Q: I’ve heard that the controlled act of psychotherapy fully comes into effect January 2020. What does this mean for supervision?

On January 1, 2018, a legal provision that defined the controlled act of psychotherapy came into effect, meaning that the controlled act of psychotherapy is now, technically, a restricted professional activity, where previously, it was not restricted.

The government provided a phase-in period to facilitate this transition which lasts until December 31, 2019. It is up to individual colleges to determine how they will interpret the laws and their regulations in light of this transition phase. On January 1, 2020, the controlled act of psychotherapy goes fully into effect.

Section 29 (b) of the Regulated Health Professions Act says that a person who is in the process of fulfilling the requirements to become a member of a profession may perform a controlled act when it is under the supervision of a member of that same profession. Because of this provision, from January 1, 2020 onward, individuals in training to practise psychotherapy who perform the controlled act will need to assure they are receiving clinical supervision from an appropriately qualified member of CRPO.

Q: As a member of CRPO, am I allowed to be supervised by a psychologist?

From CRPO’s perspective, the answer is yes – see here for more information about who can supervise who. However, you or your supervisor will need to consult with CPO regarding that College’s expectations of its members in providing supervision, particularly with regards to the controlled act. CPO’s Standards of Professional Conduct and a related FAQ can be found here and a Q&A document relating to the controlled act of psychotherapy can be found here.

As a member of CRPO, if you are required to receive clinical supervision for registration purposes, you must assure that your clinical supervisor meets the criteria set out in the definition of clinical supervisor. In addition, your relationship with any clinical supervisor
must not interfere with your ability to abide by the Professional Practice Standards for RPs.

Understand that you and your clinical supervisor would be operating within the regulatory frameworks of two distinct professions. Members of the College of Psychologists of Ontario (CPO) have a duty to maintain the standards of the psychology profession.

It is important to note that RPs can perform the controlled act of psychotherapy on their own authority, i.e. as members of CRPO. They do not require supervision to perform the controlled act of psychotherapy.

Finally, CPO has standards related to supervision which prohibit supervision for the sole purpose of third party billing. Likewise, CRPO requires RPs to participate meaningfully in clinical supervision. If meaningful supervision does not take place, and the arrangement is merely a guise to access third party billing, a member may be liable to investigation or discipline by CRPO.

Q: Will CRPO recognize “consultation,” “mentorship,” and “training” provided by psychologists as equivalent to clinical supervision for CRPO registration purposes?

Members who require clinical supervision for registration purposes must:

  • Ensure the clinical supervisor meets CRPO’s definitionof a clinical supervisor.
  • Assure that the relationship has the following purposes: 1. to promote the professional growth of the RP; 2. to enhance the RP’s safe and effective use of self in the therapeutic relationship; 3. to discuss the direction of therapy; and 4. to safeguard the well-being of the client. This is demonstrated when the RP’s knowledge, skill and judgment are assessed; when RP’s learning needs are assessed; when the RP is provided with formative feedback; and when actions are taken to ensure client safety.

Ensure that the relationship will not impede their ability to meet the Professional Practice Standards for RPs, particularly those that relate to competence, clinical supervision, informed consent, issuing accurate documents and financial record-keeping.

Q: What should I do if my supervisor does not meet CRPO’s definition of a clinical supervisor?

The answer to this question depends on your registration status. If you require clinical supervision for registration purposes (e.g. because you are a student, a Qualifying member, or a member who does not yet qualify for independent practice), you need to receive supervision from someone who meets CRPO’s clinical supervisor criteria. If you’re someone who requires clinical supervision for registration purposes and you wish to continue working with a supervisor who does not meet the criteria, it’s important for you to know that the College will not recognize this as fulfilling the requirement to practise with clinical supervision. Learn more by reading our chart on Who Can Supervise Who.

Q: Can I supervise a member of another college?

Members of CRPO may provide clinical supervision to regulated and unregulated professionals provided they have the competence to do so, and providing they adhere to the Professional Practice Standards for RPs, in particular those that relate to clinical supervision.

Members who provide clinical supervision to a supervisee who is a member of another profession must recognize that they would be operating within two regulatory frameworks. The supervisee will have a duty to adhere to the standards of their own profession, just as the RP will have a duty to uphold the standards of the psychotherapy profession.

Q: Can I supervise a student who will eventually become registered with another college?

Please consult with the college that the supervisee expects to join in order to determine whether that college will accept clinical supervision provided by a member of another profession.

Looking for more information about clinical supervision? Check out our supervision page, review the special bulletin or email us at practice@crpo.ca.