-related reasons are reasonably accommodated. This applies to all organizations. Members considering implementing such policies may find useful information about how to proceed in the Ministry of Health’s Proof of Vaccination Guidance for Businesses and Organizations under the Reopening Ontario Act, Version 2, September 27, 2021. If additional information is required, members may wish to seek independent legal advice. May I provide a client with a letter recommending an exemption to vaccination requirements? Click to copy link. It is our understanding that the criteria for an official “medical vaccination exemption” are very narrow and that these do not include psychological reasons. As well, only a physician, registered nurse or nurse practitioner may certify such an exemption for settings mandated to require proof of vaccination. It does not appear that members of the College of Psychologists are authorized to provide such certification. It is important that a client making a request of this type be aware of the limits of the member’s authority. Further information may be found in the Ministry of Health’s Questions and Answers, Version 2, September 28, 2021. If the business or organization is not covered by the mandatory vaccination legislation, members could provide a professional opinion concerning a client’s need for accommodation. In doing so, as with any professional opinion given, they must be prepared to present a rationale for such an opinion. Should a member proceed to provide a letter related to a vaccination exemption, members should clearly indicate that it is for psychological reasons and that, in keeping with Principle 10.3 of the Standards, “ must render only those professional opinions that are based on current, reliable, adequate, and appropriate information.” As well, it is important that members recognize they could be held accountable should an employer or other party mistakenly accept their letter as a valid official “medical exemption”, and remember that making a record, or issuing or sign a certificate, report or similar document that they know or ought to know is false misleading or otherwise improper, is an act of professional misconduct. Must masks be worn in the office, particularly when it’s possible to maintain a physical distance of at least 2 metres? Click to copy link. Originally published in HeadLines Volume 1 Issue 2 Regulated Health Professionals are subject to Directive #2 of the Chief Medical Officer of Health. This directive states that: In the gradual restart of services, Health Care Providers must comply with the requirements as set out in “COVID-19 Operational Requirements: Health Sector Restart” (May 26, 2020 or as current), including, but not limited to, the hierarchy of hazard controls. The hierarchy sets out the following measures, in order of priority:
As noted previously, the Ministry recommendations must be general enough to apply to all health care providers. As a result, some of the examples provided may not be applicable to psychological services. The Ministry is clear that PPE controls, such as masks, are the last tier in the hierarchy of hazard controls. Accordingly, they should not be relied on as a stand-alone primary prevention program. The Operational Requirements clearly state: Given community spread of COVID-19 within Ontario and evidence that transmission may occur from those who have few or no symptoms, masking (surgical/procedure mask) for the full duration of shifts for HCPs and other staff working in direct patient care areas is recommended. Some local areas have enacted by-laws requiring mask use in indoor public settings, with exceptions to this requirement for health care providers. It is likely that such exceptions have been made in order to enable some health care procedures which cannot be performed while a mask is being worn. The College continues to recommend that services should be provided virtually when possible. When in-person services are required, members should wear masks and require clients to do so in enclosed spaces, unless this is clinically contraindicated. What can be done if an employer refuses to provide supplies, like plexiglass screens, that a member deems necessary to use when testing clients? Click to copy link. Originally published in HeadLines Volume 1 Issue 2 This can be a difficult situation to navigate and we are advising members to make best efforts to negotiate resolution of such problems. The Standards of Professional Conduct, 2017 require: 2.1 General Conduct A member must conduct himself/herself so that his/her activities and/or those conducted under his/her direction comply with those statutes and regulations that apply to the provision of psychological services. and, 3.1.2 Employment Settings A member must assume responsibility for the planning, delivery, and supervision of all psychological services he/she provides to a client. Members working as employees must make best efforts to ensure that their work setting adheres to the Standards of Professional Conduct, 2017 in the planning, delivery, supervision and billing practices of all psychological services provided. The College is not authorized to regulate workplaces, only the conduct of individual members. As stated above, members are required to make best efforts to ensure that the work setting adheres to the Standards. This may involve escalating the issue within their organization and seeking outside assistance where necessary. Hopefully, in most cases, collaborative communication will help to resolve any “standoffs”. Members may wish to advise those with the authority to grant their requests that Directive #2 has been issued to all Regulated Health Providers under Section 77.7 of the Health Protection and Promotion Act, 1990 and requires Health Care Providers to consider which services should continue to be provided remotely and which services can safely resume in-person with appropriate hazard controls and sufficient PPE. Must all clients be actively screened, even in a setting such as a school or social service agency? Click to copy link. Originally published in HeadLines Volume 1 Issue 2 The COVID-19 Operational Requirements: Health Sector Restart indicates that health care professionals should perform active screening, although we understand this can be assigned to a staff person. Screening should be done with the client. If it is believed that a client is unable to answer the screening questions reliably, it should be done in discussion with a person’s parent or caregiver. The Operational Requirements state: Patients should be screened over the phone for symptoms of COVID-19 before coming for their appointments. If possible, any visitor accompanying a patient to an appointment, should also be screened prior to the appointment. The latest COVID-19 Patient Screening Guidance Document on the MOH COVID-19 website should be used and may be adapted as needed and appropriate for screening purposes. If a patient screens positive over the phone, the appointment should be deferred if possible and the individual referred for testing. If an assessment is conducted virtually, instead of in-person, may members violate the standard administration protocols for tests. Will norm-based scores be applicable and what effects will the stressful context of the pandemic have on test performance? Click to copy link. Originally published in HeadLines Volume 1 Issue 2 The College’s expertise and role is limited to professional regulation. It is beyond the purview of the College to provide clinical guidance to members. The College trusts that members practicing the profession have the knowledge, skill and judgment required to make appropriate clinical decisions. With the large number of tools, techniques and tests in use, members should obtain current guidance from the test publishers about the administration procedures and the applicability of norm-based scores. At those inevitable times when answers are not clear, members may find it helpful to discuss these issues with other clinicians who they believe have relevant expertise. As in all cases, interpretation of test results includes consideration of the context in which an assessment is conducted. The Standards of Professional Conduct, 2017 which guide members in making such judgments include: 10.1 Familiarity with Tests and Techniques Practical Application: At times, a member may provide services in what would be considered an emerging area of practice. In such situations, a member should inform clients that the services being offered may not, yet, have been subjected to extensive research and validation. As with any informed consent process regarding the provision of services, clients would be informed of the risks, benefits and alternatives available. 10.2 Familiarity with Interventions 10.3 Rendering Opinions 10.4 Identification of Limits of Certainty We have become aware from members that test publishers are providing guidance about how measures which rely on standardized administration procedures may be utilized. It is a member’s responsibility to ensure that they are using the tools properly, based on empirical evidence and good clinical judgment. Is there an obligation to release a client’s name and contact information to public health if a client attends a session in-person and soon after tests positive for COVID-19? What information (if any) should be disclosed to other clients or professionals who may have crossed paths with the infected individual in our workplace? Click to copy link. Originally published in HeadLines Volume 1 Issue 2 If someone has tested positive, the local Public Health agencies are expected to follow appropriate protocols with respect to notifying those who must be notified. There does not appear to be a requirement for a member of the College to make a mandatory report of someone who has identified themselves as, or is suspected of being, COVID-19 positive. There are, however, provisions in the Health Protection and Promotion Act, 1990 that authorize the Chief Medical Officer of Health to make an Order requiring the release of confidential information, as specified in that Order. If ordered to provide information, the College would not expect a member to put themself in contempt of the Order. To date, we have not heard about any members receiving such Orders. If one is unsure of the nature of such an Order or the information it may require by released, one should seek legal advice. If concerned about individuals who may have crossed paths with an infected person, it would be permissible and reasonable for a member to provide general de-identified information to other clients and suggest they may wish to be tested. One should, however, take care not to provide any information that could identify the other person. Confidentiality provisions under the Personal Health Information Protection Act, 2004 (PHIPA) prohibit the disclosure of personal health information without authorization by the client, other than in specified circumstances. Exceptions to the duty of confidentiality are set out in sections 39 (regarding certain health programs) and 40 (regarding risk of serious bodily harm). It is important to remain aware that these exceptions permit one to make disclosure but do not require this. When one uses the discretion to make a disclosure without a client’s permission, only that information which is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons should be disclosed. Additionally, such information should only be disclosed to a person who is in the position to eliminate or reduce the risk. If unsure about whether a disclosure is permissible, it may be useful to obtain the opinion of a qualified legal professional. Many professional liability insurance policies entitle the policy holder to pro-bono legal advice. CPD - Program RequirementsHow can I satisfy my CPD requirements if I am not in active practice? Click to copy link. Unless you hold a Certificate of Registration with “Retired” status, you are expected to maintain professional competence, in anticipation of your return to practice. There is a great deal of flexibility in terms of how you may earn CPD credits. While many of the opportunities to earn Category A (Professional Activities) credits involve active professional practice, there are opportunities for credit to be earned that are not directly related to professional practice. Please note that it is possible to satisfy the requirements of the program by earning as few as 10 credits over two years from Category A. Category B (Continuing Education) credits can be earned outside of the context of active service delivery. If you are experiencing circumstances that make it impossible to satisfy the requirements of the program, please contact the College to discuss this. CPD - Program AdministrationWhen must I begin mandatory CPD Program? Click to copy link. While it is expected that you will be continuously engaged in professional development activities, you are only required to declare that you have completed the requirements of the mandatory CPD program at the end of each two-year CPD cycle. Bearing this in mind, you must begin to record credits you earn at the beginning of each cycle. Ordinarily, the cycle will begin on July 1 and end on June 30th, two years later. Please note: only for members beginning the first cycle in 2017, credits may be collected for the period between May 8th, 2017, and June 30, 2019. Members with a Certificate authorizing Autonomous Practice or an Inactive Certificate must complete the Self-Assessment Guide (SAG) every two years. Those with a Certificate Authorizing Supervised Practice or Interim Autonomous Practice must complete the SAG every year, however, the CPD cycle is still two years in length, so the CPD declaration must be made every second year. If your current registration number ends in an even number you must begin and end your CPD cycle in years ending in an even number. If your current registration number ends in an odd number you must do so in years ending in an odd number. The following table indicates when to begin formally recording CPD credits and when your first CPD Declaration of Completion will be due.
