FAQs

About Psychology

What is the College?

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?

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?

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: cpo@cpo.on.ca.

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?

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
Suite 500 – 110 Eglinton Avenue West
Toronto, Ontario M4R 1A3
Tel: (416) 961-8817/(800) 489-8388
Fax: (416) 961-2635
E-mail: cpo@cpo.on.ca

Becoming a Member

How long does the application process take?

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. Unfortunately, due to the COVID-19 pandemic, the College is operating remotely and therefore, there may be delay in meeting this timeline. We apologize for any inconvenience this may cause.

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.

What is the Registration Committee?

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.

How will I know when my application is complete and ready for review?

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?

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?

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?

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 cpo@cpo.on.ca.

I have a sealed envelope containing my official academic transcript that my University issued directly to me. Will the College accept this transcript?

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 cpo@cpo.on.ca.

Will the College give me credit for any supervised work that I began before my application was approved?

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?

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?

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?

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?

The application fee may be paid by credit card on the online application site.

Can I fax or e-mail you my application form?

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?

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?
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?

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.

I disagree with a decision from the Registration Committee, what can I do?

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 registration@cpo.on.ca

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
151 Bloor Street West, 9th Floor
Toronto, ON, M5S 1S4

Telephone: 416-327-8512
Toll Free: 1-866-282-2179
TTY/TDD: 416-326-7TTY or 416-326-7889 1-877-301-0TTY or 1-877-301-0889
Fax: 416-327-8524
E-mail: hparb@ontario.ca
Website: www.hparb.on.ca

Ontario Regulation 74/15 - Registration

What is the new Registration Regulation?

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?

The revised Registration Regulation became effective on April 7, 2015.

What changes are included in the new regulation?

The most significant changes are that:

  • The new regulation is more specific about the graduate psychology training requirements for registration as a Psychologist and as a Psychological Associate. Whereas the old regulation indicated that an applicant had to have completed a degree from “a program of study with content that is primarily psychological in nature as required in the guidelines published by the College”, the new regulation indicates that a Psychologist applicant must have a doctoral degree from a CPA-accredited or equivalent psychology program. The specific curriculum content of acceptable psychology programs for master’s level Psychological Associate registration is also now outlined in the regulation.
  • Other requirements previously outlined in the guidelines, such as those regarding supervised practice, are now specified in the regulation.
  • The examinations (EPPP, JEE, and Oral Exam) applicants must pass as a requirement of registration are now specified in the regulation.
  • The new regulation eliminates the “status” of certificates for Inactive, Retired, and Academic registration; these will now become classes of certificates of registration. This does not change the conditions for holding these certificates.
How will applicants be affected by the changes to the Registration Regulation?
  • Any applicant whose completed application to the College is received on or after April 7, 2015, will need to meet the requirements as outlined in the new regulation.
  •  Applicants who applied and whose required documentation to complete their application for review by the College had been received by the College prior to April 7, 2015, will be processed under the previous (old) regulation
  • Applicants who applied and whose required documentation to complete their application for review by the College had not been received prior to April 7, 2015, will be notified that once they complete their application it will be processed under the new regulation.
Will the new regulation affect Psychologists and Psychological Associates already registered in another Canadian province who apply to register in Ontario (labour mobility applicants)?

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 cpo@cpo.on.ca  if have any questions

Registration Examinations

When 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?

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

Supervised practice members must, in order to remain in good standing, take the EPPP and the JEE within one year of issuance of the certificate for supervised practice.

Which exam do I take first?

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?

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?

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 ?

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?

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?

The College recommends that candidates review the preparatory information outlined in the document titled Preparing to take the Jurisprudence and Ethics Examination.

As well as the list of relevant Legislation and Standards

Additionally, detailed information about the JEE including (but not limited to) an Examination Blueprint of the content of the examination, pass point and scoring, number of attempts permitted, and exam accommodations is outlined in the Examinations section of the Registration Guidelines: Supervised Practice:

Psychologists’  Exams

Psychological Associates’ Exams

The Supervision Resource Manual also includes some information on how candidates can prepare to take the JEE.

