91视频

On November 3, 2025, the Ontario government passed legislative amendments that expand 鈥淎s of Right鈥� legislation to make it easier for regulated health professionals registered in other parts of the Canada to work immediately in Ontario.

As of January 1, 2026, psychologists and psychological associates who are already fully registered to practice psychology elsewhere in Canada may work in Ontario right away while they are completing their requirements for full registration with the College of Psychologists and Behavior Analysts of Ontario (91视频), for a period of up to six months.

91视频鈥檚 As of Right route is intended for those practitioners who intend to settle in Ontario and practice psychology in Ontario. As of January 1, 2026, only those practitioners who are already fully registered to practice psychology in another Canadian province or territory may apply for registration via the As of Right route.

This application is听苍辞迟听intended for applicants who hold provisional, candidate, or temporary registration in another Canadian province or territory.

No. The As of Right route for the 91视频 is limited to only those who are fully registered to practice psychology elsewhere in Canada. Applicants to the 91视频 from the USA and other countries may apply to the 91视频 via alternative application routes.

To be eligible to practice under the As of Right legislation, an applicant must:

• Hold an active registration as a psychologist or a psychological associate with an equivalent certificate in another Canadian jurisdiction
• Not been refused registration in another Canadian jurisdiction within the past two years
• Have no findings of professional misconduct, incompetence or incapacity
• Not be the subject of any current professional misconduct, incompetence or incapacity proceedings
• Have submitted a complete application form and application fee for registration with the 91视频 and signed the required Attestation Form before providing services in Ontario
• Hold professional liability insurance, applicable to practice in Ontario
• Use the relevant Ontario title (i.e., psychologist or psychological associate)
• Be physically present in Ontario to provide services to Ontario residents

Before beginning practice in Ontario, the applicant must submit to the College a complete application form (Canadian Labour Mobility (Autonomous Practice)) an As of Right Attestation form, and the application fee of $100.00.

The applicant may practice psychology in Ontario while they wait to receive a certificate of registration听 from the 91视频. It is the applicant鈥檚 responsibility to request that their home jurisdiction(s) submit a verification of their registration, directly to the 91视频 as per the application instructions.

The applicant must obtain a certificate of registration from the 91视频 within six months from the date of submission of their application to the 91视频.

Those practicing under the As of Right legislation can practice for听up to six months听while completing their听registration requirements听with the 91视频.

Applicants practicing under the As of Right legislation must stop practicing in Ontario if:

• Their 91视频 registration application is rejected
• They do not register with the 91视频 within six months
• They do not continue to meet all the eligibility criteria

• The applicant must have submitted a complete application form, including the application fee ($100.00), and an As of Right Attestation Form;
• The 91视频 must have received verification of registration directly from the applicant鈥檚 home jurisdiction(s).

A certificate authorizing interim autonomous practice as a psychologist or psychological associate will then be issued to the applicant, which will permit them to continue to practice psychology in Ontario, while they complete the Jurisprudence and Ethics Examination. Upon successful completion of the Jurisprudence and Ethics examination, a certificate authorizing autonomous practice will be issued to the applicant.

Applied Behavior Analysis (ABA) is听the application of the science of learning to understand and improve behavior that is meaningful to the person and those around them. ABA considers how the environment impacts learning. The term behaviour refers to anything a person says or does, including skills and actions needed to talk, play, and live. Behavior can also be private (e.g., thoughts and feelings).

ABA can听help increase helpful or functional skills (e.g., communication) and/or decrease behaviours that are harmful or interfere with learning (e.g., self-injury).

ABA intervention听uses evidence-based procedures such as positive reinforcement to address a client鈥檚 concerns and needs and to reduce interfering behaviour and increase desirable behaviour.听 Behaviour Analysts practice in a variety of settings with many different client populations.听听听

Resources:

1. The (ONTABA) has developed this听 to describe ABA, what it is and what it is not.听 The graphic and more information can be found on their website.
2. The (BACB) has additional information on its website about the profession of ABA and the client populations it serves.

In 2017, the Minister of Health and Long-Term Care asked the Health Professions Regulatory Advisory Council (HPRAC) to provide advice on:

• What activities or aspects associated with ABA therapy pose a significant and inherent risk of harm (if any), and whether the risk of harm of this therapy varies by client population (e.g., children and adults); and
• If there is a risk of harm, what is the range of options for an approach to oversight that could be considered?

In HPRAC鈥檚 January 2018 report to the Minister of Health and Long-Term Care, it concluded:

鈥淏ased on the evidence reviewed, HPRAC affirms that there is a risk of harm associated with most ABA interventions for clients, therefore oversight is recommended. Several oversight options to regulating providers were examined with a particular focus on clinical supervisors.鈥�

With respect to oversight, HPRAC recommended the following:

鈥淏ecause ABA therapy is deemed to pose a significant and inherent risk of harm across many client populations, HPRAC recommends that ABA providers performing a clinical supervisory role be regulated under an established health regulatory college, governed by the Regulated Health Professions Act, 1991 (RHPA). Other ABA providers would be accountable to the regulated clinical supervisors.鈥�

To protect the public from risk of harm, once regulated Behaviour Analysts who supervise and/or deliver ABA interventions will have to meet clearly defined standards.听 These standards will include having the necessary knowledge, skills, and judgement to meet practice requirements and to be allowed to use the regulated title 鈥淏ehaviour Analyst鈥�.

Anyone who wants to practise a regulated health profession in Ontario, i.e., psychologists, psychological associates, physicians, nurses, dentists, occupational therapists etc., and now, Behaviour Analysts, must be registered with, and be accountable to, a health regulatory College.听听 A College is not a university, community college, or school. Instead, its mandate is to protect the interests of the public by ensuring that clients receive competent and ethical professional services from qualified providers.

Ontario Health Regulators includes the 26 health regulatory Colleges in Ontario, including the College of Psychologists of Ontario. To learn more about how and why health professions are regulated in Ontario, visit their .

Regulated professionals are required, by law, to deliver professional services competently and ethically.听 They are accountable to the public, through their regulatory body, for their professional behaviour and activities. Once regulated, Behaviour Analysts will have to meet rigorous professional entry requirements, adhere to prescribed standards, guidelines and ethical principles and participate in quality assurance activities to continually update and improve their knowledge and skill.听 Complaints and discipline processes hold professionals accountable when a client, or other member of the public, believes that the standards may have been breached.

In contrast, the College has no authority over unregulated service providers.听 There is no regulatory body with the authority to set minimum levels of education, training, and competence or to establish and monitor professional and ethical standards of conduct.听 There is no professional regulatory body responsible to protect your interests and hold unregulated providers accountable for the services you receive.

The scope of practice or activities that a Behaviour Analyst performs when providing services to a client are not Controlled Acts or restricted activities. They are therefore, in the public domain.听 If one is not registered with the College, one must be aware of the restrictions within the Psychology and Applied Behaviour Analysis Act, 2021,听regarding how one refers to themselves in the course of providing services in applied behaviour analysis.

On July 1, 2024, the date that the Act was听proclaimed, the title 鈥淏ehaviour Analyst鈥� became a restricted title that can only be used by individuals registered with the College as Behaviour Analysts. Members registered as Behaviour Analysts may also refer to any earned certification they have, such as a BCBA or BCBA-D certification, that would assist the public in understanding their qualifications as a regulated health provider registered with the College.听 Non-members who use the title 鈥淏ehaviour Analyst鈥� or indicate any certification or designation or communicate in any way that could be considered as holding oneself out as a person who is qualified to practice as a Behaviour Analyst, could be in violation of the Act.

The applicable legislation prohibits unauthorized use of the specific title 鈥淏ehaviour Analyst.鈥� It does not otherwise prohibit the use of specific words in job titles or in describing the service offered or provided. However, in any title or description of services, individuals should be cautious about how their status as an unregulated individual will be perceived.

An unregulated person who 鈥渉olds out鈥� as qualified to practice as a Behaviour Analyst may also be in violation of the Act. In looking at whether someone is 鈥渉olding out,鈥� the College would consider all the circumstances, including the context of any communications and the language used. The focus would be on determining what a reasonable service recipient or funder would understand about whether the service was provided by, or under the supervision of, a regulated health professional.

In deciding on job titles and job descriptions for unregulated service providers, individuals should consider avoiding any confusion in the way they identify themselves, their colleagues, and their employees. Examples of some of the less ambiguous titles unregulated individuals may wish to consider using would include, but not be limited to: Supervised Instructor, Supervised Instructor-Therapist, Supervised Therapist, Supervised Interventionist, etc. The College is of the view that public protection is enhanced when behavioural services, like any other health services, are provided or directly supervised by regulated professionals.

Controlled Acts are health care activities or interventions that are considered to be potentially harmful if performed by unqualified persons.听 Some examples of Controlled Acts are administering a substance by injection, setting a broken bone, dispensing a drug, prescribing glasses, performing a surgical procedure, managing the delivery of a baby, and applying a form of energy.听 The full list of the 14 Controlled Acts may be found in section 27 of the听听(RHPA).

Due to the potential for harm, a Controlled Act may only be performed by a regulated health professional who is authorized, in legislation, to do so.听 Not all regulated health professions are authorized to perform Controlled Acts.听 Each profession specific act, e.g., the听,听,听, or听, etc., prescribes which, if any, Controlled Acts may be performed by members of that profession.

Behaviour Analysts will not be authorized to perform any of the Controlled Acts outlined in the legislation. A Controlled Act may only be performed by those professions that have been granted authorization under the Regulated Health Professions Act, 1991 and their profession specific acts. The full list of the 14 Controlled Acts may be found in section 27 of the听RHPA. This prohibition on performing any of the Controlled Acts is currently in place for individuals practicing applied behaviour analysis or any form of behaviour therapy and will continue with the proclamation of the new Act.

If a Behaviour Analyst registrant is dually registered with another regulatory College, and if their registration with that College qualifies them to perform one or more Controlled Acts, that registrant can continue to perform the Controlled Act(s) they are authorized, in legislation and in their profession specific act, to perform, while engaged in the practice for which they have been authorized to perform the Controlled Act(s).

Registrants who have been issued a certificate of registration authorizing autonomous practice as a Behaviour Analyst by the 91视频 are considered autonomous/independent practitioners of applied behaviour analysis (ABA). Therefore, autonomous practice Behaviour Analysts do not require supervision from a Psychologist/Psychological Associate or another regulated professional to practice ABA.

The College maintains a register of all current members. Information about an individual Behaviour Analyst is available in the searchable Public Register or obtained from the College by telephone 416-961-8817or by e-mail: cpbao@cpbao.ca.

The new regulation (O. Reg. 193/23) replaces O. Reg. 74/15 and includes the requirements for registration with the College as a Behaviour Analyst. The new regulation reflects changes that were approved by Council in December 2022 and approved by the Ontario government in July 2023.

