Which Of The Following Would Not Be Considered Psychotherapy

Use of terms, titles, and designations

This article was updated for the February 2023 Communiqué

Can I display my PhD or other credentials on my business card and website?

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It’s important that registrants not mislead the public about their psychotherapy credentials, which is why the practice standard about use of titles exists. This standard indicates that “the credential to be displayed must be one that is related to the practice of the profession.” This means that, if your degree or credential is not directly related to the practice of the psychotherapy, it should not appear alongside your other credentials or appear prominently on your website.

If you are not sure if your credential is related to the practice of the profession, ask yourself whether the program’s curriculum or your research addressed established psychotherapeutic theories and/or theories of human development, and whether it was concerned with the development of the skills that are necessary to engage a client in a safe, effective therapeutic process. If the answer to both questions is yes, then the credential is likely to be one that is related to the practice of the profession. If the answer to both is no, then it’s very possible the credential would not be considered related to the practice of the profession, in which case, you would be running afoul of CRPO standards.

Use of the “Doctor” or “Dr.” title

From the standard on use of titles:

Use of the title “Doctor” or “Dr.” is protected in the RHPA. Members of this College are not permitted to use this title in a clinical setting. If a person is not from one of the health professions entitled to use the doctor title (chiropractic, optometry, medicine, psychology, dentistry) or a social worker with an earned doctorate degree in social work, s/he cannot use the title “Doctor” or “Dr.” in a clinical setting. This is the case even if the person has an earned doctoral degree (e.g. the person holds a Ph.D). Under this provision, the title “Doctor” can be used in other settings, socially or in a purely academic setting, where no clients are present.

Note: The above does not prevent a member from displaying a Ph.D or other doctoral degree in his/her promotional material, if the degree is their highest credential earned and is related to the practice of the profession.

Use of terms “psychology” and “psychological”

The terms “psychology” along with “psychological” and “psychologist,” including any translations, abbreviations, and variations, are restricted under section 8 of the Psychology Act, 1991. Individuals who are not members of the College of Psychologists of Ontario must not use the term “psychology” or any of its abbreviations, when describing their services, or in any title. This means RPs must not claim to offer “psychology” or “psychological” services or use the term or an abbreviation of the term in their professional designation. The only exception provided for in the Act is for work “in the course of . . . employment by a university”, i.e., psychology professors.

Conversely, only CRPO registrants are permitted to use the title “Registered Psychotherapist”, while the title “psychotherapist” is shared among members of six regulated professions in Ontario. While there is some overlap in the work RPs and other professionals such as psychologists do (e.g., they may provide psychotherapy), these rules aim to distinguish between members of different professions.

Use of other professional titles

If a registrant has more than one registration with a regulatory body (e.g., RP and another health profession, social work, or other regulatory body such as teachers), it would be important to only use restricted titles in accordance with the law (e.g., only use titles you are legally entitled to use). (See dual registration for more information.)

Can I display the “Doctor of Medicine” or “MD” credential?

An RP would need to consider to what extent this credential is relevant to their practice of psychotherapy, and to consider the perspective of clients and members of the public who will see the credentials. The MD credential is highly recognized by the public as one that applies to physicians. If there is a chance that the credential will cause confusion to clients or members of the public, leading them to believe that the registrant is a doctor or qualified to practice medicine in Ontario, the registrant would need to consider how they would address this.

My employment role does not involve the provision of psychotherapy. Am I required to use the RP title?

Registrants often ask whether they are required to use the title in all employment settings. For example, some roles do not involve the provision of psychotherapy.

Standard 1.2 Use of Terms, Titles and Designations, notes that registrants are required to use the title conferred by the College when acting in a professional capacity. This helps members of the public identify a practitioner’s registration status and make informed choices about their health care. Protected titles indicate a regulated health professional has completed appropriate education and training and is accountable to a regulatory body for the quality of care they provide.

Depending on the situation, it might be acceptable not to display or use a regulated title. For example, the title would not be required in a job that only includes activities outside the scope of practice of psychotherapy, such as a teacher. In roles where there might be some overlap with psychotherapy, registrants are advised to use their judgement and think carefully about the implications of not using the title. Some considerations include, but are not limited to, the following:

• Does the role primarily or exclusively include activities outside of the controlled act of psychotherapy?
• Do members of the public and clients clearly understand the role and what services are being provided?
• If a member of the public were to file a complaint, how would you demonstrate that the role and services provided did not involve psychotherapy?
• Do any discrepancies between workplace policies and the Professional Practice Standards (e.g., informed consent practices, confidentiality requirements, record-keeping and use of personal health information, etc.) present a risk to the public?

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Q: What happens to my clients and clinical records if I’m suddenly no longer able to practise?

Planning for the unexpected will help you and your clients should you ever find yourself in a position where you are unable to practise. Indeed, Professional Practice Standard 6.4: Closing, Selling, or Relocating a Practice requires that CRPO registrants have a contingency plan in place that will:

• ensure the standards of the profession are met, even if you are not providing the services yourself;
• link your clients with other qualified professionals who can address their needs; and
• assure that your clients and/or their new providers have timely access to relevant information about the client’s care.