How well do candidates usually do on the JEE?

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?

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?

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

“The level of performance required for passing a credentialing test should depend on the knowledge and skills necessary for credential-worthy performance in the occupation or profession and should not be adjusted to control the number or proportion of persons passing the test.”

American Educational Research Association, American Psychological Association, National Council on Measurement in Education. (2014). Standards for educational and psychological testing. Washington DC: American Educational Research Association.

How long will it take to receive my JEE result?

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?

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?

The Registration Guidelines: Supervised Practice (psychologist) and  Registration Guidelines: Supervised Practice (psychological associate), describe the oral examination, and the Supervision Resource Manual provides information on how candidates should prepare for the oral examination.

How do I request an accommodation for taking the College’s examinations?

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 exams@cpo.on.ca for assistance.

Where can I find the examination accommodation request forms?

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 exams@cpo.on.ca for assistance.

When should I submit my request for an examination accommodation?

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?

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?

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 exams@cpo.on.ca for assistance.

Applicants Educated Outside Canada or the USA

Can I begin the application process before I move to Canada?

Yes, you can begin the application process before arriving in Canada. The Registration Guidelines outline the steps in the registration process that may be completed before moving to Canada

Registration Guidelines: Registration Process – Psychologist

Registration Guidelines: Registration Process – Psychological Associate

How do I go about having my credentials assessed?

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?

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?

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?

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?

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?

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?

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?

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?
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 - General

Should I file a complaint or a report?

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:

Investigation  Complaint / Reporter
Involvement
 Timelines  Review
Complaint The ICRC must investigate every complaint it receives.* The complainant:

  • Must identify themselves
  • Normally gets a copy of the member’s response;
  • Gets a copy of the ICRC’s decision.
150 days. The College can extend this timeline The complainant and member may ask the Health Professions Review Board (HPARB) to review the ICRC’s decision.
Report Not every report is investigated. The Registrar decides what to do with each report on a case-by-case basis A report:

  •  Can be anonymous.
  •  the person who made the report will not receive any further information from the College
There is no set time for investigating a report. HPARB cannot review the ICRC decision.
* with some limited exceptions. See additional FAQs below.
Who can file a complaint or report with the College?

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?

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?

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?

Yes. Please see additional information about the College’s facilitated resolution process.

Is the information I provide to the College confidential?

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?

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?

The role of the College is to protect the public from harm. The College does so by setting and upholding rules and Standards for its members. These rules and Standards address many different concerns, including:

  • Boundaries and sexual abuse;
  • Appropriateness of services;
  • Supervision;
  • Fees and billing;
  • Confidentiality and disclosure of information.

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?

No. The College cannot get involved in fee arrangements or make financial awards.

Can I complain about a clinic or institution?

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?

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?

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?

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?

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?

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 Report

How do I file a complaint or report?

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?

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?

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?

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 - Investigations

Does the ICRC investigate every complaint?

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?

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?

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?

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?

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:

  • Requests for extensions from the member and complainant;
  • Contacting witnesses;
  • Getting information from various sources.
What if I need more time to respond or get information?

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?

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?

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?

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?

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?

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.

Will I meet with ICRC?

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 Decisions

Will the ICRC tell me that the member did something wrong?

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?

The ICRC may take a range of actions after an investigation:

  • No further action: A panel may take no further action if it believes there is no risk to the public.
  • Advice: A panel may give advice if it identifies low risks. Advice is meant to help the member avoid future risks.
  • Undertakings: A panel may ask for an undertaking from the member if it identifies moderate risks. An undertaking is remedial and is agreed to by the member. An undertaking can range from a minor change in practice to limitations on the member’s certificate of registration.
  • Caution: A panel may caution a member if it identifies moderate risks. The member must come to the College to receive the caution in person. Cautions are remedial and may include a discussion between the panel and the member. Cautions are not open to the public.
  • Specified Continuing Education or Remediation Program (SCERP): A panel can order a SCERP if it identifies moderate risks. A SCERP is remedial and can include a specific course of study.
  • Referral to the Discipline Committee: If the ICRC identifies high risks, it will refer the matter to the Discipline Committee for a full hearing.
  • Referral to a Health Inquiry or Fitness to Practice Committee: Sometimes the ICRC identifies health issues that could affect the member’s ability to practice. In these cases, the panel will refer the matter to a Health Inquiry panel of the ICRC. A Health Inquiry panel can order treatment and monitoring.  If treatment and monitoring are not enough to ensure safe practice, the ICRC may refer the matter to the Fitness to Practice Committee.

