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)