College Requirements

Use of Terms, Titles, and Designations

Use of the “Dr.” title

Can I use the “Dr.” title in a clinical setting if I have a doctorate in medicine?

Registrants of CRPO are not permitted to use the title “Doctor” or “Dr.”  in a clinical setting. This is the case even if the person has an earned doctoral degree (e.g., the person holds a Ph.D). Under this provision, the title “Doctor” can be used in other settings, socially or in a purely academic setting, where no clients are present.

Registrants can display a Ph.D or other doctoral degree in their promotional material, if the degree is their highest credential earned and is related to the practice of the profession.

When acting in a professional capacity, registrants are expected to display only education/training credentials related to the practice of the profession, specifically, the highest credential earned that is related to the practice of the profession.

Regarding the “Doctor of Medicine” or “MD” title, we would advise a registrant to consider to what extent this credential is relevant to their practise of psychotherapy, and to consider the perspective of clients and members of the public who will see the credentials. The MD credential is highly recognized by the public as one that applies to physicians. If there is a chance that the credential will cause confusion to clients or members of the public, leading them to believe that the registrant is a doctor or qualified to practice medicine in Ontario, the registrant would need to consider how they would address this.

When reviewing a registrant’s use of the “Dr.” title, CRPO would consider whether the registrant’s regulated title is displayed in a manner that is more prominent than any other title(s); whether the registrant is using the Doctor title in a clinical practice setting; and whether the registrant is using other titles, such as educational credentials and specialty designations, in a misleading manner.

 

I am a [chiropractor, optometrist, dentist] and an RP. Can I use the “Dr.” title in a clinical setting?

Use of the title “Doctor” or “Dr.” is protected in the Regulated Health Professions Act (RHPA). Registrants of CRPO are not permitted to use this title in a clinical setting. If a person is not from one of the health professions entitled to use the doctor title (chiropractic, optometry, medicine, psychology, dentistry) or a social worker with an earned doctorate degree in social work, s/he cannot use the title “Doctor” or “Dr.” in a clinical setting. This is the case even if the person has an earned doctoral degree (e.g. the person holds a Ph.D). Under this provision, the title “Doctor” can be used in other settings, socially or in a purely academic setting, where no clients are present.

Note: The above does not prevent a registrant from displaying a Ph.D or other doctoral degree in his/her promotional material, if the degree is their highest credential earned and is related to the practice of the profession.

Chiropractors, optometrists, and dentists are authorized to use the title of Doctor. However, these professions are not authorized to practice psychotherapy; therefore, you must be very clear with clients about your education and CRPO credentials.

It is important to note that when practicing psychotherapy, your [chiropractic, optometry, dental] practice and psychotherapy practice including record keeping, advertising, billing and other business practices are wholly separate from each other and that you are informing clients that you are a registered member of the CRPO and have the appropriate knowledge, skill and judgement to practice psychotherapy in the area in which they have expressed clinical needs.

 

Can I use the “Dr” title in a research setting?

Registrants of CRPO are not permitted to use the title “Doctor” or “Dr.” in the course of providing, or offering to provide, health care to individuals in Ontario. This is the case even if the person has an earned doctoral degree (e.g., the person holds a Ph.D).

Under this provision, the title “Doctor” can be used in other settings, socially or in a purely academic setting, where no clients are present.

In a situation where an RP is conducting academic research, if they are not providing psychotherapy to the people who are research study participants and see them only in the context of [neuroscience] research, then the RP would not be using the Dr. title in the course of practicing the profession of psychotherapy, even though it would still be within a clinical setting.

In such a case, the PhD designation and the use of the Dr. title would be relevant and appropriate.

However, if the RP is offering psychotherapy treatment as part of the research protocol, then they should avoid using “doctor” and ensure they explain their role for transparency.

Use of PhD credential

Can I display my PhD credential in [neuroscience]?