In the last 5 years (January 2015 to March 2020), ICRC outcomes in relation to 416 cases were as follows:

Outcome Number* Percentage*
Withdrawal/closed 10 2%
Take No Further Action – F&V † 55 13%
Take No Further Action 157 38%
Advice 85 20%
Written Caution ‡ 37 9%
Caution 17 4%
Undertakings 41 10%
SCERP 17 4%
Refer to Discipline Committee 18 4%
Total 437 105%

*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.
‡ As of September 8, 2017, the ICRC no longer issues written cautions.

Will information about my complaint go on the Public Register?

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:

  • A notation and synopsis of any undertaking, while it is in effect;
  • A notation of any caution;
  • A notation of any Specified Continuing Education or Remediation Program (SCERP);
  • A notation of every matter referred to the Discipline Committee;
  • The specific allegations referred to the Discipline Committee;
  • The result of every Discipline proceeding;
  • The result of every Fitness to Practice proceeding;
  • Information about a member’s criminal charges or convictions; and
  • Information about any interim order that may be in effect.
What if I’m unhappy with the ICRC’s decision?

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?

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 Reports

When should I file a mandatory report?

You must file a mandatory report no later than 30 days after the reporting obligation has been triggered.

You must file a mandatory report immediately if you believe that:

  1. The member will continue to sexually abuse a patient or will sexually abuse other patients; or
  2. That the member is likely to expose a patient to harm or injury.
How should I file a mandatory report?

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?

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 invhear@cpo.on.ca

What if the professional I need to make a report about is also my client?

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:

  • No further action: A panel may decide to take no further action if it decides that the member’s conduct poses no risk to the public.
  • Advice: A panel may give advice if it identifies low risks. Advice is meant to help the member avoid future risks.
  • Undertaking: A panel may ask for an undertaking from the member if it identifies moderate risks. An undertaking is remedial and can range from a minor change in practice to having a mentor.
  • Caution: A panel may caution a member if it identifies moderate risks. The member must come to the College to receive the caution in person. Cautions are remedial and may include a discussion between the panel and the member. Cautions are not open to the public.
  • Specified Continuing Education or Remediation Program (SCERP): A panel can order a SCERP if it identifies moderate risks. A SCERP is remedial and can include a specific course of study.
  • Referral to the Discipline Committee: If the ICRC identifies high risks, it may refer the matter to the Discipline Committee for a full hearing.

COVID-19

Must masks be worn in the office, particularly when it’s possible to maintain a physical distance of at least 2 metres?

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:

  1. Elimination and Substitution – examples include not having patients physically come into the office/clinic, use of telemedicine, etc;
  2. Engineering and Systems Control Measures – examples include physical barriers like plexiglass partitions;
  3. Administrative Control Measures – examples include active screening, passive screening (signage), and visitor policies;
  4. Personal Protective Equipment – examples of PPE include gloves, gowns, facial protection (including surgical/procedure masks and N95 respirators), and/or eye protection (including safety glasses, face shields, goggles, or masks with visor attachments).

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?

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?

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?

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
Members must be familiar with the standardization, norms, reliability, and validity of any tests and techniques used and with the proper use and application of these 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
Members must be familiar with the evidence for the relevance and utility of the interventions used and with the proper use and application of these interventions.

10.3 Rendering Opinions
A member must render only those professional opinions that are based on current, reliable, adequate, and appropriate information.

10.4 Identification of Limits of Certainty
A member must identify limits to the certainty with which diagnoses, opinions, or predictions can be made about individuals or groups.

