Self-Assessment for Unregulated Providers

Unregulated providers (many of whom work with vulnerable populations in the education, social services, victim services and community sectors) often establish genuine and therapeutic relationships with their clients to improve health outcomes and well-being. While the providers may use some psychotherapeutic techniques as ancillary to their duties, the goals for meeting and the relationship created are not, nor intended to be, explicitly psychotherapy.

Does your work primarily involve one or more of the activities listed below in isolation or in the absence of a psychotherapeutic relationship?

• Advocating
• Applied Behavioural Analysis
• Case management
• Clinical follow-up/care and discharge planning
• Parental coordination
• Counselling and support, including advising/advice-giving, instruction, assisting in resolution of dilemmas, assisting in improvement of coping strategies
• Crisis intervention/management, including de-escalation, safety planning, referral to other services
• Hypnotherapy, including smoking cessation
• Information/advice and knowledge transfer
• Intake and referral
• Mediating
• Milieu therapy/milieu-based interventions
• Monitoring
• Problem solving, including information and advice giving, 12 step program, social skill development, instruction, emotional regulation
• Psychometric testing or assessment
• Rehabilitation, including helping an individual to deal with the physical symptoms of a medical illness, resuming activities of daily life, learning or relearning skills that assist in carrying out the activities of daily life
• Single session counselling
• Spiritual or faith guidance/counselling
• Teaching, including social skill development, emotion regulation, prescriptive programs

Answer: Yes/No

If you answered “yes” to question 1, you are most likely not working within the scope of practice of psychotherapy and do not need to be registered with one of the six colleges that are authorized to provide the controlled act of psychotherapy, even if these activities are provided to individuals with a serious disorder or impairment.

Psychotherapy occurs when the Registered Psychotherapist (RP) and client enter into a psychotherapeutic relationship where both work together to bring about positive change in the client’s thinking, feeling, behaviour and social functioning. Individuals usually seek psychotherapy when they have thoughts, feelings, moods and behaviours that are adversely affecting their day-to-day lives, relationships and the ability to enjoy life.

While psychotherapy and counselling are two distinct interventions, there is or may be a continuum of care where Registered Psychotherapists may include interventions that could be classifiable as “counselling” as part of the provision of psychotherapy. For instance, RPs may work with a client to address a specific and current dilemma in a particular session by offering information or advice to assist with practical coping. Likewise, counsellors may employ psychotherapeutic techniques to support the fostering of skills to assist clients in increasing their ability to cope with a specific dilemma. In spite of this overlap, providers and observers should be able to discern the distinct difference between psychotherapy and counselling in its intention and focus.

Are you establishing and maintaining an ongoing psychotherapeutic relationship with your clients as indicated by all of the following:

• There is an explicit intent to engage in psychotherapy.
• You are responsible for having a conversation with clients about the benefits, risks and expected outcome(s) of the psychotherapy.
• You are responsible for gaining the client’s informed consent.
• You are responsible for developing, with the client, a mutually agreed upon goal or plan for the psychotherapy.
• You ensure that each therapy session has a clear beginning and a clear end where problems or concerns are presented and discussed and outcomes are explored.
• You demonstrate the appropriate use of boundaries to create a safe and confidential environment.
• You are responsible for ensuring that the client’s well-being is at the forefront of the relationship.
• You work with the client to gather relevant information that will support the formulation of a plan for psychotherapy.
• You continuously evaluate outcomes of each session and the impact on overall treatment goal(s).

Answer:  Yes/No

If you answered “yes” to questions 2, 3 and 4, you are most likely working within the scope of practice of psychotherapy and should consider whether you meet the requirements for registration with CRPO or one of the other five colleges whose members are authorized to provide the controlled act of psychotherapy. A full description of CRPO’s entry-to-practice requirements and the registration application process is available.

Are you providing treatment to clients for cognitive, emotional or behavioural disturbances to improve or maintain their mental health and wellbeing?