*Credits earned from May 2017 will be accepted for this transitional cycle only. The last time I completed the Self-Assessment Guide I had a certificate for Supervised Practice (or Interim Autonomous Practice) and have gone from having and “odd” registration number to an “even” one. How will this affect my CPD cycle? Click to copy link. If you have been acquiring CPD credits for two years, regardless of changes to your Certificate of Registration, those credits would apply. In other words, despite any changes in your Certificate of Registration, you will have completed the requirements of the program if you earn 50 credits in the two years leading up to the declaration date. If you receive notice that a declaration is due but have not had a full two years in which to earn the 50 credits, the College will provide you with an alternate declaration that recognizes this. Will there be audits of the CPD program? Click to copy link. The Quality Assurance Committee will conduct random audits of member participation in the CPD Program. When audited, members will be required to provide the Quality Assurance Committee with a detailed list of their CPD activities, as well as supporting documentation of their activities, wherever these are available. It is recognized that formal documentation of participation is not available for some activities such as case conferences, self-learning or group viewing of webinars in which individual registration is not required. In such circumstances, formal documentation is not available and members will not be expected to provide it. If I am required to participate in a Peer Assisted Review will the peer reviewers have access to information about my CPD activities? Click to copy link. Yes. If you are selected for a Peer Assisted Review, the reviewer will request access to your record and documentation of your CPD activities. CPD - Activities Eligible for CreditCan credits earned prior to the beginning of the two year CPD cycle be counted towards my required total number of credits? Click to copy link. The intention of the program is to ensure that within a two year period, members are engaged in at least the minimum amount of required professional development. For that reason, only activity within the two years prior to a declaration of completion may be counted. Do the CPD categories include all of the activities that could be counted as professional development? Click to copy link. The categories are comprehensive and it is expected that every CPD activity can be included within one of the categories provided in the program description and tracking sheet available from the College. Examples provided of the activities within each of the categories convey the range of activities members may count. It should be noted that these lists are examples and are not intended to be all-inclusive. Members are expected to use their own judgment in deciding whether the particular activities they choose meet their professional development needs, as identified in the Self-Assessment Guide, and which particular requirements of the CPD program each activity will satisfy. What is meant by “peer” in reference to activities that involve peers? Click to copy link. A peer can be a professional in the field of psychology or a person who is qualified as a professional in a field relevant to the practice of psychology. Interdisciplinary interaction is encouraged by the College. What is meant by “professionally relevant programs/workshops”? Click to copy link. Professionally relevant programs/workshops are those events that enhance knowledge relevant to the psychological services a member provides. Content need not be primarily psychological in nature but must be directly related to the services provided by the member. For example, a member working within the correctional system might benefit from an educational event provided by correctional officers regarding the management of offenders within the prison system. Can I claim credit for both interacting with peers at a live conference or convention and “CE” at the same event? Click to copy link. If you have earned “CE” credits by attending live events like conferences and conventions you may claim credit for attendance at the conference or convention under Category A and also for the specific time you spend within the presentations as CE credits in Category B. For example, if attending a convention from 9 a.m. until 4 p.m., you would earn one credit for spending the day with peers under Category A8 and, if attending presentations for 4 hours, an additional 4 credits under Category B for the 4 hours you were engaged in learning during the presentations Does the College have a list of approved CE courses? Click to copy link. The College doesn’t accredit or approve courses. Members must determine whether an activity is suitable for CPD credit. If the activity is relevant to one’s CPD, it is eligible for credit. Similarly, the College also doesn’t approve or endorse specific CE accreditation bodies. Members are expected to use their own judgment in determining the appropriateness of specific CE crediting organizations. Are my CPD Activities outside of Ontario eligible for credit? Click to copy link. Any activities relevant to your Ontario practice are eligible for credit, wherever they take place. Does a poster presentation count as delivering a workshop, conference, or presentation? How can I obtain my 10 credits related to ethics? Click to copy link. Examples of how to satisfy this requirement include participating in any professional activity or continuing education activity related to ethical issues, including those addressing local jurisdictional issues. The following are a few examples of the many ways you may earn these credits:
Why can CPD credits be earned for teaching? Click to copy link. Teaching psychology requires ongoing research, up-to-date knowledge, and an ongoing exchange of information between teachers and students. For this reason, it is regarded as valuable CPD. Can practice outcome monitoring be conducted on either an individual or organizational level? Click to copy link. Formally monitoring progress towards specific outcome goals, either for individual clients or on an organizational level, can be a useful mechanism for determining whether an approach to practice is effective or not and is a valuable learning experience. Active participation in either activity is eligible for CPD credit. When conducting formal research, are writing, reviewing and editing included within the available credits? Click to copy link. It is recognized that Conducting Formal Research is a distinct activity and that not all of those involved in conducting research are responsible for writing about it. Additional credit may be obtained for writing, reviewing, and editing in Category A4. Can I gain competence in a new area of practice and/or with a new client population through the mandatory CPD program? Click to copy link. The CPD program is intended to ensure that you maintain competence within your existing authorized areas of practice and with your authorized client populations. The development of competence in additional areas of practice or with additional populations must be undertaken through a much more comprehensive and rigorous process, beyond what would ordinarily be required to satisfy the CPD requirements. If you are seeking to expand your areas of authorized practice or authorized client populations, please contact the College. May I count my own Personal Psychotherapy under category A1 (Professional Consultation/Interaction)? Click to copy link. If participating in your own therapy leads you to gain knowledge, experience, and/or skills that advance your ability to provide professional psychological services it may be counted as one type of activity under category A1 for a maximum of ten credits every two years. Would credit for Peer Review under category A1 include peer reviewing journal articles and/or others’ professional reports? Click to copy link. Peer Review under category A1 (Professional Consultation/ Interaction) is meant to include peer review of another member’s practice. Reviewing another member’s professional reports could be counted under category A1 as it is a form of professional consultation. Reviewing articles for publication may be counted under category A4 (Writing, Reviewing, Editing). CPD - Categorization of ActivitiesWhat information will I be required to provide to the College with regard to my participation in the CPD Program? Click to copy link. The College will require you to provide a declaration that you have satisfied all of the requirements of the program at the end of each two-year CPD cycle. You will not be required to provide details describing your CPD activities, or supporting documentation unless the College specifically asks you to do so. This may occur when:
What is the difference between Category A (Professional Activities) and Category B (Continuing Education)? Click to copy link. Category A (Professional Activities) includes activity-based experiences believed to enhance professional development by developing competencies in the multifaceted areas related to one’s practice. In addition to keeping abreast of scientific knowledge, members are encouraged to include other components of service enhancement in their CPD activities. Examples of these include but are not limited to, reviewing evidence for the purpose of evidence-based decision making, keeping up to date with technology, and enhancing interpersonal and multicultural competence. I participate in a monthly peer consultation group with other psychologists and plan to spend at least 10 hours doing this over the next two years. I also plan to the spend at least 10 hours in individual consultations with other psychologists and psychological associates during the CPD cycle. Would these be considered different activities and therefore be eligible for 10 credits each under category A1, for a total of 20 credits? Click to copy link. A maximum of 10 credits for any one type of activity may be counted in section A1. If what you do in the peer consultation group is different than what you would do in the individual consultations, then you could consider it to be two different activities and you could acquire 20 credits in all. There will be judgment calls to be made when deciding ‘what belongs where’ and we are leaving it up to members’ own good judgment to make these decisions, so long as they can provide a reasonable rationale for the decision if asked for one. Incidentally, you can earn peer consultation credits for consulting with any professionals, not only psychologists and psychological associates, if the discussion is with a professional and the issues are relevant to your practice. What is the difference between a “CE Credit” in Category B and a credit for general attendance at an event in Category A8? Click to copy link. Credit for general attendance at events in Category A8 is meant to reflect the value, in and of itself, inherent in interacting with colleagues and participating in the social, interpersonal, professional, and scientific activities which are part of the milieu of conferences and conventions. It is believed that being among peers enhances professional development as this leads to awareness of the practices of colleagues and of the ideas, problems, and challenges that are present in the professional environment. Continuing Education credits available under Category B reflect the acquisition of information from attending presentations while at the event. This applies whether the events are attended in person or via technology. Are the required 10 credits of Continuing Professional Development related to ethics separate from the total of 50 credits required over categories A and B? Click to copy link. No, the 10 credits related to ethics are not additional credits. You must ensure that a minimum of 10 of the credits earned in satisfaction of the 50 credits required in total are related to professional ethics. CPD - Documenting ActivitiesWhat kind of documentation should I retain in order to verify that I have earned CPD credits? Click to copy link. Many conferences and workshops provide participants with a certificate of attendance and this would be sufficient verification. For organized events that do not provide such certification, a record of your registration or payment will suffice. For other activities where formal documentation is not provided, like case rounds, self-guided learning, time spent conducting research or observing a webinar with a group where individual sign-up is not required, you may simply state that you have participated in the activity and provide a description of the activity including the organization, group, people, publication and/or other resources involved. Here is a sample completed CPD tracking form which provides the level of detail suggested. Some accredited providers of CE charge hundreds of dollars extra to obtain formal documentation of attendance. Am I required to pay for such documentation in order to claim credits under category B1? Click to copy link. The College will not require you to pay for an “official CE credit” document. Your statement, program information from the provider indicating that formal CE credits are available and confirmation of registration will be sufficient. Am I required to use the electronic tracking sheet to record my CPD credits? Click to copy link. No. The electronic tracking tool has been developed as an aid for members who wish to use it. So long as you maintain an accessible record of your CPD activities, you may keep track of them in any manner you wish. How long must I keep records related to my CPD activities? Click to copy link. You must retain your records for at least five years after completion of your last CPD cycle. Peer Assisted ReviewWhat is a Peer Assisted Review (PAR)? Click to copy link. The Peer Assisted Review (PAR) process has been in place since the fall of 1999. Each year, a number of members are randomly selected to have their practices reviewed as part of the College’s Quality Assurance Program. The PAR is described below in a series of FAQ’s, in an effort to provide members with an understanding of the process. Click to copy link. Any member with a Certificate of Registration for Autonomous Practice is a potential participant in the PAR process. How are members selected? Click to copy link. Any member who has not completed the mandatory Self-Assessment requirement of the College is required to participate in a PAR. Additionally, members are identified for participation using a computerized random, or stratified random, selection process. Who will conduct the review? Click to copy link. Two members of the College; an assessor appointed by the Committee and a reviewer nominated by the member being reviewed. Generally, both the assessor and the reviewer will have knowledge of the member’s area(s) of practice, population(s) served and practice setting(s). The member undergoing a review will have an opportunity to indicate whether they believe that there is any reason a potential assessor should not conduct the review. Efforts are also made to select an assessor who has either undergone a review themselves or who has previously acted as an assessor or reviewer. The reviewer is nominated by the member being reviewed and can be a colleague or associate. They may act as a support to the member. While this individual is nominated by the member being reviewed, in accepting this role the reviewer understands and agrees to act as an agent of the College and therefore to act in the public interest. The assessor and reviewer must undertake and agree to:
Where will the review take place? Click to copy link. The review is conducted at the member’s practice setting. In cases where a member works in more than one setting, the appropriate location for the review will be determined in discussion with the member. When will the review take place and how long will it last? Click to copy link. Members normally set aside a morning or afternoon for the review as it can take from three to four hours. The scheduling is determined by the assessor and reviewer, in consultation with the member being reviewed. It is expected that every effort will be made to schedule the review at a mutually agreeable, and convenient time for all participants and which takes into account the least disruption to the member’s work schedule. How will the review be conducted? Click to copy link. The assessor and reviewer will together observe the member’s place of practice, interview the member using a structured interview form and review some of the member’s clinical records. What happens after the review? Click to copy link. The Reviewers will provide a report to the Quality Assurance Committee. The Committee appointed assessor must provide a copy of the report as well as notice of the right to make submissions to the Quality Assurance Committee within 14 days of receipt of the report, directly to the individual who has been reviewed. The Quality Assurance Committee will review the Report and any submissions the member has made and determine whether any action is required, in the public interest. What are the potential outcomes of the review? Click to copy link. One of three outcomes is possible from the review:
What if I have questions? Click to copy link. If you have any questions regarding the PAR please don’t hesitate to contact Madeleine Lee, Professional CorporationsWhat is the difference between a Professional Corporation and a Practice Management Corporation? Click to copy link. While both are corporations, the rules that stipulate their ownership structures and the activities that they can undertake are different. Professional Corporations The shareholders of professional corporations must all be members of the same health regulatory college as must all the officers and directors of the professional corporation. Further, the only business that a professional corporation is permitted to undertake is the practice of the profession and activities that are related to or ancillary to the practice of the profession. Every professional corporation is also required to obtain a Certificate of Authorization from the college of its members before it is permitted to conduct its business. Practice Management Corporations In contrast, the ownership rules of corporations that manage practices are more relaxed. Members of different health professions, non-health professionals and even family members can be shareholders as well as officers or directors. Corporations that manage practices are not permitted to practice any regulated health profession and the shareholders of these corporations are not permitted to practice their regulated health profession through the corporation. This does not mean that members cannot work for non-professional corporations owned by others. Rather, it means that when they are working for a such a corporation, they are practicing as individual health professionals outside of the corporation. Because these corporations are not permitted to practice a regulated health profession, they are not required to register with the College or Colleges of their shareholders. The College is not in a position to legal advice with respect to the Business Corporations Act. Your legal and business advisors can provide specific advice relevant to your circumstance. My colleagues and I, some of whom are members of other health professions, have set up a corporation to manage our clinic. Do we have to register our corporation with the College and obtain a Certificate of Authorization? Click to copy link. There are differences between professional corporations and those that manage practices and are not professional corporations. A corporation that manages a practice, and is not a health professional corporation, is not permitted to practice a regulated health profession and hence is not required to register with the College or Colleges of their shareholders. The College is not in a position to legal advice with respect to the Business Corporations Act. Your legal and business advisors can provide specific advice relevant to your circumstance. Should I set up a professional corporation? Click to copy link. This is a business decision. The College recommends that you discuss your plans with an accountant or lawyer who specializes in this area. May I practise psychology through a corporation that is not a psychology professional corporation? Click to copy link. No, if you are practising the profession of psychology through a corporation it may only be a psychology professional corporation that operates under a Certificate of Authorization issued by the College of Psychologists of Ontario. I have decided to establish a professional corporation for my psychology practice. What do I need to do? Click to copy link. Members who wish to practise through a corporation are required to obtain a Certificate of Authorization from the College. Detailed information and application forms can be found on the College Website. How do I submit the application and application fee for a Certificate of Authorization? Click to copy link. You may submit the application and supporting documents via email to Or by regular mail to: Please note that due to COVID-19 the College’s office are closed we are unable to accept courier packages at this time. You may submit the application fee in the following ways:
