Registrants who operate a solo private practice and registrants who own or run a joint practice or a practice with employees or contractors are responsible for engaging in operational risk assessment and return to work planning. For those who have not yet resumed in-person services, CRPO expects that this assessment and planning will occur before in-person services are resumed. For those who have already resumed (or continued to provide) in-person services, it is expected that you will have already implemented appropriate infection prevention and control (IPAC) measures.

Assess Whether In-Person Services Are Necessary

The first step in your return to in-person practice is to assess whether it is necessary or appropriate to provide in-person services based on your client’s care needs.

Consistent with the COVID-19 Operational Requirements, CRPO expects that registrants will provide services by way of e-therapy to the extent that is reasonably possible. However, the College also recognizes there are circumstances in which it would be necessary or appropriate to provide in-person services.

Registrants must continue to evaluate their clients’ individual care needs on an ongoing basis, recognizing those clients who continue to benefit from e-therapy and those limited circumstances in which in-person contact with a client may be indicated. Unless it is not possible to do so, new clients should be assessed remotely to determine whether ongoing care via e-therapy is appropriate or whether in-person services are indicated. Registrants are encouraged to look to the direction provided by the Chief Medical Officer of Health (CMOH) in the amended directive regarding essential health care services and the  orders regarding essential workplaces. When determining which clients should be offered the option of in-person care, registrants should consider the principles set out in Directive #2: Proportionality; Minimizing Harm to Patients; Equity; and Reciprocity.

Relevant CRPO resources and guidance can also be found in the Electronic Practice Guideline (see in particular the section entitled Appropriateness); these resources offer useful information to support decision-making regarding provision of in-person services.

Evaluate Risk of Transmission in Your Practice

The next step in your return to in-person practice planning is to assess the risk of infection transmission in your practice by considering:

  • The intensity of your contacts with clients (e.g. how much time do you spend with people and how close are you); and
  • Your overall number of contacts (e.g. people in the setting at any given point in time)

You must either continue to provide e-therapy or implement IPAC measures in the setting (or a combination of both) if your contact with clients or others in the setting will result in:

  • Prolonged contact with another person in an enclosed space where the ability to physically distance is limited
  • Any contact that is closer than the recommended physical distancing measure

The extent to which IPAC measures can be implemented in the setting, and the effectiveness of those measures, must be carefully considered as part of an overall organizational risk assessment. The diagram below illustrates the domains that are within the control of individuals, employers and organizations. It sets out a range of IPAC measures that could be implemented, which are listed based on the order of the effectiveness of those interventions. Controls that appear in the top band are considered most effective, while those appearing in the lowest band are considered least effective.

The hierarchy of controls is a common model applied in occupational health and safety. The diagram used in this document was adapted from resources developed by the Government of British Columbia.

Hierarchy of Controls

Corresponding Examples

→ Eliminating in-person therapy & substituting with e-therapy wherever possible.
→ Providing services outdoors while distancing (e.g. walking therapy).
→ Adding physical barriers such as translucent screening.
→ Spacing office furniture to meet recommended guidelines.
→ Increasing ventilation and cleaning schedules. Establish and communicate effective policies, providing education & training to staff, clients and visitors.
→ Screening all staff, clients and visitors, including passive (e.g. signage) and active (e.g. pre-session by phone and onsite)
→ Reducing number of persons in the setting at any given point in time to only essential staff, clients and essential visitors.
→ Limiting gatherings in the settings (e.g. meetings, lunches).
→ Posting educational signage regarding cough/sneezing etiquette and use of PPE.
→ Making hand sanitizer, tissues and a wastebasket readily available.
→ Using PPE appropriately.

Adapted from: Key Steps to Safely Operating your Business or Organization and Reducing COVID-19 Transmission, Government of British Columbia, April 2020.

Those who own or run a practice with employees where in-person services are provided are responsible for establishing a safe practice environment and must assure that those working in the setting receive adequate education and training. Every person in the setting has a role in preventing the spread of COVID-19, and so must understand policies and expected procedures. These individuals may also have additional obligations with respect to workplace health and safety reporting and reporting staff illness to public health units.