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?

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 Act1990 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 Requirements

How can I satisfy my CPD requirements if I am not in active practice?

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 Administration

When must I begin mandatory CPD Program?

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.

Certificate class and Registration Number at the time a Declaration is required: Credits earned beginning on the following dates may be counted towards completion of the requirements: First CPD Declaration Required
Supervised Practice “odd” July 1, 2017* June 30, 2019
Interim Autonomous Practice “odd” July 1, 2017* June 30, 2019
Autonomous Practice “odd” July 1, 2017* June 30, 2019
Academic “odd” July 1, 2017* June 30, 2019
Inactive “odd” July 1, 2017* June 30, 2019
Supervised Practice “even” July 1, 2018 June 30, 2020
Interim Autonomous Practice “even” July 1, 2018 June 30, 2020
Autonomous Practice “even” July 1, 2018 June 30, 2020
Academic “even” July 1, 2018 June 30, 2020
Inactive “even” July 1, 2018 June 30, 2020

*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?

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?

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?

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 Credit

Can credits earned prior to the beginning of the two year CPD cycle be counted towards my required total number of credits?

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?

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?

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”?

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?

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?

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?

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?

Yes.

How can I obtain my 10 credits related to ethics?

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:

  • Attending an event run by a local professional group or participating in an organized discussion group that addresses professional ethics
  •  Working with a workplace ethics committee
  • Attending the Barbara Wand Symposiums, in person or by webinar, or watching the archived recordings
  • Completing online continuing educational programs offered by professional associations
  • Participating in a College or professional association activity related to ethical practice
  • Attending, or watching webcasts of public lectures which are  offered by universities and other educational organizations that are relevant to professional ethics
  • Reading books and articles that are relevant to professional ethics
Why can CPD credits be earned for teaching?

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?

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?

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?

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)?

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?

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 Activities

What information will I be required to provide to the College with regard to my participation in the CPD Program?

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:

  • You have not submitted your Declaration of Completion of  the CPD requirements by the College’s deadline
  • You have been selected when the Quality Assurance Committee conducts a random audit of member participation in the CPD program
  • You are subject to an Assessment or Review under the College’s Quality Assurance Program, including a Peer and Practice Assessment
What is the difference between Category A (Professional Activities) and Category B (Continuing Education)?

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?

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?

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?

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 Activities

What kind of documentation should I retain in order to verify that I have earned CPD credits?

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?

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?

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?

You must retain your records for at least five years after completion of your last CPD cycle.

Peer Assisted Review

What is a Peer Assisted Review (PAR)?

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.

Who will be reviewed?

Any member with a Certificate of Registration for Autonomous Practice is a potential participant in the PAR process.

How are members selected?

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?

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:

  1. Participate in the College’s Peer Assisted Review Assessor and Reviewer training before conducting the review, if I have not already done so within one year prior to the date of the review
  2. Maintain confidentiality, as required by s.36 of the Regulated Health Professions Act, 1991, S.O. 1991, c. 18
  3. Familiarize themselves with the Legislation, Regulations and the Standards of Professional Conduct relevant to the practice they will be reviewing

    and attest that:

  4. They have held a certificate of Registration for Autonomous Practice with the College of Psychologists of Ontario for at least five years
  5. They are currently in active practice as a psychologist or psychological associate
  6. They are free of any conflict of interest or bias, or any appearance of either, with respect to the review
  7. Neither themselves, nor the individual they will be reviewing is in a position of power with respect to the other
Where will the review take place?

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?

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?

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?

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?

One of three outcomes is possible from the review:

  1. Meets Standards without any qualification: This is a relatively frequent outcome in which no areas for improvement are identified. Some suggestions may be offered by the reviewers that the member may find helpful to incorporate into his/her practice.
  2. Would meet Standards with minor modifications: This is a relatively frequent occurrence in which minor areas for improvement are identified which the member has agreed, with the reviewers, to address within a specified time frame. The Quality Assurance Committee will confirm with the member and the reviewers that the recommended and agreed upon changes have been completed.
  3. Is Significantly Below Acceptable Standards: While this is not a frequent occurrence, when major areas for improvement are identified, the Quality Assurance Committee will address these directly with the member.
What if I have questions?

