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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