What is the processing timeline for an application for a Certificates of Authorization? Click to copy link. Once a complete application package has been received by the College, it takes 2 to 3 weeks for processing. The effective date of the certificate is the date the complete package and application fee was received. What is the application fee for a Certificate of Authorization? Click to copy link. The application fee for a new Certificate of Authorization is $350. What can I name my professional corporation? Click to copy link. There are restrictions on the names of professional corporations. Please refer to the College Guide to an Application for Certificate of Authorization for Professional Corporation. Briefly, the names of professional corporations must:
For detailed information, please refer to section 3.2 of the Business Corporation Act, 1990 and Ontario Regulation 39/02 under the Regulated Health Professions Act, 1991. It is also wise to consult with the College before setting up your corporation to ensure that the name is appropriate. Examples: Smith Psychology Professional Corporation; Smith and Jones Psychology Professional Corporation; John Smith Psychology Professional Corporation; J. Smith Psychology Professional Corporation. Can the name of my business or practice be different than the name of the professional corporation? Do I have to register the name of the business as well and how would I do that? Click to copy link. You may use a different practice name than the name of your professional corporation. You must list every practice name under which the professional corporation practices when completing the application form. Speak to your own lawyer or accountant about the requirements for registering business names. The College does not approve or comment on practice names, and there are no specific rules for practice names other than to ensure the name does not violate the section of the Advertising Regulation, (see section 18.1) This section prohibits in advertising, and so also in naming, something that would suggest uniqueness, specialty or something that is false or misleading. Who is permitted to be a shareholder, officer or director of a professional corporation? Click to copy link. Only members of the College of Psychologists of Ontario. Can a holding company be a shareholder of a psychology professional corporation? Click to copy link. Yes, if all the shareholders, officers and directors of the holding company are registered members with the College of Psychologists of Ontario. Can I apply for a Certificate of Authorization if I have incorporated under the Canada Business Corporations Act? Click to copy link. No. Members intending to incorporate must do so under the Ontario Business Corporations Act. For forms and instructions on how to incorporate, contact the Companies Branch of the Ministry of Government Services website or call 416-314-8880. Health profession corporations incorporated in a jurisdiction outside Ontario, including corporations federally incorporated under the Canada Business Corporations Act, cannot obtain a Certificate of Authorization from the College. They must incorporate under the Ontario Business Corporations Act, and satisfy the conditions and requirements of the RHPA to be considered a health profession corporation in Ontario. How long is the Certificate of Authorization valid for? Click to copy link. The certificate is valid for one year and must be renewed annually on the date of authorization. Members will be emailed a renewal package approximately 6 weeks prior to this date. What is the fee for to renew a Certificate of Authorization? Click to copy link. The fee for renewal of a Certificate of Authorization is $250. Why must I complete a renewal each year for my professional corporation? Click to copy link. The requirements related to issuance and renewals of Certificates of Authorization are set out in the Regulated Health Professions Act, 1991 (RHPA) and the Certificates of Authorization Regulation. They apply equally to all regulated health professions in Ontario. The general requirement for annual renewal is written into these regulations as a fixed component. The College asks members to complete only what is required under the RHPA. What is a “Corporation Profile Report” and how do I get one? Click to copy link. A Corporation Profile Report is a document issued by the Ontario Ministry of Government and Consumer Services that indicates that the corporation is registered and active. The legislation sets out the requirements for the annual renewal of your Certificate of Authorization. One of those requirements is that a current-dated Corporation Profile Report accompanies your annual renewal application regardless of how long your health professional corporation has been in existence. You may obtain a newly issued Corporation Profile Report from: Ministry of Government and Consumer Services: or through one of the private-sector service providers under contract with the Ministry of Government and Consumer Services:
The Corporation Profile Report does not need to be certified. What is meant by “a copy of every certificate endorsed under the Business Incorporations Act”? Click to copy link. You must submit articles of amendment filed with the Ministry of Government Services if you made any changes, such as a name change, to the corporation since incorporation or the last renewal. Can the College revoke my professional corporation’s Certificate of Authorization? Click to copy link. Yes – In fact, the College must revoke a professional corporation’s Certificate of Authorization in a number of circumstances. These include:
If my professional corporation’s Certificate of Authorization has been revoked, how can it be reinstated? Click to copy link. If the College revoked a Certificate of Authorization, the professional corporation must apply for a new one and meet the eligibility requirements in effect at the time of the new application. At that time one must submit the required application and supporting documents and pay the application fee. Professional PracticeWho has the right to authorize services or access to information about a child when parents are separated? Click to copy link. Originally published in Volume 2 Issue 1 of HeadLines. In the practices of most members, the answer to this question can be found in the Health Care Consent Act, 1996 (HCCA) and the Personal Health Information Privacy Act, 2004 (PHIPA). One must first establish whether the child has the capacity to make their own independent decisions in these situations. The HCCA and the PHIPA do not specify chronological ages of consent but instead set out the test for determining whether any individual, including a child, is capable of making their own health care decisions. The determination of capacity must be made by the Health Care Provider or the Health Information Custodian, as the case may be. The analogous tests for capacity to be applied are set out in section 4 of the HCCA and section 21 of PHIPA, respectively. If the child is not believed to be capable, a substitute decision-maker for the purpose of the HCCA is generally deemed to play the same role with respect to PHIPA. Section 20 of the HCCA and Section 26 of PHIPA provide specific advice with respect to the hierarchy of potential decision-makers when a child is not believed to be capable of making their own decisions. It also sets out the mechanisms for deciding what must happen when a person with the right to make decisions is not available or willing to assume decision-making responsibility. The legislation also addresses what to do if there is conflict between two individuals having equal ranking in the hierarchy. Generally, a parent can give or refuse consent on behalf of an incapable child unless this authority has been lawfully granted to a children’s aid society or other person. If both parents do not have the same rights under an Agreement or Order, a parent with custodial rights prevails over a parent who has only a right of access. In situations where the statute does not spell out clearly which parent is entitled to make the decision, statutory interpretation is necessary. Given the high stakes for all individuals involved, the most prudent course of action is to obtain independent legal advice. The College’s August 2005 Bulletin provides additional guidance with respect to this issue. Who “Owns” the Clinical Record? In a group practice comprised of members authorized for autonomous practice, who can access, contribute to, and hold copies of the clinical record? Click to copy link. Originally published in Volume 2 Issue 1 of HeadLines. The answer to this question depends upon various decisions made by the organization, including who is the Health Information Custodian (HIC), a term which is used and defined in the Personal Health Information Protection Act, 2004 . For the purposes of answering this question, either a health care practitioner or a person who operates a group practice of health care practitioners may be a HIC. There may only be one HIC and it should be the person who will have ultimate responsibility for the collection, use, disclosure, security, and retention of the information. . The HIC must ensure that their identity is made clear to all concerned, including the client. A client must provide informed consent for a specified individual or organization to collect information about them. A Health Information Custodian may have an “agent”. This is defined in PHIPA as a person that, with the authorization of the custodian, acts for or on behalf of the custodian. The HIC may, for example, appoint the service provider working in the HIC’s organization to be their agent. Copies of information may be shared with those with a need to have the information in their possession but may only be provided to anyone other than the HIC or agent with client consent. The number of copies of the same information is directly correlated to the risk of loss or unauthorized access to the information. The fewer number of copies there are of a document, the lower the risk of loss or unauthorized disclosure. There is no prohibition against storing information in more than one file/location. Standard 9.1 of the Standards of Professional Conduct, 2017 requires that a member must make best efforts to ensure that the member’s records are complete and accessible; this applies whether the record is kept in a single file or in several files and whether the record is housed in one location or at several locations. It is suggested that when records are not maintained in one file or location that a note is placed in each location indicating the location(s) of any other information. May I provide services in a Province or State in which I am not currently licensed? Click to copy link. The provision of psychological services is regulated locally within most North American provinces, states and territories, for the purpose of protecting those located within the province, state, or territory. In most jurisdictions, including Ontario, services are deemed to be delivered in the location of the client. Each jurisdiction has its own statutes and regulations and has the authority to take action with respect to unauthorized practice. For this reason, permission must be sought from the College or Board in the same province, state or territory as the person who will be receiving services is physically located. I am a member of the College of Psychologists of Ontario. May I provide services to a person who is not located in Ontario? Click to copy link. The College of Psychologists of Ontario does not have the authority to grant permission to provide psychological services anywhere other than in Ontario. College members may provide services in other jurisdictions wherever they are permitted to by the psychology regulatory body in that jurisdiction, so long as they do so in accordance with the Standards of Professional Conduct, 2017. I am registered as a psychological services provider in another province or state. May I provide psychological services in Ontario? Click to copy link. Ontario statute requires that one must be a member of the College of Psychologists of Ontario, or supervised by a member of the College, to provide psychological services to a person located in Ontario. The Psychology Act, 1991 states: Restricted titles 8 (1) No person other than a member shall use the title “psychologist” or “psychological associate”, a variation or abbreviation or an equivalent in another language. Representations of qualification, etc. (2) No person other than a member shall hold himself or herself out as a person who is qualified to practise in Ontario as a psychologist or psychological associate or in a specialty of psychology. Idem (3) A person who is not a member contravenes subsection (2) if he or she uses the word “psychology” or “psychological”, an abbreviation or an equivalent in another language in any title or designation or in any description of services offered or provided. Exception for university faculty (4) Subsections (1) and (3) do not apply to a person in the course of his or her employment by a university. Temporary, limited membership is available to individuals licensed to provide psychological services in other jurisdictions allowing them to provide services for a period of up to 12 months. To learn more and to apply for this form of membership please click here. I am registered in another jurisdiction but not in Ontario. May I provide services to families or groups of individuals where some individuals are located in my own jurisdiction, while other participants are located in Ontario? Click to copy link. In order to provide psychological services to an individual located in Ontario, or hold out as qualified to do so, the Psychology Act, 1991 requires that one must be a member of the College of Psychologists of Ontario, or be working under the supervision of a member of the College. There may be circumstances in which there is a need to include, by way of videoconferencing or teleconferencing, an individual located in Ontario in a session conducted with your clients in your own home jurisdiction. So long as the involvement of the person in Ontario is limited to their role as a resource in treating or assessing the clients in your own local jurisdiction, and not for the purpose of treating or assessing the individuals located in Ontario, they may be included. In such a case, they may be considered a collateral resource for the benefit of the clients receiving your service in your own jurisdiction. I am a registered provider of psychological services in another jurisdiction but am not a member of the College of Psychologists of Ontario. May I provide services to someone located in Ontario temporarily exclusively because of the COVID-19 Pandemic? Click to copy link. The Psychology Act, 1991 limits the provision of psychological services in Ontario to members of the College of Psychologists of Ontario. In the absence of legislative amendments, the College is not able to authorize anyone other than members of the College to provide telepsychology services to clients located in Ontario. Under normal circumstances, the College views such activities by non-members as “unauthorized practice” and considers whether there is a need for appropriate action. The College has carefully considered the extreme circumstances in which we find ourselves. We recognize this must be taken into account with regard to duly registered/licensed practitioners from other jurisdictions who must provide telepsychology services into Ontario for their existing clients during the current emergency situation. Therefore, in response to the urgent COVID-19 situation, the College will not initiate an “unauthorized practice” action against an out of province practitioner provided the practitioner is:
– existing clients temporarily in Ontario due to the COVID-19 situation when it is clinically ill-advised to temporarily stop services and/or to transfer the service to a member of the College of Psychologists of Ontario; – clients who are temporarily located in Ontario due to the COVID-19 situation and are entitled to receive those services as a benefit of their registration with a University or College or other benefit program outside of Ontario, where the services will be provided by an out of province practitioner on behalf of the University or College counselling service or other benefit program; or – clients who are temporarily located in Ontario due to the COVID-19 situation, when it is reasonably expected that the clients will require continuing services with the same practitioner upon the client’s return to the jurisdiction in which the clinician is registered. Out of province practitioners are asked to confirm their understanding and acceptance of the requirements listed above by notifying the College of their intention to provide telepsychology service to existing clients in Ontario. Practitioners should email the College () providing their name, the jurisdiction in which they are registered/licensed, and their registration/license number. While the College will endeavour to acknowledge receipt of this information, practitioners need not wait for confirmation before initiating service. What are the College’s requirements concerning raising fees for service with existing clients and is there a necessary notice period for fee increases? Click to copy link. The Standards of Professional Conduct, 2017 state that: 11.1 Fees and Billing
