Practice Advisory Service

CRPO offers a practice advisory service that Registered Psychotherapists (RPs) can connect with in order to discuss matters relating to professional practice, ethics and standards.

The structure of the practice advisory service is such that RPs can be matched with a practice advisor of a related professional background. Our six practice advisors are fellow RPs with extensive clinical experience.

RPs who have practice-related questions, who are facing ethical conundrums, or who simply want to discuss professional practice, are invited to connect with an advisor by:

Email: practice@crpo.ca
or
Phone: 416-479-4330, ext. 222

Concerned about a particular member’s practice?

The practice advisory service is designed to provide information and resources to members about professional practice. If you have a complaint or concern about a particular member’s practice, please contact complaints@crpo.ca.

Limitations of the Practice Advisory Service

The practice advisory service is meant to be an educational resource. Information provided by the College or the College’s practice advisors is not intended to replace the advice of a lawyer, expert in professional practice or other appropriately qualified professional. If you have specific concerns about your professional obligations, please consult with a qualified professional.

The College retains records of your communications with the practice advisory service, mainly to ensure the quality of the service and to inform the development of member resources. The communications will remain confidential and will only be shared if the information in the communications is deemed relevant to a proceeding before a College committee or there is reason to believe that a member has engaged in professional misconduct that would result in harm to a person or group of persons.

Practice Advisory FAQs

The Practice Advisory service also provides information for members on various topics that emerge as key trends. Many topics are not clear-cut, but it is important to be aware of basic principles and practice standards.

Dual Practice

Question:

I’m registered with CRPO and another college. As a dually-registered practitioner, what do I need to know?

Answer:

Practice Standards
As a starting point, dually-registered professionals are encouraged to review the standards and policies of the colleges with which they are registered. Many colleges have specific standards that apply to dually-registered professionals, though CRPO does not have such resources at this time. Until a standard or guideline on this subject exists, members of CRPO are encouraged to carefully review CRPO’s Professional Practice Standards in light of their dual practice, in particular Standards 1.2: Use of Terms, Titles and Designations, 1.6: Conflict-of-Interest, 1.7: Dual or Multiple Relationships, 3.1: Confidentiality, 3.2: Consent, 5.3: Issuing Accurate Documents and 6.2: Advertising and Representing Yourself and Your Services.

Administrative Matters
There are a number of administrative matters that a dually registered professional should be aware of. An obvious example is the annual registration process – the dually-registered practitioner is required to complete the annual registration requirements, including any forms and payment of fees, of each college they are registered with. In addition, the dually-registered practitioner is required to engage in the quality assurance programs of any colleges they are registered with; this includes meeting the QA requirements and deadlines of each college.

Complaints
Dually registered professionals should be aware of the possibility that a concern or complaint against them can be received by one or both colleges. While each college independently investigates complaints filed against its members, it is possible that in some cases a complaint filed against the member at one college could prompt an investigation by the other college, even if the complaint was not originally filed with that college.

Considerations
Being dually registered also has implications for clinical practice – a few examples will be covered off here. For more information, members are encouraged to connect with CRPO’s Practice Advisory Service.

The nature of your dual-practice – Depending on the nature of your dual practice, there may be some overlap in the work you do as an RP and the work you do in your other professional capacity. Dually-registered professionals are encouraged to think carefully about where any overlap may or may not occur in their practice. If your other profession does not overlap with psychotherapy, consider whether it is appropriate to refer or treat the same client in the other role.

Providing information for informed consent – Clients are entitled to provide informed consent prior to any treatment. In order for a client’s consent to be considered informed, they must be provided with all the information that one would need in order to make such a decision. Because of potential confusion, it is important that dually-registered practitioners describe their practice and services as accurately as possible, taking care to clarify to the client when the dually-registered practitioner is working in their capacity as a psychotherapist, or when they are working in their other professional capacity.

Maintaining clinical records – The dually-registered practitioner should be mindful that they will be expected to maintain clinical records in a manner that meets the standards of each college with which they are registered.

