Frequently Asked Question
Over the past two weeks the College has received numerous questions from members regarding practice issues related to service provision during the coronavirus pandemic. Since many of these were quite similar, I have prepared the following set of FAQs in an effort to address some of the more common inquiries.
In-Person vs. Remote Services
Can I continue to see clients in my office if I have personal protective equipment (PPE) and have physical distancing protocols in place? The Chief Medical Officer of Health (CMHO) issued a Directive for Healthcare Providers on March 20, 2020. In order to limit the spread of the coronavirus, the Directive required that all non-essential and elective services should cease. The exceptions to this relate to those “in which services are necessary to avert or avoid negative patient/client outcomes or situations that would have a direct impact on the safety of patients/clients”. For members of our College, it was understood that the intention of the Directive was that this would not include routine in-person psychological services. For this reason, the College strongly advises members to only provide services remotely, even if personal protective equipment and physical distancing protocols are in place. The only care that should be provided in-person, at this time, is urgent care which cannot be done remotely, and members must use their clinical judgement in determining what is urgent.
The College appreciates that some clients, in the member’s clinical judgement, may need urgent services. Hopefully, this can be provided on-line, however this may be difficult for clients without the capacity to access services electronically or for whom this would be viewed to be inadequate or inappropriate given the client’s urgent need.
Should a member determine that the client’s need is urgent, and this cannot be addressed remotely, the College strongly advises that members take appropriate steps to implement recommended safety precautions such as personal protective equipment and physical distancing.
I work in a hospital and I have been asked to continue to see some clients in-person. How do the College’s recommendations regarding in-person services relate to me?
The College’s recommendations regarding in-person vs. virtual services are most applicable to members in solo or group private practice. For members working in hospitals, correctional facilities, or other institutions designated as essential, decisions regarding the deployment of staff is left to the facility and their compliance with Ministry directives applicable to them.
Personal Use of One’s Office
I have closed my office and am providing only on-line services to those of my clients for whom this is appropriate. Privacy issues make it difficult for me to work from home. Can I go into my office and provide remote services from there?
The critical issue is limiting the community spread of the virus and preventing the possibility that clients and the public could be put at risk by continuing to operate one’s practice. While one’s physical place of business is closed, it is our understanding that currently there are no restrictions regarding entering and/or working from your closed office, by yourself.
Emergency Services: Recordkeeping
A number of us wish to offer emergency services to individuals who are experiencing anxiety and distress related to COVID-19 either as front-line service providers or family members of individuals with a positive diagnosis. Due to the nature of this service, it could be difficult to comply fully with the College’s Standards of Professional Conduct regarding recordkeeping. In these times of COVID-19, can we dispense with notetaking?
With regard to the issue of keeping notes, the College cannot provide you with blanket exemption to operate outside of the Standards of Professional Conduct or give you permission not to comply with them.
The College does appreciate that these are very difficult and different times and that not all of the rules normally in place may fit this very unique COVID-19 situation. The best advice the College can offer is that you need to make your best effort to provide services in keeping with the Standards. If, in this unique, emergency situation, you find this is not possible, you should be able to offer a clear and reasonable rationale for why the circumstances warranted you to provide services in the way you did.
It is generally seen to be in the public interest that practitioners have a note of who they saw, when, and some information about the service offered and/or its resolution as clients often find a need to return to the practitioner or, at some future time, may find value in being able to access some information about the psychological service they received.
Emergency Services: Supervision of Non-Regulated Providers
We are considering organizing a service to provide support to individuals affected by the pandemic using volunteers, such as students, who are not members of the College. They would provide services that would involve support and/or psychoeducation but not psychotherapy. It would not be feasible to supervise these individuals, but we would provide consultation to them. Would the College have concerns about this?
While the type of service you are suggesting may certainly be of benefit to some individuals during this very difficult time, there are some issues that should be considered. If a service is provided under the auspices of a member of the College or identified to the public as being overseen by members of the College, then it is a psychological service. As such, if non-regulated individuals, such as students, are providing the service, they must be supervised as psychological services may only be provided by a member of the College or someone being supervised by a member.
The public has an expectation that when a service is identified as a psychological service or provided under the auspices of a member of the College, they can assume that it will be provided competently and ethically and in keeping with the College’s Standards of Professional Conduct. This can only be assured if it is provided by, or supervised by, a member.
As with the discussion above on recordkeeping, the College does appreciate that these are very difficult and different times and that not all of the rules normally in place may fit this very unique COVID-19 situation. As such, you may find it is not possible to fully adhere to all of the supervision requirements set out in Principle 4 of the Standards of Professional Conduct. If, in this unique, emergency situation, full compliance is not possible, you should be able to offer a clear and reasonable rationale for why the circumstances warranted you to provide services in the way you did.
It is important that one appreciate that, as a member of the College, you are responsible for the nature, quality and ethically competent services provided under your auspices.
Keep healthy and safe,
Rick Morris, Ph.D., C.Psych.
Registrar & Executive Director