COVID and Practice:

COVID and the Application/Registration Process:

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COVID and Practice:

Is CRPO saying I cannot see clients in person because of COVID-19?

No, CRPO continues to expect and support RPs to use their clinical judgement in deciding when it is appropriate to provide in-person therapy to clients. For clients who will derive benefit from e-therapy, CRPO continues to recommend that RPs provide care virtually.

Directive #2 for Health Care Providers from Ontario’s Chief Medical Officer of Health (CMOH) notes that health professionals are in the best position to determine which services should be in-person and that this decision-making should be guided by the principles of proportionality, minimizing harm to patients (clients), equity and reciprocity.

If therapy is to be in-person, registrants must ensure that needed infection control measures are in place, as per CMOH’s Operational Requirements: Health Sector Restart. Practical guidance on implementing these measures is provided in Developing a Return to In-Person Practice Plan.

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Do my clients and I have to wear a face covering or non-medical mask during in-person therapy appointments?

A face covering (a cloth or non-medical mask) must be worn in situations where physical distancing is not possible. This obligation comes from the Operational Requirements for Health Sector Restart Document, which is part of the Chief Medical Officer of Health’s  Directive #2,  and so applies to all regulated health professionals.

Please see page 6:

“Signage should be posted at the entrance to the office/clinic and at reception areas requiring all patients and any visitors to wear a face covering/nonmedical mask (if available and tolerated), perform hand hygiene, and then report to reception to self-identify…”

If you are not able to ensure physical distancing, or implement other controls to prevent transmission of COVID-19, (please continue to refer to CRPO’s Assessing Necessity of In-Person Practice and Risk of Transmission in Your Setting and Guidance for Return to In-Person Practice to assist you in this work) cloth masks would be required for both you and your client during in-person appointments.

Should you have a client who cannot tolerate wearing a face covering or non-medical mask, you will need to consider if in-person services are required and, if they are, whether you can provide them in a way that reduces the possibility of infection transmission.

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I have a client who does not feel they will be able to have a therapy session while wearing a mask. Is CRPO saying that I must require them to wear a mask if I am seeing them in-person?

The directive that masks are required actually comes from the Chief Medical Officer of Health (CMOH) of Ontario as part of the Operational Requirements: Health Sector Restart.

This directive applies to all regulated health professionals and so must be followed by RPs. It is not something that CRPO, as a regulatory college, has any authority to change.

We would note that the Operational Requirements indicate that a mask must be worn if tolerated. Certainly if you are providing in-person services to a client who cannot tolerate wearing a mask, the hierarchy of controls (which is included as part of CRPO’s Assessing Necessity of In-Person Practice and Risk of Transmission in Your Setting) outlines the other infection prevention measures you can implement in order to mitigate any risk to you or your client.

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What should I know about electronic practice?

If you have the appropriate technology in place and the possess the array of competencies that are necessary to engage clients in a safe, effective therapeutic process,  electronic practice may be an option for you to continue to provide care to clients remotely.

Please ensure that you consider issues such as consent, confidentiality, and professional liability insurance.  CRPO has information to provide guidance on electronic practice available on the website:

For more specific guidance, please see the latest post on Implementing Electronic Practice as a way of providing care during the pandemic.

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What platform should I use if I decide to provide services over videoconferencing?

CRPO can’t recommend a specific platform because technology is constantly evolving and there are so many options available.  However, you can refer to our webpage on Selecting a Communications Platform for guidance on how to choose one.

You may also refer to Virtual Care and the Novel Coronavirus (COVID-19), a resource developed by the Ontario Medical Association and OntarioMD. It includes a comprehensive list of electronic tools that were developed specifically for “video visits” and other forms of virtual or remote health care services.

Please note that CRPO cannot attest to the effectiveness or appropriateness of these platforms.

Please also note that privacy requirements should be considered from end to end – from the security of your internet access point, to the devices you use, to the features of the specific platforms you use. This tool can help you evaluate your own security practices.

