On September 22, 2022, the Council and senior management team of the College of Registered Psychotherapists of Ontario (CRPO) met in person for the College’s second strategic planning session.
Coming to work together in-person for the first time in 30 months, the group entered into the day with the aim of reviewing and confirming or revising the vision and plan that was set in 2019. This work was supported by considerable data related to regulatory and operational risks as well as to public protection outcomes for the CRPO as a regulator and performance as an organization.
In preparation for the planning session, Council was asked to review and reflect on resources that included:
- Situational Analysis on the State of Governance
- Regulatory Objectives
- CRPO 2021 College Performance Measurement Report
- Fostering Excellence, Trustworthiness and Accessibility: CRPO Strategic Plan 2020-2023
Taken together, the resources provide a useful picture of what is being asked or required of Ontario’s health regulators, what CRPO has achieved since the last planning session and what work remains.
At the session, the discussion was used to look specifically at what it means to be strategic in the context of:
- the required regulatory response to system pressures (noting that they have been heightened by the pandemic)
- a clear call to action in ensuring that the College is working to dismantle barriers to access for members of equity-deserving communities who are seeking the protection afforded by or registration with the regulator
- opportunities that will come from continued steps towards modernizing the governance of Regulated Health Professions Act colleges in Ontario
The planning session concluded with a number of decisions having been made. These included:
- CRPO’s regulatory objectives remain relevant but can be improved to:
- provide a more accurate way of articulating CRPO’s role within the mental health system
- incorporate the importance of a trauma-informed approach in all of the College’s work
- Council would benefit from more engagement with the CPMF (both requirements and progress) as a way of tying the metrics for ‘excellence’ to the college-specific vision of regulating psychotherapists.
- Council is committed to ongoing governance improvement and is interested in exploring enhanced onboarding and succession planning for leadership positions.
- the Executive Committee was directed to review the current offerings and approach and to consider:
- arranging ‘council buddies’ for all newly elected or appointed members
- committing resources to a formal mentoring program for members interested in leadership positions
- providing more opportunities for exposure to leadership roles (guest chairing, committee observership, etc.)
- including non-Council appointees in succession planning
- the Executive Committee was directed to review the current offerings and approach and to consider:
- Communication with stakeholders needs to be more strategic and focused on supporting understanding of the right touch, risk-based approach and to highlight the College’s commitment to trauma-informed practices.
To develop standards and procedures to regulate psychotherapists in the public interest, striving to ensure competent and ethical practice within a professional accountability framework.
Leadership in professional self-regulation, dedicated to the principles of excellence, fairness, openness, responsiveness and respect for diversity.
Leadership, Excellence, Accountability, Equity, Integrity, Teamwork, Respect, Openness
During strategic planning, CRPO Council developed a vision statement that guided the process:
Through our work, people across Ontario will understand that Registered Psychotherapists are regulated, trustworthy mental health professionals who can assess, treat and support cognitive, emotional, behavioural, interpersonal and situational issues and challenges. They will recognize that there are multiple modalities, but that all are aimed at promoting mental health and well-being. Registered Psychotherapists will have a strong professional identity, and as a profession, will be working to provide competent, safe and ethical services to meet the expanding mental health needs of Ontarians.
CRPO will be recognized as a trusted, accessible source for public and professional guidance about, and resolution of, issues related to psychotherapy. CRPO will work with the public, registrants, other regulators, government and other stakeholders to support both the sustainability and accountability of the profession. Because of CRPO’s work, it will be widely understood that anyone who is a Registered Psychotherapist in Ontario adheres to a standard of excellence, characterized by safe, ethical and competent practice. Everyone connected with CRPO will feel heard when expressing matters of concern and as stakeholders in developing and maintaining a system where mental health is valued and supported.
Priority: Build CRPO’s presence as a trusted authority for psychotherapy
Goal: CRPO will be recognized as a leader in ensuring the value of psychotherapy, its role in the mental health system, and what constitutes safety, competence and quality in psychotherapeutic practice and excellence in regulatory oversight. CRPO will be the first source for all issues related to Registered Psychotherapists among health professions, the public, government, the media and other stakeholders, and will be recognized as an exemplar of fostering professional competency and standards of practice.
- Continue to strengthen the practice of psychotherapy through clearly defined standards, continuing competence requirements and support for excellence in practice
- Create public outreach to build understanding about psychotherapy and make CRPO more visible and accessible
- Cooperate with other stakeholders to build knowledge about and access to psychotherapy as a regulated profession
Priority: Further develop communications to support clear, transparent and dynamic interaction with stakeholders
Goal: CRPO will be in active dialogue and communication with the public, registrants, government and other stakeholders. A focus on ensuring communications with the public and registrants will support their experience of CRPO as open, transparent and accessible. The public will know where to locate information about Regulated Psychotherapists and how to access CRPO to respond to questions and address concerns about care. Registrants will report clarity about the role and purpose of CRPO, will feel their modality of work is respected and valued, and will recognize CRPO as a supportive resource for good practice. CRPO and registrants will both recognize their shared goal of maintaining excellent practice to build public trust.
- Develop effective, proactive communication initiatives based on assessment of public need for information
- Strengthen communications with registrants, with a focus on the College’s commitment to fairness, due process and a trauma informed approach, to ensure clarity and transparency and to build trust and a better understanding of regulatory requirements
- Actively participate in efforts to create useful dialogue with stakeholders across Ontario’s mental health sector
Priority: Strengthen operational and governance infrastructure
Goal: CRPO will have governance practices, technology and information resources that will foster a culture of growth, continual improvement, adaptability and responsiveness to the public, registrants and other stakeholders, while meeting all legislative accountability requirements.