Arrangements Practical Application: Fees for services should be determined on a consistent basis, regardless of the payer. A member may, however, offer pro bono services or apply a sliding scale to ensure access to services and affordability. While this Standard is most often thought of in the context of initiating services with a new client, it also can be read to apply with respect to the ongoing provision of services. That is, “providing psychological services” could be read to mean each instance of providing a psychological service. It would be inappropriate for a client to learn that their fees had been increased when they receive a bill for a service that had already occurred. Increased fees may be an important consideration for clients in the ongoing informed consent to service process and some clients may need to reconsider whether they are able, or prepared, to continue at the new proposed rate. There is no specific period of notice for a fee change set out in any Regulations or in the Standards as this is a matter of professional judgment. Adequate notice of the change however, is important and there may be clients who experience a fee increase as akin to indirect termination of therapy. In cases where the client may not agree to an increased fee, and a member is not prepared to continue to provide services at the existing rate, guidance regarding the termination of services can be found in section 8 of O.Reg. 80.1/93: Professional Misconduct. This section of the Regulation states that termination of service that is needed is an act of professional misconduct unless: i. the client requests the discontinuation, Although there are informal ‘rules of thumb’ with respect to ‘winding down of therapy’, often based upon the length of time a person has been receiving treatment, the College does not set any particulars in this regard. If the client requires additional services but can not or will not pay the increased rate, it would be reasonable and appropriate to work with them for a time period that, in the member’s professional judgment, is sufficient to arrange for a transfer of care to another service provider and avoid any harm due to a disruption of treatment. I am supervising non-members who are providing services at a clinic that is not my own. The supervision is only schedule to occur for a limited period of time. When the supervision is concluded, who keeps the patient files? Is it the clinic that the patient has been going to or am I required to maintain the file? Click to copy link. The answer to this question depends upon who has been identified as the Health Information Custodian. Under the Personal Health Information Protection Act, 2004 (PHIPA), it is possible that either a health care practitioner or a person who operates a group practice of health care practitioners can act as the Health Information Custodian (HIC). While either is possible, only one must be established at the onset of services. Generally, this will be the particular individual or entity they authorize to collect their Personal Health Information. If, in this scenario, the operator of a group practice is not the HIC, then, the following Standard is applicable: 4.1 Responsibility of Supervisors of Psychological Service Providers It then follows that the records are considered to be the records of the supervising member. This is supported by the following additional Standard: 9.1.2 Members Responsible for Supervising Supervised Practice Members and Non- Members If the organization is not the HIC, at the end of the engagement, in most case it is the supervising member who is the HIC and the records must remain with them for the required retention period. When consulting to an organization, such as a foster agency, about children in their care, what are my obligations with respect to the client? For example, who is required to obtain informed consent or to collect and maintain the records containing personal health information? Click to copy link. In order to answer this question, it is important to consider what is meant by “consulting” as it can be understood to mean different things in different contexts. Consultation is defined in the Standards of Professional Conduct, 2017 as: the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information. If this describes the nature of the relationship with the agency, then the organization is generally considered to be the client. In the case of an organizational client, the member providing consultation is required to maintain records in accordance with the following Standard: 9.3 Organizational Client Records The “nature of each material service provided to the organizational client” in c) above, should likely include sufficient information to address queries about the quality of the particular consultation, should that information ever be needed. An organizational client record must be retained for at least ten years following the organizational client’s last contact. If the organizational client has been receiving service for more than ten years, information contained in a record that is more than ten years old may be destroyed, if the information is not relevant to services currently being provided. It is the responsibility of the individual providing services to ensure that proper client consent is obtain for the service being providing. A person acting as a consultant to a service provider would not likely be in a position to seek consent from the person receiving services from the consultee. The consultant may, in fact, never come into contact with the person receiving services from the consultee. In some cases they may not even know their name. If a member is identified as a “consultant” but they are personally providing the psychological assessment, diagnosis, opinion or intervention, as opposed to “consulting” to or supervising another service provider, this would likely be considered a direct service. In this case, all of the Standards relevant to direct service provision, including those pertaining to consent and record-keeping, would be applicable. In circumstances where it is unclear whether one is providing direct service or consultation, it may be useful to ask: Is this a service I would provide autonomously to an individual or family in a clinical practice, or is it providing advice to another autonomous service provider who is simply looking for the input with respect to clinical decisions they must make themselves? What Should I Consider when Transferring Clients When I Transition from Supervised Practice to Autonomous Practice? Click to copy link. Following the successful completion of an Oral Examination, and after you are issued a Certificate of Registration authorizing Autonomous Practice, you will no longer require supervision in your authorized areas of practice and client populations. Although formal supervision is no longer required, consultation and other forms of peer support can be of great value throughout your professional career. Under Supervised Practice, your supervisor was responsible for your adherence to the Legislation, Regulations, Standards and Ethical Guidelines applicable to your practice. If you have been issued a Certificate of Registration authorizing Autonomous Practice you are now fully accountable for the discharge of your own professional and ethical responsibilities. While the applicability of various statutory and ethical obligations can be straightforward when taking on new clients, taking on the management of professional responsibilities with clients who were initially seen under supervision often leads to questions about such matters as informed consent, fees and billing, and clinical records. Continuing to Work with Clients you had Previously been Supervised with If you will be continuing to work with individuals who you worked with during your period of Supervised Practice, it is important consider the changes your new Autonomous Practice registration entails. It’s important to:
I am a member of the College of Psychologists of Ontario but will be residing/traveling outside of Ontario. May I provide services to clients residing in Ontario? Click to copy link. A member of the College of Psychologists of Ontario may provide services to clients located in Ontario, whether or not the College member is in Ontario at the time. In other words, a member of the College of Psychologists of Ontario who is travelling outside of the province may provide services via technology to clients located in Ontario while they are away. Specific information about the provision of services via technology may be found in in Standard 15 of the Standards of Professional Conduct, 2017. Addressing Possible Incapacity of a Colleague: A colleague, who is also a member of the College, has disclosed to me that they are suffering from “burnout”. They recognize the risks of this to their clients. I am providing them with peer support, which appears to be helping but wonder if there is a duty to report this situation to the College? Click to copy link. First, it is good to know that you are helping them to address these issues, as a colleague. It does not appear that you have a duty to report this situation. There are two situations in which you may have a mandatory reporting obligation, but this does not sound like it is one of them. The two situations are set out in Section 85.2 and Section 85.5 of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991. The first applies to operators of facilities in which a health professional provides services: Reporting by facilities 85.2 (1) A person who operates a facility where one or more members practise shall file a report in accordance with section 85.3 if the person has reasonable grounds to believe that a member who practises at the facility is incompetent, incapacitated, or has sexually abused a patient. From your description of the situation, it doesn’t sound like you operate a facility in which this colleague practices, therefore this section would not apply. The second relevant section of the Code applies to reporting by employers, etc. Reporting by employers, etc. 85.5 (1) A person who terminates the employment or revokes, suspends or imposes restrictions on the privileges of a member or who dissolves a partnership, a health profession corporation or association with a member for reasons of professional misconduct, incompetence or incapacity shall file with the Registrar within thirty days after the termination, revocation, suspension, imposition or dissolution a written report setting out the reasons. Same (2) Where a member resigns, or voluntarily relinquishes or restricts his or her privileges or practice, and the circumstances set out in paragraph 1 or 2 apply, a person referred to in subsection (3) shall act in accordance with those paragraphs:
Application (3) This section applies to every person, other than a patient, who employs or offers privileges to a member or associates in partnership or otherwise with a member for the purpose of offering health services. 1993, c. 37, s. 23. Once again it does not appear that you would have a reporting obligation unless you are the colleague’s employer and due to concerns of incapacity you terminated their employment or revoked, suspended or imposed restrictions on their privileges to practice or you dissolved a partnership, a health profession corporation or association with them. Hopefully, with your collegial support, this individual will be able to mitigate the risks to themself and their clients and find relief from their distress. If it appears advisable for your colleague to obtain professional services, then you should consider referring them to an appropriate mental health professional, to avoid becoming involved in a dual relationship. Addressing Possible Incapacity of a Client: I am providing therapeutic services to a member of another regulated health profession and think that mental and behavioural impairments may be interfering with their effective or safe practice. Do I have a duty to report if I believe the client is impaired due to a mental health condition? Click to copy link. There are two situations in which members have a duty to report incapacity-related concerns. These are set out are set out in Section 85.2 and Section 85.5 of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991. Neither of these appear to apply to a situation in which the concern regarding incapacity is with a client. If you believe that this individual is putting members of the public at risk you can always make a report to the professional’s College, with their consent. In addition, Section 40 of The Personal Health Information Protection Act, 2004 also permits you to make a voluntary report, without the client’s consent, if you believe, on reasonable grounds that such a disclosure is necessary as they are putting clients at significant risk of serious bodily harm: Disclosures related to risks
Duty to Take Steps to Avoid Incapacity: We are funders of psychological services and are aware of some College members who appear to provide services for 10 hours a day, on a daily basis with no indication of breaks, lunch, or dinner. This raises concern about “burnout” and, ultimately, client care. Does the College have any rules which limit the number of consecutive sessions members can offer or require members to limit their activities, for their own sake and the sake of their clients? Click to copy link. Section 13, specifically 13.2, of the Standards of Professional Conduct, 2017 requires members to responsibly assess their well-being and avoid impairment:
13.2 Compromised Objectivity, Competence or Effectiveness Due to Other Factors A member must not undertake or continue to provide psychological services when personal, scientific, professional, legal, and financial or other interests could reasonably be expected to:
Members are expected to use their professional judgement in considering their personal workload tolerance. The Quality Assurance Committee had developed a Self-Care Plan to provides some guidance in this area. The Quality Assurance Program requires that every member formally reflect upon their own need for self-care and mitigate the risk of harm to their own well-being and consequently that of their clients. Can members who employ other practitioners offer financial or other incentives based upon clinical productivity and performance? Click to copy link. It is appropriate for private practitioners, including contractors, to be compensated based on time spent and the complexity of services provided. If providing additional incentives to treatment providers could be reasonably expected to lead to decisions about service planning that are motivated by factors beyond client needs this could be problematic. For example, this could be problematic if compensation rather than client needs lead to practicing the profession while in a conflict of interest and/or providing services which are not likely to benefit the client; both of which are considered acts of Professional Misconduct. Members are advised to support their staff and contractors in ensuring that client need is the primary consideration in service planning. I am aware of the requirement for supervisors to co-sign “all psychological reports and formal correspondence related to psychological services”. Does this mean they should co-sign all clinical notes, like progress notes in the client’s chart? Click to copy link. As required by Standard 4 of the Standards of Professional Conduct, 2017, members supervising anyone who is not a member of the College and any member with a Certificate of Registration Authorizing Supervised Practice must co-sign all psychological reports and formal correspondence related to psychological services prepared by their supervisee. The term “formal” has not been officially defined so members must use their professional judgment based upon the particular circumstances of each situation. In generally, formal documents would likely include printed or electronic communications which ordinarily require the person responsible for the information to provide their endorsement of the information in the form of a signature. This might include letters, reports, official memos, and emails about a client which would reasonably be expected to provide information about a client to anyone outside of the organization in which the supervision is occurring. When in doubt about whether to co-sign a document, it may help to consider that a supervisor’s signature is meant to provide an assurance to readers of the information it has been endorsed by the professional responsible the service. Even if not strictly required to co-sign a document, supervising members may do so if they wish to inform readers that they endorse the contents. Can a person authorized to work with individuals but not families involve family members in the individual’s therapy. In other words, where is the line between family therapy and involving family members to support interventions with an individual? Click to copy link. The answer to this question depends upon the reason for involving family members in the treatment of an individual. Individual therapists appropriately may involve a client’s family member(s) for the purpose of facilitating support for intervention with the individual. For example, a person’s family member(s) might be asked to become involved in making changes in the client’s environment to facilitate change or to be trained to provide reinforcement for desirable behaviours as part of a behavioural intervention program. A family member could also be asked to attend sessions with a person who, for some reason, may not be able to successfully participate in individual therapy without support. In such a scenario, the family member(s) attending would not be the object of the intervention themselves but would instead be there to help the client obtain optimal benefit from the individual therapy. If the purpose of involving family members is to facilitate any changes in the family dynamics or the way in which family members interact with one another, this would be viewed as an family intervention. For example, this would be the case when it is the therapist’s intention to address an individual’s symptoms or behaviours of concern by addressing the patterns of interaction between family members which precipitate or maintain the difficulties. In order to provide such intervention to families, one must have specialized knowledge and training and the specific authorization of the College. Must I report suspected harm to self or others? Click to copy link. Originally published in Volume: 1 Issue: 1 of HeadLines. In Ontario, there is no duty to warn, if one interprets “duty” to mean a mandatory requirement. That is, there is no obligation to report concerns that a client/patient may pose a danger to themselves or others. It is important to understand however, that this does not mean that one cannot, or should not, take some action in the face of such serious concerns. The Personal Health Information Protection Act, 2004 (PHIPA) sets out a member’s obligations with respect to maintaining the confidentiality and privacy of personal health information. The legislation does provide an exception to the duty of confidentiality where a member finds it necessary to notify someone of a serious risk to a person’s safety. PHIPA states: 40 (1) A health information custodian may disclose personal health information about an individual if the custodian believes on reasonable grounds that the disclosure is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons. 2004, c. 3, Sched. A, s. 40 (1). A key concept within this section of PHIPA is contained in the words “may disclose”. PHIPA does not oblige a member to make such disclosures, but it permits one to do so “for the purpose of eliminating or reducing a significant risk of serious bodily harm”. With this purpose in mind, PHIPA reinforces a member’s need to use their knowledge of the client/patient and their professional judgement to determine the best, most appropriate, action to take. Q1: As a member of the College, I am considering closing my physical office and offering exclusively virtual services. Is this permitted and what things should I be considering? Q2: As a member of the public, I would like to know why the College does not require members to see individuals in person, particularly those for whom virtual services would be considered less than optimal? Click to copy link. With the relaxation of pandemic-related restrictions on in-person services, some members are exploring whether to return to in-person service delivery or to continue providing all services virtually. There is no specific prohibition against offering online services. Members must use their professional judgment in deciding whether to offer in-person vs. virtual services, taking into consideration the needs of each individual seeking services and the available evidence regarding efficacy. Members are expected to provide services in a safe and effective manner. If a member wishes to restrict their practice to virtual services, they must decide which populations and problem areas can be effectively assisted without in-person contact, and under what circumstances this would be appropriate. There is no ‘one size fits all’ when it comes to planning service delivery in psychology. It may be that some clients are more comfortable with on-line services and might be more likely to engage in services provided via technology and some intervention models may lend themselves to on-line delivery more than others. Members should also consider some concerns that have been raised about services delivered via technology. These include: • loss of many visual cues and other sensory inputs which are less accessible via the computer screen or telephone than when physically present with a client; Members providing virtual care must adhere to all of the Standards of Professional Conduct, 2017 including, but not limited to, Standard 15, Use of Technology in the Provision of Psychological Services. An additional resource members may find useful is the American Psychological Association’s Guidelines for the Practice of Telepsychology. This is a helpful guide in reflecting upon the delivery of services via