Billing – Members of CRPO are required to issue clear, accurate documents to third-parties. This means that receipts and invoices should include an accurate description of the services provided to the client, and it should be clear in all financial records in which professional capacity the member was working in when those services were provided to the client.

This FAQ does not address members who practise in unregulated fields in addition to the regulated profession of psychotherapy. This will be addressed in a future article.

Fees and Billing

Question:

I am an RP and I am opening a private practice. I’m confused about fees and billing. How much should I be charging my clients? What should my receipts look like? What needs to be included? What are CRPO’s guidelines? I want to make sure I am doing this correctly for CRPO and also for my clients.

Answer:

Setting Fees
According to Professional Practice & Jurisprudence for Registered Psychotherapists, “Establishing professional fees charged by members is not within the mandate of the College, and the College does not set the fees for members’ services. In fact, the college does not regulate the amount a member may charge a client, unless the fee is excessive. A fee is considered excessive if it takes advantage of a vulnerable client or is so high that the profession would conclude that the RP is exploiting a client.” For additional information regarding fees, consult the Professional Practice Standards, Standard 6.1: Fees.

Billing and Receipts
Many members, especially those in private practice, collect payment after each psychotherapy session and issue a receipt to the client. The College has information on financial record-keeping, including billing and receipts, in the Professional Practice Standards, Standard 5.3: Issuing Accurate Documents and Standard 5.5: Record-keeping – Financial Records. Members must provide clients with accurate records and other documents, including invoices, bills and receipts.

In short, receipts should include:

  • the member’s legal name (and any alternate name used in practice);
  • title conferred by the College and registration number;
  • amount paid;
  • date the service was provided;
  • type of services provided; and
  • full name of the client.

Members are expected to be accurate, transparent and reasonable in their fee and billing practices. For example, if a member works with associates, it should be clear which psychotherapist saw the client.

Practising Out-of-Province

Question:

I am an RP and I received a request for e-therapy from a person who does not live in Ontario. I am only registered in Ontario. Am I permitted to provide psychotherapy electronically or by phone to someone who does not reside in Ontario? Also, what if I am outside of Ontario and my clients in Ontario would like to continue therapy with me via the telephone or e-therapy, is that ok?

Answer:

Client is Out-of-Province
With regards to providing psychotherapy to clients outside Ontario, the general rule is that the location of the client is what governs. A Registered Psychotherapist may provide services to clients who reside outside of the province; however, you would need to contact the psychotherapy or counselling regulator in the location (state, province or country) where your client lives to make yourself aware of their regulations, if any. You should also ensure that your professional liability insurance covers you providing telephone or e-therapy to clients outside of province or country.

Client is in Ontario and RP is Out-of-Province
The general rule is that the location of the client governs. If you are an RP with CRPO, you may provide services to clients who reside in Ontario, even if you do not. You should ensure that your professional liability insurance covers you providing tele-therapy to clients outside of province of country. Non-members of CRPO must not use the title “psychotherapist” or hold themselves out as qualified to practice as a psychotherapist in Ontario.

Record-Keeping

Question:

Is it preferable to keep paper or electronic files?

Answer:

Members (or the organization they work for) are free to choose whichever record-keeping system is best suited to their needs and access to technology. The same principles apply to both paper and electronic record-keeping. For example, modifications to any record need to be tracked. In other words, the originals must not be overridden or erased.

Security of paper records would include locking and storage, while for electronic records it would include encryption, virus prevention, backups, and physically restricting access to the computer and display. When using electronic record-keeping systems, an alternate process for record-keeping must be ready in case the electronic system is down or unavailable. Check out CRPO’s Professional Practice Standard 5.6: Recordkeeping – Storage, Security and Retrieval as well as the CRPO Professional Practice and Jurisprudence Manual for more detail.

Question:

I have been using paper in the past and want to switch to electronic record-keeping. Can I scan and destroy the paper copies?

Answer:

There are options when it comes to transitioning from paper to electronic record-keeping. You may either convert all existing paper records into electronic form, or retain paper records and begin entering information into an electronic format on a subsequent basis. In either case, client care and appropriate record-keeping practices must continue without interruption.

