COVID and Practice:
How do I decide if I should see a client in-person?
Before providing any in-person care, you must appropriately screen your clients using the Ministry’s COVID-19 Patient Screening Guidance Document and 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 document indicates that clinicians should evaluate each client to determine whether e-therapy is (or continues to be) beneficial or whether in-person services are necessary.
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 available in the Electronic Practice Guideline.
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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Can I ask a client if they have been vaccinated?
The current (as of August 26, 2021) Ministry of Health COVID-19 Patient Screening Guidance Document screening tool includes the background question “Did the person receive their final (or second) vaccination dose more than 14 days ago?”.
This question is included in order to determine if people being screened should be asked about travel outside Canada and exposure to confirmed cases of COVID-19. Fully immunized individuals do not need to be asked these questions.
To be clear: asking about vaccine status is not intended to be an automatic disqualification for in-person services. CRPO continues to advise RPs to use their clinical judgement and consider specific decision-making criteria if determining if in-person care is required.
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Can I refuse to provide in-person treatment based on a client’s vaccination status?
Under the Ontario Human Rights Code, service providers have a “duty to accommodate people who may be unable to receive a COVID-19 vaccine, for reasons related to disability or creed, unless it would amount to undue hardship based on cost or health and safety.”
If a client is unvaccinated or if they choose not to confirm their vaccination status and they decline virtual care, RPs will need to use their clinical judgement to determine if it is reasonable for them to provide in person care in a way that is safe for both them and the client. This may mean referring the client to another provider who is able to provide in-person care. Registrants are encouraged to review Standard 6.3 Discontinuing Services to support them in meeting their professional obligations in such situations.
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If my clients and I have been fully vaccinated, can I resume in-person therapy?
CRPO expects that RPs who choose to provide in-person services with clients, regardless of their vaccination status or that of their clients, will only do so if they can implement appropriate infection prevention and control (IPAC) precautions.
CRPO continues to advise RPs to use their clinical judgement to determine where in-person care is required on a case-by-case basis. You are encouraged to review this FAQ response and decision-making criteria for determining if in-person care is required.
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My practice space is large enough that my clients and I can sit more than 2 meters apart. Does this mean we don’t have to wear masks?
Ontario Ministry of Health requirements currently stipulate that “you do not need to wear a face covering when you are working in an area that allows you to maintain a distance of at least 2 metres from anyone else while you are indoors.”
However, data cited by Toronto Public Health “suggests that COVID-19 can more easily spread through the air when there are a higher number of people indoors, for a longer period of time, with poor airflow or ventilation.”
Registrants should consider that physical distancing is only one infection prevention and control measure that should be used to help keep you and your clients safe.
If you are seeing clients in person, effective infection prevention and control measures include:
- symptom screening
- self-isolation for people with symptoms
- practicing good hand hygiene and respiratory etiquette
- wearing a mask at all times when indoors to contain respiratory droplets
Registrants should be looking at their situation and office space in determining if it is advisable to see clients without wearing masks. Information related to the spread of COVID-19, specifically about concerns related to airflow and ventilation, time spent indoors, asymptomatic spread of virus and the use of air purifiers should be reviewed and considered in decision-making. Toronto Public Health has useful guidance on COVID-19: Transmission, Aerosols and Ventilation that you may wish to consult.
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 requirement comes from the Operational Requirements for Health Sector Restart Document and 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 where physical distancing is not possible 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.
The Ministry of Health stipulates that people do not need to wear a face covering if they:
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What should I know about proof of vaccine or vaccine passports and medical vaccine mandate exemptions?
The Ministry of Health document Medical Exemptions to COVID-19 Vaccination provides specific and detailed information regarding the reasons for exemptions to vaccine mandates.
Medical exemptions must be supported by a nurse practitioner or physician.
Since receiving the COVID-19 vaccine is voluntary, service providers – including RPs – do not have the authority to require proof of vaccination or medical exemption. Further, while Ontarians will need to be fully vaccinated and provide their proof of vaccination to access certain high-risk public settings and facilities, these requirements do not apply to settings where people receive health care.
Can CRPO registrants advise clients about COVID-19 vaccines?
It is important to note that providing advice or specific recommendations to clients about medications, including vaccines, is not within an RP’s scope of practice. If a client wanted to explore the topic of whether or not to vaccinate or what type of vaccination to obtain during a session, an RP would need to consider referring the client to their nurse practitioner, family physician or other qualified professional for advice. (See Standard 1.9: Referral: https://www.crpo.ca/standard-1-9/.)
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Can CRPO registrants share anti-vaccination information with clients?
No. As noted above, it is not within an RP’s scope of practice to provide advice or specific recommendations about medications, including vaccinations.
An RP might be personally opposed to vaccination. In all situations, CRPO Standards require RPs to ensure their influence does not affect the personal decision-making of a client. In other words, RPs may not use their position to promote personal opinions or causes with clients.
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Is the COVID-19 vaccine mandatory for Registered Psychotherapists?