technology. Some of the areas addressed in the article are the need to: regularly monitor and assess the progress of the client/patient to determine if the continued provision of telepsychology services remains appropriate and beneficial; discuss any concerns with the client/patient; and appropriately terminate remote services and provide assistance in arranging alternative services, if necessary. If a member initially agreed to provide in-person services to a client; transitioned to on-line services during the pandemic; and wishes to continue with on-line services beyond the point at which it seems necessary, this can be problematic if the client wishes to return to in-person services. In such a situation, a member may decide to terminate services against a client’s wishes, but should be mindful of the section 1.8 of O. Reg. 801/93: Professional Misconduct Regulation which sets out the manner in which one can do so that would not be considered professional misconduct. Must I call 911 to report suspected harm to self or others? Click to copy link. Originally published in Volume: 1 Issue: 1 of HeadLines The legislation does not direct a member to contact any particular organization, institution or individual should it be determined there is a need to take some action. In considering a breach of confidentiality under section 40 of PHIPA, it is important that, in keeping with the stated purpose, the disclosure be made to someone who is in a position to ‘eliminate or reduce a significant risk of serious bodily harm’. When faced with serious concern about a client’s/patient’s risk of harm to self or others, members have to make the difficult judgment about who to contact in this time of crisis. When initially reviewing the limits of confidentiality regarding risk of harm with a client/patient, members may wish to discuss this with the client/patient. That is, engage the client in a discussion of who they believe should be called in the event of a crisis. The client/patient may identify a family member, other health care provider, close friend, member of the clergy, a community worker, an organization with which they have been involved or some other individual. While the ultimate decision rests with each member based on their best clinical judgement, taking into account their understanding of the client/patient and the particular situation, this previous discussion may prove helpful in deciding upon the most appropriate action. It is important to make a distinction between situations of client/patient risk of harm to themselves or others, often referred to as “duty to warn” and other mandatory reporting obligations. Section 40 of PHIPA does not apply to situations where one has reasonable grounds to suspect that a child is in need of protection or one suspects abuse or neglect in a retirement or long-term care facility. In these situations, mandatory reporting to the appropriate authority is required. I have been asked to release client records which contain information about multiple parties. In this case, one member of a family wishes to gain access to family therapy records which contains information about other individuals of which some members of the family are not aware. Are there rules about what I must, or may, redact? Click to copy link. The answer to this question requires interpretation of legislation and College staff are not qualified or authorized to provide legal advice. Members who are considering refusal of a specific request for information may wish to obtain independent legal advice, given that release of confidential information, or the refusal to do so, can be a high-stakes decision for all concerned. The following information may be of assistance in obtaining legal consultation. The Personal Health Information Protection Act, 2004 (PHIPA)sets out the applicable rules to be
considered when addressing a request for personal health Personal Health Information is defined, in section 4.(1)(a) of the Act, as information that “relates to the physical or mental health of the individual, including information that consists of the health history of the individual’s family. . .” Section 1 (b) of PHIPA states that one of the purposes of the Act is “to provide individuals with a right of access to personal health information about themselves, subject to limited and specific exceptions set out in this Act”. The Act also provides that information an individual is entitled to access can be provided to another party, with the consent of the individual or of the individual’s authorized substitute decision-maker. Whenever faced with a decision about whether to provide access to information contained in a client record, it is a good idea to review the list of exceptions to the requirement to do so. These exceptions are set out in in Section 52(e) of the Act where one is not required to allow access to information if, (e) granting the access could reasonably be expected to, i. result in a risk of serious harm to the treatment or recovery of the individual or a risk of serious bodily harm to the individual or another person, The Act, section 52(2) goes on to say that a health information custodian may provide only parts of a person’s record “that can reasonably be severed from the part of The Information and Privacy Commissioner of Ontario recently considered a complaint about an agency’s refusal to grant one family member access to the entirety of a family’s therapy records. In PHIPA Decision 158, the Commissioner found that the Personal Health Information (PHI) of each family therapy participant is theirs alone and not PHI of the other therapy participants. They went on to say that family therapy records may contain “communal” or “shared” information that can form part of each participant’s PHI. Communal or shared information was described as information about family health history, overall family relationships or dynamics, as well as general themes that arose in the course of family therapy. The Commissioner ultimately decided that the complainant’s right of access under PHIPA was limited to only to PHI that can reasonably be severed from the records. The Decision explains that the Act is intended to enable individuals to access information about their family health history allowing them to make informed decisions about their own health care but that anything beyond shared or communal information, may have been collected with an expectation that it would remain confidential. The Decision further explained that this best respects the confidentiality of that information; fosters trust between family therapy participants and custodians; promotes participant autonomy over access to their own personal health information; and promotes candid discussion and unguarded participation in family therapy sessions. The Decision indicated that the right of access to information is limited by section 52(3), of the Act, which provides that an individual will only have a right of access to an entire record if the record is “dedicated primarily” to their personal health information. The following examples of factors to consider in determining whether a record is “dedicated primarily” to the personal health information of a requester are provided:
The following “best practices” are suggested within the Decision:
What is the exact age range of clients that may be treated by someone authorized in adult Clinical Psychology? Click to copy link. Originally published in Volume: 1 Issue: 2 of HeadLines The College doesn’t specify hard borders between age ranges for the different population groups but recognizes that there are not always clear demarcations with respect to population groups, particularly with respect to age. Members are expected to use their professional judgment to determine whether, in all the circumstances, the person’s status is consistent with the status of those for whom they are authorized to provide service. For example, when trying to determine whether a client, at a border age, is an “adult”, “adolescent”, or for that matter a “senior”, it would be important to consider whether the person’s abilities, life circumstances and challenges are consistent with those which would normally be expected within the population groups for which the member is authorized to work. May a member authorized in Clinical Neuropsychology conduct a psychoeducational assessment, or must they be authorized in School Psychology? Click to copy link. Originally published in Volume: 1 Issue: 2 of HeadLines As members know, the College has defined Authorized Areas of Practice. The definitions for the authorized areas of practice focus on the nature of difficulties the services are intended to address, as opposed to the specific type of service offered. In order to answer questions like this it may be most helpful to keep this distinction in mind. The Practical Application posted with Standard of Professional Conduct, 2017 5.1 states: In deciding whether one is authorized and competent to provide a service, the nature of the client’s presenting difficulties will generally determine whether the member has the appropriate and required authorization. For example, if a client who has suffered a traumatic brain injury has been referred because of a need to assess the nature of their neuropsychological deficits, it is expected that the member providing the assessment would have clinical neuropsychology as an authorized area of practice. If the person was referred because of difficulty performing activities of daily living or occupational requirements, it is expected that the member would be authorized to work in the area of rehabilitation psychology. If the person was referred because of suspected anxiety or depression, then it is expected that the member would be authorized to practice in clinical psychology… It’s likely that most of what are often called “psychoeducational assessments” are meant to help identify the reason an individual has difficulty learning in an educational environment and to provide information for the purpose of planning for remediation of these difficulties. If there is reason to believe that the nature of difficulties is neuropsychological in nature, then it would appear reasonable for someone with authorization in the area of Clinical Neuropsychology to assess the client. At the same time, authorization in School Psychology requires certain knowledge not generally required for the practice of Clinical Neuropsychology, including knowledge of:
If making specific recommendations which require such knowledge, it’s expected that a member who has not acquired this knowledge would seek the professional guidance of another member who is authorized to practice School Psychology. Is a member permitted to provide virtual family therapy, where one family member is located outside of Ontario during the sessions? Click to copy link. Originally published in Volume: 1 Issue: 2 of HeadLines Members may provide services to an individual located in another jurisdiction, but only if they have been authorized by the College or Board in that jurisdiction to do so. If the psychology regulator in the other jurisdiction permits this practice, it would also be important to confirm that one’s professional liability insurance coverage extends to one’s work with an individual in the other jurisdiction. When conducting parenting sessions, in the context of child and adolescent treatment, is it permissible to issue an invoice or receipt under the child’s name if the child has not participated in the session? Click to copy link. Originally published in Volume: 1 Issue: 3 of HeadLines The Professional Misconduct Regulation and Standards of Professional Conduct, 2017 do not specifically address the issue of whose name to put on an invoice. Therefore, one must ensure adherence to the broader rules when deciding about how to proceed regarding what information to put on an invoice or receipt. The most important thing is to ensure is that any document, including an invoice or receipt, could not reasonably be seen as, 20. Making a record, or issuing or signing a certificate, report, or similar document that the member knows or ought to know is false, misleading or otherwise improper. [O.Reg 801/93 Professional Misconduct] In cases where multiple members of a family are treated at different times and in different constellations, it would be reasonable to make a principled decision and apply the same logic whenever similar situations arise, regardless of the wishes of the particular client or what their insurance coverage allows. In this particular case, if an intervention is intended to impart parenting skills to the parent, it might be reasonable to assume that parenting work is intended to help the parents change their behaviour and consider that the services were provided to the parents. This would be different than meeting with the parents in order to provide them with therapy progress information or information to help them support the work being done individually with the child. Most of the time this question comes up in the context of a family with per-person insurance coverage limits. In situations like this, a parent may ask to revise invoices or receipts once a family member reaches their insurance coverage limit. One must be careful not to issue an invoice in a manner where it could be alleged that the person issuing the invoice was participating in something that could be seen as misleading. Wherever possible, it might be helpful to ensure an invoice provides clear information about the nature of service and identifies those to whom the service was provided. If a person to whom the service was provided is different than the person who is the focus of the treatment, it may be appropriate to note on the invoice something like services were provided to Mr. and Mr. Smith re: the treatment of their child James Smith. Clients may also be asked to consult with their benefits providers about how to best maximize their coverage and the insurer’s preferences with respect to billing. While it may feel helpful to assist clients in maximizing their insurance coverage, insurers are becoming increasingly vigilant about such matters and this could result in denial of benefits to the client and a complaint to the College. It should be left to the client(s) and their insurers to work out issues about insurance coverage limits. Is it permissible to introduce clients with similar concerns to each other, for the purpose of facilitating mutual support? Click to copy link. Originally published in Volume: 1 Issue: 3 of HeadLines This scenario presents some potential challenges. Consent may be more complicated than might initially meet the eye. The clients in such a situation could decide to enter the relationship because of a perceived expectation by the therapist that they will agree and not want to disappoint the therapist by declining the invitation. For this reason, if this were to occur, such an opportunity would have to be presented in an entirely neutral manner. To be fully informed consent, each client would have to be made aware of all the potential benefits and risks. These benefits would obviously include mutual support. On the downside, entering a relationship in which the client could be taking on further emotional (and perhaps other) demands should be presented as a risk to their own therapeutic relationship with the therapist and consequently to their therapeutic progress. Confidentiality could also become a challenge when clients are introduced and encouraged to communicate. While each client would know that the other was seeing the same therapist, the therapist would have to be vigilant not to share any information about the other client without authorization. This would become difficult if they wished to talk about the other client or about interventions being used with them and it could become difficult to avoid inadvertently providing information, even in refusing to actively answer certain questions that could be posed. Even if information about one client was never disclosed to the other, the therapist would have to be vigilant about avoiding the collection of information about one from the other without consent. Even with full consent, collection of such information could pose challenges to professional objectivity, if information arose about any conflict arising between these individuals or any adverse information about them. This would become a dual relationship in the same way as working with clients who are relatives or friends of one another would, and it’s best to avoid dual relationships. There are no specific prohibitions against introducing clients, but these are some of the challenges in managing such an intervention, without the safeguards of therapist mediated interaction between clients, as might occur in a therapist mediated mutual support group. After retiring may a retired or former member hold themselves out as an expert at a trial involving a current client? Click to copy link. Originally published in Volume: 1 Issue: 3 of HeadLines A member of the College with a Retired Certificate of Registration or a former member may not provide any psychological services of any kind. They would however, be able to provide information regarding services provided while holding a Certificate of Registration Authorizing Autonomous Practice. If, for example, the court required the client to be reassessed or needed testimony about matters not addressed while the member held a Certificate of Registration Authorizing Autonomous Practice, this would appear to be a new service and not one that should be provided unless one is authorized to provide psychological services. The College is not in a position to require, and assure the public, that members with a Retired Certificate of Registration are maintaining their professional competence through continuing professional development. They are also not required to maintain their professional liability insurance coverage, which protects clients who may have a legitimate claim for financial awards as a result of a member’s professional activities. This is obviously also the case for retired members as well. May I provide a professional opinion about a client, when the information is likely to be used for purposes unrelated to the focus of the service I have provided? Click to copy link. Originally published in Volume: 1 Issue: 4 of HeadLines This question often arises when a member has been treating or assessing a client where the primary focus of clinical attention has not involved an assessment of the factors bearing upon the opinion being sought. This may occur, for example, when a member has conducted a psychoeducational assessment, or treatment for an anxiety disorder, and the member is later asked to provide information to be used in a parental rights matter. Another example is when a member has provided psychotherapy to address a client’s emotional disorder and is then asked to provide a letter regarding the individual’s readiness to return to work after an injury. In providing professional opinions, a member must consider the following requirement in section 10.3 of the Standards: 10.3 Rendering Opinions In the first example above, a member should only provide information that they can reasonably expect to be used to determine custody or access arrangements if they have conducted an appropriate assessment for the purpose of determining child custody and/or access. Likewise, in the second example, a member should only opine on a person’s suitability to return to work after appropriate consideration of the person’s rehabilitation needs and the task requirements of the workplace. Members must ensure that they work only within their authorized areas of practice and provide only those services in which they have the adequate knowledge, skill, and experience, within those authorized areas. Even when a member is authorized and qualified to provide an opinion unrelated to the service they have been providing, and have conducted an adequate assessment, problems may arise if they assume a dual role. Usually, such requests for information are related to the rights and entitlements of the client. They also have an impact on others, such as family members, colleagues, or employers. A clinician who has not conducted an appropriate, objective assessment of the matter at hand can face challenges with respect to whether they have exercised sufficient neutrality. There