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:
- Ensure that clients who wish to continue working with you as an autonomous practitioner, know that you will now be solely responsible now for their care, that your supervisor no longer considers them to be their clients and that you are no longer under supervision;
- Engage in an independent informed consent process with clients, outlining your new, autonomous professional responsibilities and confirm agreement with respect to what services you will be providing, and on the fees you will be charging;
- Clarify that the personal health information collected during your period of Supervised Practice must remain with the person or organization who was the Health Information Custodian during your supervision;
- If you are to be considered the Health Information Custodian going forward, you may obtain a copy of records made to date only with the client’s consent; information about who is the Health Information Custodian can be found here: 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?
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
If members are supervising psychological services provided by a member holding a certificate for supervised practice or any other unregulated or regulated service provider who is not an autonomous practice member of the College, the clients are considered to be clients of the supervisor…
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
Members supervising Supervised Practice members and non-members are responsible for the security, accessibility, maintenance, and retention of records.
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.