While it is not within the College’s authority to implement a vaccination mandate for RPs, CRPO continues to encourage all registrants to consider being vaccinated against COVID-19. Vaccines are an important tool to help stop the spread of the virus and allow individuals, families and workers to safely resume normal life. As noted in Ontario Ministry of Health Guidance for Prioritizing Health Care Workers for COVID-19 Vaccination, COVID-19 vaccination is strongly recommended for all health care workers but remains voluntary for providers outside designated high-risk settings.
Ontario’s Chief Medical Officer of Health has issued Directive #6 mandating COVID-19 vaccination policies be enacted in high-risk settings by September 7, 2021. This Directive applies to all staff, contractors, students and volunteers in hospitals, community care and long-term care settings. RP’s who work in these settings will be required, under this Directive, to comply with any policy requirements.
At a minimum, the government mandated policies are to require either proof of full vaccination or a medical reason for not being vaccinated or, alternatively, the completion of a vaccination education session. Individuals in these high-risk settings who do not provide proof of full vaccination against COVID-19 will be required to undergo regular antigen testing.
Do CRPO registrants have to disclose their vaccination status when asked?
An individual’s vaccination status is considered personal health information. If an RP chooses to disclose their personal health information to clients, it must be of therapeutic benefit and shared in a professional manner. Clients also have the right to give informed consent to treatment. If the client specifically asks about the RP’s vaccine status as part of their decision to receive in-person treatment, the RP should not provide a false or misleading response.
If you and the client have determined that they require in-person care and they are unwilling to see you based on vaccine status, you should be prepared to provide appropriate supports. Standards 1.9 Referral and 6.3 Discontinuing Services provide guidance on this front.
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Is it acceptable for RPs who are opposed to vaccines, vaccine mandates or vaccine passports to make public statements or post on social media about their opposition?
An RP might be personally opposed to vaccination or particular public health measures. People are free to express themselves politically. However, if an RP is actively spreading misinformation, especially while referring to their psychotherapy credentials or expertise, contravening legally required public health measures, or if they are involved in violence or harassment at a protest, they run the risk of contravening CRPO’s General Conduct standard.
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.
Although Directive #2 for Health Care Providers from Ontario’s Chief Medical Officer of Health (CMOH) has been revoked, health professionals continue to be in the best position to determine which services should be in-person. Decision-making should be guided by the principles of proportionality, minimizing harm to patients (clients), equity and reciprocity.
Please note that while resuming in-person services is permitted, it is not required.
If therapy is to be in-person, registrants must ensure that needed infection control measures are in place, as outlined in 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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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 the Virtual Care page on OntarioMD News, 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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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. What should I do?
The Ontario government provides updated direction regarding Travelling during COVID-19 that you should consult to understand quarantine and other public health requirements.
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I think I may have been exposed to someone who has tested positive for COVID-19. What should I do?
The Ontario government provides updated direction regarding What to do if you’ve been exposed to COVID-19 that you should consult to understand quarantine and other public health requirements.
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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. Unchanged: 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.
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My employer has redeployed me to perform duties outside my scope of practice.
On April 21, 2021, Ontario Regulation 305/21, Regulated Health Professionals, made under the Emergency Management and Civil Protection Act, 1990, was enacted.
Under this temporary Regulation, health care professionals, including Registered Psychotherapists (RPs), who are employed, contracted, appointed or otherwise engaged by a hospital to provide services are authorized to provide patient care services outside their regular scope of practice, provided the services are necessary to respond to, prevent, or alleviate the effects of the COVID-19 outbreak. The Regulation also enables hospitals to employ, contract, appoint, or otherwise engage regulated health professionals from out-of-province.
The College interprets this Regulation to apply only to practising RPs who are employed and providing care within a hospital setting. The Regulation does not permit RPs to practise outside of the scope of practice while they are employed in a clinic or private practice setting.
The College expects registrants to continue uphold the Code of Ethics and abide by the Professional Practice Standards.
For example, it is important to consider whether an RP employed in a hospital setting has the training, knowledge, skill, and judgement (i.e., competence) to perform the specific duties. As well, an RP would need to consider dual relationships with clients and how to maintain appropriate boundaries. For example, if an RP were already providing psychotherapy to a client in the hospital setting, there could be ethical issues to consider in taking on the extra role of providing non-psychotherapy services.
Registrants continue to be subject to the jurisdiction of the College for incompetence that occurs while the registrant provides services under this new regulation. If a complaint is made against a registrant who is performing duties under this Regulation, the registrant would be subject to CRPO’s complaints process. In responding to complaints and reports, CRPO considers all relevant contextual information, including the circumstances in which registrants are working.
Directive #2 has been revoked. Does this change CRPO’s guidance?
While RPs are no longer subject to the requirements of Directive #2, CRPO’s guidance to Registered Psychotherapists (RPs) remains the same.
CRPO continues to advise that registrants are in the best position to determine when and if it is appropriate to resume in-person services. Please note that while resuming in-person services is permitted, it is not required.
RPs are expected to use their clinical judgement to determine where in-person care is essential on a case-by-case basis. RPs who choose to provide in-person services with clients will only do so if they (or their employer) can implement appropriate infection prevention and control (IPAC) measures.
See decision-making criteria for determining if care is essential and How do I decide if I should see a client in person?
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