may also be a perceived conflict of interest if it appears that a continued professional relationship could be endangered by offering an opinion that is seen to be unfavourable to the client’s interests. When supervising non-members, or supervised practice members of the College, am I required to sign the client invoices and receipts? Click to copy link. Originally published in Volume: 1 Issue: 4 of HeadLines Section 4.1.1 of the Standards of Professional Conduct, 2017 requires that: 8) the supervising member must ensure that billing and receipts for services are in the name of the supervising member, psychology professional corporation or employer and clearly identify the name of the supervising member and the name, relevant degrees and professional designations of the supervised psychological service provider There is no explicit requirement under this Standard for there to be a signature, however, the following Standards are also applicable to these situations: 4.1.2 Supervision of Supervised Practice Members; and Invoices (and receipts) would be considered by most to be “formal correspondence” and should be co-signed by supervisors. Within the past few years, the College has received an increasing number of complaints about the transparency of such documents and what some third-party payers have alleged to be misleading practices by members. Increasing vigilance by third-party payers has, unfortunately, led to denial of insurance benefits for some clients. It has also led to an increased level of scrutiny of College members by claims adjusters. Supervisors should demonstrate that they carefully oversee the administration of their services by personally applying their own signatures to invoices issued in their names. What are the record keeping requirements with respect to a client I met under a consultation contract to an agency? Click to copy link. Originally published in Volume: 1 Issue 4 of HeadLines In determining the appropriate record keeping requirements it’s important to consider what is meant by “consultation”. Sometimes, those using the title “consultant” are actually providing direct services to individuals. For example, this would be the case if the service involved interviewing clients of an agency and providing an assessment of their treatment needs. The member would, in such a situation, be required to create a client record in accordance with section 9.2 of the Standards of Professional Conduct, 2017. Even if, by virtue of the administrative arrangements, the client is also a client of the agency and agency is the Health Information Custodian, the definition of client in the Standards is applicable: Client: an entity receiving psychological services, regardless of who has arranged or paid for those services. A client can be a person, couple, family or other group of individuals with respect to whom the services are provided. A person who is a “client” is synonymous with a “patient” with respect to the administration of the Regulated Health Professions Act (1991). If involvement in a case was limited only to discussing the client with the clinician providing the direct client care, it is more likely that the consultation met the definition provided in the Standards: Consultation: the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information. If acting as a consultant, as it is defined above, then the following requirements regarding contents of records apply: 9.3 Organizational Client Records
Even though the phrase “nature of” each material service, is not defined above, most prudent members record enough information to indicate the nature of the problem discussed and the nature of advice given. Standard 9.4 provides the record retention requirements with respect to organizational records: 2) The organizational client record must be retained for at least ten years following the organizational client’s last contact. If the organizational client has been receiving service for more than ten years, information contained in the record that is more than ten years old may be destroyed if the information is not relevant to services currently being provided to the client. Standards of Professional Conduct 2017What are the College’s requirements concerning raising fees for service with existing clients and is there a necessary notice period for fee increases? Click to copy link. The Standards of Professional Conduct, 2017 state that: 11.1 Fees and Billing Arrangements Practical Application: Fees for services should be determined on a consistent basis, regardless of the payer. A member may, however, offer pro bono services or apply a sliding scale to ensure access to services and affordability. While this Standard is most often thought of in the context of initiating services with a new client, it also can be read to apply with respect to the ongoing provision of services. That is, “providing psychological services” could be read to mean each instance of providing a psychological service. It would be inappropriate for a client to learn that their fees had been increased when they receive a bill for a service that had already occurred. Increased fees may be an important consideration for clients in the ongoing informed consent to service process and some clients may need to reconsider whether they are able, or prepared, to continue at the new proposed rate. There is no specific period of notice for a fee change set out in any Regulations or in the Standards as this is a matter of professional judgment. Adequate notice of the change however, is important and there may be clients who experience a fee increase as akin to indirect termination of therapy. In cases where the client may not agree to an increased fee, and a member is not prepared to continue to provide services at the existing rate, guidance regarding the termination of services can be found in section 8 of O.Reg. 80.1/93: Professional Misconduct. This section of the Regulation states that termination of service that is needed is an act of professional misconduct unless: i. the
client requests the discontinuation, Although there are informal ‘rules of thumb’ with respect to ‘winding down of therapy’, often based upon the length of time a person has been receiving treatment, the College does not set any particulars in this regard. If the client requires additional services but can not or will not pay the increased rate, it would be reasonable and appropriate to work with them for a time period that, in the member’s professional judgment, is sufficient to arrange for a transfer of care to another service provider and avoid any harm due to a disruption of treatment. Questions and Answers Regarding the Controlled Act Related to Psychotherapy. The following information is intended to address the most frequently asked Question the College has received. Click to copy link. Introduction The College has received many questions from members of the College and the public about the Controlled Act related to Psychotherapy since it was proclaimed on December 30, 2017. Members of the College of Psychologists are permitted to perform the Controlled Act related to Psychotherapy, so members need not be concerned whether psychotherapy they provide falls within the definition of the Controlled Act. As always, members are responsible to ensure that they are competent to provide any psychological service they offer. The definition of when services fall within the Controlled Act becomes much more important when one is considering supervising someone in the performance of the Controlled Act. Information currently available on the College website may address some of the member inquiries. This can be found in the Practical Applications to the Standards of Professional Conduct, 2017 in the Standards of Professional Conduct. Further information is available and in the Questions and Answers document accompanying the Standards The following information is intended to address the most frequently asked Questions the College has received. If there are other questions, you please email them to . Definitions The Controlled Act related to Psychotherapy is defined in section 27(2) of the Regulated Health Professions Act, 1991 (RHPA) as:
The legislation does not define the terms used in this definition particularly “psychotherapy” and what is meant by “serious”. Within the Psychotherapy Act, 2007 however, the ‘practice of psychotherapy’ is defined as:
The legislation does not define “serious” with respect to what is a “serious disorder . . . that may seriously impair”. This is left to the treatment provider to apply his/her own education, skill, and training to determine. As noted above, this need not be of concern to members personally offering psychotherapeutic services as members of the College are authorized to perform this Controlled Act. It is important, however, when one is considering providing supervision. In the absence of any available jurisprudence defining these terms within the definition, especially as related to a “serious disorder . . . that may seriously impair” members of the College are expected to exercise their professional judgment in deciding whether the services which they contemplate supervising constitute the Controlled Act. Whether an activity constitutes the Controlled Act requires consideration of the level of difficulty and potential impairment experienced by the client and is not dependent on a specific diagnosis or therapeutic modality. Members who are not comfortable exercising their own professional judgment in deciding whether a service falls within the “serious disorder . . . that may seriously impair” definition of the Controlled Act should consult with another member, another regulated colleague authorized to perform this Controlled Act or seek legal advice. Questions and Answers 1. Is the provision of all “psychotherapy service” now controlled by the new legislation? It is important to note that College members may continue to supervise individuals they believe have the competence to provide psychotherapeutic services when those services fall outside of the Controlled Act. 3. With regards to performing the Controlled Act of psychotherapy, may I supervise:
4. Are there any circumstances when a member may supervise others in providing services, including performance of the Controlled Act, because a third-party payer will only cover services if they are supervised by a
Psychologist or Psychological Associate? Client Group Ages – My authorized area of practice includes Clinical Psychology with adults. I recently received a referral to provide service to an 18 year old. Would it be outside of my area of competence to see this person although she could be considered an adolescent? Click to copy link. The College has not set out specific, concrete age boundaries between the various client populations: children and adolescents; adolescents and adults; adults, and seniors. One usually goes by conventional definitions. That is, children to age 12 or 13; adolescents to age 19 or so; adults to 65 or 70. While age is not an issue when considering providing service to a client who falls within these conventional age groups, problems can arise at the boundary ages, i.e., 12-13; 18-20; 65-70. When determining whether it is within one’s area of competence to provide service to a “boundary age” individual, many things other than just chronological age come must be considered. The concern that arises should a member, with demonstrated competence in working with adults, decide to provide service to an older, boundary age adolescent is that one may impart to the older adolescent some adult traits, characteristics, or difficulties based on one’s training and experience. Conversely, a member may not recognize some adolescent trait, as one is approaching the client from an “adult” perspective. Issues can also arise with the use of assessment measures and intervention techniques as one may be most familiar with both the objective and subjective norms related to working with adults. The Registration Regulation (O. Reg. 74/15) requires that members practice the profession only within those areas of the member’s competency that are authorized by the College [s. 10 (2) 1.] There is some room at the boundary ages, however, for a member to provide service to a client who might fall, by convention, just outside of one’s authorized population group. Whether a member is practicing within one’s area of competency, as required by the Regulation, is a determination a member must make on a case by case basis, based on the characteristics of the individual client. A member whose area of competence is Clinical Psychology with adults may occasionally see a boundary age adolescent (18-20 age range), who many might consider a young adult, dependent upon the evaluation of his/her level of development and maturity. It is important to stress however, that should such requests for service become a more regular occurrence, it would be prudent for the member to one consider expanding one’s authorized population groups. While the above information relates to a boundary age adolescent and a member whose area of competency is with adults, the principles can be applied to a member considering providing psychological service to the other boundary age client groups. Making “Best Efforts” to Ensure a Work Setting Adheres to the Standards of Professional Conduct (Standard 3.2) – I am an employee at a clinic where it is difficult and sometime impossible for me to comply with the standards. I note that I am required to make “best efforts” to ensure that my workplace adhere to the Standards. So far, management has been unresponsive to my request for changes in policy. What should I do? Click to copy link. You’ve asked about situations in which you are being required to act in contravention of the Standards. The Standard requiring best efforts to affect change in the workplace relates to situations in which others in the workplace are doing things that contravene the Standards. When attempting to address the conduct of others in the workplace, Standard 3.1.2 does require you to make the best efforts to ensure that your work setting adheres to the Standards. If your efforts to change the behaviour of others at work meet resistance, best efforts could include presenting additional information that supports a compelling argument for the changes, writing a formal memo to those in a position to modify policies, or escalating the issue to a higher level in the organization. You would not be expected to take steps like resigning from your position and losing your livelihood, as this would be considered undue hardship. It is different if you, as opposed to others in the organization, are required to contravene the Standards, as a failure to comply with the Standards, yourself, would constitute Professional Misconduct. For example, if an employer were to ask you to provide services outside of your authorized areas of practice and/or competence, without the opportunity for supervision, you would not be permitted to so under any circumstances. Fortunately, it is in the best interests of most employers to support ethical practice and most of the time it is possible to affect change. If you are unable to resolve this problem with your employer on your own, it may be necessary to seek independent legal advice to discuss your range of options. Please don’t hesitate to contact the College’s Practice Advisory service if you’d like to discuss any specific situations like the ones described above. Supervision of Research and Other Non-Clinical Services (Standard 4.1) – I employ a research assistant who helps conduct psychological research. The assistant does not provide any clinical services. Do the Standards of Professional Conduct regarding supervision apply? Click to copy link. The Supervision standards apply to the supervision of all psychological services and psychological research is deemed to be a psychological service. In the public interest, it is important to ensure that research is conducted ethically and that it produces reliable and valid information. Some activities which non-members perform in the course of assisting with research may not require supervision if one would not need professional education, training, and/or experience in order to perform them. For example, tasks like administratively providing and collecting self-administered questionnaires may be performed without the supervision of the nature required by the Standards. Tasks which do require professional education, training, and/or experience, like interactive administration of tests and/or interpretation of subjects’ responses, would require supervision in the manner set out in the Standards. Training vs. Supervision (Standard 4.1) – I am considering a request by a member of another profession to train and evaluate him with respect to a particular therapeutic technique. He is not fully licensed and is not permitted under the Regulations and Standards of his own profession to practice autonomously, therefore all of his professional activities must be supervised. I would prefer not to take on all of the responsibilities of a supervisor, but would be prepared to train and evaluate him. Would agreeing to train and evaluate him make me a “supervisor”? Click to copy link. If you do not wish to take on the responsibilities of a supervisor, you would need to ensure that he would be satisfied with your acting as a consultant and/or trainer, but not as a supervisor as defined within the Standards of Professional Conduct for members of the College of Psychologists of Ontario. You’d have to have an agreement with him that makes it clear that you are not clinically responsible for the casework, that it’s his responsibility to evaluate any information you are providing to him and that he would need to make his own independent decisions about whether to heed any advice you give. In the event that he requires someone to assume clinical responsibility for his services, you must make it clear to him that by consulting and/or training you would not be assuming responsibility for client care. Supervision of a Supervisee’s Partial Caseload (Standard 4.1) – If I am supervising another professional on some cases, am I required to supervise their entire practice, and would this be different if the other professional is a member of another regulated profession? Click to copy link. Your question suggests that you would be supervising another professional’s “practice”. It is important to remember that clients seen under your supervision are actually considered to be your own clients and, as such, you should consider them as clients of your practice and not the supervisee’s. There is no specific prohibition against supervising another professional with respect to the care of some individuals, without supervising the care of all of the individuals they work with. It can, however, be challenging to ensure that all of those concerned are aware of which activities you are supervising and which ones you are not. In addition to complying with the Standards relevant to supervision, you would have to be mindful of adhering to all of the other relevant Standards, including: 6.4 Public Announcements
9.1.2 Members Responsible for Supervising Supervised Practice Members and Non Members
11.1 Fees and Billing Arrangements
