The Regulated Health Professions Act, 1991 (RHPA) restricts certain activities, called controlled acts, due to the risk they carry if performed by an unqualified person. For example, performing a procedure on tissue below the dermis is an activity that can mainly be performed by regulated professionals who are authorized to do so, such as nurses or doctors. These authorizations are set out in the legislation that governs each profession.
CRPO registrants are authorized to perform the controlled act of psychotherapy, which is defined as follows:
To treat, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception, or memory that may seriously impair the individual’s judgment, insight, behavior, communication, or social functioning.
Five other professions are authorized to perform the controlled act of psychotherapy, including: nurses, occupational therapists, physicians, psychologists and/or psychological associates, and social workers and/or social service workers. These professionals perform the controlled act of psychotherapy in accordance with the regulations, requirements and/or standards established by their respective regulatory bodies.
The controlled act of psychotherapy, which is comprised of five elements, is only a component of the broader scopes of practice that respectively apply to CRPO registrants and the other regulated professions listed above. Each of the five elements must be present for a particular activity to be considered the controlled act of psychotherapy. You can read more about the five elements of the controlled act of psychotherapy in in the Controlled Act Task Group documents available on the College website.
Registrants may perform the controlled act of psychotherapy providing they possess the knowledge, skill and judgment to do so safely and effectively. Refer to the Professional Practice Standards, Section 2: Competence.
Registrants who are not sufficiently competent in performing the controlled act of psychotherapy may only do so if additional study, training, consultation or clinical supervision would allow them to gain the appropriate level of competence.
While the RHPA restricts controlled acts mainly to regulated health professionals, it enables others to perform them when specific circumstances apply. For example, anyone can perform any controlled act providing they are:
- helping someone in an emergency;
- helping someone with activities of daily living;
- treating by prayer or spiritual means according to the tenets of one’s religion; and
- when administering a substance or communicating a diagnosis to a member of one’s household (e.g. telling your child that she has a cold).
Exceptions for Students
Students who intend to register with CRPO may perform the controlled act of psychotherapy as long as they:
- are in the process of fulfilling the requirements to become registered with CRPO; and
- are receiving clinical supervision from a qualified RP for the aspects of their practice that involve the controlled act.
Exemption for Addictions Treatment
Ordinarily, CRPO registrants are restricted from performing any procedure below the dermis. However, an exemption applies for those who provide acupuncture as part of an addiction treatment program within a “health facility”. Health facility is defined by legislation, and includes, for example, facilities that are governed or funded by the:
- Public Hospitals Act
- Independent Health Facilities Act
- Alcoholism and Drug Addiction Research Act
Registrants who perform acupuncture in accordance with the exemption may only do so if they possess the knowledge, skill and judgment necessary to do so safely and effectively. Refer to the Professional Practice Standards, Section 2: Competence.
Delegation is a mechanism that enables a regulated health professional to grant another person the authority to carry out a professional activity that the person would otherwise be restricted from doing.
Making a Delegation
CRPO registrants are restricted from delegating the controlled act of psychotherapy, except in the following circumstances:
- with prior approval of Council
- in an emergency, providing Council is informed after the fact
Receiving a Delegation
Registrants may only accept and carry out a delegation if:
- the regulated health professional who made the delegation is working within their scope of practice, following the requirements and standards established by their regulatory college, and will take responsibility for the actions of the registrant receiving the delegation;
- the act being delegated to the registrant falls within the scope of practice of the psychotherapy profession; and
- the registrant has the competence necessary to carry out the delegation in a manner that is safe and effective. Refer to the Professional Practice Standards, Section 2: Competence.
STANDARD: Controlled Acts
Providing they have the competence to do so in a manner that is safe and effective, registrants are authorized to perform the controlled act of psychotherapy. Registrants refrain from delegating the controlled act of psychotherapy, unless an exception applies.
Demonstrating the Standard
A registrant demonstrates compliance with the standard by, for example:
- declining to perform a controlled act if it is beyond the registrant’s competence, or when doing so would, in his/her professional judgment, be counter-therapeutic;
- declining to perform a controlled act under delegation if the delegating professional is not providing supervision and/or will not take responsibility for the actions of the registrant receiving the delegation.
- Standards, Section 4: Clinical Supervision
- Standard, Section 2: Competence
- Understanding When Psychotherapy is a Controlled Act
- Controlled Act Task Group Consultation Documents
- Psychotherapy Act
- Professional Misconduct Regulation, provisions 10, 12
Note: College publications containing practice standards, guidelines or directives should be considered by all members in the care of their clients and in the practice of the profession. College publications are developed in consultation with the profession and describe current professional expectations. It is important to note that these College publications may be used by the College or other bodies in determining whether appropriate standards of practice and professional responsibilities have been maintained.
 Nursing Act, 1991, s. 4.1; Medicine Act, 1991, s. 4.2
 Psychotherapy Act, 2007, s. 4
 Regulated Health Professions Act, 1991 (RHPA), s. 29(1)(a, c-e)
 RHPA, s. 29(1)(b)
 Controlled Acts Regulation under the RHPA, s. 8.(5)
 Controlled Acts Regulation under the RHPA, s. 8.(6)
 Professional Misconduct Regulation, under the Psychotherapy Act, s. 12