When acting in a professional capacity, registrants should display only education/training credentials related to the practice of the profession, specifically, the highest credential earned that is related to the practice of the profession. In other words, in order to use an academic degree alongside “RP”, the degree needs to be related to the practice of psychotherapy and should have developed an individual’s skills in psychotherapy. Please see Professional Practice Standard 1.2 on the Use of Terms, Titles and Designations.

Our Practice Matters FAQ on displaying a PhD or other credentials includes a series of questions to help determine if a PhD designation could appropriately be used.  Registrants can display a Ph.D or other doctoral degree in their promotional material, if the degree is their highest credential earned and is related to the practice of the profession.

If you determine that it is appropriate to use your PhD designation, you may want to consider adding “neuroscience” in parentheses for extra transparency.

Use of “psychotherapist” title

What is the difference between the title “psychotherapist” (as regulated in Ontario) and “Counselling Therapist” (as regulated in the provinces of New Brunswick and Nova Scotia)?

Credentialing/licensing/registration/certification is a provincial responsibility in Canada.

In Ontario, the College of Registered Psychotherapists of Ontario (CRPO) regulates its registrants in the public interest in accordance with the Psychotherapy Act, 2007 and the Regulated Health Professions Act, 1991 (RHPA) and the regulations and by-laws made under these Acts.

The Psychotherapy Act, 2007 restricts the use of the titles “Psychotherapist”, “Registered Psychotherapist”, and “Registered Mental Health Therapist,” as well as any variations and abbreviations of these titles.

There is enough overlap between psychotherapy and counselling that the terms can sometimes be used interchangeably, and CRPO acknowledges that some organizations prefer one term over the other.  In the case of title protection, CRPO recognizes that other jurisdictions have chosen to protect other titles, such as “counselling therapist”.

Currently, members of the College of Counselling Therapists of New Brunswick (CCTNB), the Nova Scotia College of Counselling Therapists (NSCCT), and holders of a Psychotherapy Permit in Québec are eligible to apply for registration with CRPO under labour mobility laws, regardless of the title they use in their home jurisdiction. The key factor in determining equivalent competency is whether the scope of practice in the jurisdiction is substantially equivalent to the scope of practice for RPs in Ontario.

This document may also provide some historical insights on why Ontario chose to regulate psychotherapy: https://www.hprac.org/en/reports/resources/New_Directions_April_2006_EN.pdf#page=208.

Finally, we note that the RHPA exempts “counselling” from some aspects of regulation, and that CRPO registrants come from a variety of psychotherapy and clinical counselling backgrounds.

Reporting unsafe practices/Duty to report/Limits to confidentiality

Mandatory self-report

Should a registrant self-report issues like parking tickets, red light tickets, and speeding tickets to CRPO?

The CRPO website has a Mandatory Reporting page, which outlines the following:

One requirement of being a member of a regulatory body is self-reporting certain events to the college. The following is a list of items that registrants needs to disclose to CRPO:

  • A finding of guilt in relation to any offence in any jurisdiction.
  • Any current offence charges or bail conditions.
  • A finding of professional misconduct, incompetence or incapacity (or any similar finding), made by another regulator in any jurisdiction.
  • Any  current proceeding for professional misconduct, incompetence or incapacity made by another regulator in any jurisdiction.
  • A finding of professional negligence or malpractice in any jurisdiction.
  • A refusal by a regulatory body to issue registration or a license.
  • Any resignation or revocation of a registrant’s license with another regulator in any jurisdiction, and whether the registrant’s license was in good standing at the time.
  • Any other event that would provide reasonable grounds for the belief that the registrant will not practise psychotherapy in a safe and professional manner.
  • Change of name or contact information.