All of the information above applies, regardless of whether the supervisee is a member of another health regulated profession if you are supervising them in the provision of psychological services. New Practice Area or Client Group – How do I go about adding a practice area or new client group? Click to copy link. Autonomous practice members wishing to add an area of practice or a client group must undertake training and supervision to achieve competency comparable to other members of the College who are recognized for similar practice. Members are required to make a written request to the Registration Committee specifying the practice area or client group they wish to add and to provide detailed information about how they have or plan to acquire the knowledge and skills in this new area. The College’s Guidelines for Change of Area of Practice, outline the process in more detail. The Registration Committee meets approximately every other month, dates of upcoming meetings are posted on the College’s website. Release of Raw Test Data – I have received a request from a client to obtain the raw test data from the tests administered in the course of a recent assessment. Am I allowed to release this information? Click to copy link. The question of the release of raw test data involves an understanding and interpretation of the Personal Health Information Protection Act (PHIPA) which speaks to responding to requests for personal health information. It should be noted that the College does not provide legal advice or legal interpretations of legislation but recommends that members seek legal advice on such matters. While not providing legal advice, the College does offer some comments which may be helpful in understanding this question and informing the discussions with legal counsel The Personal Health Information Protection Act (PHIPA) gives a client, or legal guardian, the right of access to, or the right to consent to the disclosure of, his/her personal health information. This would include much of the information in the psychology file. There are some exceptions, however, to this right. These include information that could pose a risk of harm and confidential third party information. As well, “raw test data from standardized psychological tests” [PHIPA 51.(1)] is excluded from this right. Therefore, the legislation does not appear to provide a right to access raw data. In considering PHIPA 51.(1), it is important to recognize the distinction between a right and a permitted disclosure. There does not appear to be any statements in PHIPA that prohibit the release of “raw test data from standardized psychological tests”. The difference to be understood is between what the client may have a right to obtain, and what they may be permitted to receive. In this regard, the legislation is permissive, rather than prescriptive. Recognizing this permissive language in the legislation, the College position related to the release of raw test data may be found in Principle 10 – Assessment and Intervention of the Standards of Professional Conduct; specifically section 10.8. This section notes that the College recommends that when the request is reasonable and appropriate, and with proper authorization, the raw data should be released to clients and others. It is important to note that Principle 10.8 emphasizes the member’s responsibility to distinguish between raw test data from standardized psychological tests and test materials or forms. This suggests that test protocols, test items, summary sheets, etc., most of which are materials copyrighted by the publisher, should not be reproduced based on voluntary consent. Rather, one may have to recopy the information ensuring not to include any copyrighted materials. Of course, should one receive a court order, summons to appear and bring materials to court, or some other legal vehicle compelling the release of the entire file, then this could also include the raw test data protocols. In such cases, members are encouraged to consult with legal counsel and/or the test publisher. Providing Administrative Supervision to Health Care Professional (Standard 4.1) – I provide administrative supervision of Behaviour Analysts who are not under my clinical supervision. What are my supervisory obligations in doing this under the new Standards? Click to copy link. The Standards relevant to supervision are only applicable to the supervision of psychological services. If your supervisory role is strictly administrative and you only do such things as approve vacation time, arrange scheduling or perform other human resources-related activities, then you would not be subject to the requirements for supervisors of psychological services. If you do supervise activities that would fall within the scope of practice of psychology, then you are required to adhere to the Standards regarding the supervision of psychological services. Section 3 of the Psychology Act, 1991 defines the practice of psychology as:
Telepsychology – A client I have been seeing for some time has recently moved out of Ontario. He would like to continue to receive service from me. Can I continue to provide psychological services to him through telepsychology? Click to copy link. In Canada, the practice of psychology is regulated at the provincial/territorial level. That is, each province/territory is responsible for the regulation of psychological services delivered within its borders. Within the United States, psychology is similarly regulated. At this time, most jurisdictions regulating psychology in Canada and the US, including the College of Psychologists of Ontario, view services to be delivered in the province/territory/state in which the client is located whether such service is provided in person or through telepsychology. That is, the service is deemed to be provided where the client is, regardless of where the psychologist or psychological associate may be located. Given this, many regulatory bodies expect the practitioner to be registered/licensed in the jurisdiction in which the service is being provided. At this time, there is some variability in the expectations of the various Canadian jurisdictions with regard to what is required of a practitioner providing services by telepsychology into their province/territory. Some may have temporary or courtesy registers which permit a member to practise within their jurisdiction for a limited period of time without formal registration with them. For members considering providing service by telepsychology into another jurisdiction, it is recommended that they contact the regulatory body of the jurisdiction into which they may be considering practising to determine what may be required of them in terms of registration/licensing or formal notification of the regulatory body for psychology. The College of Psychologists of Ontario has adopted, as advice to members, the Model Standards for Telepsychology developed by the Association of Canadian Psychology Regulatory Organizations (ACPRO). In addition, a joint task force of the Association of State and Provincial Psychology Boards (ASPPB), the American Psychological Association (APA) and the American Psychological Association Insurance Trust (APAIT) has recently developed Guidelines for the Practice of Telepsychology. The Canadian Psychological Association has also published Draft Ethical Guidelines for Psychologists Providing Psychological Services Via Electronic Media. Members considering providing telepsychological services will find these documents very useful as they provide guidance on a variety of issues related to this type of service. This includes ensuring one is legally entitled to practise in another province, territory, or state and one is familiar with the relevant laws and regulations applicable within that jurisdiction. Supervision Agreements (Standard 4.1.1) – Is it necessary for me to have a supervisory agreement with a psychometrist in the workplace? Click to copy link. If you are supervising the psychometrist, then a supervisory agreement is necessary. In institutional settings, such as school boards, hospitals, and correctional facilities, if your employment contract and the supervisee’s employment contract both address the required terms of supervision referred to in the Standards, this would be considered to constitute a supervision agreement. Supervision Requirements (Standard 4.1) – Why can services which are within the scope of practice of psychology be provided by unregulated practitioners without supervision, but if provided under my supervision, be subject to such rigorous standards? Click to copy link. If you are supervising psychological services, the public is entitled to rely on an expectation that the services delivered will meet the standards of the profession. There are unregulated professionals providing many services in Ontario, including behavioural intervention, counselling, and rehabilitation therapy. These professionals may be providing competent and ethical work but they are not subject to rigorous entry to practice requirements, standards of conduct to comply with, mandatory quality assurance requirements or a complaints mechanism to address concerns that may arise about the services. When a College member is supervising the provision of any psychological services, the College and its members have an obligation to the public to ensure that the services meet the same standards as they would if delivered directly by the member. Supervision Agreements for Non-Clinical Supervision (Standard 4.1.1) – Is it necessary to have supervision agreements when a supervisee is not providing health services, as would be the case if the supervisee were exclusively conducting research under supervision? Click to copy link. Many of the elements of a supervision agreement listed within the Standards apply broadly to any situation in which supervisors take responsibility for the work done by their supervisees. Some elements of Standard 4.1.1 (5) which may be applicable to the supervision of research and other non-clinical activities include: a) the date upon which the agreement is effective and the expected date upon which it will expire; In institutional settings, such as Universities and hospitals, employment contracts that address the terms of supervision referred to in these Standards may be considered to constitute a supervision agreement. Supervision Records for Supervision of Non-Clinical Services (4.1.1) – Is it necessary to have supervision records when a supervisee is not providing health services, as would be the case if the supervisee were conducting research under supervision? Click to copy link. Many of the elements of supervision records listed within the Standards apply only to the care of clients. Some, however, apply more broadly to any situation in which supervisors take responsibility for the work done by their supervisees. Some elements of Standard 4.1.1 (3) which may be applicable to the supervision of research and other non-clinical activities include: a) the date and length of time of each supervision meeting; A supervisor would be expected to make a record of any relevant ethical, professional, and jurisprudence issues discussed, directives provided, and strengths and needs for development identified during a supervision meeting. If few or none of these things were discussed at a particular meeting, then only a very brief notation including only the date and length of the meeting would be required. Indirect Supervision Agreements (Standard 4.1.1) – In our setting we have agreements with educational institutions regarding the students they provide to us for supervision. These agreements are analogous to those used in employment contexts in which agreements are made between the supervisor and employer and between the supervisee and employer but not directly between the supervisor and supervisee. Would such arrangements be considered sufficient for the purposes of the Standards or would it also be necessary to have supervision agreements directly between supervisors and supervisees? Click to copy link. The Standard is intended to ensure that there is clear agreement between the supervisor and supervisee with respect to all of the minimum elements listed in the Standards. It may be onerous to individuals make agreements that are redundant. So long as it can be demonstrated that each individual supervisor and supervisee has agreed to all of the following elements, whether directly or through a third party, you could consider that there is an agreement which meets the Standards:
To the extent that any of the minimum elements of an agreement listed above are not addressed, an additional agreement covering the missing elements would be required. Format of Supervision and Consultation Agreements (Standard 4.1.1) – Would you please provide template supervision and consultation agreements that we may modify for use in our own practices? Click to copy link. Because of the diversity of supervision and consultation arrangements members are involved in, the College could not possibly provide examples or templates of agreements that would cover every situation. We encourage you to design agreements that make sense for your own particular practice that contain at least the minimum information specified in the Standards. You are also free to add any additional elements you consider important in an agreement and may use any kind of language you wish to use. If it would help to see how some similar agreements are structured, here is a link to a few sample supervision contracts online: http://www.cfalender.com/supervision-contracts.html. These may or not be relevant or appropriate for all kinds of relationships but may provide a sense of what others’ agreements look like. Use of the Client Names in Supervision Records (Standards 4.1.1 [3]) – The Standards require information that will permit identification of each client discussed at each supervision meeting. What about client confidentiality? Click to copy link. Although the Standards require you to record information that will permit the identification of each client, there is no need to use full client names, as long as it is possible for you to associate these identifiers with the clients should you need to. The use of coded names would prevent the release of unnecessary personal health information about clients to those reviewing a file for purposes related only to the supervisee. Examples of appropriate references to clients in a supervision file include: “Discussed Interpretation of Test Scores for A.L. and asked Supervisee to correct tabulations and reinterpret with new scores” or “Discussed Supervisee’s own reaction to N.Q.’s disclosure, Supervisee discussed own discomfort with this issue and we generated a list of other possible responses, including seeking more information or waiting for the client to reflect before problem-solving. Will discuss Supervisee’s reactions to client information again following N.Q’s next session.” Client Information in Supervision Notes (Standard 4.1.1 [4]) – My supervision notes include personal health information about clients my supervisee is working with. Am I required to provide supervision notes containing client information when a request for client records is made? Click to copy link. When a client makes a request for his or her record, or authorizes release of it to another person, subject to the specific exceptions in privacy legislation, you must comply with the request. All information about a client that is relevant to the services provided should, however, be contained within the client record. There should be no information relevant to client care in a supervision record that would not also be found in the client’s own file. A supervision record should contain only information relevant to the member’s supervision of the supervisee’s performance, developmental goals, progress, and challenges. It should only include incidental reference to clients to relate the narrative to specific cases. If for any reason, you are compelled to provide a supervision record because it contains information related to a client, it would be important to ensure that information about other clients recorded in the supervision record is not disclosed without their consent or unless you are legally compelled to release it. Similarly, you should not release personal information about the supervisee without the supervisee’s consent, unless you are legally compelled to release it. If faced with a request which leads you to believe that supervision records are specifically being sought, you may indicate that the supervision records pertain to the supervisee’s own developmental goals, training, and growth, that all client-related information is incidental to these issues, and that all client-related information is contained in the client file. Again, unless required by a court of law, you must not release supervision records unless both the supervisee and client specifically authorize you to do so. Supervising Non-Members in the Performance of Non-Controlled Acts (Standard 4.1.3) – Does a non-member who is a member of another professional regulatory College, or who is not a member of any regulated profession, have to be seeking registration in a College to provide counselling under my supervision? Click to copy link. You may supervise anyone you believe has the competence to provide services under supervision, so long as they are not performing one of the Controlled Acts as listed and described in the Regulated Health Professions Act, 1991, which include: communication of a diagnosis; applying or ordering the application of a form of energy; and, once proclaimed in force, the Controlled Act of Psychotherapy. As counselling is not a controlled act, there is no requirement that they be registered, or seeking registration, in a College. Supervision vs. Consultation (Standard 4.1.5) – I train and have some input into the administration of test and counselling by members of other regulated health professions. These people are not, however, accountable to me and they are approved by the test publishers to use any test they administer. What are my obligations with respect to these activities? Click to copy link. Consultation is defined in the Standards as:
Supervision is defined as:
In providing exclusively training and advice to other professionals, it is more likely that you are providing consultation than supervision. If this is the extent of your involvement with these individuals, adherence to the requirements under section 4.1.5., which involves clarification of the limits of your involvement as a consultant, would be sufficient and appropriate. Your question indicates that you ‘have some input into the administration of tests and counselling’. If your input involves only making recommendations to other practitioners who take responsibility for the decision about whether to accept the recommendations, this would be consistent with the role of a consultant. If, however, “input” means directing which tests and counselling interventions will be used, and the recipients of the input are required to follow your directions, it may be that you are providing supervision and would be bound to adhere to the Standards regarding supervision of non-regulated professionals. If you are interpreting test results yourself, then you are considered to be actually providing a psychological service to the clients, and you are expected to adhere to all of the Standards which apply to the direct provision of psychological services. Training vs. Supervision (Standard 4.1.5) – Training within a consultation relationship can be highly structured and lengthy and can feel like direction. Would a relationship which includes intensive training with respect to client care be considered a form of supervision? Click to copy link. Providing training does not necessarily make a relationship supervisory. A relationship in which you have been specifically asked to provide training, or a consulting relationship which may have a training component, only becomes a supervisory relationship if it becomes evaluative and hierarchical and when the person receiving information from you is required to do as you instruct. In the kind of consultation situation, you have described it is particularly important to ensure that an agreement makes it clear that you are not taking on responsibility for client care and that that responsibility is exclusively the consultee’s.
Supervision vs. Consultation (Standard 4.1.5) – I work alongside Behavior Therapists and I am a resource in the agency to them. In some cases, I provide case specific recommendations. In other cases, I discuss general issues that come up without referring to specific clients and advise on processes for the therapists to follow. I do not evaluate their work and they are not accountable to me. Am I correct in believing that I am not in a supervisory relationship with them? Click to copy link. Making case specific recommendations to behavior therapists, advising with respect to the development of processes, and discussing general issues, are activities which are consistent with the role of a consultant, so long as it is understood that the recipients of the recommendations and advice are fully responsible for deciding whether to implement your recommendations. If you are in a relationship with the behavior therapists that is educational, evaluative, and hierarchical, and they are required to comply with your direction, you would be considered to be supervising them.
