Professional Liability Insurance Requirements

CRPO’s By-laws require that all registrants, other than Inactive members*, have Professional Liability Insurance (PLI) coverage that meets the following requirements:

• a minimum of no less than $1,000,000 coverage per occurrence;
• annual aggregate coverage of no less than $5,000,000;
• a deductible of no more than $4,000 per occurrence;
• run-off coverage (sometimes called enduring or tail coverage) for a minimum of two years;
• the insurer is licensed with the Financial Services Commission of Ontario or the Office of the Superintendent of Financial Institutions Canada; and
• includes coverage for therapy and counselling for every person eligible for funding under subsection 85.7(4) of the Health Professions Procedural Code, i.e. every person eligible for counselling/therapy due to sexual abuse by the registrant for the maximum amount of funding that may be provided for the person under the Regulated Health Professions Act, 1991.

*Inactive registrants are required to carry run-off coverage for a minimum of two years in relation to incidents that occurred while they were practising.

Applicants and registrants are responsible for determining whether their coverage meets the above requirements.

Once registered, registrants are required to maintain PLI in the amount and in the form required under CRPO’s By-laws. Registrants must provide the College with written details within two days of becoming aware of not having PLI as required under the By-laws. The Registrar may suspend a registrant’s membership if they do not have the coverage required.

An Inactive member who has practised the profession within the previous two years must carry PLI run off coverage (sometimes called enduring or tail coverage) consistent with CRPO’s By-laws for a minimum of two years after the registrant last practised. Likewise, former registrants who have retired from practice are well-advised to maintain run off coverage for a reasonable period of time.

The College strongly encourages registrants to obtain individual PLI coverage, even if their employer’s insurance coverage protects them as employees. Several insurers have designed coverage for CRPO registrants that are not restricted to a particular employment setting or practice site. Insurance policies are available at group discount rates through various Canadian and Ontario psychotherapy professional associations. Contact your professional association for information.

The College will accept coverage provided through an applicant’s or registrant’s employer. Coverage must meet the requirements set out in CRPO’s By-laws.

A registrant with employer-specific PLI must not practise the profession in any other setting unless they obtain PLI that covers the other setting.

The College may conduct audits seeking proof of registrants’ PLI coverage. During such an audit, and upon request, the registrant must provide proof (generally a copy of their insurance certificate or a letter from their employer), which must include the following information:

• policy number;
• name of the insured that matches the name of the registrant*;
• address of the insured;
• policy period; and
• coverage details.

* There may be instances of registrants whose insurance is covered by employers, and are therefore not able to produce a certificate with the registrant’s name on it. In this instance, the letter from the employer must indicate that the registrant is indeed covered by the policy being cited.

If a PLI policy does not explicitly refer to coverage for therapy and counselling for persons eligible for funding under subsection 85.7(4) of the Health Professions Procedural Code, i.e. every person eligible for therapy/counselling due to sexual abuse by the registrant, the applicant or registrant is well-advised to obtain assurance from their employer that a covered claim would include such funding. In the absence of such an assurance, applicants and members should obtain their own individual PLI coverage that meets the requirements set out in CRPO’s By-laws.