On July 20, 2023, the Ontario Government approved the regulations made under the听, for the profession of Applied Behaviour Analysis (ABA). The听Act听was proclaimed effective听July 1, 2024, when the College changed its name to the 鈥�91视频鈥�. Beginning on July 1, 2024, only ABA practitioners who are registered with the 91视频 will be allowed to use the title 鈥淏ehaviour Analyst鈥� in Ontario.

On June 3, 2021, the enabling legislation to authorize the College of Psychologists of Ontario to regulate the profession of Applied Behaviour Analysis (ABA), 听听received Royal Assent. Included in听听of this Bill is the legislative authority for the College to regulate the profession of applied behaviour analysis (ABA). On July 1, 2024 this legislation was proclaimed by the Ontario government and repealed the听Psychology Act, 1991听and replaced it with the听Psychology and Applied Behaviour Analysis Act, 2021.

The new Act establishes the regulation of two separate and distinct professions, psychology and ABA within one College. The College of Psychologists of Ontario was renamed the 91视频 to reflect its expanded role as the regulator of both professions. The legislation maintains the regulatory framework for current registrants, Psychologists and Psychological Associates, but additionally:

• Defines the scope of practice for ABA: 鈥淭he practice of applied behaviour analysis is the assessment of covert and overt behaviour and its functions through direct observation and measurement, and the design, implementation, delivery and evaluation of interventions derived from the principles of behaviour in order to produce meaningful improvements鈥�;
• Restricts the use of the title 鈥淏ehaviour Analyst鈥� to registrants of the new College registered as Behaviour Analysts;
• Expands the 鈥淩epresentations of Qualifications鈥� restriction to include holding oneself out as qualified to practice as a Behaviour Analyst or in a specialty of applied behaviour analysis; and
• Updates the size and composition of the current College鈥檚 Council to enable fair representation for both professions.

Only members of the 91视频 registered to practise psychology may use the title 鈥楶sychologist鈥� or 鈥楶sychological Associate鈥�; use the terms 鈥榩sychology鈥� or 鈥榩sychological鈥� in any description of services offered or provided, or hold themselves out to be a Psychologist or Psychological Associate. Psychologists and psychological associates respectively may also identify themselves with the designation C.Psych. or C.Psych.Assoc. after their names.

To qualify for professional registration to practise psychology requires successful completion of graduate education and training in professional psychology, supervised professional experience, and examinations. A member of the College is required to practise in accordance with applicable legislation, regulations, standards of conduct, professional guidelines, and professional codes of ethics.

Psychologists and Psychological Associates are trained in the assessment, treatment, and prevention of behavioural and mental conditions. They diagnose neuropsychological disorders and dysfunctions as well as psychotic, neurotic and personality disorders and dysfunctions. In addition, Psychologists and Psychological Associates use a variety of approaches directed toward the maintenance and enhancement of physical, intellectual, emotional, social and interpersonal functioning.

Psychologists and Psychological Associates usually focus their practice in specific areas such as clinical psychology, counselling psychology, clinical neuropsychology; school psychology; correctional/forensic psychology; health psychology; rehabilitation psychology; or industrial/organizational psychology. Within these areas, a Psychologist or Psychological Associate may work with a variety of individual client populations such as children, adolescents, adults or seniors, or may focus their attention on families, couples, or organizations. They work in a range of settings including schools, hospitals, industry, social service agencies, rehabilitation facilities, and correctional facilities. Many Psychologists and Psychological Associates have their own private practice.

A Psychologist or Psychological Associate who holds a certificate of registration authorizing autonomous practice may provide services without supervision, within his or her area of competence, and may charge a fee for these services. While most members of the College have no explicit term, condition, or limitation on their certificates of registration, some do and must practice in accordance with any such restriction.

The College maintains a register of all current members. Information about an individual Psychologist or Psychological Associate may be found in the searchable Public Register or obtained from the College by telephone 416-961-8817or by e-mail: cpbao@cpbao.ca.

Occasionally clients of Psychologists and Psychological Associates need to have forms completed and signed by their treating professional in order to obtain insurance reimbursement for psychological services or to qualify for some other benefit or service from an insurer or government agency. Normally both Psychologists and Psychological Associates may complete and sign such forms. If there are any questions or difficulties in having such forms accepted, please contact the College for guidance.

The difference is in how they are trained. Both have completed an undergraduate degree and have gone on to complete a graduate degree in psychology.

Psychological Associates have completed a masters level degree in psychology (e.g. M.A., M.Sc., M.Ps., M.Ed.), which is then followed by four years of experience working in the scope of practice of psychology. Psychologists have completed a doctoral level degree in psychology (Ph.D., Psy.D., Ed.D., D.Psy.) which typically includes a one-year internship.

Both Psychologists and Psychological Associates have then completed at least one additional year of formal supervised experience approved by the College and passed the three examinations required by the College.

The profession of psychology in Ontario has a single scope of practice. There is no distinction made in the legislation or in the regulations between Psychologists and Psychological Associates with respect to scope of practice or with respect to controlled/authorized acts.

All members must have knowledge and skills respecting interpersonal relationships, assessment and evaluation, intervention and consultation, understanding and applying research to professional practice and knowing and applying professional ethics, standards and relevant legislation to professional practice. Every member of the College, with the exception of individuals whose practice is limited to Industrial/Organizational Psychology, must be competent to formulate and communicate a psychological diagnosis.

*Note: In June 2009, the Federal/Provincial Agreement on Internal Trade was signed and in December 2009, the Ontario Labour Mobility Act (2009) was enacted. As a result of this legislation, the College must offer registration as a Psychologist to individuals who have been registered as Psychologists in other Canadian jurisdictions, regardless of the level of their graduate degree in psychology. There are some Canadian jurisdictions that award the title Psychologist to individuals at the Masters, rather than Doctoral level. The recent legislation requires that the College recognize this title for these individuals. Therefore, while the majority of psychologists and psychological associates in Ontario will have the differential training and experience described above, there are some Psychologists, who have come to Ontario from another Canadian jurisdiction, who may have a Masters degree. Members of the College are required to indicate their degree and title in any professional correspondence, report or promotional information.

In summary, both Psychologists and Psychological Associates are members of the College and are qualified psychological practitioners in the province of Ontario.

Questions?

Questions regarding Psychologists and Psychological Associates or other inquiries related to the regulation and practice of psychology in Ontario may be directed to the College:

The 91视频
Suite 500 鈥� 110 Eglinton Avenue West
Toronto, Ontario M4R 1A3
Tel: (416) 961-8817/(800) 489-8388
Fax: (416) 961-2635
E-mail: cpbao@cpbao.ca

Applications for registration are received and reviewed on an on-going basis throughout the year. Once the College has received your completed application form, the application fee, and all supporting documentation, your application is ready for review. The review process is usually completed in four to six weeks (up to 30 business days).

Once the College has received your completed application form, the application fee, and all supporting documentation, your application is听ready for review. The review process is usually completed in four to six weeks (up to 30 business days).

After the review, if the Registrar has any doubts or concerns about your meeting the academic or good character requirements, or about your training in your proposed area(s) of practice, your application is referred to the Registration Committee for further review.听 You will be notified of this referral and given 30 days to submit any further information to assist the Registration Committee in its review.听 The Registration Committee meets about every six weeks throughout the year.听 The application review will be scheduled for the next available meeting after the 30-day notice period.

Once the review of your application is complete, you will receive a letter confirming the outcome.

Applicants are encouraged to submit their completed application form and supporting documentation as soon as possible. You can track the status of your application using the Checklist feature in the navigation panel of your application. This checklist will tell you which documents have been received and which are outstanding.

Any supporting documentation that arrives at the College before your application will be filed according to your name. Once your application arrives, the supporting documentation will be included with it.

Once the College receives your application and fee, you have 24 months to submit all the supporting documentation. The application will expire after 24 months unless a certificate of registration or a confirmation of eligibility has been issued.听 At this point, the application and all supporting documents will be destroyed. The application fee is non-refundable.

The College will accept a pre-convocation transcript in order to review your application if you have completed all requirements for your degree but have not yet convocated.听 The transcript must be accompanied by a signed letter from the Senate or Registrar of the University or an appropriate Department of Psychology designate such as the Director of Clinical Training. The letter must confirm the date that your degree requirements were successfully completed.听The letter must be submitted to the College directly from the University. The College will not accept a student copy of the letter. Universities may send official electronic letters directly to cpbao@cpbao.ca.

The College will accept electronic versions of supporting documents sent directly to the College by the issuing authority. Applicants can request e-versions of their supporting documents to be sent directly to the College via email to cpbao@cpbao.ca.

If e-mail is not possible, please have the organization mail the document to:

The 91视频

110 Eglinton Ave West, Suite 500

Toronto, ON

M4R 1A3

No. The College will only accept academic transcripts sent to the College directly from a University. It is your responsibility to contact the University and ask them to send a copy of the official academic transcript directly to the College. Universities may send official electronic transcripts directly to cpbao@cpbao.ca.

Applicants must have their university submit an official copy of their transcript(s) directly to the College. Applicants should request that an electronic version of their transcript be emailed to the College at cpbao@cpbao.ca.

If e-mail is not possible, please have the university mail the document to:

The 91视频

110 Eglinton Ave West, Suite 500

Toronto, ON

M4R 1A3

The College will approve the start date for supervised practice based upon the date that听both听your Primary and Alternate Supervisors confirm that their supervision of your work began,

or

the date that the last supporting document for your application was received, whichever date is听later.

Applicants who have completed their education but have not yet secured employment and supervisors in Ontario, may opt to apply for an eligibility review. During this review, the College will review your academic credentials. Many candidates choose to submit an application before they鈥檝e secured employment and supervision because, it offers them the opportunity to write the Jurisprudence and Ethics Examination (JEE), and Examination for Professional Practice in Psychology (EPPP) once they鈥檝e been deemed eligible by the College.

You can apply for an eligibility review now by starting an application at . The College understands that you will not be able to complete the section titled 鈥淎uthorized Supervised Practice鈥� and the Primary and Alternate Supervisors鈥� Agreement Forms.

The College will proceed to evaluate your academic credentials. If your application is found to be acceptable, the Registrar will wait to issue you the certificate for supervised practice until you have found an appropriate work setting and named two supervisors.

Yes.听 Supervised practice is intended to prepare you to practice psychology in Ontario.听 It must be completed here under the College鈥檚听Standards of Professional Conduct听and Ontario legislation.听 The College鈥檚 mandate is to protect the public of Ontario.听 Psychological services provided in another province or state follow the rules of the regulatory board for psychology in that province or state only.

You are responsible for finding a suitable job as well as your Primary and Alternate Supervisors.听 Generally, once you find a job, your employer will have a member(s) of the College on site or who consults to the organization who can supervise your work. The College鈥檚 online Public Register (www.cpbao.ca), may be of assistance in your search for supervisors. The Ontario Psychological Association () provides a listing of its members who may be available to provide supervision.

The application fee may be paid by credit card on the online application site.