While the particular details of a contingency plan will depend on your practice, it is likely to include:

• the contact information for one or more individuals (designates) who have agreed to carry out specific tasks on your behalf in the event you are suddenly unable to practise;
• a list of contacts, including clients and colleagues and others with whom you have significant professional relationships;
• directions for the designate(s), including those that relate to contacting clients or their substitute decision-makers to inform them of the situation, provide referral information, and discuss maintenance or transfer of clinical records.

Below are some considerations that will help as you shape your contingency plan. Your own research and discussion with colleagues will also be helpful in your planning process.

Identifying an appropriate designate

In the event you were unexpectedly unable to practise, how would your clients learn that you are no longer available to provide services?

• If you are self-employed in a private practice, you will need to identify an appropriate designate who can carry out specific aspects of your contingency plan.
• If you work in an agency or hospital setting, it’s possible that a contingency plan already exists to address such a situation – you might find it helpful to speak with your manager for more information.
• If you provide services under contract to a third party, it will be helpful to carefully consider any existing contracts, policies set by the third party, and your overall role in order to understand what responsibilities would fall to a designate.

When selecting a designate, ensure they have the competence necessary to fulfill the duties set out in the contingency plan. Standard 6.4 does not indicate that a designate must be a fellow RP; however, it would be helpful for the designate to at least be a member of a regulated health profession in Ontario, as these individuals are likely to be familiar with the framework of health care law and regulation.

Understanding the needs of the clients you serve is also important, as this is likely to influence your selection of the designate who will carry out specific duties described in the plan, in addition to your plans for referral of clients to other suitably qualified professionals.

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Referral to Alternate Service Providers

Professional Practice Standard 1.9: Referral identifies that registrants must refer their clients to other qualified, competent professionals when they are not available to provide services. In light of this, your contingency plan must take into account referral to other professionals where applicable, as would be the case if you had active clinical files. The reasons for the referral must be explained to the client, and, if the referral process requires disclosure of the client’s personal health information, the client’s consent must be obtained before their information is disclosed.

See Standard 1.9 for more information.

Clinical Records

According to the Personal Health Information Protection Act, individuals who have received health care services in Ontario have a right to access to the personal health information that is contained in clinical records. Health information custodians are responsible for ensuring that clients have access their personal health information in a timely manner.

Health information custodians are individuals or organizations who have custody or control over a client’s personal health information. For example, an RP in private practice is responsible for storing and maintaining client clinical records, and would likely be considered the health information custodian; an RP who is an employee at a hospital or agency, on the other hand, is likely to be considered an agent working on behalf of a health information custodian, i.e. the hospital or agency.

Professional Practice Standard 5.1: Clinical Records identifies that CRPO registrants must maintain clinical records “for at least 10 years from the date of the last interaction with the client, or for 10 years from the client’s 18th birthday, whichever is later.”

If you are the health information custodian, your contingency plan must:

• account for the maintenance of clinical records in a manner that accords with relevant laws and the Professional Practice Standards; and
• include measures that will facilitate client access to their personal health information, or transfer of the client’s personal health information to another health provider, for the period defined in the Professional Practice Standards.

See Standards 5.1 and 5.6 on record-keeping for more information.

Instruction to Designate to Notify CRPO

As you prepare your contingency plan, consider adding an instruction for your designate to contact CRPO in the event of your death or incapacity to provide the following information:

• relevant information about the circumstances; and
• the name and contact information of the health information custodian designated in the contingency plan.

This information would be retained in CRPO’s records and used only to facilitate a client’s access to their clinical records. Only the name and contact information of the designated health information custodian would be shared.

By including this instruction in your contingency plan, you would be increasing the likelihood that a client would be able to access their clinical records in the event you are not available to provide access yourself.

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Q: I’m working with a young child whose parents are going through a divorce. What do I need to know about consent in this situation?

According to Professional Practice Standards Section 3: Client-Therapist Relationship, registrants have a duty to place the well-being of the client at the forefront of the therapeutic relationship. With this in mind, consider the following:

The client’s ability to provide consent

In Ontario, there is no “age of consent” with respect to personal health care decisions. In general, clients of any age are considered capable of refusing or providing consent to their own treatment as long as they possess the maturity to reasonably understand the information provided and can appreciate the consequences of their decisions. Where a client is a minor (e.g. under the age of 16 for health care decisions, or under the age of 18 for decisions involving contracts), their capacity to provide consent must be determined on a case-by-case basis.

Every health practitioner who proposes a treatment to a client may perform this type of capacity assessment. Registrants are advised to use their professional judgement and to exercise appropriate care in determining whether a child is capable of consenting to treatment. Where a registrant determines that a child is incapable, treatment may not be carried out unless consent has been obtained from an appropriate substitute decision maker (SDM). Review Standard 3.2: Consent, to see the hierarchy of SDMs.

Keep in mind that a client may be capable of giving consent for some aspects of care, but not others. It is registrants’ responsibility to identify the points where consent is possible and to engage the client in an appropriate informed consent process.