As well, the Jurisprudence Handbook states, “Members must inform the college when they have been found guilty of an offence (i.e. finding by a court). All offences, including criminal offences, offences under federal drug or other legislation and provincial offences (e.g. highway traffic offences) must be reported to the college. Only courts can make offence findings. Thus any findings by a body that is not a court, such as a tribunal, are not reportable under this provision. All findings are reportable regardless of whether or not they resulted in a conviction, for example, an absolute discharge order for assault, a conditional discharge order for theft or a conviction for public mischief.”

To clarify, only courts can make offence findings. An offence means any breach of law that is prosecuted in a court. In general, RPs are not required to report “ticketable” offences such as parking tickets, red light tickets, and speeding tickets. However, if an RP were charged with excessive speeding or another traffic offence that led to a careless driving charge for which they had to appear in court, the RP would need to report it to CRPO immediately. Registrants should use their judgment and knowledge of the profession and the practice standards when considering whether a charge may be relevant to suitability to practice psychotherapy and should be reported.

Do I have a duty to report?

My client disclosed a crime/past crime. Do I need to report it?

Please see the response under Limits to Confidentiality in Standard 3.1 Confidentiality.

Limits to confidentiality

My client disclosed a crime/past crime. Do I need to report it?

Please refer to CRPO Standard 3.1: Confidentiality. The starting point is confidentiality, unless a specific exception applies. You can read a list of mandatory reporting duties here. There is no duty listed to report crimes disclosed during therapy. There would be a duty to report if you learned about a child in need of protection, or another item listed in the mandatory reporting table.

If there were a significant risk of serious harm to a person in the future, you would be permitted to disclose information to prevent future harm. CRPO’s Disclosing Information to Prevent Harm Guideline provides suggestions to consider and defines terms such as “reasonable grounds”, “necessary”, “significant risk”, “serious bodily harm”, and “person or group of persons”. These definitions can help you with your decision-making process as it relates to maintaining confidentiality or disclosing information to prevent harm.

Other Considerations:  

  1. a) Ethical Dilemma

The situations you have described are not directly related to the limits of confidentiality (i.e., imminent harm to self or others, suspected child abuse, etc.) In such cases, the possibility of disclosing information for the prevention of harm could be understood in the context of an ethical dilemma.  An ethical dilemma is generally described as a situation where there are two or more competing issues (in this case, to maintain the client’s confidentiality or to breach their confidentiality).

A few suggestions when dealing with ethical dilemmas include:

– Reviewing relevant regulatory legislation (i.e., Professional Practice Standards), code of ethics, and other documents  (such as the ones mentioned above).

– Consulting with peers/colleagues or seeking clinical supervision around this ethical dilemma.

– Making a decision-making tree and including various perspectives.  This is where you can include discussions and/or dialogue you’ve had with a clinical supervisor/consultation, CRPO and so forth, as this document is more for you.  When making a decision-making tree, once one has outlined the possibilities, the pro and cons of those possible decisions, then it will be something one can then further refer to, and/or consult on and review in order to make a decision based on the ethical dilemma presented.

  1. b) Using an Ethical Decision Making Tool

The Ontario College of Social Workers and Social Service Workers offers an ethical decision-making tool that you could use: https://www.ocswssw.org/professional-practice/ethical-decision-making-tool/

Ultimately the decision about whether to breach confidentiality will be up to you, as you know the client best. Seeking clinical supervision or consultation and/or obtaining legal advice, along with the tools mentioned above will help you navigate your decision-making process.

Controlled acts, scope of practice, and competence

Controlled acts other than psychotherapy

Can an RP provide acupuncture/controlled act other than psychotherapy?

Acupuncture is a method that is regulated under the Registered Health Professions Act as it falls in the category of a technique that is performed below the dermis, which is the second layer of skin. However, it is not a procedure that is considered psychotherapy, so the CRPO is not the organization that authorizes this. The CRPO does not have the authority to authorize the use of any regulated activity other than the controlled act of psychotherapy.

Acupuncturists are regulated by the College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario (CTCMPAO). You will need to consult with them to see if an exception applies to this method. If CTCMPAO gives you the authorization or exception to use that method then you may consider using it.