In order to be issued with a certificate of registration by the College, an applicant must be authorized to work in Canada. Under O.Reg.193/23 of the , an applicant must be either a Canadian citizen, a permanent resident, or authorized to practice in the profession under the Immigration and Refugee Protection Act (Canada). Applicants who are not citizens or permanent residents of Canada but who hold a valid work permit may also meet this requirement.

This requirement applies to all classes of registration, and also applies to applicants whose sole intention is to provide telehealth services.

For more information about Canadian work permits, including how to apply, visit

The requirements and process to obtain a work permit in Canada are separate from the College’s own requirements.

You may receive a copy of all information and each document that the College has that is relevant to your application.听 Please note that the College does not return original documents however, you may ask for a copy of the documents in your registration file.

To obtain a copy of your registration file you must makea written request to the College either in-person, by mail, or by e-mail. There is a charge of 20垄 per page for this. Upon receiving the written request, registration staff will determine the number of pages in the record and advise you of the cost before proceeding.

No, applicants and registrants are not required to reside in Ontario. However, Section 3.3. of the Registration Regulation, specifies that, in order to be issued with a certificate of registration the applicant must be a Canadian citizen, a permanent resident of Canada or authorized under the Immigration and Refugee Protection Act (Canada) to engage in the practice of the profession. Applicants who are not citizens or permanent residents of Canada may meet the requirement by holding a valid work permit, for example. For information respecting authorization to work in Canada go to听.

As noted in the Registration Guidelines: Supervised Practice Psychological Associate:

鈥淓ligibility Review

Applicants who have completed their education but have not yet secured employment and supervisors in Ontario, or have not yet completed their 4 years of supervised post-master鈥檚 work experience, may opt for an eligibility review. During this review, the College will review the applicant鈥檚 academic credentials. Many candidates choose to submit an application before they鈥檝e secured employment and supervision because, it offers them the opportunity to write the Jurisprudence and Ethics Examination (JEE), and Examination for Professional Practice in Psychology (EPPP) once they鈥檝e been deemed eligible by the College. Through this application review, it can also be determined whether an applicant may need to undertake any additional听training as part of their registration process.鈥�

You can apply for an eligibility review now by starting an application at . At this time, you will not be able to complete the section of the application form titled 鈥淎uthorized Supervised Practice鈥� and the Primary and Alternate Supervisors鈥� Agreement Forms.听 Only your academic credentials will be reviewed until you have completed the required post-master鈥檚 work experience.

Activities that could be included towards the supervised post-master鈥檚 work experience requirement include supervised provision of psychological services in the activities of assessment/evaluation, intervention/consultation, research, teaching, report writing/report preparation, and supervision.

To include families on your Declaration of Competence, you must be engaged in family assessment and family intervention during your supervised practice period. In such cases, the family would be the primary client.听 If however, you will not be providing direct services to families, but instead will see parents or families in the context of your work with the children or adolescents within the family, then it is not appropriate to indicate families on your Declaration of Competence. The College recognizes that working with children and adolescents as declared client groups often involves meetings with parents or families.听 It is important to distinguish between families as a specific client group with whom one works, and family involvement in the context of working with the children or adolescents in the family.

The Registration Committee is a statutory committee under the Health Professions Procedural Code. In accordance with the By-laws, the Registration Committee is composed of at least three members of the Council who are members of the College, at least two public members of the Council, and at least two members of the College who are not members of the Council.

Under the Code, if an applicant meets the qualifications and requirements, the Registrar may issue a certificate of registration. However, if the applicant does not meet the qualifications and requirements, the Registrar refers the application to the Registration Committee for a determination. It is then the duty of a panel of the Registration Committee to determine the eligibility of the applicant for a certificate of registration. In addition, applicants may be referred to the Registration Committee for advice and recommendations as to how they can bring themselves to meet the registration requirements and to acquire and demonstrate the knowledge and skills required for their declared area of competence.

The Committee is divided into two panels. One Co-Chair of the Committee serves on each of the panels.听 The Registration Committee meets approximately every other month. For the convenience of applicants wishing to submit information to the Committee, meeting dates are posted on the College’s website. Submissions must be received 10 days in advance of a meeting.

Should you have any questions or concerns about a Registration Committee decision, you may contact the College directly to speak with a Registration Assistant, or you may e-mail the College at registration@cpbao.ca

If you disagree with a decision of the Registration Committee you have the right to appeal the decision to the Health Professions Appeal and Review Board (HPARB).

You must write directly to HPARB within 30 days of receiving the Registration Committee鈥檚 decision letter.

HPARB may be contacted at the address below:

Health Professions Appeal and Review Board
151 Bloor Street West, 9th Floor
Toronto, ON, M5S 1S4

Telephone: 416-327-8512
Toll Free: 1-866-282-2179
TTY/TDD: 416-326-7TTY or 416-326-7889 1-877-301-0TTY or 1-877-301-0889
Fax: 416-327-8524
E-mail:听hparb@ontario.ca
Website:听

Yes, you can begin the application process before arriving in Canada. The Registration Guidelines outline the steps in the registration process that may be completed before moving to Canada

Registration Guidelines: Registration Process – Psychologist

Registration Guidelines: Registration Process – Psychological Associate

If your degrees are from a university outside of Canada or the United States they must be evaluated to determine if they are comparable in level to a degree from a Canadian university. This evaluation may be arranged through either World Education Services (WES)听 or Comparative Education Service (CES) .

This evaluation must demonstrate that your highest degree in psychology is at either the masters or doctoral level. While the statement from WES or CES will indicate to the College whether the academic credentials are comparable in level to either a master鈥檚 or doctoral degree granted by a Canadian university, the College reserves the right to make a final determination of the level and will evaluate, in accordance with the guidelines to determine, whether the content of the degree(s) is primarily psychological in nature.

Educated Outside of Canada/USA / Evaluation of Academic Credentials

If your transcript and official university documents are in a language other than English or French, you must arrange to have these documents translated by an official translator. Applicants are responsible for any fees associated with the translation of their documents.

If a university outside Canada or the U.S. is unable to send a transcript directly to the College, the College may accept a certified copy of the transcript the university issued to the applicant.

No. You may submit an application for supervised practice along with all the supporting documentation, including the application fee, with the exception of the section of the application form titled 鈥淎uthorized Supervised Practice鈥� and the primary and alternate supervisors鈥� agreement forms.听 Your academic credentials will be reviewed but further consideration of your application will be deferred until you have found suitable employment and supervisors.

In the meantime, if your credentials are approved, you can take the Examination for Professional Practice in Psychology (EPPP) and the Jurisprudence and Ethics Examination (JEE).

No. It is acceptable for post-master鈥檚 work experience to be completed outside of Ontario or Canada.

The steps in the registration process are outlined in detail in the Registration Guidelines, however, a flowchart illustrating the steps in the registration process for applicants whose degrees are from outside of Canada and USA is also available in the 鈥淎pplicants鈥� section of the College鈥檚 website. There is a flow chart for Psychological Associate applicants and a flow chart for Psychologist applicants. You can find the flowcharts here:

Psychological Associate Registration Flowchart

Psychologist Registration Flowchart

You are responsible for finding a suitable job as well as your Primary and Alternate Supervisors.听 Generally, once you find a job, your employer will have a member(s) of the College on site or who consults to the organization who can supervise your work. The College鈥檚 online Public Register (www.cpbao.ca), may be of assistance in your search for supervisors. The Ontario Psychological Association () provides a listing of its members who may be available to provide supervision.

In order to be issued with a certificate of registration by the College, an applicant must be authorized to work in Canada. Under O.Reg.193/23 of the , an applicant must be either a Canadian citizen, a permanent resident, or authorized to practice in the profession under the Immigration and Refugee Protection Act (Canada). Applicants who are not citizens or permanent residents of Canada but who hold a valid work permit may also meet this requirement.

This requirement applies to all classes of registration, and also applies to applicants whose sole intention is to provide telehealth services.

For more information about Canadian work permits, including how to apply, visit

The requirements and process to obtain a work permit in Canada are separate from the College’s own requirements.

You may receive a copy of all information and each document that the College has that is relevant to your application.听 Please note that the College does not return original documents however, you may ask for a copy of the documents in your registration file.

To obtain a copy of your registration file you must makea written request to the College either in-person, by mail, or by e-mail. There is a charge of 20垄 per page for this. Upon receiving the written request, registration staff will determine the number of pages in the record and advise you of the cost before proceeding.

As noted in the Registration Guidelines: Supervised Practice Psychological Associate:

鈥淓ligibility Review

Applicants who have completed their education but have not yet secured employment and supervisors in Ontario, or have not yet completed their 4 years of supervised post-master鈥檚 work experience, may opt for an eligibility review. During this review, the College will review the applicant鈥檚 academic credentials. Many candidates choose to submit an application before they鈥檝e secured employment and supervision because, it offers them the opportunity to write the Jurisprudence and Ethics Examination (JEE), and Examination for Professional Practice in Psychology (EPPP) once they鈥檝e been deemed eligible by the College. Through this application review, it can also be determined whether an applicant may need to undertake any additional听training as part of their registration process.鈥�

You can apply for an eligibility review now by starting an application at . At this time, you will not be able to complete the section of the application form titled 鈥淎uthorized Supervised Practice鈥� and the Primary and Alternate Supervisors鈥� Agreement Forms.听 Only your academic credentials will be reviewed until you have completed the required post-master鈥檚 work experience.

Once your application for registration has been approved by the College, you will be provided with details on how to register to take the EPPP and the JEE. While you do not need to hold a certificate authorizing supervised practice in order to be eligible to take these examinations; your application for registration must have been approved by the College.

The EPPP is a computer based multiple choice examination and is available throughout the year at various designated computer testing centres throughout Canada and the United States.

The JEE is a multiple-choice examination offered on-line two times per year 鈥� each Spring and each Fall. Upcoming JEE dates are posted on the College鈥檚 website here.听

Supervised practice members must, in order to remain in good standing, take the EPPP and the JEE within one year of issuance of the certificate for supervised practice.

You may take the EPPP and the JEE in any order that you prefer.

The oral examination is the last step in the registration process. To be invited to attend an oral examination, you must have passed the EPPP and JEE and fulfilled all other requirements, including the period of authorized supervised practice.

No. College staff are not permitted to convey exam results over the telephone or fax. Exam results are sent to candidates via email. If you are concerned because you have not yet received your exam results, please contact the College to enquire.

Once your application for registration has been approved by the College, you will be provided with details on how to register to take the EPPP and the JEE.

The College does not recommend any particular method of preparation for the EPPP. Some candidates find materials published by commercial examination study companies to be helpful, but these commercial study materials are not endorsed by the College. Information on how to prepare for the EPPP, including a computer based practice exam, can be found on the website of the Association of State and Provincial Psychology Boards (ASPPB) at听.

Applicants who took the EPPP as part of the registration/licensure requirements in another jurisdiction, and who received a scaled score of at least 500 or a percentage score of at least 70% are not required to re-take this examination.