Your professional association or an information technology consultant may be able to offer guidance or support on this front.

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What advice can you provide about returning to in-person practice?

Please review our Guidance for Return to In-Person Practice document.

We would also encourage you to check with your professional association as they may have guidance or resources that would be useful to you.

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How do I decide if I should see a client in-person?

Before you can resume any in-person services, you must assure that you are able to implement measures that will help to prevent the spread of COVID-19 in accordance with the COVID-19 Operational Requirements provided by the Ministry of Health and guidance provided by CRPO.

The Operational Requirements indicates that you should evaluate each client to determine whether e-therapy is (or continues to be) beneficial or whether in-person services are necessary. Communications with clients at this stage should take place remotely.

Registrants must rely on their professional judgment to determine if it is appropriate to provide in-person services to a client, taking into consideration the guidance offered by the directive from the Chief Medical Officer of Health and the guidance made available in the Electronic Practice Guideline.

The directive says:

Health Care Providers are in the best position to determine which services should continue to be provided remotely (online, by telephone or other virtual means) and which should be provided in-person. This should be guided by best clinical evidence. Health Care Providers must also adhere to the guidance provided by their applicable health regulatory college, and the following principles:

  • Proportionality. Decision to restart services should be proportionate to the real or anticipated capacities to provide those services.
  • Minimizing Harm to Patients. Decisions should strive to limit harm to patientswherever possible […]
  • Equity. Equity requires that all persons with the same clinical needs should be treated in the same way unless relevant differences exist […]
  • Reciprocity. Certain patients and patient populations will be particularly burdened as a result of our health system’s limited capacity to restart services. Consequently our health system has a reciprocal obligation to ensure that those who continue to be burdened have their health monitored, receive appropriate care, and be re-evaluated for emergent activities should they require them.

Decisions regarding the gradual restart of services should be made using processes that are fair to all patients.

The Electronic Practice Guideline says:

Situations to consider when evaluating appropriateness may include:

  • A client is showing severe cognitive symptoms, such as loss of contact with reality (psychosis)
  • Where there is a risk of adverse reaction during treatment, such as a panic attack
  • Where there is a risk of harm to self or others
  • Impacts of trauma the client has experienced […]

 [B]efore commencing therapy, a member’s initial assessment should also consider whether it is appropriate to engage the client in a form of therapy that would be conducted primarily though communications technology. Factors that may be relevant to this assessment process include:

  •  The nature of the therapeutic relationship.
  • The nature of the client’s concerns.
  • Anticipated shifts in the depth or focus of the therapy.
  • The client’s ability to access the technology reliably and in a safe, private setting.
  • The client’s overall capabilities, comfort and familiarity with the technology.
  • The client’s capacity to participate.
  • Access to local supports.

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Do I have to report clients to public health if I suspect they have COVID-19?

Primary health providers, hospitals and long-term care facilities are required to report confirmed or probable cases. RP’s are not required to report suspected cases.

Under powers granted by Ontario’s public health laws, public health authorities can issue an order directing any health information custodian to provide information, including a client’s personal health information.  This order can only be made where there are grounds to believe the information is necessary to investigate, eliminate or reduce the immediate and serious risk to the health of any persons.

During a pandemic, public health officials will be making every effort to trace contact for individuals with confirmed cases of COVID-19. If you receive a request from a public health authority for the personal health information of one of your clients for this reason, you may cooperate with the request if you have reasonable grounds to believe that the disclosure is necessary for the purposes of eliminating or reducing a risk of harm. In the event you ever receive an order, you should only provide as much information as is necessary for the purposes. See section 77.6(1)-(7) of the Health Protection and Promotion Act.

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I just got back from a trip outside of Canada OR I think I may have been exposed to someone who has tested positive for COVID-19. What should I do?

If you have just arrived in Canada, you are required to self-quarantine for 14 days.

