Whether a client resides in Ontario or in another jurisdiction, registrants may provide services using communications technologies as long as:
- they are able to do so competently and in a manner that abides by the Professional Practice Standards;
- there is no law, regulation or standard in the other jurisdiction that would restrict or prohibit the registrant from providing services to a client located in that jurisdiction; and
- they have appropriate liability insurance coverage considering the particular technologies used to provide services, the risks these technologies may present, and the possibility that the registrant’s practice will cross into other jurisdictions.
Registrants who provide psychotherapy using communications technologies (e.g. phone, video conference, etc.) have an electronic practice. Professional Practice Standard 3.4: Electronic Practice and the accompanying Guideline (linked in Related Resources below) set out expectations for registrants who engage in electronic practice, some of which are highlighted below.
Registrants who wish to work with a client located in another jurisdiction must determine whether any law or regulation in that jurisdiction that would prevent them from providing therapy to the client. This might require, for example, that registrants investigate whether the practice of psychotherapy or counselling is regulated in the client’s jurisdiction and if so, that the registrant makes inquiries with the regulatory body there.
To an extent, a communications platform is its own therapeutic milieu that influences the therapeutic relationship and the therapy itself. Being able to leverage this therapeutic milieu safely and to the benefit of clients is an important skill. Familiarity and comfort with the technologies that are used in electronic practice can help registrants meet their obligations with respect to confidentiality and enable them to resolve technical issues that might arise during a session.
Before any therapy is provided, registrants must first evaluate the appropriateness of therapy, given the nature of the client’s concerns, their ability to access technologies safely and privately, and their overall comfort and capability with communications technologies. Registrants must also consider whether providing therapy in this manner would present a risk of harm to a client in light of the client’s symptoms and individual risk factors, for example, safety in the home or possibility of adverse reaction during therapy.
There are added considerations for the informed consent process. For example, registrants are expected to enter into a contract with clients before providing services. In addition, therapists must inform clients of the technologies that will be used and discuss the risks to confidentiality that these technologies may present.