Please arrange to have your EPPP results forwarded directly to the 91视频 by contacting the Association of State and Provincial Psychology Boards (ASPPB) at the following link:听

The College recommends that candidates review the preparatory information outlined in the document titled听Preparing to take the Jurisprudence and Ethics Examination.

As well as the list of relevant Legislation and Standards

Additionally, detailed information about the JEE including (but not limited to) an听Examination Blueprint听of the content of the examination, pass point and scoring, number of attempts permitted, and exam accommodations is outlined in the听Examinations section of the Registration Guidelines: Supervised Practice:

Psychologists’听 Exams

Psychological Associates’ Exams

The听Supervision Resource Manual also includes some information on how candidates can prepare to take the JEE.

You can expect to receive your JEE score via email approximately 6 weeks after taking the examination.

College staff are not permitted to convey exam results over the telephone, or fax.

The College does not provide feedback regarding a candidate鈥檚 performance within specific areas of the blueprint of the JEE or make recommendations for remediation.听 Only the total score that the candidate achieved is provided, along with the cut-score, mean, and standard deviation.

The JEE is a professional licensing exam. Professional licensing exams are used to evaluate knowledge, skills, and abilities (i.e. competence) required to practise a profession at an entry-level, in the interest of the protection of the public. These types of examinations are not designed or intended to provide feedback to candidates. In this case, the JEE is used to evaluate knowledge of jurisprudence, ethics, and standards related to the practice of psychology in Ontario.

The reliability of the results of any exam is strongly related to the number of items (questions) on the exam. Similarly, the reliability of any information provided to candidates related to scales within the exam is related to the number of items within that scale. Given the JEE Examination Blueprint (as outlined in the Registration Guidelines), some categories may have as few as four to seven items. When there is a small number of items in a scale the reliability and also validity of any report based on these scales would be questionable as feedback to the candidate.

The听Registration Guidelines: Supervised Practice (psychologist)听and听听Registration Guidelines: Supervised Practice (psychological associate), describe the oral examination, and the听Supervision Resource Manual听provides information on how candidates should prepare for the oral examination.

Candidates who have special requirements arising from documented impairments or disabilities may request accommodations in taking any of the College鈥檚 required examinations.

The College鈥檚听Examination Accommodation Policy听is found in the Registration Guidelines, and the forms required for requesting an accommodation are found in the application for registration.

If you have a question about requesting an examination accommodation you may contact听exams@cpbao.ca for assistance.

The forms required for requesting an examination accommodation are found in either the application for supervised practice or the application for interim autonomous practice. How to Apply

If you have a question about completing the examination accommodation forms you may contact听exams@cpbao.ca听for assistance.

You may submit your request for an examination accommodation at the same time that you apply for registration with the College or you may submit your request later if necessary.

In all cases, the College鈥檚 examination accommodation request form, and documentation, either from your regulated health care professional or the university from which you graduated, must be submitted to the College听at least 60 calendar days听in advance of an examination administration in order to allow sufficient time for your request to be reviewed and for accommodations to be arranged.

Exam candidates requesting accommodation will be advised of the College鈥檚 decision within ten (10) business days of the submission date, unless more information is needed to effectively evaluate the accommodation request.

A candidate who has applied and has been granted examination accommodation for a permanent or long-term disability will not be required to re-apply for accommodation for subsequent attempts but must confirm to the College that accommodations are still required.

If the request was related to a temporary condition (e.g. recent injury or pregnancy-related conditions) or if five years have passed since the initial accommodation request, the College may request updated information confirming the continued need for accommodation.

When re-applying to take the JEE, the College鈥檚 JEE Registration Form will require you to indicate whether you need accommodations, and if so to indicate whether you have already submitted the necessary accommodation request form.

When re-applying to take the EPPP, the ASPPB鈥檚 candidate request form will require you to indicate whether you need accommodations.

If the accommodation that you require has changed in any way from what was previously granted, you may be required to re-apply. Please contact听exams@cpbao.ca听for assistance.

The Supervisor’s Agreement and Confirmation of Private Practice Arrangements Form required for all Entry Level Route (Supervised Practice) Behaviour Analyst applicants can be found in the Reference Library under “Become a Member”. Applicants may upload the completed form to their application.

The major milestones between the two registration routes are otherwise largely the same: graduate-level education (master’s or higher), at least 1500 supervised hours, an entry-to-practice examination, and completion of the College’s Jurisprudence and Ethics Course and Assessment in Applied Behaviour Analysis (JECAABA). The main factor is timing. For this reason, Transitional Route 1 will be the fastest registration route for many applicants, primarily because the required supervised fieldwork can be accrued as soon as the graduate coursework begins. In contrast, Entry Level Route applicants must wait until they have submitted a complete application to the College before they can begin accruing supervised practice hours. However, it is important to understand that Transitional Route 1 will close at 11:59pm on June 30, 2026. After this deadline, only the Entry Level Route and a new Labour Mobility Route will be available. Please note that the Labour Mobility Route is intended for Behaviour Analysts who are registered/licensed or certified for autonomous practice outside of Ontario. To assist you in making your decision, the Regulation Resource Task Force of the Ontario Association for Behaviour Analysis (ONTABA) has published several resources , including a BCBA and 91视频 Comparison Chart and Student FAQ.

The temporary Transitional Routes 1 and 2 will close at 11:59 p.m. on June 30, 2026.

At a minimum, you must meet all criteria and submit an application form and pay the application fee by the deadline to qualify for registration via one of the transitional routes. Specifically, applicants must receive BCBA certification for Transitional Route 1, or meet the practice currency and knowledge requirements for Transitional Route 2 by the deadline.

Supporting documentation will continue to be accepted after the deadline, e.g. BACB verification letter, transcript(s), and Vulnerable Sector Checks. However, if a complete application (i.e. application form, fee, and all supporting documentation) is not received within 2 years of submission of the application form, it will expire. For this reason, the College encourages applicants to submit the application form and fee, and order supporting documentation at the earliest opportunity.

After June 30, 2026, eligible applicants will still be able to complete the College鈥檚 Jurisprudence and Ethics Course and Assessment in Applied Behaviour Analysis (JECAABA) under both transitional routes. Those applying through Transitional Route 2 may also write the Ontario Examination for Professional Practice in Applied Behaviour Analysis (OEPPABA).

Applicants who are in the process of receiving their BCBA or BCBA-D certification with the Behavior Analyst Certification Board are encouraged to complete the requirements for their certification and apply to the College under Transitional Route #1. The transitional routes will close at 11:59pm on June 30, 2026. At a minimum, an application form and application fee must be submitted by this deadline. Supporting documents will continue to be accepted after the deadline. However, incomplete applications expire 2 years after submission of the application form.

The College will accept electronic versions of supporting documents sent directly to the College by the issuing authority. Applicants can request e-versions of their supporting documents to be sent directly to the College via email to cpbao@cpbao.ca.

If e-mail is not possible, please have the organization mail the document to:

The 91视频

110 Eglinton Ave West, Suite 500

Toronto, ON

M4R 1A3

It is an individual鈥檚 decision if they will maintain their BCBA certification. Only individuals who are registered with the College as Behaviour Analysts will be able to use their BCBA credential in Ontario. A BACB certification is necessary for registration in most of the States where ABA is regulated; therefore, maintaining certification provides mobility options to the US.

The BACB recently that effective July 1, 2026, 鈥淥ntario residents will no longer be able to apply for BCBA certification or take the examination鈥�. Existing BCBA and BCBA-D certified individuals will be able to maintain their certification after July 1, 2026.

Behaviour Analyst Transitional Route 2 applicants can download the Attestation A/B, Attestation C, and Peer Assessment Forms from the “Download Documents” section in the application portal or from the “Become a Member” section of the Reference Library.

Yes, the Peer Assessment may be conducted in-person or virtually. Any confidential documentation must be shared via a secure platform, and either anonymized or with the consent of the client.

Yes, provided that you submit an application form and fee by 11:59pm on June 30, 2026, the deadline for the closure of the transitional routes. Once a complete application (i.e. application form, fee, and all supporting documentation) has been received and approved, you will be given access to the Jurisprudence and Ethics Course and Assessment in Applied Behaviour Analysis (JECAABA) (Transitional Routes 1 & 2), and the Ontario Examination for Professional Practice in Applied Behaviour Analysis (OEPPABA) (Transitional Route 2 only). Applicants who do not submit an application form and fee by the deadline will not qualify for registration via a transitional route, and therefore, must apply via the Entry Level Route.

In order to be issued with a certificate of registration by the College, an applicant must be authorized to work in Canada. Under O.Reg.193/23 of the , an applicant must be either a Canadian citizen, a permanent resident, or authorized to practice in the profession under the Immigration and Refugee Protection Act (Canada). Applicants who are not citizens or permanent residents of Canada but who hold a valid work permit may also meet this requirement.

This requirement applies to all classes of registration, and also applies to applicants whose sole intention is to provide telehealth services.

For more information about Canadian work permits, including how to apply, visit

The requirements and process to obtain a work permit in Canada are separate from the College’s own requirements.

Registration for the Entry Level Route (Supervised Practice) for Behaviour Analyst applicants opened on November 14, 2024.

Prospective applicants are encouraged to:

1. Carefully review the听Registration Guidelines听for this route.
2. Begin ordering the necessary supporting documentation for their application, including:
   • Vulnerable Sector Check (please visit the听Vulnerable Sector Screening Policy听for more information)
   • Official Academic Transcript(s)
   • Confirmation of registration from other regulatory authorities (if applicable)

We look forward to welcoming new registrants to the College for Supervised Practice. For further inquiries not addressed by the Registration Guidelines or the College鈥檚听FAQs page, please email us at听aba@cpbao.ca.

Only Behaviour Analysts who hold a Certificate of Registration Authorizing Autonomous Practice with the College can provide clinical supervision to Behaviour Analysts in Supervised Practice.

No, applicants and registrants are not required to reside in Ontario. However, Section 3.3. of the Registration Regulation, specifies that, in order to be issued with a certificate of registration the applicant must be a Canadian citizen, a permanent resident of Canada or authorized under the Immigration and Refugee Protection Act (Canada) to engage in the practice of the profession. Applicants who are not citizens or permanent residents of Canada may meet the requirement by holding a valid work permit, for example. For information respecting authorization to work in Canada go to听.

The College will not give credit for supervised fieldwork hours completed prior to the commencement of your supervised practice period. The College will approve the start date for supervised practice based upon the date that your supervisor confirms that their supervision of your work began,

or

the date that the last supporting document for your application was received, whichever date is听later.

Psychological associates/psychologists can only provide services within their competence (i.e. knowledge, skill, and clinical judgement). ABA services can fall within the scope of practice of psychological associates and psychologists and can be considered a 鈥減sychological intervention鈥� given the overlap in behavioural competencies. Although there is considerable overlap between the scope of practice of ABA and psychology, these are distinct professions. Psychological associates and psychologists must identify themselves to the public by their psychology title and cannot use the title 鈥淏ehaviour Analyst鈥� unless dually registered.

