CRPO Communiqué
January 2018
January 16, 2018


Message from the Registrar 
Deborah Adams Registrar


The long-awaited legislative changes concerning psychotherapy were proclaimed into force on December 30, 2017.
 
Proclamation included provisions in the Regulated Health Professions Act, 1991 setting out the controlled act of psychotherapy and authorizing members of six colleges [1]  to perform it in compliance with the acts, regulations and by-laws that govern each of their professions. It also included the provision permitting members of the other colleges who are authorized to perform the controlled act of psychotherapy to use the title "psychotherapist", in compliance with certain conditions.
 
The proclamation incorporated an amendment that provides for a two-year transition period, beginning December 31, 2017, so that individuals may become registered with the appropriate colleges or change their practices so that they do not perform the controlled act of psychotherapy. By the end of the two-year transition period, anyone performing the controlled act of psychotherapy must be registered with one of the six colleges whose members are eligible to do so.
 
In conjunction with the proclamation of the controlled act, CRPO has been tasked by the Minister of Health with using its regulation-making authority under section 11 of the Psychotherapy Act, 2007 to make a regulation "prescribing therapies involving the practice of psychotherapy, governing the use of prescribed therapies and prohibiting the use of therapies other than the prescribed therapies in the course of the practice of psychotherapy", as well as developing policies, guidelines and other resources that clearly articulate the activities that Council does not consider to be part of the controlled act of psychotherapy. This work must be concluded by July 1, 2018.
 
The College recognizes the significance of the job ahead of us and we are committed to approaching it with an absolute focus on public protection. We believe that we are well-positioned to look at the practice of psychotherapy in Ontario through the lens of the work that was undertaken by the Transitional Council to define the entry-to-practice competencies and by the Council's Registration Committee and staff to review close to 7,000 applications over the past three years. We will also be engaging with stakeholders to ensure that the regulations, policies and guidelines we develop are informed by the perspective of those receiving services from our members, by others who play a role in the mental health and social services systems of the province and by our registrants themselves. Please look for updates on the process in this Communiqué and on the College's website in the coming months.


[1] In addition to members of CRPO, this includes members of College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers, College of Nurses of Ontario, College of Occupational Therapists of Ontario, and College of Physicians and Surgeons of Ontario.
 Quick Links

In This Issue
Message from the President

I would like to take this opportunity to wish CRPO members and stakeholders a Happy New Year! I expect that 2018 will prove busy for CRPO's Council and committees and encourage members and stakeholders to use the website - relaunched in November - and these monthly communiqués to learn new information and find helpful reminders. 
 
Andrew Benedetto, RP
President
Important Information About Renewal of Membership for 2018-19

CRPO members are required to renew their membership on an annual basis, before the end of March each year. The Renewal form for the 2018-19 membership is now available under the "Renewal" tab found in members' user accounts . In addition to the online Renewal form, members will find their membership fee invoice for the next year (April 1, 2018 to March 31, 2019) under the "Invoices" tab.
 
Members are advised to pay the membership fee early in the renewal period, but no later than March 27, 2018 to allow at least three business days for the bank transfer payment to clear before the deadline of 11:59 p.m. ET on April 3, 2018 (Please note CRPO's office will be closed on Friday, March 30, 2018 and Monday, April 2, 2018 for the Easter holiday). Once the payment has cleared, you must remember to return to the online Renewal form and click "Submit" to send the Renewal form to us before the deadline of 11:59 p.m. ET on April 3, 2018, or risk incurring a late fee. 
 
It normally takes a regulatory body several months to review all membership renewals. Members can continue to practise as usual while their renewal is being processed.
 
Note: Please be sure to keep a record of your login information for your CRPO user account. We receive a high volume of requests for forgotten information and answering these inquiries is very time consuming for staff and takes away from processing renewals, thus causing a delay and ultimately costs the College and the members.
 
Registration staff will send a message through members' user accounts if there are questions about their renewal (e.g. about currency hours, or if more information is required). Members will not receive a new Certificate of Registration for every membership year but any changes to names, employers or practice sites will be updated on the Public Register.
 
Detailed instructions for completing your renewal can be found in the Guide to Completing Your Membership Renewal . If you have general questions about the renewal process, please visit the  Renewal page of CRPO's website or contact us using the "Messages" tab through your  CRPO user account .