- Continue to cultivate excellence, accountability and responsiveness among Council and committee members through professional development and policy guidance
- Foster diversity and inclusion among staff, Council and registered psychotherapists
- Implement effective governance and risk-management frameworks across all operational and regulatory functions
- Measure progress through strategic planning, risk assessment and key performance indicators
Priority: Collaborate with other system partners to contribute to better access to mental health services
Goal: Through collaboration with other system partners, we will build collective best practices, and advocate for changes that will strengthen regulated health professions and improve public access and experience with mental health services.
- Build on existing relationships among the Colleges whose members have the authority to perform the controlled act of psychotherapy, the Health Professions Regulators of Ontario network and other Canadian psychotherapy regulators to:
- define and foster leadership in regulatory excellence
- create collective solutions to allow alignment in addressing concerns with mental health service provision
- Engage with the Ministry of Health to provide useful and timely information and advice about Registered Psychotherapy and the mental health system
- Formalize work of recognizing, reporting on and adapting to changes in the practice environment to support health system improvement
Regulatory objectives are specific and measurable efforts needed to achieve the goal of public protection dictated by the RHPA. Establishing and communicating regulatory objectives allows a regulator to demonstrate how the work they do is in the public interest. Stated objectives also support accountability within a right-touch approach: if an initiative cannot be measured against one of the objectives, it likely should not be undertaken.
1. Serve and protect the interest of the public The College of Registered Psychotherapists of Ontario’s (CRPO) mandate is public protection. This obligation to Ontarians begins with ensuring the safety of individuals receiving care from a Registered Psychotherapist but, in keeping with the client and family-centred approach to care, it extends to the protection of the well-being of family members of those accessing services.
By establishing rigorous entry-to-practice competency requirements and requiring active, ongoing participation in quality assurance and professional development activities, CRPO plays a proactive role in ensuring that RP’s have the needed knowledge, skills and clinical judgement to practice safely. By providing barrier-free access to the complaints and reports process for clients, their families and other professionals, CRPO ensures that it can respond in an appropriate and timely manner to concerns about the competence or conduct of an RP.
2. Promote confidence in professional regulation
The authority and mandate of CRPO is drawn from the Regulated Health Professions Act, 1991, the Psychotherapy Act, 2007 as well as the regulations under it and the ensuing standards, guidelines and policies set by CRPO. Working within this framework to ensure that the College complies with its mandate and the law, Council acts in a manner that embodies and promotes excellence in professional regulation.
By acting in a way that promotes confidence in professional regulation, CRPO upholds the reputation, integrity and independence of the profession. In holding RPs accountable to standards and a code of ethics, CRPO also fosters public trust in the profession.
3. Regulate in a transparent, principled, proportionate, unbiased, proactive manner
Above all else, CRPO will carry out all its core work in a manner that complies with good regulation principles and instills both public and registrant confidence in regulation. CRPO’s Council has adopted a right touch/risk-based approach to regulation. This framework is geared toward ensuring both efficacy and efficiency by ensuring that the level of regulation is proportionate to the level of risk to the public.
By promoting standards of competence and conduct, by acting where these standards are breached, and through quality assuring professional development, CRPO supports professionalism and protects the public interest. CRPO does not seek to address all aspects of risk, rather it works proactively to evaluate and mitigate the potential for harm, using regulatory measures that support positive behaviour change and the exercise of professional judgement among RPs.
4. Promote equity, diversity and inclusion in the provision of psychotherapy services
Discrimination that persists in the provision of health care and social services in Ontario creates barriers to access to mental health care. In particular, these biases can negatively affect individuals from racialized communities, those with low-income, the elderly, members of the LGBQT community and those with mental illness.
By engaging with the public, registrants and other stakeholders, CRPO works toward freedom from discrimination through the promotion of diversity and inclusivity in psychotherapy education and practice. Holding RPs to standards that respect the diversity and dignity of all persons ensures that they can competently and respectfully serve individuals and families from across the diverse spectrum of age, race, culture, background, sexual orientation and gender identity.
5. Regulate to support the mental health system in being more accessible
There is an increasing acknowledgement of the difficulties that many Ontarians face in accessing needed mental health services. CRPO is aware that barriers to access to care with RPs exist across the province for a variety of reasons. When considered in relation to ability to receive needed mental health services, the importance of the psychotherapeutic relationship and the benefits of continuity of care, these barriers constitute a risk of harm to the public.
By effectively regulating RPs, CRPO ensures that qualified individuals are authorized and available to practice, that they maintain their competence and that any issues with competence or conduct are addressed promptly and appropriately. This allows stakeholders in the health care system to be confident in the quality of care provided by RPs and supports leveraging the growing number of RPs within the system broadly, resulting in improved access to appropriate continuity of care with providers and in the setting of choice.
Testing initiatives against objectives
As a practical tool, using a series of questions – in conjunction with regulatory objectives – is one way of determining to what degree any initiative measures up against the public interest mandate.
A. Does it relate to the College’s statutory objects?
B. Does it further one of the regulatory objectives?
i. Is it being done transparently?
ii. Who is the primary beneficiary of the initiative?
iii. Would this better fit into another’s mandate (for example, a professional association)?
iv. Who would be unhappy with the initiative? Why?
v. How would it look in news or social media?
vi. How would our accountability bodies (for example, the Fairness Commissioner) respond?