Working as a Member of an Interdisciplinary Team (Standard 4.1.5) – I work on an interdisciplinary team that provides interdisciplinary consultation with respect to clients who are not under my direct care but are under the direct care of members of other professions. I do have input into treatment planning for the clients, however, the entire team makes treatment decisions together. What obligations do I have in this situation? Click to copy link. Consultants are typically in the role of an external contributor to case discussions, where the recipients of the consultant’s ideas are free to either accept or reject them. If you are in the role of a consultant, while you may be providing advice to those making decisions about client care, you should not actually participate in making the decisions (e.g., “have a vote”), even when the responsibility for decision-making is shared. Consultation is defined as:
If this description fits your role with respect to the treatment team then it is likely that you would be considered a consultant and are required have a clear and formal agreement delineating responsibility for client care which spells out that the person receiving your consultation retains full responsibility for client care, in accordance with Standard 4.1.5. If you are a participant in the actual clinical decision making with respect to the clients, as opposed to being simply a resource for the decision-makers, then you are more than a consultant and have the same obligations as any member of the College providing services to a client, in a way that is analogous to an assessor or file reviewer who does not provide intervention but must comply with all of the Standards with respect to client care. Group Consultation Agreements (Standard 4.1.5) – I participate in group consultation on a weekly basis with a multi-disciplinary Consultation Team. Do I need an agreement with each member or may I contract with the team as a whole? Click to copy link. There is no reason you cannot have an agreement that multiple parties can sign onto, so long as it includes everyone with whom you require an agreement. You could update this agreement whenever someone joins or leaves the team. Defining “Formal” and “Ongoing” with Respect to Non-supervisory Consultation (Standard 4.1.5) – If I respond to a “one off” call for an opinion and then get another a month later, would this oblige me to have a consultation contract? If not, at what point would it be necessary to have an agreement to clarify that the service I am providing is not Supervision? Click to copy link. It would be reasonable to understand “formal” in this context to mean that contacts with the consultee(s) have been arranged, or are expected to occur in the future, specifically for the purpose of consultation, where consultation is defined as:
This would be different than the regular discussions which frequently occur between professional peers on either an ad hoc basis or at team meetings or case conferences. It would be reasonable to consider a consultation arrangement to be “ongoing” if the participants expect to have future contact for the purpose of consultation. Defining “Formal” and “Ongoing” with Respect to Non-supervisory Consultation (Standard 4.1.5) – Would my participation in a regularly scheduled discussion group be considered “formal, ongoing consultation”? Click to copy link. If all members of the discussion are simply exchanging ideas, and you were not designated to make specific recommendations to others by virtue of your specialized expertise, it would not be considered “consultation”, which is defined as:
Rather, it could be simply understood as team discussion or team development. If, however, a relationship is established with specific individuals or groups, where you are identified as a person who is designated to provide advice or information regarding psychological matters, and there were plans for you to meet with them to provide advice or information more than once, then it would be considered to be formal, ongoing consultation. Authorized Areas of Practice and Client Populations (Standard 5.1) – I understand that the Standards have been revised to remove age limits with respect to client populations. Does this mean that if I am authorized to work with adults but not seniors, I can now work with seniors? Click to copy link. There have been no changes to the Standards with respect to members limiting their services to their authorized client populations. We have tried, in revising the Standards, to make more members aware of the advice we provide about both the limits to authorized client populations and authorized areas of practice. Members are still required to limit their services to their authorized populations and areas of practice. The College has never set age cutoffs, with the belief that members will use good judgment to determine whether a person is a child, adolescent, adult, or senior. Those distinctions should be based upon whether, in the member’s judgment, the client’s abilities, life situation, and challenges are consistent with those commonly associated with a particular group. We’ve provided some examples in the Practical Applications to Standard 5.1 contained within the Standards. If you are not authorized to work with seniors, it would not be appropriate to take on a client facing age-related mental health challenges such as cognitive decline or social isolation. If deciding whether to continue ongoing treatment with a client who has recently begun to experience the adverse effects of old age, it would be a good idea to refer him or her to someone authorized to work with seniors and, until this has occurred, seek consultation from someone with the specific training, skills and experience and who is authorized to work with seniors. If an existing client is at a chronological age when age-related difficulties could reasonably be expected but are not yet occurring, it may be reasonable to still consider the client an “adult”. For example, if the client continues to work productively, live independently, has a vigorous fitness routine, is free from age-related health concerns, has meaningful and satisfying close relationships, etc., he or she need not be categorized as a “senior” for the purposes of the Standards, even if his or her age exceeds a commonly applied age marker such as 65. Responsibility for Files of Clients Seen by Supervisee (Standard 9.1) – Who is responsible for physically keeping the files of a supervisee who is neither a member of the College, nor working in my practice? Click to copy link. The clients receiving services directly from your supervisee are considered to be your clients. As such, the client file is actually yours even while in the possession of a supervisee under your direction; this is the case with respect to files of clients seen by members of the College with Certificates of Registration Authorizing Supervised Practice as well as non-members of the College. You may decide that, rather than keeping client files in your possession while services are being provided, your supervision would extend to ensuring that the supervisee maintains the files in a secure, confidential and accessible manner, in accordance with the Standards and the applicable legislation. When the supervision period ends, the record of services which you had always been responsible for remain your responsibility. Given that you will not have authority over the conduct of the former supervisee, you must personally ensure that the records remain secure, confidential and accessible in the manner required by the Standards. Responsibility for Supervision Files when Supervisor Leaves (Standard 9.1.2) – If I leave my workplace, should I take supervision files with me or do they, like client files, belong to the organization? Click to copy link. The Standards do not specifically prescribe what you must do with supervision files when you leave an organization in which you are providing supervision. In most cases, supervision of services to the clients of the organization would be considered an activity of the organization which is performed by the supervisor. If this is the case, the file likely belongs to the organization and it would make sense for the file to be left in the organization’s care and dealt with in accordance with the privacy legislation applicable to the organization. It is important to make the best efforts in these situations to ensure that the organization will retain the files for at least two years, as this is the prescribed retention period for supervision files when they belong to individual members who are not carrying out supervision in an organizational context. To use the analogy of a human resources file, if you would leave a human resources record with the organization in which you managed staff, then it’s likely that you would be expected to leave the record of supervision with the organization within which the supervision was provided. With respect to any information about an identifiable client in the files, the organization would, in most cases, be considered the Health Information Custodian and would be responsible for ensuring that the requirements of the Personal Health Information Protection Act are met. Fees and Billing Arrangements (Standard 11.1) – The prohibition regarding fee splitting has been removed from the Standards. Why was this and does it mean that I can now pay for, or be paid for, referrals? Click to copy link. The prohibition against fee splitting has been removed from the Standards but the prohibition against paying for referrals remains in force. The Professional Misconduct Regulation still strictly prohibits:
Many people found the language used to address the practice of fee splitting in the previous version of the Standards difficult to understand. The College decided that concerns underlying the former specific fee splitting rule are already adequately addressed within the Professional Misconduct Regulation, which prohibits:
and by the following requirements which have been carried forward from the previous Standards to the new ones:
Fees and Billing Arrangements (Standard 11.1) – With the removal of the prohibition against fee splitting removed from the Standards, may I now charge a supervisee a percentage of fees collected by the supervisee, a fixed dollar amount for each client or a fixed, flat fee charged on a weekly, bi-weekly, monthly or quarterly basis? Click to copy link. As a supervisor, you are providing a psychological service and it is important that your own fee structure for this service complies with the requirement that your fees are based on the amount of time you spend providing the service and the complexity of the service you are providing. Charging a percentage of fees collected or the number of sessions a supervisee has with a client may not correspond to the amount of time you are providing supervision. Charging a flat fee for a time period, without regard to the specific number of hours spent within that time period, would also be inconsistent with the standard and would have the potential to also violate the prohibition against exploitation of supervisees (section 13.4(2), as a supervisee could possibly be charged for supervision which was out of proportion to the time spent. Fees and Billing Arrangements (Standard 11.1) – If I have an associate working for me in my private practice, given that fee splitting is no longer specifically prohibited, may I now make an arrangement with an associate within my practice such that I would receive a percentage of the fee collected and the associate would receive the remainder? Click to copy link. The prohibition of fee splitting was difficult to understand and misunderstood by many, so it was decided that, because concerns about the adverse consequences of fee splitting are addressed elsewhere in the Standards and the Professional Misconduct Regulation, that the Standard regarding fee splitting would be omitted from 2017 version. The Professional Misconduct Regulation still strictly prohibits:
Additionally, the Standards still require that:
As long as the practice you are describing does not occur in a supervisory relationship and your practice is compliant with respect to all of the above, you are now able to enter into percentage based arrangements. What constitutes “Telepsychology” (Standard 15) – The Standards do not define “telepsychology.” Would you please provide a definition? Click to copy link. The College has adopted the Association of Canadian Psychology Regulatory Organizations (ACPRO) Model Standards for Telepsychology Service Delivery. The Model Standards define Telepsychology as “the use of information and communications technology to deliver psychological services and information over large and small distances”. Practice within psychology using this modality would include all client-centered services, consultation, supervision of students/professionals/colleagues, and the education of the public and/or other professionals delivered to individuals outside of Ontario. What constitutes “Telepsychology” (Standard 15) – Is psychological service provided by telephone, considered “communications technology”, or is the Standard intended to apply only to ‘high tech’ ways of communicating? Click to copy link. A telephone (landline or mobile) would be considered “communications technology”. While some of the items within the “Use of Technology…” section of the Standards may not be relevant to simpler, older technologies, some items would be relevant and applicable to even ‘lower-tech’ devices, including a corded or land-line telephone. Examples of requirements applicable to the use of all technologies in service provision would include the need to obtain authorization from the relevant jurisdiction before providing services to someone who is located outside of Ontario, ensuring the privacy of the person you are communicating with, and having contingency plans in the event of a technological failure. For Employers, Insurers & Third Party PayersWho can provide psychological services in Ontario? Click to copy link. There has been some confusion with respect to who may provide psychological services in Ontario and who may bill for such services. This information is provided in an effort to clarify any misunderstandings related to these issues. To practise psychology in Ontario, an individual must hold a current certificate of registration from the College of Psychologists of Ontario; the regulatory body for the profession of psychology. Under the authority of the Regulated Health Professions Act, 1991 and the Psychology Act, 1991, the College registers two classes of autonomous practitioners: Psychologists and Psychological Associates. A Psychologist or Psychological Associate who holds a Certificate of Registration Authorizing Autonomous Practice may provide services without supervision, within his or her area of competence, and may bill for these services. While most members of the College have no explicit term, condition, or limitation on their certificates of registration, some do and must practice in accordance with any such restriction. To qualify for professional registration to practise psychology requires successful completion of:
Once registered, a member of the College is expected to practise in accordance with applicable legislation, regulations, standards of conduct, professional guidelines, and professional codes of ethics. Only a member of the College may offer psychological services in the province or use the title Psychologist or Psychological Associate. In addition, the use of the terms psychology or psychological, or any abbreviations or variations of these terms and titles in describing services, is restricted to members of the College. Psychologists and Psychological Associates respectively may also identify themselves with the designation C.Psych. or C.Psych.Assoc. after their names. The College maintains a register of all current members. Information about an individual psychologist or psychological associate may be found in the searchable Public Register or obtained from the College by telephone 416-961-8817 or by e-mail: The College has received inquiries with respect to the status of psychological associates providing services under legislative provisions such as the Statutory Accident Benefits Schedule (SABS) as well as under other public and private third party insurance programs. In 1996, the Registrar of the College sought clarification respecting providers under the SABS in an exchange of correspondence with Mr. Rob Sampson, MPP, who was at that time Parliamentary Assistant: Financial Institutions, Ministry of Finance. In his letter addressing this issue, Mr. Sampson stated:
More recently, the College sought clarification from the Federal Minister of Finance regarding the ability of Psychological Associates to certify eligibility for the Disability Tax Credit (DTC). In a letter from Mr. James Flaherty, Minister of Finance dated January 31, 2007 he stated:
In summary, both Psychologists and Psychological Associates are members of the College of Psychologists. Members with either title are qualified psychological practitioners in the province of Ontario. Questions regarding Psychologists and Psychological Associates or other matters related to the regulation and practice of psychology in Ontario may be directed to the College. Funding for Therapy to Address Sexual Abuse by MembersWho is eligible for funding? Click to copy link. Under the legislation, a person may be eligible for funding if it is alleged, in a complaint or report, that they were sexually abused by a member while a client of the member. How much funding is available? Click to copy link. The legislation sets the maximum amount of funding that can be awarded as the amount that the Ontario Health Insurance Plan (OHIP) would pay for 200 half-hour sessions of individual out-patient psychotherapy with a psychiatrist on the day the person becomes eligible. Currently, a total amount of $17,370 in funding is available. If OHIP or a private insurance plan covers some of the costs, the College would only pay the amount not covered. Are there any restrictions on how I spend the money? Click to copy link. Yes. The legislation specifically states the funding must be used only to pay for therapy or counselling and must be paid to the therapist or counsellor directly. The College will not pay for missed appointments. As well, funds from the program cannot be used to pay for travel, accommodation or other incidental costs even if they are incurred directly as a result of therapy. How long is the funding available? Click to copy link. Funding is available for up to five years from the time an application is approved by the Client Relations Committee or, if therapy to address the effects of sexual abuse began before such approval was granted, five years from day upon which the funded therapy began. Does the therapist or counsellor have to be a Psychologist or Psychological Associate or another regulated health professional? Click to copy link. No. Any therapist or counsellor may be selected, if:
Do I need to meet with the Commitee? Click to copy link. No. The Committee reviews documents only. Will the Committee have access to all of the detailed information I provided to the College regarding the abuse? Click to copy link. The Client Relations Committee requires sufficient information to be satisfied that the criteria for eligibility have been met. The College recognizes however, that the information provided is very personal and sensitive. To this end, the Client Relations Committee will access only the minimum amount of information required to adequately undertake its review. An applicant’s surname will not be shared with the Committee and will be known only by College staff presenting the application to the Committee and processing the payments. Is the funding confidential? Click to copy link. Applicants will be asked to keep confidential all information obtained through the application for funding process, including the fact that funding has been granted and the reasons, if any, given by the Committee for granting the funding. Furthermore, a decision by the Committee concerning eligibility for funding does not constitute a finding against the member and shall not be considered by any other Committee of the College dealing with the matter. Other College processes, including investigation and hearings may remain ongoing even during the funding application process and while funding is being provided. Click to copy link. Individuals who wish to apply for funding for therapy or counselling under this program, may contact the Deputy Registrar, Mr. Barry Gang. His contact information is available below. Mr. Gang will answer any further questions applicants may have and will provide assistance in applying for funding. Applicants
will be asked to provide a written statement from the therapist or counsellor to the Client Relations Committee indicating: If the therapist or counsellor is not a Regulated Health Professional, the applicant will be asked to sign a document indicating that they understand that the therapist or counsellor is not subject to professional discipline. Where are psychologist most frequently found working?Here are some of the common settings in which psychologists work:. Private practices. Some psychologists have their own offices, similar to private doctor's offices. ... . Health care settings. ... . Universities and research centers. ... . Education institutions. ... . Government agencies and law enforcement. ... . Private businesses.. Where can psychologist work?Where You can Work as a Psychologist. Schools including universities and colleges, high schools and primary school.. Medical schools.. Hospitals and healthcare institutions.. Business or non-profits.. Government establishments, especially medical centres.. Independent practice.. Which area is most likely to be the focus of an experimental psychologist?2. Experimental psychology. Generally speaking, experimental psychologists are interested in exploring theoretical questions by creating a hypothesis and then proving or disproving it through experimentation.
Who is a counseling psychologist most likely to provide treatment to?Counseling psychologists provide psychotherapy to people experiencing psychological disturbances, behavioral problems, emotional difficulties, stress, and related issues. These professionals share many commonalities with clinical psychologists.
|
In which of the following settings would you be likely to find a psychologist working
zusammenhängende Posts
Urheberrechte © © 2024 de.ketajaman Inc.