Please refer to the chart below for more information.

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[1] Supervised practice is the formal period of training required by the College in order to become an autonomous registrant.[2] Psychologists and psychological associates may supervise Behaviour Analysts in supervised practice, but cannot serve as their primary supervisor; this must be a Behaviour Analyst[3] Autonomous psychology members may seek out supervision to expand their practice in particular psychological interventions, including ABA services.[4] Autonomous Behaviour Analysts may seek out supervision from psychology or ABA members, such as when serving new populations and/or in specific ABA techniques.

Supervision is defined as:

鈥�an ongoing educational, evaluative and hierarchical relationship, where the supervisee is required to comply with the direction of the supervisor, and the supervisor is responsible for the actions of the supervisee.

Supervision in ABA is a regulated professional service. The ABA supervisor is in a hierarchical relationship with their supervisees, whereby the supervisees must comply with the supervisor鈥檚 direction.

Models of care in ABA can sometimes include multiple teammates working together to serve a client鈥檚 needs.

The College does not permit 鈥渟econd-order鈥� supervision. This means that, while a Behaviour Analyst鈥檚 supervisees may have varying roles and responsibilities as among themselves, including some oversight or supervisory roles, the Behaviour Analyst is directly responsible for all supervisees.

It may be helpful to think of the Behaviour Analyst as the one responsible for all services provided to the client. There may be multiple individuals involved in providing those services, who may have varying roles and responsibilities. The Behaviour Analyst is responsible for all the individuals involved in the provision of services to clients. The illustration above is meant to assist in emphasizing the Behaviour Analyst鈥檚 supervisory responsibilities across different models of care.

Under the Regulated Health Professions Act (RHPA), the use of the title 鈥淒octor鈥� is restricted in Ontario. With the exception of chiropractors, optometrists, physicians, psychologists, and dentists, 鈥渘o person shall use the title 鈥渄octor鈥�, a variation or abbreviation or an equivalent in another language in the course of providing or offering to provide, in Ontario, health care to individuals鈥� (33 (1), RHPA).

Registered Behaviour Analysts will not be allowed to use the title 鈥渄octor鈥�, a variation, or abbreviation, while providing or offering to provide services in applied behaviour analysis.

No. The hallmark of self-regulation is a professional鈥檚 ability to independently reflect and make ethical decisions in the best interest of their clients. This self-awareness is relevant to practicing within one鈥檚 competence, which requires knowledge, skill, and clinical judgment. Registration as a Behaviour Analyst does not imply that one can practice with any client, in any situation, and for any purpose within the scope of applied behaviour analysis. One must know what they know, but as importantly, they must know that they don鈥檛 know everything. Awareness of limits of professional competence and taking disciplined steps to practice safely is required of all registrants of the College as indicated by the听Standard of Professional Conduct (2024)听which states:

5.1.1. Behaviour Analysts

Although Behaviour Analysts are not subject to limitations related to authorized areas of practice or client groups, Psychologists and Psychological Associates have limitations on their certificates of registration that prohibit them from practicing outside of their particular authorized areas of practice and client groups. Registration as a Behaviour Analyst does not, however, imply that one can practice with any client, in any situation, and for any purpose within the scope of applied behaviour analysis. Practitioners must remain aware of practicing within the bounds of their own scopes of competence.

For more information, visit the Applied Behaviour Analysis (ABA) Portal on the College鈥檚 website, watch the College鈥檚 video information session on the regulation of ABA, review the FAQs page for answers to frequently asked questions, or contact the College at aba@cpbao.ca.

You may also find it useful to review the resources published by the Regulation Resource Task Force of the Ontario Association for Behaviour Analysis (ONTABA) .

Applicants applying for registration as a Behaviour Analyst will be required to obtain a Vulnerable Sector Check. Applicants living in regions that do not issue Vulnerable Sector Checks for registration purposes will be asked to provide a Level 2 Criminal Record and Judicial Matters Check. These applicants will also be required to sign an Undertaking and Agreement with the College.

A Vulnerable Sector Check is the standard police screening for individuals who work with vulnerable persons. A Vulnerable Sector Check collects information on offences, including convictions, outstanding warrants, judicial orders, charges, and record suspensions (pardons) for sexual offences.

All applicants for registration as a Behaviour Analyst are required to provide the results of a Vulnerable Sector Check as part of their application. The practice of applied behaviour analysis is used widely to treat autism and other developmental disabilities, and Behaviour Analysts work closely with and have authority over children and other vulnerable persons in their care. A Vulnerable Sector Check provides an added level of public protection by obtaining information from an outside entity about an applicant鈥檚 good character.

All applicants must upload the original Vulnerable Sector Check results to the College through the application portal. Applicants should keep a scanned copy for their records. If the Vulnerable Sector Check is password-protected, please email the password to cpbao@cpbao.ca. If your original results were issued as a paper hard copy from the police, please submit them to the College in an enclosed letter:

The 91视频
110 Eglinton Ave West, Suite 500
Toronto, ON, M4R 1A3

For more information, click here.

The College will only accept Vulnerable Sector Checks that were issued within 6 months from the date the College receives it.

To obtain a Vulnerable Sector Check, please contact your local police service for more information. You will be responsible for obtaining the correct type of check and ensuring all related fees are paid.听Each police service has different processing times, and it may take time to receive the results of a Vulnerable Sector Check. It is recommended to allow yourself enough time to apply for the Vulnerable Sector Check ahead of your registration date, but no more than 6 months before.

All applicants must upload the original results of the Vulnerable Sector Check to the College through the application portal. Applicants should keep a scanned copy for their records. If the Vulnerable Sector Check is password protected, please email the password to cpbao@cpbao.ca. If your original results were issued as a paper hard copy from the police, please submit them to the College in an enclosed letter:

The 91视频

110 Eglinton Ave West, Suite 500

Toronto, ON, M4R 1A3

If you currently reside outside of Canada and are unable to obtain a Vulnerable Sector Check, please contact the College at aba@cpbao.ca.

Complaints and reports are different ways of letting the College know about your concerns. There are several key differences between a complaint and a report:

Anyone who has a concern about a psychologist, psychological associate, or behaviour analyst can file a complaint or submit a report. This includes a client, a family member, or friend of the client, an employer, an insurer, a colleague, or a general member of the public.

Clients do not have to make a complaint or report. However, some people, in some situations, do have to make a Mandatory Report. For more information, please听click here.

You do not have to be involved in the College鈥檚 investigation. The College will still conduct a full investigation of your complaint and give you a copy of the decision.

Yes. Please see additional information about the College鈥檚 facilitated resolution process.

The College has a strict duty of confidentiality. It will not share your information with anyone outside of the ICRC investigation. However, on some occasions, the information may become public:

Referral to the Discipline Committee: Discipline hearings are public. However, the Discipline Committee can ban the publication of information that could identify you.

HPARB review: The College must give its investigation record to HPARB. HPARB also holds public hearings. HPARB is independent of the College and has its own processes. You may contact听听 directly should you have any questions.

Complainants may find it helpful to have a lawyer, but it is not necessary. Most complainants proceed without a lawyer.

Members often do use lawyers when responding to complaints or reports. This is because the process may have a significant impact on the member鈥檚 practice and career.

The role of the College is to protect the public from harm. The College does so by setting and upholding听听and听Standards for its members. These rules and Standards address many different concerns, including:

• Boundaries and sexual abuse;
• Appropriateness of services;
• Supervision;
• Fees and billing;
• Confidentiality and disclosure of information.

The College鈥檚 standards and rules cover most of the concerns brought to the College鈥檚 attention. Please contact the听College if you are not sure whether your concerns are covered.听

No. The College cannot get involved in fee arrangements or make financial awards.

No. The College only has jurisdiction over individual members.

Yes. The College will investigate if you have concerns about services provided under the supervision of a psychologist, psychological associate, or behaviour analyst registered with the College. Psychological and behaviour analytic services provided under supervision are the supervising member鈥檚 responsibility. However, the investigation will focus on the College member, and not on the supervisee.

The College also investigates misuse of the titles 鈥淒octor,鈥� 鈥減sychologist鈥�, 鈥減sychological associate鈥�, and 鈥渂ehaviour analyst鈥�. The College also investigates non-registrants who imply that they can provide psychological services.

The College will try to direct you to another body that may be able to address your concerns.

No, the College cannot process anonymous complaints. The College shares your name and concerns with the member as part of its investigation.

If you want to provide information to the College without filing a complaint, you can make an anonymous report. However, depending on the information you provide, the College may be limited in its ability to investigate.

Please see the FAQ about the difference between complaints and reports.

No, there is no time limit for filing a complaint. However, the College recommends that you raise your concerns as soon as possible. The earlier a complaint or report is received, the fewer problems may arise with the investigation. For example, it is more likely that relevant documents will still exist and witnesses can be located.

Mandatory reports have specific timelines attached. Please see the FAQs about mandatory reports.

You can submit a听听or听听to the College through electronic forms. You may also submit a complaint or report in writing or other recorded format, including film and audio. These can be sent directly to the College by听email, fax, or regular mail.

You should provide as many details about your concerns as possible. Supporting documents such as emails, reports or bills are also helpful. You may also provide the names of relevant witnesses.

You may search for a member on the College鈥檚听. Please contact the College staff if you have trouble identifying the member.

You can request to withdraw your complaint. The Registrar or the ICRC will review your complaint and request. If your concerns are serious, the Registrar or ICRC may still decide to continue with the investigation.

The College must investigate every complaint, with limited exceptions. The College will not investigate a complaint that is 鈥�.鈥�

This can happen when the complaint is about something that happened before the professional was a member of the College. Another example is where the conduct is private and does not relate to the member鈥檚 professional practice.

The College will notify you and the member if it decides not to investigate. You will have a chance to respond to that decision before it becomes final. Once it is final you may ask that HPARB review that decision.

Your complaint will be assigned to a Case Manager, who will manage the complaint file. The Case Manager will be your contact person at the College and is available to answer your questions.

The College will send your complaint to the member. The member will have a chance to review the complaint and respond. In most cases, the College will request that the member provide the clinical record. At the same time, the College will acknowledge your complaint in writing.

The Case Manager will also conduct further investigation. This can include interviewing witnesses and getting other documents.

When the investigation is complete, the complaint file will go to a panel of the ICRC.

Let the case manager know which information you want to access. The College may be able to get that information by way of summons.

The legislation requires the College to complete investigations within 150 days. However, this is not always possible. The legislation also allows the College to extend this timeline, with notification to the complainant and member.

The听Inquiries, Complaints and Reports Committee, or ICRC, is responsible for decisions about complaints.

A panel of the ICRC will review your complaint and make a decision about how to proceed. Every panel includes one public and two professional members of the Committee.

The ICRC is a screening committee. It cannot make findings of fact or credibility. The role of the ICRC is to decide how to best protect the public from possible harm.