CRPO does not prohibit a Registered Psychotherapist from using any technique they are trained, competent, and authorized to use. As a Registered Psychotherapist, all CRPO Professional Practice Standards continue to apply.

The controlled act of psychotherapy

Can a student perform the controlled act of psychotherapy?

The Regulated Health Professions Act, 1991 (RHPA) sets out 14 controlled acts that are inherently risky and should only be performed by a properly qualified professional to ensure client/patient safety. It is illegal for someone to perform the controlled act if they are not authorized to do so. In Ontario, only registrants of six Ontario colleges* are authorized to perform the controlled act of psychotherapy.

* The other professions who are permitted to provide psychotherapy services in Ontario are members of College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers, College of Nurses of Ontario, College of Occupational Therapists of Ontario, and College of Physicians and Surgeons of Ontario.

The RHPA includes the following exception for non-regulated individuals to perform the controlled act of psychotherapy:

29 (1) An act by a person is not a contravention of subsection 27 (1) if it is done in the course of,

(b) fulfilling the requirements to become a member of a health profession and the act is within the scope of practice of the profession and is done under the supervision or direction of a member of the profession;

This means that an individual who is not yet registered but who is fulling requirements to register with one of the six colleges (e.g., a student), can perform the controlled act of psychotherapy under the supervision of someone of the same profession (i.e., college) that they intend to register with. Therefore, students intending to join CRPO will need to be supervised by an RP in order to perform the controlled act of psychotherapy as part of their education. The RP supervisor must meet CRPO’s definition of a clinical supervisor.

Students with clients in Ontario will need to confirm with their placement site if they will be performing the controlled act. If so, they need an RP supervisor to fulfill the terms of the exception above and enable them to perform the controlled act. If the student is not supervised by an RP, they cannot perform the controlled act of psychotherapy prior to registration. They can still work within the broader scope of practice of psychotherapy and these hours will count toward CRPO requirements.

For work within the broader scope of practice of psychotherapy, students may have a non-RP supervisor (e.g., a social worker or psychologist), as long as the supervisor meets our definition of a clinical supervisor. How much supervision is required from an RP will depend on the frequency with which the student is performing the controlled act prior to registration. See: https://www.crpo.ca/controlled-act-faq/#howmuch

Students can use the Self-Assessment Tool to determine whether their work falls within the scope of practice of psychotherapy (Questions 1-3) and whether they are performing the controlled act (Questions 4-6): https://www.crpo.ca/self-assessment-tool

RP (Qualifying) registrants are full members of CRPO; therefore, they are authorized to perform the controlled act. As soon as an individual is registered in the RP (Qualifying) category, they no longer need supervision from an RP specifically to perform the controlled act. They could receive supervision from a psychologist exclusively, for example. During the pandemic, students can apply for registration in the Qualifying category once they have completed 90% of their coursework, even if they have not started or completed clinical placements.

Scope of practice

Are clinical assessments part of an RPs scope of practice? Is supervision required for an RP to conduct a [SPECIFIC] assessment?

RPs are permitted to assess cognitive, emotional and behavioural disturbances in the course of their work (please see Scope of Practice). However, RPs cannot communicate a diagnosis, as this is a controlled act reserved for psychologists, physicians, and other specific health professionals.

The ability to perform a [SPECIFIC] assessment is not a required competency for all RPs. However, individual RPs may have this competence based on their training and experience. Whether they require supervision or not depends on their level of training and experience. If using a supervisor, that supervisor would need to be competent in the activity performed.

Please refer to CRPO’s standard on competence for more information: https://www.crpo.ca/competence/

 

Can an RP perform duties outside the controlled act, for example, [psychometric testing]?

RPs can perform duties outside their scope of practice, as long as they have the knowledge, skill, and judgement (i.e., competence) to do so.