If you have been in contact with someone who has tested positive for COVID-19 or has symptoms of COVID-19, you must:

  • stay home and self-isolate for 14 days after your last contact with that person.
  • monitor for symptoms of COVID-19. If you develop symptoms and you are concerned, use the government of Ontario’s COVID-19 self-assessment tool, which includes a list of assessment centres if you need a COVID-19 test.

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I am employed by a program that offers counselling for people who are struggling because of the pandemic. I am being told to describe myself as a “counsellor” rather than an RP when I provide care through this program. Is this ok?

First, Registered Psychotherapist is a protected title, so RPs must use it when providing mental health services (see Standard 1.2 Use of Terms, Titles and Designations). You may with to use “RP, counsellor.” Second, ensure clients understand your role and the work you will be doing together (see Standard 3.2 Consent). Finally, be aware that you are still acting in capacity as an RP and thus are subject to same standards of care.

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I have clients within this counselling program who require the controlled act. What should I do?

First, seek clarification from the program supervisor as to whether providing the controlled act of psychotherapy is part of the scope of the program. If clients who require this level of care cannot receive it under the program umbrella, you will need to refer the client to a psychotherapist who can provide is. See Standard 1.9 Referral for details.

The counselling program in question is paying RPs a lower rate when they work in this role. Is this ok?

It is not be appropriate for CRPO, as the regulator, to take a position on issues related to compensation. You may wish to follow up with your professional association, whose role it is to address these matters.

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COVID and the Application/Registration Process:

Will hours accumulated by delivering online therapy count for those who are in the application process or accumulating hours for category transfer?

Yes, if the hours of online therapy are providing care within the scope of psychotherapy and are appropriately supervised, they will count toward the direct client contact hours that are required for registration and for category transfer.

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Can I provide/receive supervision online?

Clinical supervision can be undertaken using the same electronic platforms as remote psychotherapy. Supervisors and supervisees are encouraged to look at the information CRPO has provided about how best to ensure that the approach taken and platform being used will comply with the standards of practice and be an effective way of connecting.

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Will the processing of my application be impacted by the pandemic?

No. While the CRPO team is operating remotely, staff continue to work full time to process and approve applications. We post on our Facebook page regarding which batch of applications we are reviewing, sorted by month.

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My graduation date is impacted by the pandemic. When can I apply to CRPO?

Zero clinical experience is required to apply to CRPO. This is not a change as a result of the pandemic.

CRPO does require an applicant to be substantially completed their psychotherapy program prior to submitting an application. Normally, substantial completion means an applicant:

  • is in their final semester prior to graduation;
  • has completed 90% of their program, including coursework and clinical placements; or
  • has completed their program with the exception of a thesis.

CRPO is aware that many students are delayed in completing their clinical placements as part of their psychotherapy program due to the pandemic. CRPO will accept applications from students who have substantially completed their coursework (i.e. 90% done classroom courses) even if they have not started or substantially completed clinical placements.

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How are documentation requirements for applying to CRPO impacted by the pandemic?

Transcripts & Credential Assessments
Normally, to apply to CRPO, a transcript/substantial completion letter or credential evaluation received from the institution is required to demonstrate the applicant is substantially completed or completed their psychotherapy program. If an applicant applies when they have substantially completed their program, a final transcript or credential evaluation received from the institution is required prior to signing up for the Registration Examination.

Up to July 31, 2020, CRPO will accept an unofficial transcript, substantial completion letter, or credential evaluation uploaded by the applicant to their Documents tab in their CRPO account. After application approval and prior to signing up for the Registration Examination or transferring to the RP category, a final transcript or credential evaluation received directly from the institution will be required.

As of August 1, 2020, CRPO will return to their normal policy requiring a transcript, substantial completion letter, or credential evaluation received directly from the institution at the time of application.

CRPO will now accept electronic copies of transcripts, substantial completion letters and credential evaluations sent from the institution to CRPO. The Supporting Documents Checklist has been revised to reflect this change. Please note that if your institution is only sending mailed copies, CRPO staff are still working remotely and collecting mail once a week. Therefore, mailed documents should not require a signature for delivery.