Updating Practice Sites and Contact Information
Members must ensure that they have provided up-to-date information for their practice sites and personal contact information (e.g. home address, phone number, email address). This information is necessary to communicate with members, identify practice sites on the Public Register and establish eligibility to be nominated and vote in annual Council elections. 
 
Carefully review the information found in your Renewal form to ensure it includes any changes that may have been omitted, including any changes indicating your primary practice site.

Transferring to the Inactive Category
Inactive members are practitioners who are not currently engaged in the practise of the profession, or who need to take an extended leave from active practice, but wish to maintain membership with CRPO.

A member should carefully weigh their options before applying to transfer into this category since Inactive members are prohibited from:
  • providing or supervising direct client care;
  • providing supervision; and
  • making any claim or representation to having any competence in psychotherapy.
Members in the Inactive category must use the appropriate title: Registered Psychotherapist (Inactive) or the acceptable abbreviated form, RP (Inactive).

* Qualifying members and RP (Temporary) members cannot transfer to the RP (Inactive) category.
 
Note: Transferring to the Inactive category of membership is different from resigning membership. If you resign your membership with CRPO, and wish to return to active practice at any future date you will be required to submit a new application for registration, pay all associated fees and demonstrate that you meet all registration requirements at the time of re-application. Thus, if you are only planning to leave for a short time and/or think you might ever want to return to active practice in Ontario, transferring to the Inactive category would be a better choice than resignation. More information about resigning membership can be found further on in this Communiqué.
 
Fees
The annual membership fee for a member who transfers into the Inactive category before the renewal period is $286 +HST.
 
Note : The College does not provide any credit, refund or reimbursement to a member who moves from RP status to Inactive at any point during the membership year, which runs from April 1 - March 31.
 
Professional Liability Insurance
CRPO requires that Inactive members carry liability run off coverage (sometimes called enduring or tail coverage) for a minimum of two years since last practising in Ontario. Review the Professional Liability Insurance page of CRPO's website for more information about insurance requirements. Contact your insurance provider to discuss your options.
 
Note : Members who are covered by employer liability insurance should contact their employer for more information about coverage during leave. The onus is on the member to ensure they have liability coverage which meets the criteria stipulated by CRPO.
 
Renewal of Membership in the Inactive Category
If you would like to switch to the Inactive category for the upcoming 2018-19 membership year, you must upload the Transfer form and notify CRPO in writing by March 2, 2018 and everything needs to be complete with your renewal all by April 3, 2018 to avoid incurring a late fee. To have everything complete with your renewal, the following steps need to be met:
  1. Complete and upload the Transfer form to your CRPO user account by March 2, 2018.
  2. A new Inactive category invoice will be issued. Pay this invoice, allowing at least three business days for funds to clear the banking system.
  3. Complete and submit the online Renewal form.
For more information about the Inactive category or to complete the Transfer form , please visit the Renewal page of CRPO's website and read the "Transferring to the Inactive Category" section.
 
Resignation of Membership
Any CRPO member who wishes to resign their membership should understand what it means to resign. Resignation means your membership with CRPO ceases. Annual renewal and participation in other College programs, such as the Quality Assurance Program, would no longer be required.
 
A non-member may not:
  • Use the title "psychotherapist", "Registered Psychotherapist" or any abbreviation or variation thereof in any language.
  • Hold oneself out as qualified to practise as a psychotherapist in Ontario (no matter what title one uses).
  • Perform the controlled act of psychotherapy* once it is in effect (January 1, 2020).
* Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual's serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual's judgment, insight, behaviour, communication or social functioning.
 
A former member wanting to return to practice at any future date must submit a new application for registration and pay all associated fees. The former member would also need to demonstrate that they meet all registration requirements at the time of re-application. Specifically, those members who were initially registered through the grandparenting route would not necessarily meet the regular route requirements. No refunds of membership or other fees will be made. If any fees are owed by you to CRPO, you will need to be in good standing with the College before re-applying.
 
Resignation and Quality Assurance
Former members, who resigned at any point during a Quality Assurance review process, including the Professional Development tool review and Peer and Practice Review, should expect to resume these processes in the event of re-registration with the College.
 
