October 15, 2019
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As of January 1, 2020, only certain regulated professionals will be authorized to perform the controlled act of psychotherapy (defined below).
Who Does this Impact and How?
Students and Graduates Seeking to Register with CRPO
Individuals who are training to become Registered Psychotherapists will need to have an RP supervisor in order to perform the controlled act of psychotherapy, e.g. during practicum. CRPO is aware that many education and training programs have interprofessional faculties and that clinical supervision in placements provided by these programs might involve supervision by other professionals. While the Regulated Health Professions Act, 1991 requires that those intending to register as RPs receive clinical supervision of the controlled act from only RPs, there is no reason that students cannot also receive supervision from other professionals for the broader scope of practice. Learn more on our Who Can Supervise Who page. Individuals applying for registration who have received supervision from both an RP and another professional would be required to submit two attestation forms (one for each supervisor) as part of their application.
Students are strongly encouraged to apply for registration once they have substantially completed their psychotherapy program. If they do not register once they are eligible to do so, they will no longer be permitted to perform the controlled act of psychotherapy.
CRPO endeavours to process applications for registration in a timely fashion. Applicants who are referred to a panel of the Registration Committee will see a longer processing time than those who are accepted at the initial application point. Individuals are encouraged to ensure that their application is complete and accurate and to respond to requests for clarification or further information as promptly as possible.
Unregulated providers performing the controlled act of psychotherapy will need either to restrict their practice or register with CRPO or one of the five other colleges whose registrants can practice psychotherapy*. Complete our Self-Assessment Tool to help determine if you are performing the controlled act.
There are limited exceptions or exemptions that allow an unregulated provider to perform a controlled act. These include treating someone by spiritual means according to the tenets of the religion of the person providing the treatment, Indigenous persons providing Indigenous healing to other Indigenous persons or members of an Indigenous community, or acting in an emergency.
Non-RP Regulated Practitioners
Non-RPs registered with one of the other five colleges whose registrants can practice psychotherapy* should contact their respective college with any questions about performing or supervising the controlled act.
*Includes College of Nurses of Ontario, College of Occupational Therapists of Ontario, College of Physicians and Surgeons of Ontario, College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers.
What Could Happen if I Perform the Controlled Act When I Am Not Competent or Authorized to Do So?
If an unregulated individual performs the controlled act, the College could investigate, take legal action, and publish information about the individual on CRPO’s website. Regulated providers may be investigated by their own college if they do not perform a controlled act in accordance with professional standards.
What is the Controlled Act of Psychotherapy?
The Regulated Health Professions Act, 1991 sets out 14 controlled acts that are inherently risky and should only be performed by a properly qualified professional to ensure client/patient safety. The controlled act of psychotherapy is one of these legally restricted acts. It is defined as:
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 controlled act applies to practitioners physically present in Ontario, and those located outside of Ontario who are providing services to clients in Ontario (e.g. via Skype).
Find more clarification in these resources: