This article was first published in August 2023 and updated in September 2024
Many registrants have education, training, and experience in non-regulated professions in addition to their psychotherapy training. Sometimes these unregulated activities complement psychotherapy treatment; in other cases, the situation is less clear. In all instances, registrants are encouraged to consider their role(s) carefully.
Scope of practice
Registered Psychotherapists (RPs) are permitted to assess and treat cognitive, emotional, and behavioural disturbances in the course of their work. CRPO recognizes that RPs practise a diversity of modalities and interventions. Registrants are expected to have experience and knowledge in the modalities they use, and to seek out training, supervision, or consultation as required. See Standard 2.1: Seeking Consultation, Clinical Supervision and Referral, linked in Related Resources below.
RPs can provide care outside the scope of psychotherapy, if they have the knowledge, skill, and judgement (i.e., competence) to do so, and if they manage the activity responsibly. When working outside the scope of psychotherapy, registrants need to be vigilant to avoid treating or advising clients in ways that pose a risk of harm. At all times, registrants are required to adhere to CRPO Professional Practice Standards.
Informed consent
Any intervention provided must be considered with the client’s well-being and best interest in mind. In addition, informed consent is required for anything done for a therapeutic or other health-related purpose.
Registrants may incorporate some non-psychotherapy activities as an adjunct to their main psychotherapy practice. For example, an appropriately trained RP might guide clients in yoga poses or breathing exercises to promote grounding and relaxation, before engaging in psychotherapy.
When incorporating other healing practices in psychotherapy sessions, registrants must provide the client with “sufficient information to understand the nature of the therapy and potential risks and benefits, as well as information about other available therapeutic options and the implications of not proceeding with therapy. Information provided to clients must not misrepresent potential benefits or raise unrealistic expectations. If therapy is expected to probe troubling experiences or to cause emotional distress, this should be explained to the client and noted in the client record.” See Standard 3.2: Consent, linked in Related Resources below.
In other situations, to avoid confusion, a registrant may need to explain that they are not providing psychotherapy in a particular session or with a particular client. This may be the case if the registrant is also a career counsellor, academic counsellor, case manager, or family mediator.
Informed consent can be accomplished by having a clear dialogue with the client about their expectations of the relationship and for the RP to articulate clearly what services they are providing to the client in each context. This helps ensure that the client fully understands the nature of the relationship and avoids any confusion.
Billing practices
When an RP works in two or more separate and distinct practices, it is important to ensure all billing for psychotherapy services remains aligned with Practice Standards. For example, it would not be appropriate to describe a yoga or reiki session as “psychotherapy” on receipts. See Standard 5.3: Issuing Accurate Documents and Standard 5.5: Financial Records, both linked in Related Resources below.
Advertising and competence
In general, registrants must ensure that any clinical advice or information they provide is based on reasonable professional opinion and is consistent with professional standards and ethics. In addition, registrants must ensure it is clear whether an advertisement pertains to psychotherapy or different products/services that the registrant offers. See Standards 2.1: Seeking Consultation, Clinical Supervision, and Referral and 6.2: Advertising, linked in Related Resources below.
Interventions that involve touching a client
Registrants must be very cautious when implementing interventions that involve touching a psychotherapy client. Please take note that a wide range of actions constitute sexual abuse under the Regulated Health Professions Act, and refer to the following resources for further explanation of expectations (linked in Related Resources below):
- In the Jurisprudence e-Learning manual, under Standard 1.8, see “Sexual Abuse” and “Examples of Sexual Abuse”
- In the Jurisprudence e-Learning manual, under Standard 1.7, see “Touching”
- CRPO webpage on Sexual Abuse in Therapy
Considerations and reflection questions for dual practice
The following reflection questions summarize the information presented above:
- Is the client clear on what kind of treatment they are receiving?
- Does the client understand the treatment that is being offered and potential risks and benefits?
- Does the RP have the competence to offer the services?
- Does the combination of psychotherapy and non-psychotherapy treatment create a dual relationship or cross professional boundaries?
- Is the billing record accurate if it claims to relate to psychotherapy services?
- Does any advertising cause confusion or conflate two distinct practices? Would other RPs support any claims made about the services or products being offered as reasonable?
- Are there any legal or professional obligations that apply, not only for the psychotherapy practice but also for the other service?
- Do any conflicts of interest exist? Are safeguards in place to ensure any recommendations are in the client’s interest only? Do any revenue-sharing agreements align with CRPO Practice Standards?