This article was first published in the December 2022 Communiqué and updated in September 2024
Clients request letters and other kinds of documentation from Registered Psychotherapists (RPs) for a variety of reasons, for example, to confirm they require a support animal, regarding return to work, or as part of disability claims. Whether or not a CRPO registrant can provide such documentation requires careful consideration and professional judgement. The Professional Practice Standards can provide guidance.
Scope of practice
RPs are permitted to assess cognitive, emotional, and behavioural disturbances in the course of their work. However, it is not within an RP’s scope of practice to provide a diagnosis. See Standard 1.4: Controlled Acts, linked in Related Resources below.
In situations where a client is requesting documentation that falls outside an RP’s scope of practice, the RP should consider explaining their role and limitations to the client and referring the client to their family physician or other qualified health professional for assistance. For example, some disability insurance claims may require a report by a diagnosing professional. In some cases, an RP may be able to collaborate with a diagnosing professional in producing the report, or an RP may be able to provide factual information about the client’s condition and treatment, without formulating a diagnosis.
Competence
Registrants are expected to continually assess their knowledge, skill, and judgment, i.e., their competence, to determine whether they are equipped to work with particular clients. When asked to write a letter for a client, it is necessary for an RP to consider whether they have the knowledge, skill, and judgment necessary to provide such documentation. See Standards Section 2: Competence, linked in Related Resources below.
Informed consent and confidentiality
A conversation with the client about the intended use of the documentation would be helpful, as this might impact the format or the information that will be included. For example, employers may request that a specific form be completed, or that a letter include certain information. Where the client will rely on the documentation for general purposes, take care not to disclose more information than is necessary.
This conversation is also an opportunity to engage the client in an informed consent process, to ensure that the client consents to the disclosure of any personal health information that will be included in the documentation.
See Standards 3.1 Confidentiality and 3.2: Consent, linked in Related Resources below, for more information.
Record-keeping considerations
Consider how you will document your assessment, opinion, and any other relevant information in the clinical record. Copies of letters provided to clients must be retained in accordance with Standard 5.1: Clinical Records.
Registrants are expected to issue timely reports when requested to do so by a client or a client’s authorized representative. Registrants must write a letter confirming treatment unless there are reasonable grounds not to do so. For example, one reasonable ground would be if the registrant does not have the competence to provide the information sought, although a registrant may still be able to provide factual information, such as treatment dates and presenting issues. (See Standard 5.2 for more examples.)
In addition, registrants must ensure that documents they sign or transmit in a professional capacity contain accurate and complete information.
See Standards 5.1: Clinical Records; 5.2: Requests for Reports, and 5.3: Issuing Accurate Documents, all linked in Related Resources below.
Service animals
According to the Integrated Accessibility Standards, which fall under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA), CRPO registrants, along with a number of other regulated health professionals, may provide documentation that confirms that a person requires a service animal for reasons relating to disability. See section 80.45(4)(b). An RP considering writing such a letter needs to have knowledge of the nature of the client’s disability, and how it connects with the need for the support animal.
Other relevant resources (linked in Related Resources below)
- Standard 1.9: Referrals
- CRPO Practice Matters article on Obtaining consent to release information
- CRPO Practice Matters article on custody matters*
* Responding to requests for letters relating to divorce and custody matters requires detailed consideration. Registrants who want guidance in this area are encouraged to consider seeking legal advice; obtaining clinical supervision; documenting all actions and considerations taken; and consulting with CRPO’s Practice Advisory Service at practice@crpo.ca.