If you have any questions regarding the PAR please don’t hesitate to contact Ms. Julie Hahn, Quality Assurance Coordinator at 416-961-8817, ext. 243 or at jhahn@cpo.on.ca.

Professional Corporations

Should I set up a professional corporation?

This is a business decision. The College recommends that you discuss your plans with an accountant or lawyer who specializes in this area.

I have decided to establish a professional corporation for my psychology practice. What do I need to do?

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?

You may submit the application and supporting documents via email to corporations@cpo.on.ca

Or by regular mail to:
110 Eglinton Avenue West
Suite 500
Toronto, Ontario  M4R 1A3

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:

  • Electronic Bill Payment may be made through web banking.
  • Email Transfer payments may be sent to payments@cpo.on.ca. Please use  CPO + your registration number as the password (ex. CPO####)
  • Mail a Cheque to the College.
What is the processing timeline for an application for a Certificates of Authorization?

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?

The application fee for a new Certificate of Authorization is $350.

What can I name my professional corporation?

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:

  • Include the surname of one or more shareholders of the corporation as the surname is set out in the College register;
  • Indicate the health profession practised by the shareholders (i.e. “psychology”);
  • Include the words “Professional Corporation” or “Société professionnelle”.

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?

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?

Only members of the College of Psychologists of Ontario.

Can a holding company be a shareholder of a psychology professional corporation?

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?

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?

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?

The fee for renewal of a Certificate of Authorization is $250.

Why must I complete a renewal each year for my professional corporation?

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?

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:
Companies and Personal Property Security Branch
Website: www.mgs.gov.on.ca
Telephone: 416-314-8880 or 1-800-361-3223

or through one of the private-sector service providers under contract with the Ministry of Government and Consumer Services:

ESC Corporate Services Ltd.
Website: www.eservicecorp.ca
Telephone: 416-595-7177 Toll free: 1-800-668-8208

OnCorp Direct Inc.
Website: www.oncorp.com
Telephone: 416-964-2677 Toll free: 1-800-461-7772

Cyberbahn, a division of Thomson Reuters Canada Limited
Website: www.carswelllegalsolutions.com
Telephone: 416-306-3070 Toll free: 1-800-267-0183

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”?

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.

Professional Practice

Must I report suspected harm to self or others?

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.

Must I call 911 to report suspected harm to self or others?

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.

What is the exact age range of clients that may be treated by someone authorized in adult Clinical Psychology?

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?

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:

  • academic, instructional and remedial techniques;
  • interdisciplinary team approach for case management, program planning and crisis intervention;
  • consulting, counselling, and primary, secondary and tertiary intervention programs and techniques;
  • systems and group behaviours within, and related to, the school organization, including school climate and culture.

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?

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?

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?

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?

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?

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
A member must render only those professional opinions that are based on current, reliable, adequate, and appropriate information

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?

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.

What are the record keeping requirements with respect to a client I met under a consultation contract to an agency?

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 StandardsConsultation: 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

  1. A member must keep a record related to the services provided to each organizational client.
  2. The record must include the following:
    a) the name and contact information of the organizational client;
    b) the name(s) and title(s) of the person(s) who can release confidential information about the organizational client;
    c) the date and nature of each material service provided to the organizational client;
    d) a copy of all agreements and correspondence with the organizational client; and
    e) a copy of each report that is prepared for the organizational client.

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 2017

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.

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 practiceadvice@cpo.on.ca.

Definitions

The Controlled Act related to Psychotherapy is defined in section 27(2) of the Regulated Health Professions Act, 1991 (RHPA) as:

14. Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgement, insight, behaviour, communication or social functioning.

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:

3. the assessment and treatment of cognitive, emotional or behavioural disturbances by psychotherapeutic means, delivered through a therapeutic relationship based primarily on verbal or non-verbal communication.

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?