Resignation and Outstanding Investigations
  • If a member resigns during, or as a result of a complaint/investigation into their conduct, a notation to this effect will be made on the Public Register.
  • If the former member then re-applies for registration with the College, the outcome of re-application may be affected by the decision to resign.
  • If re-registered as a member, the complaint/investigation process may resume.
  • If a complaint or report is received after a member has resigned, the College can still investigate and prosecute conduct that occurred while the person was a member.
Professional Liability Insurance
Former members are advised to maintain run off liability insurance coverage for a reasonable time period after the last date of practise (please consult with your insurance provider for more information).
 
If you would like to resign your membership with CRPO, you may do so at any time by completing and uploading the  Membership Resignation form to your CRPO user account and notifying the College through the "Messages" tab in your CRPO user account. To avoid receiving late notices, incurring a late fee and having your membership suspended for non-payment of fees, your Membership Resignation form needs to be submitted no later than March 27, 2018. No matter when you resign your membership, no refunds will be given for any fees already paid
Suspension and Revocation for Non-Payment of Fees

CRPO members must renew their membership by the renewal deadline each year. For the upcoming 2018-19 membership year, the deadline is April 3, 2018. Any member who does not meet all of the renewal requirements within the stipulated deadlines risks suspension of their membership with CRPO. After the stated renewal deadline, any member who has not completed the requirements for renewal incurs a late fee and is given an additional 30 days to complete outstanding requirements (e.g. pay fees in sufficient time for the payment to clear ahead of the new deadline, submit the online Renewal form, etc.). Periodic reminders are sent, however, if the outstanding requirements are not completed in time, the member is suspended.
 
Note: Any member who does not maintain professional liability insurance in the form and amount required in CRPO's By-laws may also be suspended. Under this circumstance, unlike suspensions or revocations for non-payment of fees, if/when the member is reinstated, the former suspension notation remains visible on the Public Register.
 
What are the implications of suspension and will it affect my practise of the profession?
In effect, the suspension means that a member has forfeited their good standing with the College, is no longer a member of CRPO, and so is not permitted to use any restricted title, practise or supervise the provision of psychotherapy for the purposes of registration with the College, nor hold themselves out as qualified to practise as a psychotherapist in Ontario. In other words, if a member sees clients or provides clinical supervision to other practitioners who see clients, these services must cease effective from the date of the suspension, as must use of the restricted title. In the interest of public protection, the suspension is also reflected on the Public Register.
 
How do I return to good standing?
To return to good standing, any member who is suspended needs to submit the online Renewal form or any other documentation as required, pay any outstanding fees (i.e. the annual membership fee, late fee and the additional penalty fee levied by the Registrar to lift a suspension). The Registrar will lift the suspension if they are satisfied that the former member has paid the outstanding fees, has professional liability insurance coverage in the amount and form required under the By-laws, and will be in compliance on the anticipated date on which the suspension is to be lifted with any outstanding requirements or orders issued by CRPO's statutory committees (e.g. Inquiries, Complaints and Reports Committee, Discipline, Fitness to Practise or Quality Assurance Committees).
 
When the outstanding items are completed and conditions satisfied, the member is reinstated to good standing, details of the suspension are removed from the Public Register and the member is permitted to resume practice of the profession and use of the title.
 
Revocation and Reinstatement
If the Registrar suspends a Certificate of Registration and the member does not take the steps outlined above to lift the suspension, the Registrar has authority to revoke the member's certificate two years after the day it was suspended. Again, this status will be reflected on the Public Register.
 
If a former Member, whose Certificate of Registration was revoked because they failed to pay a fee that is required to be paid in accordance with the By-laws, wishes to return to active practice, the Registrar has the authority to reinstate the certificate if certain conditions are met. The former member will have to satisfy a panel of the Registration Committee that they are competent to safely practise psychotherapy, will pay the outstanding fees, have professional liability insurance coverage in the amount and form required under the By-laws, and will be in compliance on the anticipated date on which membership is to be reinstated with any outstanding requirements or orders issued by CRPO's statutory committees (e.g. Inquiries, Complaints and Reports Committee, Discipline, Fitness to Practise or Quality Assurance Committees).
 
For more information about the conditions associated with suspensions and revocations, see sections 23 - 27 of the Registration Regulation .
 
