CRPO often asks the public, members and stakeholders for their feedback on proposed policies, processes, standards and by-laws. This process of gathering input is called a consultation and helps to support CRPO’s work to protect the public interest.
By-law Consultation: Registration History on the Public Register
At the March 1, 2019 Council meeting, College staff and Executive Committee recommended amendments to CRPO’s By-laws pertaining to posting registration history on the public register. Council discussed the proposed amendments and approved their circulation for 60-day public consultation.
Currently, every member’s current registration category and initial date of registration are published on the public register. In contrast, historical registration category changes and the date of those transfers are not retained on the public register. Similarly, if a member was suspended due to non-payment of fees, then once the suspension has been lifted, there is no public record retained of the past suspension. In other words, a member of the public cannot tell from the public register if a member has been suspended for non-payment of fees in the past. In contrast, past suspensions for other reasons, such as for discipline, are publicly recorded indefinitely. CRPO always posts the reason for suspension. A suspension for administrative reasons is described differently on the public register than a suspension for disciplinary reasons.
College staff and Executive Committee believe transparency favours making registration history available on the public register. In particular, members of the public, including clients, employers and insurance companies, have an interest in knowing if there was a period of time in the past during which a member was not entitled to practise, e.g. whether they were Inactive or suspended for non-payment of fees. Providing this information to the public can assist the College in receiving reports about non-compliance and risk of harm, e.g. an insurance company notifies CRPO a member may have been practising during suspension, a client informs CRPO a Qualifying member was practising without supervision. Publicly posting this information also aligns with CRPO’s Position Statement on Access to Care, which states, “A strong regulatory environment means that all stakeholders in the health care system can be confident in the quality of care provided by RPs.”
As a self-funded organization, the College depends on members to contribute collectively to the work of the College. The College depends on membership fees for the vast majority of its revenue and cannot regulate effectively if members practise while suspended or inactive. In addition, suspended and inactive members are not subject to the same quality assurance and oversight as active members.
Other colleges, for example the College of Physicians and Surgeons of Ontario, and the Ontario College of Social Workers and Social Service Workers, post registration history on the public register.
It is unlikely members hold an expectation of privacy in their past registration categories in that the information is not sensitive. In contrast, until now a member suspended for non-payment may expect CRPO to remove the notation upon lifting the suspension. Thus, there is an argument that registration category transfers be published retroactively, but that past suspensions for non-payment only be published after the by-law comes into effect. For clarity, it is proposed that:
- Past transfers between Qualifying, Inactive and RP be Published retroactively
- Past suspensions for non-payment be Published only after by-law enactment date
The following proposed changes to the CRPO by-laws would post registration history on the public register, including past suspensions for non-payment (proposed changes shown in italics):
21.08 – Additional Register Information
In addition to the information set out in subsection 23(2) of the Code, the register shall contain the following information with respect to each Member:
(vi) if the Member ceased to be a Member, a notation specifying the reason for the termination of membership and the date upon which the Member ceased to be a Member except that such a notation shall be removed upon reinstatement of the Member’s membership if the suspension was only for non-payment of fees and membership was terminated on or before [Date of Enactment of By-law];
(xxiii) the classes of certificate of registration held by the member and the date on which each certificate was issued.
The College would appreciate your feedback on these proposed amendments by May 7, 2019.
Closed Consultations 2019
Draft Regulation Defining "Client" for Sexual Abuse Provisions
Electronic Practice Guideline
Closed Consultations 2018
Draft Guideline: Sexual Contact with Former Clients beyond 5-Years Post Termination of Care
Draft Regulation Categories of Prescribed Therapies Involving the Practice of Psychotherapy
On December 30, 2017, the government of Ontario proclaimed into force the controlled act of psychotherapy with a two-year transition period to allow the mental health sector a period of time in which individuals may become registered with one of the appropriate colleges or restrict their services so that they do not perform the controlled act.
In conjunction with the proclamation, the Minister of Health and Long-Term Care directed the College of Registered Psychotherapists of Ontario (CRPO) to provide more clarity on the meaning of the controlled act of psychotherapy.
CRPO engaged in a broad stakeholder consultation process to get input on the regulation. Feedback on the regulation was closed on June 15, 2018. Survey responses can be reviewed here.
Projet de règlement : catégories de thérapies prescrites comprisesdans la pratique de la psychothérapie
Pour consulter les documents de la Projet de règlement: catégories de thérapies prescrites comprises dans la pratique de la psychothérapie et remplir le sondage, cliquez sur les liens.
Documents de consultation de la Groupe de travail sur l’acte autorisé (Français)
Pour consulter les documents de la Groupe de travail sur l’acte l’authorise et remplir le sondage, cliquez sur les liens.
Draft Policy for "Cooling Off" Period
CRPO received feedback for a 60-day period, closing June 9, on the draft Sexual Contact with Former Clients Within a Five-year “Cooling Off” Period Policy. CRPO Council recommended it for implementation in anticipation of the relevant section of Bill 87, Protecting Patients Act, 2017, being proclaimed into force. This is the section that will allow the CRPO to set out in regulation the time period for defining a “cooling off” period during which an individual would continue to fall under the definition of “client” for the purpose of the sexual abuse provisions of the Regulated Health Professions Act (RHPA). This is an interim measure that is being proposed while we wait to be able to pass a regulation, since it is unknown how long the regulation making process will take.
Feedback received can be reviewed here.
Controlled Act Task Group Draft Consultation Documents (English)
On December 30, 2017, the government of Ontario proclaimed into force the controlled act of psychotherapy. In conjunction with the proclamation, the Minister of Health and Long-Term Care directed the College of Registered Psychotherapists of Ontario (CRPO) to provide more clarity on the meaning of the controlled act of psychotherapy and what practices would not be considered to be part of the controlled act as provided by Registered Psychotherapists.
Specifically, CRPO was compelled to develop:
- a regulation prescribing therapies involving the practice of psychotherapy, governing the use of prescribed therapies and prohibiting the use of therapies other than the prescribed therapies in the course of the practice of psychotherapy; and
- policies and other supporting resources that clearly articulate the activities that Council does not consider to be part of the controlled act of psychotherapy.
Draft Guideline: Disclosing Information to Prevent Harm
CRPO invited stakeholder comment on a Draft Guideline: Disclosing Information to Prevent Harm.
Closed Consultations 2016
Transparency By-laws (Phase II)
CRPO invited stakeholder comment on this second phase of proposed by-law provisions designed to enhance transparency of College processes.
Criminal Record Checks
CRPO invited stakeholder comment regarding a possible implementation of a requirement that a completed criminal record check be submitted to the College by applicants and/or Members.
Professional Practice Standards
CRPO invited stakeholder comment on a new Professional Practice Standard: Affirming Sexual Orientation and Gender Identity, and a proposed change to Standard 3.1: Confidentiality.