As you have noted, [psychometric testing] is an activity that has been deemed to be outside the controlled act of psychotherapy. (See https://www.crpo.ca/activities-outside-the-controlled-act/).

To clarify, a Registered Psychotherapist might perform [psychometric testing] (and other activities) as an ancillary activity within the scope of their psychotherapy practices, but providing only such services would not constitute the controlled act.

The ability to perform [psychometric testing/ other activity] is not a required competency for RPs. However, individual RPs may have this competence based on their training and experience. Please refer to CRPO’s standard on competence for more information: https://www.crpo.ca/competence/

[If applicable] Your email mentions you are also registered with the OCSWSSW. You are encouraged to contact the OCSWSSW for their opinion as well. CRPO has a Practice Matters article on dual registration that might be of interest to you: https://www.crpo.ca/practice-matters/#dual

 

Does CRPO take a position on specific interventions, recommending some but not others?

CRPO recognizes that RPs practise a diversity of modalities and interventions. Registrants are expected to have experience and knowledge in the modalities they use and to seek out training, supervision, or consultation as required. See Practice Standard 2.1: Consultation, Clinical Supervision and Referral.

Further, CRPO identifies five broad categories of prescribed therapies, and all psychotherapeutic modalities used by Registered Psychotherapists should fall within these categories. These categories, along with a non-exhaustive list of examples of each, can be found here: https://www.crpo.ca/modalities-of-psychotherapy/

Currently, the only form of psychotherapy that is restricted in any way is conversion therapy. Please see Standard 3.7: Affirming Sexual Orientation and Gender Identity for more information about this.

 

Do I need CRPO’s approval to be trained in hypnotherapy?

At this time, the College does not have a program to formally recognize and approve specialty designations (please see Standard 1.2: Use of Terms, Titles and Designations https://www.crpo.ca/standard-1-2/ for more information). There is nothing in the Standards that would prevent you from training/engaging in this form of psychotherapy, providing that you have the knowledge, skill and judgment necessary to practise safely, effectively and ethically. As noted above, it is important that RPs have the competence to provide psychotherapy services in the modality they practise, and that they abide by the College’s Professional Practice Standards.

General conduct

Ethical dilemmas

An ethical dilemma is generally described as a situation where there are two or more competing issues (e.g., accommodating clients by offering a sliding scale payment option and balancing business needs by asking sliding-scale clients to attend appointments during off-peak hours).

A few suggestions when dealing with ethical dilemmas include:

– Reviewing relevant regulatory legislation (i.e., Professional Practice Standards), code of ethics, and other documents  (such as the articles mentioned below).

– Consulting with peers/colleagues or seeking clinical supervision around this ethical dilemma.

– Making a decision-making tree and including various perspectives.  This is where you can include discussions and/or dialogue you’ve had with a clinical supervisor/consultation, CRPO and so forth, as this document is more for you.  When making a decision-making tree, once one has outlined the possibilities, the pro and cons of those possible decisions, then it will be something one can then further refer to, and/or consult on and review in order to make a decision based on the ethical dilemma presented.

  1. b) Using an Ethical Decision Making Tool

The Ontario College of Social Workers and Social Service Workers offers an ethical decision-making tool that you could use: https://www.ocswssw.org/professional-practice/ethical-decision-making-tool/

  1. c) The Entry to Competency Profile for Registered Psychotherapists:

The CRPO Entry to Competency Profile for Registered Psychotherapists may be a good resource to review. In particular, Competency 3.2, Applying an ethical decision-making process, states:

a Recognize ethical issues encountered in practice.

b Resolve ethical dilemmas in a manner consistent with legislation and professional standards.

c Accept responsibility for course of action taken.

For situations where an RP might disagree with their employer’s policies, we have the following resources that might be of interest to you:

Practice matters article: My employer’s policies clash with CRPO’s practice standards. Which one should I follow?

Practice matters article: Professionalism in business relationships

Conflict-of-interest