No.  As noted in the definition, only psychotherapy delivered to a client with a “serious disorder . . . that may seriously impair” their functioning falls within the Controlled Act.

2. In general, under what circumstances may I supervise the performance of the Controlled Act?

Most of the concerns raised are related to supervision by College members of others who are performing the Controlled Act.  The RHPA specifically sets out that a person who is not yet authorized to perform the Controlled Act independently may do so under supervision but only if she/he is fulfilling the requirements to become a member of a health profession, the act is within the scope of practice of the profession and is done under the supervision or direction of a member of the profession [emphasis added].

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:

a) Doctoral psychology students in practica or internship placements or individuals is in the process of obtaining their four years of supervised experience necessary to apply to become a psychological associate?

The legislation permits one to supervise individuals who are fulfilling the requirements of our College.  This includes supervised practice members, students in practica or internships as well as those gaining their required post-masters experience.

b) Autonomous practice members of the College who may require supervision to expand their authorized areas of practice or their authorized population groups or who require supervision pursuant to a decision of the Inquiries, Complaints and Reports Committee (ICRC) or Discipline Committee?

Yes. Given that one is permitted to supervise a Supervised Practice member as noted above, it would seem inconsistent with the intention of the legislation for members not to be able to supervise another autonomous practice member to meet College requirements to practice in specific areas or with specific populations or fulfill a condition required by the ICRC or Discipline Committee.

c) Autonomous practice members of the College who may wish to increase their psychotherapy skills within their authorized areas of practice or their authorized population groups?

Generally, these members would become involved in a mentorship, consultation or training relationship, rather than a formal supervisory one.  Since they are already authorized in the area or with the population, the College does not require supervision when a member is learning new techniques or increasing the scope of their activities within their authorized areas.

d) Individuals who are in the process of becoming a member of the College of Registered Psychotherapists of Ontario (CRPO) or another College whose members are authorized to perform the Controlled Act?

On December 21, 2017, the Minister of Health and Long-Term Care announced that, “Individuals who provide these services [the controlled act] will have a two-year transition period, beginning December 31, 2017, to register with a regulatory college.”  Therefore, supervision of individuals in the process of becoming a member of the CRPO or another College whose members are authorized to perform the Controlled Act is permitted as follows:

Transition Period to December 31, 2019:
The transition period appears to permit individuals to perform the controlled act whether or not they are under supervision.  In keeping with the apparent intention of the transition period, that is to provide an opportunity for individuals to register with a relevant regulatory College; the College is of the view that it would be appropriate to permit members to supervise individuals who are preparing to become a member of the CRPO, during the transition period.

It is important to note that there is no restriction with regard to College members offering training, support, consultation and mentorship to other practitioners.  While the CRPO may use the term “supervision” in their requirements for candidates, their use of the term may connote a less formal arrangement than that outlined in Principle 4 of our Standards. Individuals seeking registration with the CRPO should inquire of their College if a mentorship, training or consultation relationship, rather than a formal supervisory one, as defined by our College, may satisfy the requirement. In agreeing to consult, the College would expect members to inform CRPO qualifying members that they should not indicate to clients that they are being ‘supervised’ as this could be misleading and suggest a degree of responsibility by the College member which is inaccurate. Rather it would be appropriate for them to explain that they are seeking consultation and training from a member of our College.

Post Transition Period:
The legislation only permits one to supervise individuals who are fulfilling the requirements of their own College, in our case, the College of Psychologists.  Therefore, after December 31, 2019 one cannot provide supervision, as it is defined by the College, to individuals who are becoming members of another College.

As noted above, there is no restriction with regard to College members offering training, support, consultation and mentorship to other practitioners.  While the CRPO may use the term “supervision” in their requirements for candidates, their use of the term may connote a less formal arrangement than that outlined in Principle 4 of our Standards. Individuals seeking registration with the CRPO should inquire of their College if a mentorship, training or consultation relationship, rather than a formal supervisory one as defined by our College, may satisfy the requirement.

e) Members of another regulated health profession who themselves are authorized to perform the controlled act?

