Standard 1.4: Controlled Acts

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. Additional information and common questions pertaining to the controlled act of psychotherapy can be found in the related resources below.

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 physicians. 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: Five elements, all of which must be present, are necessary to constitute the controlled act of psychotherapy:

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.

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 standards established by their respective regulatory bodies.

The RHPA also sets out an exemption for Indigenous healers who provide traditional services to Indigenous persons or communities.

You can read more about the five elements of the controlled act of psychotherapy in the Controlled Act Task Group documents, available on in the related resources below. Unregulated practitioners unsure if their practice falls under the controlled act of psychotherapy may wish to consult the self-assessment tool developed by the College also listed in the resources below.

Registrants may perform the controlled act of psychotherapy providing they possess the knowledge, skill, and judgement to do so safely and effectively as determined by Standard 2.1.

While the RHPA restricts all of the 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, as may occur when administering Naloxone or Narcan;
• helping someone with activities of daily living;
• treating by prayer or spiritual means according to the tenets of one’s religion; or
• 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).

Other exceptions not requiring a delegation include exceptions for students, Traditional Indigenous Healers, and addictions treatment.

Students who intend to register with CRPO may perform the controlled act of psychotherapy as long as they:

1. Are in the process of fulfilling the requirements to become registered with CRPO; and
2. Are receiving clinical supervision from a qualified RP for the aspects of their practice that involve the controlled act.

Additional information on student exceptions can be found in the related resources below.

In recognition of traditional practices that have been utilized prior to the establishment of psychotherapy as a controlled act, Indigenous persons providing traditional healing to other Indigenous persons or members of an Indigenous community are exempt from the RHPA and therefore are not required to register with a regulatory college to provide care that overlaps with the scope of psychotherapy.

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 judgement necessary to do so safely and effectively. Refer to the Professional Practice Standards, Section 2: Competence.

Registrants may only accept and carry out a delegation if:

1. 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;
2. Performing the delegated act would not violate therapist-client boundaries; and
3. 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.