For every complaint, the ICRC considers the possible risks of the member鈥檚 conduct to the public. The ICRC considers both impact and recurrence risks. If the risks are low, the ICRC may decide not to take any action. If the risks are moderate or high, the ICRC is likely to take some kind of action.

The ICRC has developed a table to help with its consideration of risks. This table is available听here.

The ICRC meets in person every month from September to May. The ICRC attempts to meet twice over the summer months.

The ICRC also meets by teleconference throughout the year.

The College will send you a formal acknowledgment of your complaint within 14 days of receiving your complaint.

The Case Manager assigned to your complaint will be in touch with you directly if they need additional information.

If the College is unable to meet the 150-day timeline, the College will let you know. The College will then set new timelines.

The College will send you a copy of the ICRC鈥檚 decision once it is finalized.

A panel of the ICRC might not come to a final decision when they consider a complaint. The panel may have some questions for one of the parties or may want more information. They will then need to meet again to reach a decision.

The panel also needs some time to write the decision. College staff is not able to communicate any information about an unfinished decision.

No. The ICRC does not meet with either the complainant or the member. The ICRC reviews information contained in paper or electronic records.

No. Only the Discipline Committee can make a finding of professional misconduct after a hearing.

The ICRC can decide whether to refer allegations to the Discipline Committee. If it does not make a referral, the ICRC can still express concern about conduct and take some action.

The action the ICRC takes will depend on the risks associated with the member鈥檚 conduct. Please see more information about the ICRC Risk Assessment Framework.

The ICRC may take a range of actions after an investigation:

• No further action: A panel may take no further action if it believes there is no risk to the public.
• Advice: A panel may give advice if it identifies low risks. Advice is meant to help the member avoid future risks.
• Undertakings:听A panel may ask for an undertaking from the member if it identifies moderate risks. An undertaking is remedial and is agreed to by the member. An undertaking can range from a minor change in practice to limitations on the member鈥檚 certificate of registration.
• Caution: A panel may caution a member if it identifies moderate risks. The member must come to the College to receive the caution in person. Cautions are remedial and may include a discussion between the panel and the member. Cautions are not open to the public.
• Specified Continuing Education or Remediation Program (SCERP):听A panel can order a SCERP if it identifies moderate risks. A SCERP is remedial and can include a specific course of study.
• Referral to the Discipline Committee:听If the ICRC identifies high risks, it will refer the matter to the Discipline Committee for a full hearing.
• Referral to a Health Inquiry or Fitness to Practice Committee:听Sometimes the ICRC identifies health issues that could affect the member鈥檚 ability to practice. In these cases, the panel will refer the matter to a Health Inquiry panel of the ICRC. A Health Inquiry panel can order treatment and monitoring.听 If treatment and monitoring are not enough to ensure safe practice, the ICRC may refer the matter to the Fitness to Practice Committee.

In the last 5 years (January 2015 to March 2020), ICRC outcomes in relation to 416 cases were as follows:

*The Percentages add up to more than 100% due to multiple outcomes in some cases, i.e. caution and undertaking. The 437 outcomes here relate to 41 cases.

鈥犔�Frivolous, vexations, made in bad faith, moot, or an abuse of process. See the FAQs above.
鈥√�As of September 8, 2017, the ICRC no longer issues written cautions.

The College is required to post specific information on the Public Register. The College will not post any information that could identify the complainant or client. Information posted on the Public Register includes:

• A notation and synopsis of any undertaking, while it is in effect;
• A notation of any caution;
• A notation of any Specified Continuing Education or Remediation Program (SCERP);
• A notation of every matter referred to the Discipline Committee;
• The specific allegations referred to the Discipline Committee;
• The result of every Discipline proceeding;
• The result of every Fitness to Practice proceeding;
• Information about a member鈥檚 criminal charges or convictions; and
• Information about any interim order that may be in effect.

In most cases, you and the member can ask that the Health Professions Appeal and Review Board (HPARB) review the ICRC鈥檚 decision. HPARB cannot review referrals to the Discipline or Fitness to Practice Committees. There are not final decisions but rather involve other College processes.

In a review, HPARB will consider whether the College鈥檚 investigation was adequate. It will also consider whether the decision was reasonable. The College sends instructions on how to ask for a review with your copy of the ICRC decision.

No. Section 36(3) of the听Regulated Health Professions Act, 1991听does not allow information from a College proceeding to be used in civil court.

The sets out mandatory reporting requirements for:

a) healthcare providers;
b) facility operators; and
c) employers.

a) Healthcare Providers

The Mandatory Reporting requirements for healthcare providers includes incidents or suspected cases of sexual abuse, child protection or abuse or neglect of elders.

Specifically, states:
(1) A member shall file a report in accordance with section 85.3 if the member has reasonable grounds, obtained in the course of practising the profession, to believe that,
(a) another member of the same or a different College has sexually abused a patient; or
(b) a registrant of the Health and Supportive Care Providers Oversight Authority has sexually abused a patient who receives health care or supportive care services from the registrant. 2021, c. 27, Sched. 2, s. 70 (2).

The , Section 125 sets out mandatory reporting requirements to a Children鈥檚 Aid Society when it is suspected that a child under the age of 16 years is in need of protection. Additionally, someone who is concerned that a 16-or 17-year-old may be in need of protection may, but is not required to make a report.

The has helpful resources, including the .

The 听Section 24 and the Section 75 set out mandatory reporting requirements if it suspected that there is abuse or neglect in a retirement or Long-Term Care facility. The , and the for more information.

The states that disclosure of personal health information may be required upon urgent demand.

b) Facility Operators

The Mandatory Reporting requirements for facility operators includes incident or suspected cases of sexual abuse, incompetence or incapacity. Specifically states:

Reporting by facilities
85.2 (1) A person who operates a facility where one or more members practise shall file a report in accordance with section 85.3 if the person has reasonable grounds to believe that a member who practises at the facility is incompetent, incapacitated, or has sexually abused a patient.

Additionally, the section 2(1) states: Every facility that treats a person for a gunshot wound shall disclose to the local police service or the local Ontario Provincial Police detachment the fact that a person is being treated for a gunshot wound, the person鈥檚 name, if known, and the name and location of the facility.

c) Employers

The Mandatory Reporting requirements for employers includes incidents of termination, revocation, suspension, imposition or dissolution of a partnership or association with a registrant for reasons of professional misconduct, incompetence or incapacity. Specifically the HPPC states:

Reporting by employers, etc.
85.5 (1) A person who terminates the employment or revokes, suspends or imposes restrictions on the privileges of a member or who dissolves a partnership, a health profession corporation or association with a member for reasons of professional misconduct, incompetence or incapacity shall file with the Registrar within thirty days after the termination, revocation, suspension, imposition or dissolution a written report setting out the reasons.

(2) Where a member resigns, or voluntarily relinquishes or restricts his or her privileges or practice, and the circumstances set out in paragraph 1 or 2 apply, a person referred to in subsection (3) shall act in accordance with those paragraphs:

1. Where a person referred to in subsection (3) has reasonable grounds to believe that the resignation, relinquishment or restriction, as the case may be, is related to the member鈥檚 professional misconduct, incompetence or incapacity, the person shall file with the Registrar within 30 days after the resignation, relinquishment or restriction a written report setting out the grounds upon which the person鈥檚 belief is based.

2. Where the resignation, relinquishment or restriction, as the case may be, takes place during the course of, or as a result of, an investigation conducted by or on behalf of a person referred to in subsection (3) into allegations related to professional misconduct, incompetence or incapacity on the part of the member, the person referred to in subsection (3) shall file with the Registrar within 30 days after the resignation, relinquishment or restriction a written report setting out the nature of the allegations being investigated. 2014, c. 14, Sched. 2, s. 12.

Talking with Clients about Mandatory Reporting of Sexual Abuse by Health Professionals

If you identify an immediate risk of harm, such as for child or elder abuse, you should file the report immediately.

The requirements for the timing of mandatory reporting is set out in . If there is no immediate risk, generally you must file a report within 30 days of becoming aware of the situation.

Section 85.3 (2) states:
Timing of report
(2) The report must be filed within 30 days after the obligation to report arises unless the person who is required to file the report has reasonable grounds to believe that the member will continue to sexually abuse the patient or will sexually abuse other patients, or that the incompetence or the incapacity of the member is likely to expose a patient to harm or injury and there is urgent need for intervention, in which case the report must be filed forthwith. 2007, c. 10, Sched. M, s. 62 (1).

85.5 (1) A person who terminates the employment or revokes, suspends or imposes restrictions on the privileges of a member or who dissolves a partnership, a health profession corporation or association with a member for reasons of professional misconduct, incompetence or incapacity shall file with the Registrar within thirty days after the termination, revocation, suspension, imposition or dissolution a written report setting out the reasons. 1993, c. 37, s. 23; 2000, c. 42, Sched., s. 36.

A report must be filed in writing. Please use the College鈥檚 form available on the College鈥檚 website. You may also write to the College directly through fax, mail or email.

You must report child abuse directly to a

Elder abuse must be reported to the Registrar of the .

Outside of the situations described above (sexual abuse, child abuse, elder abuse), there is no requirement to report concerns that a client may pose a danger to themselves or others. That said, there may be situations that would warrant a provider to disclose confidential information if an individual may be at risk.

The sets out a registrant鈥檚 obligations for maintaining the confidentiality and privacy of personal health information. The legislation provides an exception to the duty of confidentiality where a registrant finds it necessary to notify someone of a serious risk to a person鈥檚 safety. PHIPA does not oblige registrants to disclose confidential information, but it permits one to do so 鈥渇or the purpose of eliminating or reducing a significant risk of serious bodily harm鈥�. Therefore, PHIPA reinforces a registrant鈥檚 need to use their knowledge of the client/patient and their professional judgement to determine the best, most appropriate, action to take.

PHIPA states:
40 (1) A health information custodian may disclose personal health information about an individual if the custodian believes on reasonable grounds that the disclosure is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons. 2004, c. 3, Sched. A, s. 40 (1).

If you are a registrant considering whether to breach confidentiality, you should first determine if there is “significant risk of serious bodily harm to a person or group of persons”. You should also determine whether there is someone in a position to 鈥榚liminate or reduce a significant risk of serious bodily harm鈥�. Registrants may elect to discuss with the client whether someone such as a family member or the Police should be called. The College recommends seeking legal advice before breaching client confidentiality.

Reflection Questions:
鈥� What is the nature of the harm that may result, does it meet the threshold to be considered 鈥渟erious bodily harm鈥�?
鈥� Is the risk posed significant?
鈥� Is there a person or person(s) that may be able to reduce or eliminate the risk?
鈥� What is the basis for the risk determination, do I have 鈥渞easonable grounds鈥�?
鈥� Would disclosing confidential information have the potential to place the client at more a risk?
鈥� Has the appropriate risk assessment tool been used?
鈥� Have I consulted with the College and/or sought legal advice?

While providing psychotherapy or any professional service to another regulated health professional you may be required to make a mandatory report for incidents or suspected cases of sexual abuse in accordance with . Your report should also contain your opinion, if you are able to form one, as to whether this registrant is likely to sexually abuse patients in the future.

