Practicing Psychotherapy Across Borders

The registrant and client are both physically present in Ontario. There do not appear to be any inter-jurisdictional practice issues to consider.

The registrant must consider whether there are any restrictions in the client’s jurisdiction on the registrant’s ability to provide services to the client. For example, is there a restricted title the registrant cannot use or advertise in the client’s jurisdiction without being registered there?

Additional considerations may include:

• whether the client normally resides in Ontario and is only temporarily out of province;
• how often the registrant provides services to out-of-province clients; and
• whether the registrant is specifically advertising to clients in a particular jurisdiction outside Ontario.

Registrants are advised to obtain legal advice or contact the regulator in the jurisdiction in which the client resides.

CRPO registrants are able to provide services to clients in Ontario through their registration with CRPO. There is no requirement to live or work in Ontario as a CRPO registrant.

While the client is in Ontario, the registrant is not. The registrant should inquire into which laws impact their practice in the location where they are physically located.

Neither the registrant nor the client are in Ontario. The registrant and client might be in the same jurisdiction outside Ontario, or they might be in two different jurisdictions outside Ontario.

The registrant must consider whether there are any restrictions in either the therapist’s or the client’s location on the ability to provide services to the client. For example, is there a restricted title the registrant cannot use in the client’s jurisdiction without being registered there?

Additional Information:

Registrants are advised to obtain legal advice or contact the regulator in the jurisdiction in which the therapist and client reside to develop an understanding of any requirements that may apply. Because the therapist is a CRPO registrant, they are required to meet CRPO practice standards and are accountable for their conduct, even if they and the client are both located outside Ontario.

The trainee therapist and client are both physically present in Ontario. There do not appear to be any inter-jurisdictional practice issues to consider.

Individuals who are training to become Registered Psychotherapists are permitted to perform the controlled act of psychotherapy in Ontario as long as they do so under the supervision of a CRPO registrant who is qualified to provide clinical supervision. The trainee must not use the title “psychotherapist.” Students may still receive clinical supervision from another psychotherapy-practising professional* (as long as the supervisor meets the definition of clinical supervisor). However, that supervision will not enable the student to perform the controlled act of psychotherapy.

* The other professions who are permitted to provide psychotherapy services in Ontario are registrants of College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers, College of Nurses of Ontario, College of Occupational Therapists of Ontario, and College of Physicians and Surgeons of Ontario.

While the trainee is physically present in Ontario, the client is not. The trainee should consider whether there are any restrictions in the client’s jurisdiction on their ability to provide services to the client. For example, is there a restricted title the trainee cannot use or advertise in the client’s jurisdiction without being registered there? Is there a restricted practice or controlled act the trainee therapist cannot perform in the client’s jurisdiction without being registered there?

Trainees are advised, in collaboration with their training program, to obtain legal advice or contact the regulator in the jurisdiction in which the client resides to develop an understanding of any requirements that may apply.

While the trainee is not in Ontario, the client is. Because the trainee is fulfilling requirements to join CRPO, they are permitted to perform the controlled act of psychotherapy in Ontario as long as they do so under the supervision of a CRPO registrant who is qualified to provide clinical supervision. The trainee must not use the title “psychotherapist.” The trainee should inquire which laws impact their practice in the location where they are physically located.

Neither the trainee nor the client are in Ontario. This situation is out of CRPO’s jurisdiction. If the trainee is planning on applying for registration with CRPO, they should familiarize themselves with CRPO’s registration requirements.

This does not appear to be a cross-border practice situation. The client and therapist are both in Ontario. The therapist is not a CRPO registrant. Unless the therapist is registered with one of five other Ontario regulatory bodies* whose registrants practise psychotherapy, the therapist cannot:

• use the title “psychotherapist”, “Registered Psychotherapist” or any abbreviation or variation thereof in any language;
• hold out as qualified to practise as a psychotherapist in Ontario (no matter what title is used); or
• perform the controlled act of psychotherapy.

* The other professions who are permitted to provide psychotherapy services in Ontario are registrants of College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers, College of Nurses of Ontario, College of Occupational Therapists of Ontario, and College of Physicians and Surgeons of Ontario.

This situation involves a non-CRPO registrant in Ontario who is providing services to clients in other provinces or countries. Unless the therapist is registered with one of five other Ontario regulatory bodies* whose registrants practise psychotherapy, the therapist cannot:

• use the title “psychotherapist”, “Registered Psychotherapist” or any abbreviation or variation thereof in any language;
• hold out as qualified to practise as a psychotherapist in Ontario (no matter what title is used); or
• perform the controlled act of psychotherapy.

Because the client is not in Ontario, CRPO will determine based on individual circumstances whether any action is warranted. Relevant factors may include, but are not limited to, whether:

• there are reports of client harm;
• the individual is regulated in another jurisdiction;
• the individual is using a restricted title or performing the controlled act of psychotherapy; and
• the individual appears to be evading regulatory requirements.

The therapist should consider whether they need to and are qualified to register with CRPO.

The therapist is not in Ontario but the client is. In Ontario, non-registrants cannot use the title “psychotherapist” or hold themselves out as a psychotherapist (unless they are registrants of one of five other Ontario professions that practise psychotherapy). If the therapist uses the title or holds themselves out as a psychotherapist in their home jurisdiction, and their connection to Ontario is insignificant, CRPO will not take the position that they are using the title or holding out in Ontario. However, if the therapist’s connection to Ontario is substantial (e.g., advertising focuses on Ontario, a significant number of clients are in Ontario, or the therapist is regularly physically present in Ontario), they would not be able to use the title psychotherapist or hold themselves out as a psychotherapist unless they become regulated in Ontario.

Non-registrants cannot perform the Controlled Act on clients in Ontario, except in cases of emergency or where another exception applies (e.g., indigenous or spiritual healing). If a practitioner is a regulated counselor or psychotherapist in another province, territory, state or country, CRPO will consider this as a mitigating factor. Because the practitioner is already accountable to another regulator, CRPO will generally not take action against that individual for providing infrequent e-therapy to a client who is located in Ontario.

In this situation, neither the therapist nor the client are in Ontario. The therapist is not a CRPO registrant. CRPO does not have jurisdiction or a position regarding this situation.