- Standard 4: Supervision, Standards of Professional Conduct, 2017
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.
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.”
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.
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.
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
4.1.3 Supervision of Non-Members
In addition to the responsibilities outlined in 4.1.1:
a) the supervising member must co-sign all psychological reports and formal correspondence related to psychological services provided by non-member supervisees;
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.
The Standards of Professional Conduct, 2017 require that supervising members must be authorized to autonomously provide services to the specific populations before supervising others in that work. Furthermore, the Standards also requires that
Supervising members must assess the knowledge, skills and competence of their supervisee and provide supervision as appropriate to the supervisee’s knowledge, skills, and competence, based on this assessment;
Unless a supervisor has sufficient information about a client and the client’s difficulties, they would not be able to provide adequate supervision appropriate to the supervisee’s knowledge, skills and competence.
It is the responsibility of a supervisor to be sufficiently familiar with the client’s demographics and needs before permitting their supervisee to commit to provide services. The adequacy of the supervision could be in question if a supervisor reviews and signs off on reports without having been involved in a direct or supervised intake process, or does not actively supervise the work leading up to any final reports.
Even though the Standards do not require supervisors to meet and interact with clients receiving services under their supervision, a supervisor should only permit a supervisee to work with a client after they have satisfied themselves that the client is within their authorized areas of practice and belongs to a population with whom they are authorized to work.