If you have competence or capacity-related concerns about a colleague or a client who is a regulated professional and there is a significant risk of serious bodily harm to a person or groups of persons, registrants have ethical obligations to breach confidentiality and make a report to the professional鈥檚 College as per

This expectation is also outlined for psychologists in which states:

II.43 Act to stop or offset the consequences of seriously harmful activities being carried out by another psychologist or member of another discipline, when there is objective information about the activities and the harm. This may include reporting to the appropriate regulatory body, authority, or committee for action, depending on the psychologist鈥檚 judgment about the person(s) or body(ies) best suited to stop or offset the harm, and would be consistent with the privacy and confidentiality rights and limitations of the individuals and groups involved. (See Standards I.45 and IV.17.)

and for Registered Behaviour Analysts in the , which states:

2.04 Disclosing Confidential Information Behavior analysts only share confidential information about clients, stakeholders, supervisees, trainees, or research participants: (1) when informed consent is obtained; (2) when attempting to protect the client or others from harm; (3) when attempting to resolve contractual issues; (4) when attempting to prevent a crime that is reasonably likely to cause physical, mental, or financial harm to another; or (5) when compelled to do so by law or court order. When behavior analysts are authorized to discuss confidential information with a third party, they only share information critical to the purpose of the communication.

All registrants are required to self-report certain information to the College as set out in sections 85.6.1 through 85.6.4 of the , being Schedule 2 to the Regulated Health Professions Act, 1991.

Registrants , as soon as reasonably practicable:

1. Finding of guilt or conviction for any offence (Section 85.6.1 of the Code and section 4(1) of O.Reg. 193/23)
2. Charge for an offence (Section 85.6.4 of the Code)
3. Finding of professional negligence or malpractice in relation to any profession (Section 85.6.2 of the Code and section 4(4) of O.Reg. 193/23)
4. Finding of professional misconduct or incompetence by another body that governs a profession inside or outside of Ontario (Section 85.6.3 of the Code and section 4(2) of O.Reg. 193/23)
5. Finding of incapacity in relation to any health profession (section 4(2) of O.Reg. 193/23)
6. A proceeding for professional misconduct, incompetency or incapacity in relation to any health profession (Section 4(3) of O.Reg. 193/23)
7. A proceeding in any jurisdiction in which the member is alleged to have committed professional negligence or malpractice that is in relation to the practice of a health profession (section 4(5) of O.Reg. 193/23)

Details of the above such as bail conditions or restrictions must also be reported through the online .

Registrants must also report in their annual renewal form if they are a member of any other body that governs a profession, in any jurisdiction, e.g., nursing, law, psychotherapy, etc.

The mandatory reporting form will prompt you for the information necessary with respect to each report. If you have any additional questions about your report, please contact the College at 416-961-8817/1-800-489-8388; or听invhear@cpbao.ca

Once you are notified of your selection by 91视频, you will submit preliminary information to assist in the appointment of a suitable Assessor, and advise us of your Peer Nominated Reviewer, should you wish to include one.

91视频 will notify you once your Assessor has been appointed so that coordination of the meeting date can begin.

To facilitate an efficient and effective review, Reviewees must be responsive to their Assessors requests to schedule a meeting date and share their review materials in advance. If the review will be conducted virtually, materials will need to be shared electronically through a secure platform.

When preparing for your review, you will need to provide your Assessor with:

• Practice Files: An anonymized file list and the files which are randomly selected by your Assessor from the list must be shared. Your Assessor will select at least 2 current practice files to review and discuss. Selected files may be anonymized, but must make clear that all required elements of the files, per the Standards, are included.
• QA Records from your current and last-completed QA cycles. Your assessor will review your most recently completed Self-Assessment Guide (SAG), as well as a Continuing Professional Development (CPD) tracking sheet, which shows your participation in activities during your current two-year cycle.
• Virtual Walkthrough听of your primary practice setting. If the review is conducted virtually, provide photos or video of your practice space to facilitate discussion about client accessibility, safety and privacy. If you are working in a non-private setting and are unable to provide a photo/video, you should be prepared to describe your setting.

All registrants with an Autonomous or Academic certificate of registration are eligible to be reviewed.

There are several ways you may be selected for a PAR. The QA Committee may select registrants via random or stratified random sampling using its own criteria. Additionally, registrants who fail to complete their Self-Assessment requirements and make their QA Declaration of Completion or have had concerns identified in a previous audit or assessment process, may be selected.

A fellow registrant who has been approved and trained will be appointed by 91视频 as an Assessor to conduct the review. Efforts will be made to match Assessors and Reviewees by area(s) of practice, client group(s), and practice setting(s), as appropriate.

The Reviewee will be permitted to indicate whether they believe that there is any reason a 91视频-appointed Assessor should not conduct their review.

Additionally, the Reviewee may choose to involve a Peer-Nominated Reviewer to support them in the review process. This individual must be another 91视频 registrant and may be a colleague or associate, but may not have a connection or relationship which poses a conflict of interest.

All Assessors and Peer Nominated Reviewers are required to sign an Undertaking and Attestation.

Most reviews occur virtually via secure videoconferencing from the Reviewee鈥檚 primary practice location. There may be situations where the review is required to take place in person.

Reviews are expected to be complete within 3-4 months of initiation.

Interviews typically take three to four hours, at a mutually convenient time determined by the Assessor, Reviewee and Peer Nominated Reviewer (if applicable).

The assessor and reviewer will together observe the member鈥檚 place of practice, interview the member using a structured interview form and review some of the member鈥檚 clinical records.

The Assessor will submit a report to the QA Committee and the Reviewee. The Reviewee may choose to make a written submission to the Committee within 14 days of receipt of the report.

The Committee will review the report and any submissions made by the Reviewee to determine whether further action is required.

In most cases, registrants are found to meet professional standards without concern, and the PAR process is concluded.

Occasionally, improvement opportunities may be identified, and the Committee may

• endorse the Assessor’s recommendations,
• direct that its own recommendations be implemented, or
• take further steps to address concerns.

If you have any questions regarding the PAR 听please contact the Quality Assurance Coordinator at qualityassurance@cpbao.ca

A professional corporation is a legal business structure that allows regulated professionals to offer their services through a corporation rather than as individuals. When services are provided through a professional corporation, the corporation is the service provider from a business and tax perspective. Registrants who provide services through a corporation are still responsible for following the Standards of Practice.

Incorporating your practice isn鈥檛 a requirement and is entirely your decision. This is a business decision that impacts administrative, financial and tax aspects of your professional practice. 91视频 recommends consulting with an accountant or lawyer who specializes in this area to determine if incorporation is right for you.

Please submit your application and supporting documents to cpbao@cpbao.ca. Once received, we will post an invoice to your account for payment of your application fee.

A Corporation Profile Report is a document issued by the Ontario Ministry of Public and Business Service Delivery that shows your corporation is registered and active. You must include a current-dated Corporation Profile Report with your initial and annual renewal application.

You must obtain the report directly from the . For step-by-step instructions, please review the Guide to Retrieve a Corporation Profile report.

The application fee for a new Certificate of Authorization is $350. The annual renewal fee is $250.

Processing takes approximately 1 week after 91视频 receives your complete application package. Your certificate鈥檚 effective date will reflect the date we received your complete application package and fee.

There are very specific rules for naming a professional corporation under of the RHPA. See the Application Guide for more details.

You may consult with 91视频 before setting up your corporation to ensure that the name is appropriate.

Yes. You must list every practice name your professional corporation uses on the application form.

91视频 诲辞别蝉苍鈥檛 review or approve practice names. Registrants are free to choose a name, as long as it meets the requirements of the (section 6).

Only 91视频 registrants.

Yes, if all the shareholders, officers and directors of the holding company are 91视频 registrants.

No. Registrants must incorporate under the Ontario Business Corporations Act. Health profession corporations incorporated outside Ontario, including corporations federally incorporated under the Canada Business Corporations Act, cannot obtain a Certificate of Authorization from 91视频.

No. If you want to provide professional services through a corporation, it must be a professional corporation that holds a Certificate of Authorization. This 诲辞别蝉苍鈥檛 mean that you must have a professional corporation to provide professional services, nor does it prevent you from being employed by non-professional corporations owned by others. In those cases, you are practicing as an individual health professional, separate from the corporation, from a business and tax perspective.

Your professional corporation can only provide services in psychology or applied behaviour analysis, or activities that are ancillary, meaning they directly support those services. The word 鈥渁ncillary鈥� is not defined in the Business Corporations Act, 1990, which sets this condition. In practice, it 诲辞别蝉苍鈥檛 include services provided by autonomous practitioners of other professions (such as the College of Registered Psychotherapists of Ontario or the Ontario College of Social Workers and Social Service Workers), even if they seem similar.

While both are types of business structures, the rules that stipulate their ownership and the activities that they can undertake are different.

Professional Corporations
Shareholders, officers are directors of professional corporations must all be registrants of the same profession and regulated by the same college. Further, the only business that a professional corporation is permitted to undertake is the practice of the profession and activities that are related to or ancillary to the practice of the profession. Every professional corporation is also required to obtain a Certificate of Authorization from the College before it is permitted to conduct its business.

Practice Management Corporations
In contrast, the ownership rules of corporations that manage practices differ. Registrants of different health professions, non-health professionals or family members can be shareholders, officers or directors. Registrants/shareholders are not permitted to practice any regulated health profession through a Practice Management Corporation. Practice Management Corporations are not required to register with the College.

To renew your professional corporation, the following items are required:

1. Online Professional Corporations Renewal Form鈥擳o access the renewal form, please log into your and click on your corporation鈥檚 name on the left menu. Before submitting the form, please review every section and make any necessary changes to ensure that the information is accurate as of the day your renewal is submitted.
2. Corporation Profile Report
3. Declaration鈥擜 Declaration of a director of the corporation, signed no more than 15 days before your renewal is submitted. You may download a copy here.
4. Renewal Fee鈥擳he annual renewal fee is $250 and will be invoiced to your member account after you submit your application and supporting documents to cpbao@cpbao.ca. To pay by credit card, please log into your , click on your corporation鈥檚 name on the left menu and click 鈥淧ay Invoice鈥� under your corporation鈥檚 name.
5. Certificate of Incorporation (if applicable)鈥�You must submit a Certificate of Incorporation and Articles of Amendment filed with the Ministry of Government Services only if you made any changes, such as a name change, to the corporation since incorporation or your previous renewal.

Yes. 91视频 must revoke a professional corporation鈥檚 Certificate of Authorization in the following circumstances:

• The corporation no longer meets the eligibility requirements to hold a Certificate of Authorization.
• The corporation stops practicing the profession for which the Certificate of Authorization was issued.
• The corporation fails to meet one or more of the renewal requirements of the Certificate of Authorization.
• The corporation carries on any business activities that are not the practice of the regulated profession or directly related or ancillary to the practice of that profession.