If you have any questions about suspension, please contact us using the "Messages" tab in your CRPO user account
Transferring from RP (Qualifying) to RP

All members registered in the RP (Qualifying) category must complete one or more additional requirements to move to the Registered Psychotherapist category, including:
  • the education and training requirements if not completed when applying to the College. This involves completing either the member's education and training programs or relevant upgrading activities;
  • successfully completing the Registration Examination; and
  • any remaining clinical experience hours (direct client contact and clinical supervision).
Qualifying members must be actively pursuing completion of the remaining requirements to move from the Qualifying category into the Registered Psychotherapist category. Unless given direct written permission to postpone completing a specific requirement to leave the Qualifying category, a Qualifying member's Certificate of Registration may be subject to expiration if the College becomes aware the member is not pursuing completion of outstanding requirements.
 
Qualifying members are permitted a maximum of five years from the date that a completed application and fee are received by the College in which to satisfy all the requirements for registration as an RP (completing clinical experience and passing the Exam).

The Registration Examination
In order to fulfil the requirements for registration as a Registered Psychotherapist (RP), all Qualifying members are required to pass the Canadian Professional Standard for Counselling and Psychotherapy (CPSCP): Entry to Practice Competency Assessment (commonly referred to as the "Registration Examination"). The Exam assesses a practitioner's knowledge of various key entry-to-practice competencies and their information-gathering and decision-making skills in a variety of typical scenarios and simulations. 
 
Conditions for Completing the Registration Examination
  • The candidate must be registered in the RP (Qualifying) category.
  • The candidate must have completed the education and training requirements. This involves completing an education and training program submitted at application if the member was only substantially completed or any upgrading deemed necessary to satisfy the requirements.
  • The first attempt at the Exam must be made no later than 24 months following the date that a complete application for registration as a Qualifying member, and fee, are received by the College. There will be at least one sitting of the Registration Exam each year (but usually there are two, one in the spring and one in the fall).
  • A candidate must successfully complete the Exam in no more than three attempts.
  • In the event of two failed exam attempts, the third and final attempt is permitted only after the Qualifying member has completed upgrading activities, if any, required by a panel of the Examination Committee. The third attempt must be made no later than five years after the date of application for registration in the Qualifying category, unless additional time is permitted by the Examination Committee, in exceptional circumstances.
Successful Completion of the Registration Examination and Clinical Requirements (Category Transfer)
Once you have successfully passed the Registration Examination and completed all clinical requirements (450 DCC hours and 100 clinical supervision hours), you will be eligible to transfer registration categories from Registered Psychotherapist (Qualifying) to Registered Psychotherapist (RP). Members who are deemed eligible to transfer registration categories will have 90 days from the date they become eligible to transfer to complete the registration category transfer process. This process involves payment of transfer and pro-rated registration fees, as well as completion of the Registration Category Transfer Checklist .
 
If an eligible member does not successfully complete the transfer of registration categories within the 90 day time-frame, the following steps will be taken:
  • The member will receive a letter confirming they have not fulfilled their requirement to transfer registration categories and will be invoiced a late fee.
  • The member will be given an additional 30 days (from the date the message/letter is sent) to complete the transfer process, including payment of the late penalty.
  • After the 30-day extension period, if the member still has not completed the registration category transfer process, their registration will be administratively suspended for non-payment of fees. The conditions associated with suspension will apply and will be reflected on the Public Register.
  • An additional fee of $156 +HST will be invoiced to lift the suspension.
  For further information, please visit the Registered Psychotherapist (Qualifying) page of our website. If you have any questions, please contact us using the "Messages" tab in your CRPO user account
CRPO Updates
  1. Public Consultation
  2. QA Focus Group Call for Participation
1. Public Consultation - Draft Guideline: Disclosing Information to Prevent Harm
CRPO would appreciate your feedback on a Draft Guideline: Disclosing Information to Prevent Harm . Please read the draft guideline and complete our short survey by Wednesday, February 14, 2018. We thank you in advance for your time and participation.

2. QA Focus Group Call for Participation - Help Us Create Member Resources
We need your help to develop a key resource for members on informed consent. CRPO needs 10 experienced RPs who will contribute their time and expertise by providing feedback on the draft Informed Consent Workbook during a webinar focus group. The focus group will be held on Friday, January 26, 2018.
 