Yes. If these individuals are authorized by their own College to perform the controlled act, they can do so independently or under the supervision of a member of the College of Psychologists. As with members of the College of Psychologists who are authorized to perform the Controlled Act [as per 3.c) above], in most circumstances it may be appropriate to establish a non-supervisory relationship that would afford them training, support, consultation and mentorship. If, however, there is a reason that non-supervisory supports would be insufficient, and supervision is necessary, a member of the College may enter into a supervisory relationship as outlined Principle 4 of the Standards. 

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?

Supervision of the controlled act of psychotherapy or any other psychological service may not be undertaken solely to facilitate third-party payment [Standards of Professional Conduct 4.1.1 (6)].

5. May I supervise a Registered Psychotherapist or Social Worker in services which fall outside of the definition of the Controlled Act?

Yes. You are permitted to supervise activities that fall outside of the definition of the Controlled Act by a Registered Psychotherapist or Social Worker or anyone else that you believe has the education, training and experience to provide those services under your supervision.

6. Can exceptions to the restrictions on performance or supervision of the Controlled Act be made for clients who require services in remote communities or who would be affected because a therapist is no longer eligible for supervision?

The legislation does not provide for any exceptions and the College cannot recommend or condone any activity that would not be permitted by legislation. In assuming responsibility for the supervision of a psychological service, the supervisor has taken on responsibility for the client’s care. Where a supervisee is no longer able to provide the supervised service, the supervisor may provide client care him or herself, or help the individual to find another competent practitioner from whom they can receive services. 

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?

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?

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?

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”?

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?

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
Public announcements of psychological services and fees must be offered in the name of an
autonomous practice member of the College.

This means that you may not permit a supervisee to advertise the services which you supervise under his or her own name, and must instead advertise the supervised services as part of your own practice.

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.

This means that you must ensure that you have full control over the records of those clients whose services you supervise, and take possession of those files when the supervision (and your authority) ends.

11.1 Fees and Billing Arrangements
A member must reach an agreement with an individual, group, or organization concerning the psychological services to be provided, the fees to be charged, and the billing arrangements prior to providing psychological services. Any changes in the services to be provided must be agreed to by the client before the service is delivered or fees are changed. Fees must be based on the amount of time spent and complexity of the services rendered.

This means that you must be directly involved in all agreements for services, as well as fees and billing arrangements, prior to the supervisee beginning to provide service or before arrangements are changed.

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?

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?

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?

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:

… the assessment of behavioral and mental conditions, the diagnosis of neuropsychological disorders and dysfunctions and psychotic, neurotic and personality disorders and dysfunctions and the prevention and treatment of behavioral and mental disorders and dysfunctions and the maintenance and enhancement of physical, intellectual, emotional, social and interpersonal functioning. 1991, c. 38, s. 3.

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?

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?

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?

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?

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;
b) the specific duties and obligations of the supervisee;
c) any limitations imposed upon the activities of the supervisee;
d) the specific duties and obligations of the supervisor;
e) the expected frequency and length of supervision meetings;
g) contact information and emergency contact information for both the supervisor and supervisee;
h) confirmation that the supervisee will comply with all requirements under the legislation and regulations relevant to the service and the Standards of Professional Conduct (2017); and
i) identification of a plan for appropriate support for the supervisee in the event of the supervisor’s unavailability.

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?

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;
d)    a summary of discussions regarding any relevant ethical, professional and jurisprudence issues discussed at each supervision meeting;
e)    a notation of any directives provided to the supervisee at each supervision meeting; and
f)     a notation of any of the supervisee’s strengths and needs for further development identified at 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?

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:

a) the date upon which the agreement is effective and the expected date upon which it will expire;
b) the specific duties and obligations of the supervisee;
c) any limitations imposed upon the activities of the supervisee;
d) the specific duties and obligations of the supervisor;
e) the expected frequency and length of supervision meetings;
f) the manner in which the supervisor will be directly involved in the planning, monitoring and evaluation of the services provided to clients;
g) contact information and emergency contact information for both the supervisor and supervisee;
h) confirmation that the supervisee will comply with all requirements under the legislation and regulations relevant to the service and the Standards of Professional Conduct (2017); and
i)  identification of a plan for appropriate support for the supervisee in the event of the supervisor’s unavailability.