When scanning paper records, members are responsible for ensuring their integrity upon conversion into electronic format. This includes verifying that documents have been properly scanned and that the entire record is intact, including any attached documents and notes. You should establish specific procedures for converting files and document these procedures in writing. It may be helpful to enlist a reputable commercial organization to assist in this process[1].

The Information and Privacy Commissioner of Ontario states that old paper records should not be destroyed unless the required retention period has expired or the entire paper-based record has been duplicated in electronic format[2].

Question:

How do I determine who is the “health information custodian”?

Answer:

CRPO often receives questions about who is responsible for health information recorded by a member. The answer to this question depends on identifying the “health information custodian.” The term “health information custodian” is defined in the Personal Health Information Protection Act, 2004 (PHIPA) [3,4]. In short, a custodian is an individual or organization that has has custody or control of personal health information.

If practising alone, a member is the health information custodian of their clients’ information. If employed by another health information custodian such as a hospital, the employer is the health information custodian and the member is expected to follow the record management practices of their employer.

Where a member is employed by a non-health organization such a school, university, college or municipality, the member is considered to be the custodian. In these situations, the member cannot disclose personal health information to his or her employer without the client’s consent or another legal exception.

In other situations, the answer may not be clear, and Members will need to speak with their employer. The Information and Privacy Commissioner of Ontario also has resources on this topic [5,6].

Question:

How do I properly destroy my client files?

Answer:

Records need to be kept for 10 years from the last interaction with the client or from the client’s 18th birthday, whichever is later. Financial records, appointment and attendance records need only be kept for five years [7].

When the time period for keeping the record has expired, the records should be destroyed. If the therapist destroys any records, they should record the names of the destroyed files and the date they were destroyed.” For paper records, destruction means cross-cut shredding, not simply continuous (single strip) shredding, which can be reconstructed. You should consider pulverization or incineration of records that are highly sensitive. You might also hire a licensed service provider to destroy your files. In doing so, look for a provider accredited by an industrial trade association, such as the National Association for Information Destruction (NAID) [8].

For questions about confidentiality and health records, contact the Information and Privacy Commissioner of Ontario.
https://www.ipc.on.ca
Toronto Area: 416-326-3333
Toll Free: 1-800-387-0073
info@ipc.on.ca

[1] From “Ontario Policy Statement # 4-12, Electronic Records”, 2000, College of Physicians and Surgeons, p. 5.
[2]From “Personal Health Information: A Practical Tool for Physicians Transitioning from Paper-Based Records to Electronic Health Records”, 2009, Information and Privacy Commissioner of Ontario, p. 20.
[3]From “Frequently Asked Questions Personal Health Information Protection Act”, 2015, Information and Privacy Commissioner of Ontario, p.7-9.
[4]From “Personal Health Information Protection Act”, 2004, Information and Privacy Commissioner of Ontario, Section 3(1).
[5] From “A Guide to the Personal Health Information Protection Act”, 2004, Information and Privacy Commissioner of Ontario.
[6]From “ Frequently Asked Questions Personal Health Information Protection Act”, Information and Privacy Commissioner of Ontario, 2015.
[7]From “Professional Practice Standards for Registered Psychotherapists”, 2014, The College of Registered Psychotherapists of Ontario, page 68.
[8]From “Personal Health Information: A Practical Tool for Physicians Transitioning from Paper-Based Records to Electronic Health Records”, 2009, Information and Privacy Commissioner of Ontario, p. 22.

Self-Referral

Question:

I am an RP. I work for an agency and also have a private practice. What are CRPO’s guidelines for referring a client of the agency to my private practice?

Answer:

CRPO’s Professional Practice Standard 1.9: Referral, states that a member may “self-refer” a client from one practice to another, in certain circumstances. The key is allowing the client to make an informed choice and not taking advantage of an existing professional relationship in order to secure more business. This Standard also provides a description of what a self-referral is, when a self-referral may be made, safeguards to avoid a conflict of interest as well as exceptions.

Some employers may not allow members to self-refer clients to their private practice. In this case, members should act in accordance with their employer’s policies; the College generally does not get involved in employer-employee issues.

Please consult Standard 1:9: Referral, for additional detail.