The intent of the Workbook is to help members understand the law and their obligations with respect to the informed consent process, including:
  • information that must be shared with the client
  • consent of children and youth (minors)
  • when to engage the substitute decision-maker
  • consent in exceptional circumstances
If you meet the criteria listed below, and you are available from 11:30 a.m. to 1:30 p.m. on Friday, January 26, 2018, please sign up for the focus group here: Workbook Focus Group Registration .

Ten focus group participants are needed - only those who meet the eligibility criteria will be selected to participate. If you have been selected, CRPO will contact you to provide confirmation and send you the Informed Consent Workbook.

Participants will be expected to review the Informed Consent Workbook in advance of the focus group session, and will be asked in the session to provide feedback on the content, structure, practice scenarios and exercises.

In order to be considered eligible, you must:
  • have practised the profession for at least five years;
  • be currently practising and engaged in direct client work;
  • hold a current Certificate of Registration as a Registered Psychotherapist and meet the annual renewal requirements;
  • have no prior history with the College or another regulatory body resulting in a decision of the ICRC, the Executive Committee, the Fitness to Practice Committee or the Discipline Committee, other than a decision to take no action; and
  • have successfully completed (or are up-to-date with) all requirements under the Quality Assurance Program.
CRPO makes every effort to reflect the diversity of the profession in its selection processes - participants will be selected based on a combination of experience and professional background.
Other News
  1. Controlled Act Update
  2. Registration Under the Private Career Colleges Act for Operators Offering Psychotherapy Programs in Ontario
1. Controlled Act Update
As you will have read in the Registrar's message, the Ontario government has proclaimed the controlled act of psychotherapy and they have included a transition period of two years, which began December 31, 2017, so that individuals may become registered with the appropriate colleges or change their practices so that they do not perform the controlled act of psychotherapy. By the end of the two-year transition period, anyone performing the controlled act of psychotherapy must be registered with one of the six colleges whose members are eligible to do so (College of Registered Psychotherapists of Ontario, College of Psychologists of Ontario, Ontario College of Social Workers and Social Service Workers, College of Nurses of Ontario, College of Occupational Therapists of Ontario, and College of Physicians and Surgeons of Ontario).
 
As noted in the Health Bulletin , CRPO has been tasked by the Minister of Health and Long-Term Care with providing further clarity on the practice of psychotherapy. We will be doing the necessary work over the next six months.
 
Without a thorough review of a full application, we cannot determine if one's practice involves the provision of psychotherapy that falls outside the controlled act or if your combination of education and training and experience would meet the criteria for registration. This review process has been developed to ensure that each applicant has the opportunity to provide CRPO with all relevant information required.
 
When considering if you should apply for registration with CRPO, please review the  clarification document  as well as the  Applying to CRPO  page of our website, which outlines the competencies as well as the requirements to qualify for registration as a Registered Psychotherapist (RP). If you believe that your practice may involve the provision of psychotherapy as it is contemplated by the controlled act (i.e. you are treating by psychotherapeutic techniques, delivered through a therapeutic relationship, cognitive, emotional or behavioural disturbances that may seriously impair an individual) then your work falls within the scope of practice and you will be required to register/remain a member. Moreover, if you are using the title "psychotherapist", "Registered Psychotherapist" or any abbreviation thereof, or if you are  holding yourself out as qualified to practice as a psychotherapist in Ontario (no matter what title you may use), you are required to be a member. 
 
We will continue to communicate any updates about the controlled act with our stakeholders as they become available.

2. Registration Under the Private Career Colleges Act for Operators Offering Psychotherapy Programs in Ontario
The College has received a number of enquiries regarding changes to the Private Career Colleges Act, 2005. While these changes are not something that CRPO had any involvement with, we are aware that the result is a requirement that private career colleges that provide students with the skills and knowledge necessary to obtain employment must register with and have their programs approved by the Superintendent of Private Career Colleges.
 
The College received this letter from the Ministry of Advanced Education and Skills Development and is sharing it with our stakeholders in the interest of ensuring that accurate and comprehensive information is available. If you have any questions about the letter, please direct them to the Ministry of Advanced Education and Skills Development.
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