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?

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?

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?

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?

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?

Consultation is defined in the Standards 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.

Supervision is defined as:

…an ongoing educational, evaluative and hierarchical relationship, where the supervisee is
required to comply with the direction of the supervisor, and the supervisor is responsible for the actions of the supervisee.

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?

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?

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?

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:

… 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 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?

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?

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:

… 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.

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”?

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:

… 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.

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?

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?

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?

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?

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:

  • Receiving or conferring a rebate, fee or other benefit by reason of the referral of a client from or to another person (Section 1.26)

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:

  • Providing a service that the member knows or ought to know is not likely to benefit the
    Client (Section 1.9); and
  • Practising the profession while the member is in a conflict of interest (Section 1.10);

and by the following requirements which have been carried forward from the previous Standards to the new ones:

  • Fees must be based on the amount of time spent and complexity of the services rendered (section 11.1); and
  • A member must not exploit persons over whom he/she has supervisory, evaluative, or other authority such as clients, students, supervisees, research participants, or employees (section 13.4(2)).
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?

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?

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:

  • Receiving or conferring a rebate, fee or other benefit by reason of the referral of a client from or to another person (Section 1.26)
  • Providing a service that the member knows or ought to know is not likely to benefit the client (Section 1.9); and
  • Practising the profession while the member is in a conflict of interest (Section 1.10)

Additionally, the Standards still require that:

  • Fees must be based on the amount of time spent and complexity of the services rendered (section 11.1); and
  • A member must not exploit persons over whom he/she has supervisory, evaluative, or other authority such as clients, students, supervisees, research participants, or employees (section 13.4(2)).

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?

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?

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 Payers

Who can provide psychological services in Ontario?

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:

    • Rigorous educational and training requirements;
    • Acceptable supervised professional experience;
    • A standardized written examination that evaluates comprehensive knowledge in psychology and is used throughout Canada and the United States;
    • A written examination that evaluates the candidate’s ability to apply knowledge in jurisprudence, ethics and professional standards for practice in Ontario; and,
    • An oral examination designed to evaluate readiness for autonomous professional practice.

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: cpo@cpo.on.ca

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:

“I have asked legal staff to review the definition in the Statutory Accident Benefits Schedule (SABS) and whether a psychological associate falls within this definition.

I am pleased to report the definition of psychologist used in the SABS includes psychological associates. Under the SABS a “psychologist” means a person authorized by law to practise psychology. As both a psychologist and psychological associate are authorized under the Psychology Act to practice they both meet the definition under the SABS.

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:

“It is my understanding that the Ontario Psychology Act authorizes both Psychologists and Psychological Associates to practice psychology.  Accordingly, holders of both titles are allowed to certify impairments with respect to an individual’s ability in mental functions necessary for everyday life for the purposes of eligibility for the DTC.”

My officials have contacted their colleagues at the Canada Revenue Agency (CRA) to communicate this understanding.  The appropriate changes have been made to CRA’s administrative practices to ensure that Psychological Associates are allowed to certify impairments in mental functions necessary for everyday life.”

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 Members

Who is eligible for funding?

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?

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?

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?

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?

No. Any therapist or counsellor may be selected, if:

(a) it is confirmed that they have not at any time or in any jurisdiction been found guilty of professional misconduct of a sexual nature or been civilly or criminally liable for an act of a similar nature; and
(b) the therapist or counsellor is not a member of the client’s family.

Do I need to meet with the Commitee?

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?

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?

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.

How can one apply?

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:
(a) confirmation that the therapy or counselling is being provided to the client and that the funds are being devoted only to the therapy or counselling;
(b) a short description of the therapy or counselling to be offered;
(c) the fees to be charged for the service;
(d) whether the therapist or counsellor has liability insurance; and
(e) the details of the therapist’s or counsellor’s training and experience and whether the therapist or counsellor is a member of a Regulated Health Profession;

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.