Custody orders and parental agreements

Where a client is not capable of providing consent, it is important to know information about the custody arrangements and whether a custody order or parental agreement exists, as these will inform who may make health care decisions on behalf of the child. For example, even when parents have joint custody, there may only be one parent who, under the custody order, may make decisions relating to the health care of the child.

This document provides information about the differences in custodial arrangements and the implications for health care decisions. See the section entitled “Types of parenting arrangements” where these concepts are explained:

Sharing personal health information

In situations where the client is a minor who is capable of providing consent, be advised that you will require the client’s informed consent in order to share their personal health information with parent(s) or guardian(s). Sensitivity to the issues that can arise in cases of separation and divorce, along with an awareness of the client’s particular concerns, will help you provide the information the client needs to make informed decisions about the sharing of their personal health information.

For more information, see our Informed Consent Workbook.

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Q: I’m registered with CRPO and another college. As a dually-registered practitioner, what do I need to know?

Practice Standards As a starting point, dually-registered professionals are encouraged to review the standards and policies of the colleges with which they are registered. Many colleges have specific standards that apply to dually-registered professionals, though CRPO does not have such resources at this time. Until a standard or guideline on this subject exists, CRPO registrants are encouraged to carefully review CRPO’s Professional Practice Standards in light of their dual practice, in particular Standards 1.2: Use of Terms, Titles and Designations, 1.6: Conflict-of-Interest, 1.7: Dual or Multiple Relationships, 3.1: Confidentiality, 3.2: Consent, 5.3: Issuing Accurate Documents and 6.2: Advertising and Representing Yourself and Your Services.

Administrative Matters There are a number of administrative matters that a dually registered professional should be aware of. An obvious example is the annual registration process – the dually-registered practitioner is required to complete the annual registration requirements, including any forms and payment of fees, of each college they are registered with. In addition, the dually-registered practitioner is required to engage in the quality assurance programs of any colleges they are registered with; this includes meeting the QA requirements and deadlines of each college.

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Complaints Dually registered professionals should be aware of the possibility that a concern or complaint against them can be received by one or both colleges. While each college independently investigates complaints filed against its registrants, it is possible that in some cases a complaint filed against a registrant with one college could prompt an investigation by the other college, even if the complaint was not originally filed with that college.

Considerations Being dually registered also has implications for clinical practice – a few examples will be covered off here. For more information, registrants are encouraged to connect with CRPO’s Practice Advisory Service.

The nature of your dual-practice – Depending on the nature of your dual practice, there may be some overlap in the work you do as an RP and the work you do in your other professional capacity. Dually-registered professionals are encouraged to think carefully about where any overlap may or may not occur in their practice. If your other profession does not overlap with psychotherapy, consider whether it is appropriate to refer or treat the same client in the other role.

Providing information for informed consent – Clients are entitled to provide informed consent prior to any treatment. In order for a client’s consent to be considered informed, they must be provided with all the information that one would need in order to make such a decision. Because of potential confusion, it is important that dually-registered practitioners describe their practice and services as accurately as possible, taking care to clarify to the client when the dually-registered practitioner is working in their capacity as a psychotherapist, or when they are working in their other professional capacity.

Maintaining clinical records – The dually-registered practitioner should be mindful that they will be expected to maintain clinical records in a manner that meets the standards of each college with which they are registered.

Billing – CRPO registrants are required to issue clear, accurate documents to third-parties. This means that receipts and invoices should include an accurate description of the services provided to the client, and it should be clear in all financial records in which professional capacity the rgistrant was working in when those services were provided to the client.

This FAQ does not address registrants who practise in unregulated fields in addition to the regulated profession of psychotherapy. For guidance, please see the article Dual practice: Can I incorporate non-psychotherapeutic activities in my practice?

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Dual practice: Can I incorporate non-psychotherapeutic activities in my practice?

This article was first published in August 2023

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

RPs are permitted to assess and treat cognitive, emotional, and behavioural disturbances in the course of their work (please see Scope of Practice). 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: Consultation, Clinical Supervision and Referral.)

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.)

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 – https://www.crpo.ca/standard-5-3-issuing-accurate-documents/ and Standard 5.5: Record-keeping – Financial Records – https://www.crpo.ca/standard-5-5/.)

Advertising

In general, psychotherapists must ensure that any information, advice, or comments they offer to clients or others can be supported as reasonable professional opinion and are consistent with professional standards and ethics. (See CRPO Professional Practice Standard 6.2: Advertising and Representing Yourself and Your Services.)

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 sections of the Professional Practice & Jurisprudence for Registered Psychotherapists Manual for further explanation of expectations:

• Under Standard 1.8, see “Sexual Abuse” and “Examples of Sexual Abuse” https://www.crpo.ca/professional-practice-and-jurisprudence-for-registered-psychotherapists/#standard18
• Under Standard 1.7, see “Touching” https://www.crpo.ca/professional-practice-and-jurisprudence-for-registered-psychotherapists/#standard17

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?

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