Answer: Yes/No

If you answered “yes” to questions 2, 3 and 4, you are most likely working within the scope of practice of psychotherapy and should consider whether you meet the requirements for registration with CRPO or one of the other five colleges whose members are authorized to provide the controlled act of psychotherapy. A full description of CRPO’s entry-to-practice requirements and the registration application process is available in the Related Resources below.

The controlled act of psychotherapy is defined as:

i) Treating,

ii) by means of psychotherapy technique,

iii) delivered through a therapeutic relationship,

iv) an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that,

v) may seriously impair the individual’s judgement, insight, behaviour, communication or social functioning (RHPA 1991).

All five elements of this definition must be present in order for the controlled act to have taken place.

In order to determine if you are performing the controlled act of psychotherapy, service providers must assess the seriousness of an individual’s disorder and impairment. This includes an individual’s disorder or impairment of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the client’s judgement, insight, behaviour, communication or social functioning. Assessment is a process that is ongoing and issues that may require the controlled act are not always immediately identifiable. In making this assessment, service providers should consider the following:

• The client’s subjective assessment of the level of seriousness of their condition.
• The clinician’s subjective assessment of the level of seriousness of the client’s condition.
• The assessment by another care provider of the level of seriousness of the client’s condition.

Are you trained in, competent with and using psychotherapy modalities from one or more of the five categories of prescribed therapies described in regulation or policy? 

• Cognitive and behavioural therapies
• Experiential and humanistic therapies
• Psychodynamic therapies
• Somatic therapies
• Systemic and collaborative therapies

For more examples of each category, see the Controlled Act of Psychotherapy page linked in Related Resources at the bottom of the page.

Answer: Yes/No

If you answered “yes” to questions 2, 3 and 4, you are most likely working within the scope of practice of psychotherapy and should consider whether you meet the requirements for registration with CRPO or one of the other five colleges whose members are authorized to provide the controlled act of psychotherapy. A full description of CRPO’s entry-to-practice requirements and the registration application process are available in the Related Resources below.

Are you using psychotherapy techniques to treat a client’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory?

Answer: Yes/No

If you answered “no” to question 1 and “yes” to questions 2 through 6, then you are most likely performing the controlled act of psychotherapy. You must either restrict your practice or register with one of the six colleges authorized to provide the controlled act, if you meet the registration requirements.

Could your client’s judgment, insight, behaviour, communication or social functioning be seriously impaired by the disorder referred to in question 5?

Answer: Yes/No

If you answered “no” to question 1 and “yes” to questions 2 through 6, then you are most likely performing the controlled act of psychotherapy. You must either restrict your practice or register with one of the six colleges authorized to provide the controlled act, if you meet the registration requirements.

Would you meet all of CRPOs entry-to-practice requirements, including:

Have you been awarded a master’s degree in a program that has been approved by the Registration Committee or have successfully completed a program that the Registration Committee considers to be substantially equivalent?

Answer: Yes/No

If you answered “no” to question 1, “yes” to questions 2 through 6 but cannot answer “yes” to question 7 (related to entry-to practice requirements), you will need to restrict your practice in order to ensure that you are not engaged in unauthorized practice of the controlled act of psychotherapy.

If you answered “yes” to question 1, you are most likely not working within the scope of practice of psychotherapy and do not need to be registered with one of the six colleges that are authorized to provide the controlled act of psychotherapy, even if these activities are provided to individuals with a serious disorder or impairment.

If you answered “yes” questions 2, 3 and 4, you are most likely working within the scope of practice of psychotherapy and should consider applying for registration with the College of Registered Psychotherapists of Ontario or one of the other five colleges whose members are authorized to provide the controlled act of psychotherapy. A full description of CRPO’s entry-to-practice requirements and the registration application process are available in Related Resources below.

If you answered “yes” to questions 5 and 6, then you are most likely performing the controlled act of psychotherapy and must be registered with one of the six colleges authorized to provide the controlled act.

If you answered “yes” to questions 2 through 6 but cannot answer “yes” to question 7 (related to entry-to practice requirements), you will need to restrict your practice in order to ensure that you are not engaged in unauthorized practice of the controlled act of psychotherapy.