Statutory Declaration
CRPO normally requires the statutory declaration to be signed by an authorized individual (e.g. Commissioner of Oaths, notary public or judge).

Up to July 31, 2020, CRPO will accept statutory declarations only signed by the applicant. Applicants will be required to confirm in writing that they undertake/promise to provide a properly completed statutory declaration by the date they sign up for the Registration Examination. CRPO staff will contact an applicant in a message in their CRPO account to request this confirmation in writing after the application is submitted.

As of August 1, 2020, CRPO will return to their normal policy of requiring the statutory declaration to be signed by an authorized individual at the time of application.

During the pandemic, the statutory declaration can be completed virtually by an authorized individual with electronic signatures.

Clinical Experience Documentation
Documentation to support clinical experience hours for transferring from Registered Psychotherapist (Qualifying) to Registered Psychotherapist or for independent practice is always submitted by the applicant/registrant to their Documents tab. CRPO must be notified in a message when new documents are uploaded any time after an application is submitted. During the pandemic, CRPO still requires clinical experience documents to be signed with a handwritten or electronic signature. A typed signature or no signature, will not be accepted. If the signatory is unable to sign the document because they do not have a printer/scanner or correct version of Adobe, they can email the completed form directly to info@crpo.ca.

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Can I transfer from Registered Psychotherapist (Qualifying) to Registered Psychotherapist without having met the clinical experience requirement and/or passing the Registration Examination?

No. It is not in the public interest for transfers to be facilitated prior to a registrant meeting the legal requirements to demonstrate competency.

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Can CRPO waive clinical supervisor criteria requiring 30 hours of directed learning in providing clinical supervision during the pandemic?

No. It is not in the public interest to waive this requirement. While in person courses may be cancelled, the 30 hours of directed learning is flexible and can include learning completed online.

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Government Notices & Resources

Infection Prevention and Control (IPAC) – Online Learning
Cleaning and Disinfection for Public Settings
Environmental Cleaning Toolkit
Health and Safety Guidance During COVID-19 For Employers of Office Settings
Hand Hygiene E-Learning Tool
Just Clean Your Hands – videos
How to Wash Your Hands – signage
COVID-19 Operational Requirements: Health Sector Restart
REVISED: Ministry of Health Directive #2 for Health Care Providers
Face Coverings and Face Masks
A Framework for Reopening Our Province
COVID-19 Patient Screening Guidance Document
Detailed List of Stage 1 Openings
Workplace PPE Supplier Directory
COVID-19 Guidance: Community-Based Mental Health and Addiction Service Providers in Residential Settings
COVID-19 Guidance: Primary Care Providers in Community Setting
COVID-19 Self-Assessment Tool
Ministry of Health Managing Health Worker Illness and Return to Work
Ministry of Health Directive Regarding Regulated Health Professionals
Government of Canada: For Health Professionals
Government of Ontario Guidance for Health Care Sector
Health Care Provider Hotline 1-866-212-2272
Coronavirus disease (COVID-19): For health professionals– this page is the Government of Canada hub for information for health care providers
COVID-19 Guidance for the health sector – this page is the Government of Ontario hub for information for health care providers
Government of Canada – Get COVID-19 Updates – this page allows you to sign up to receive updates from the Government of Canada about COVID-19
Coronavirus disease (COVID-19): Prevention and risks – this page provides general information on the spread and prevention of infection
Taking care of your mental health during the COVID-19 pandemic – this may be a resource to share with clients who are not able to see you through virtual visits or who need additional support
Health Canada and Public Health Agency of Canada social media resources: COVID-19 – this page provides links government social media channels you may wish to follow along with messaging and images that you can use in your own social media posting

Other Health Care Provider Resources

Virtual Care and the Novel Coronavirus (COVID-19)
Public Health Ontario Routine Practices and Additional Precautions
APA COVID-19 Information and Resources – the American Psychological Association has a list of resources related to aspects of practice, research, self-care, education and public information that is continuously updated