While the College Standards set out the minimum length of time for record retention, there are no rules against keeping information indefinitely. It is not advisable though, to keep information which is not likely to be useful any longer than one needs to, due to the risks associated with unauthorized access to any record.

It鈥檚 our understanding that many members 听do keep a log of the files they have destroyed, with information such as you have outlined in your question. It is important to know that the information in such a record is considered Personal Health Information 听and that these lists themselves are subject to the same privacy legislation and Standards as the records themselves were, because they identity individuals who have received health care. If you do decide to keep such a record you might also consider including the date of destruction

It depends. The name on the invoice should reflect the service provided and the intended recipient. For example, if the service involves imparting parenting skills to adults, the parents鈥� names should appear on the invoice. If the service is providing parents with a progress update or information to support a child鈥檚 therapy, the child鈥檚 name should appear on the invoice, as the service is intended to support the child.

All documents, including invoices or receipts, must be factual and accurate. (). If appropriate, additional information may be added on the invoice to clarify details about the service.

Registrants should not involve themselves with insurance coverage matters, including per-person limits. These should be addressed between the client(s) and their insurers.

Reflection questions:

• Who is the recipient of services?
• What is the purpose of the intervention, and who is it targeted towards?
• Could the name on the invoice appear to be false or misleading?

Originally published in Volume: 1 Issue: 3 of HeadLines

This scenario presents some potential challenges.

Consent may be more complicated than might initially meet the eye. The clients in such a situation could decide to enter the relationship because of a perceived expectation by the therapist that they will agree and not want to disappoint the therapist by declining the invitation. For this reason, if this were to occur, such an opportunity would have to be presented in an entirely neutral manner.

To be fully informed consent, each client would have to be made aware of all the potential benefits and risks. These benefits would obviously include mutual support. On the downside, entering a relationship in which the client could be taking on further emotional (and perhaps other) demands should be presented as a risk to their own therapeutic relationship with the therapist and consequently to their therapeutic progress.

Confidentiality could also become a challenge when clients are introduced and encouraged to communicate. While each client would know that the other was seeing the same therapist, the therapist would have to be vigilant not to share any information about the other client without authorization. This would become difficult if they wished to talk about the other client or about interventions being used with them and it could become difficult to avoid inadvertently providing information, even in refusing to actively answer certain questions that could be posed. Even if information about one client was never disclosed to the other, the therapist would have to be vigilant about avoiding the collection of information about one from the other without consent. Even with full consent, collection of such information could pose challenges to professional objectivity, if information arose about any conflict arising between these individuals or any adverse information about them. This would become a dual relationship in the same way as working with clients who are relatives or friends of one another would, and it鈥檚 best to avoid dual relationships.

There are no specific prohibitions against introducing clients, but these are some of the challenges in managing such an intervention, without the safeguards of therapist mediated interaction between clients, as might occur in a therapist mediated mutual support group.

Originally published in Volume: 1 Issue: 4 of HeadLines

This question often arises when a member has been treating or assessing a client where the primary focus of clinical attention has not involved an assessment of the factors bearing upon the opinion being sought. 听This may occur, for example, when a member has conducted a psychoeducational assessment, or treatment for an anxiety disorder, and the member is later asked to provide information to be used in a parental rights matter. Another example is when a member has provided psychotherapy to address a client鈥檚 emotional disorder and is then asked to provide a letter regarding the individual鈥檚 readiness to return to work after an injury.

In providing professional opinions, a member must consider the following requirement in听section 10.3 of the听Standards:

10.3 Rendering Opinions
A member must render only those听professional opinions that are based on current, reliable, adequate, and appropriate information.听

In the first example above, a member should only provide information that they can reasonably expect to be used to determine custody or access arrangements if they have conducted an appropriate assessment for the purpose of determining child custody and/or access. Likewise, in the second example, a member should only opine on a person鈥檚 suitability to return to work after appropriate consideration of the person鈥檚 rehabilitation needs and the task requirements of the workplace.

Members must ensure that they work only within their authorized areas of practice and provide only those services in which they have the adequate knowledge, skill, and experience, within those authorized areas.

Even when a member is authorized and qualified to provide an opinion unrelated to the service they have been providing, and have conducted an adequate assessment, problems may arise if they assume a dual role. Usually, such requests for information are related to the rights and entitlements of the client. They also have an impact on others, such as family members, colleagues, or employers. 听A clinician who has not conducted an appropriate, objective assessment of the matter at hand can face challenges with respect to whether they have exercised sufficient neutrality. There may also be a perceived 听conflict of interest if it appears that a continued professional relationship could be endangered by offering an opinion that is seen to be unfavourable to the client鈥檚 interests.

Originally published in Volume: 1 Issue: 4 of HeadLines

Section 4.1.1 of the Standards of Professional Conduct, 2017听听requires that:

8) the supervising member must ensure that billing and receipts for services are in the name of the supervising member, psychology professional corporation or employer and clearly identify the name of the supervising member and the name, relevant degrees and professional designations of the supervised psychological service provider

There is no explicit requirement under this听Standard for there to be听a signature, however, the following Standards are also applicable to these situations:

4.1.2 Supervision of Supervised Practice Members;听and
4.1.3 Supervision of Non-Members
In addition to the responsibilities outlined in 4.1.1:
a) the supervising member must co-sign all psychological reports and formal correspondence related to psychological services provided by non-member supervisees;

Invoices (and receipts) would be considered by most to be 鈥渇ormal correspondence鈥� and should be co-signed by supervisors.

Within the past few years, the College has received an increasing number of complaints about the transparency of such documents and what some third-party payers have alleged to be misleading practices by members. Increasing vigilance by third-party payers has, unfortunately, led to denial of insurance benefits for some clients. 听It has also led to an increased level of scrutiny of College members by claims adjusters. Supervisors should demonstrate that they carefully oversee the administration of their services by personally applying their own signatures to invoices issued in their names.

Originally published in Volume 2 Issue 1听of听HeadLines.

In the practices of most members, the answer to this question can be found in the听听(HCCA)听and the听听(PHIPA).

One must first establish whether the child has the capacity to make their own independent decisions in these situations. The听HCCA听and the听PHIPA听do not specify chronological ages of consent but instead set out the test for determining whether any individual, including a child, is capable of making their own health care decisions. The determination of capacity must be made by the Health Care Provider or the Health Information Custodian, as the case may be. The analogous tests for capacity to be applied are set out in section 4 of the听HCCA听and section 21 of听PHIPA, respectively.

If the child is not believed to be capable, a substitute decision-maker for the purpose of the听HCCA听is generally deemed to play the same role with respect to听PHIPA.

Section 20 of the听HCCA听and Section 26 of听PHIPA听provide specific advice with respect to the hierarchy of potential decision-makers when a child is not believed to be capable of making their own decisions. It also sets out the mechanisms for deciding what must happen when a person with the right to make decisions is not available or willing to assume decision-making responsibility.听 The legislation also addresses what to do if there is conflict between two individuals having equal ranking in the hierarchy.

Generally, a parent can give or refuse consent on behalf of an incapable child unless this authority has been lawfully granted to a children鈥檚 aid society or other person. If both parents do not have the same rights under an Agreement or Order, a parent with custodial rights prevails over a parent who has only a right of access. In situations where the statute does not spell out clearly which parent is entitled to make the decision, statutory interpretation is necessary. Given the high stakes for all individuals involved, the most prudent course of action is to obtain independent legal advice.

The College鈥檚听August 2005听Bulletin听provides additional guidance with respect to this issue.

Originally published in Volume 2 Issue 1听of听HeadLines.

The answer to this question depends upon various decisions made by the organization, including who is the Health Information Custodian (HIC), a term which is used and defined in the听, 2004听. For the purposes of answering this question, either a health care practitioner or a person who operates a group practice of health care practitioners听may听be a HIC. There may only be one HIC and it should be the person who will have ultimate responsibility for the collection, use, disclosure, security, and retention of the information. .

The HIC must ensure that their identity is made clear to all concerned, including the client. 听A client must provide informed consent for a specified individual or organization to collect information about them.

A Health Information Custodian may have an 鈥渁gent鈥�. This is defined in听PHIPA听as a person that, with the authorization of the custodian, acts for or on behalf of the custodian. The HIC may, for example, appoint the service provider working in the HIC鈥檚 organization to be their agent.

Copies of information may be shared with those with a need to have the information in their possession but may only be provided to anyone other than the HIC or agent with client consent. The number of copies of the same information is directly correlated to the risk of loss or unauthorized access to the information. The fewer number of copies there are of a document, the lower the risk of loss or unauthorized disclosure.

There is no prohibition against storing information in more than one file/location.听Standard 9.1 of the Standards of Professional Conduct, 2017听requires that听a member must make best efforts to ensure that the member鈥檚 records are complete and accessible; this applies whether the record is kept in a single file or in several files and whether the record is housed in one location or at several locations. It is suggested that when records are not maintained in one file or location that a note is placed in each location indicating the location(s) of any other information.

First, it is good to know that you are helping them to address these issues, as a colleague. It does not appear that you have a duty to report this situation.

There are two situations in which you may have a mandatory reporting obligation, but this does not sound like it is one of them. The two situations are set out in and of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991. The first applies to operators of facilities in which a health professional provides services:

听Reporting by facilities

85.2 (1) A person who operates a facility where one or more members practise shall file a report in accordance with section 85.3 if the person has reasonable grounds to believe that a member who practises at the facility is incompetent, incapacitated, or has sexually abused a patient.听

听From your description of the situation, it 诲辞别蝉苍鈥檛 sound like you operate a facility in which this colleague practices, therefore this section would not apply.

The second relevant section of the Code applies to reporting by employers, etc.

Reporting by employers, etc.

85.5 (1) A person who terminates the employment or revokes, suspends or imposes restrictions on the privileges of a member or who dissolves a partnership, a health profession corporation or association with a member for reasons of professional misconduct, incompetence or incapacity shall file with the Registrar within thirty days after the termination, revocation, suspension, imposition or dissolution a written report setting out the reasons.

听Same

(2) Where a member resigns, or voluntarily relinquishes or restricts his or her privileges or practice, and the circumstances set out in paragraph 1 or 2 apply, a person referred to in subsection (3) shall act in accordance with those paragraphs:

1. Where a person referred to in subsection (3) has reasonable grounds to believe that the resignation, relinquishment or restriction, as the case may be, is related to the member鈥檚 professional misconduct, incompetence or incapacity, the person shall file with the Registrar within 30 days after the resignation, relinquishment or restriction a written report setting out the grounds upon which the person鈥檚 belief is based.

听

2. Where the resignation, relinquishment or restriction, as the case may be, takes place during the course of, or as a result of, an investigation conducted by or on behalf of a person referred to in subsection (3) into allegations related to professional misconduct, incompetence or incapacity on the part of the member, the person referred to in subsection (3) shall file with the Registrar within 30 days after the resignation, relinquishment or restriction a written report setting out the nature of the allegations being investigated. 2014, c. 14, Sched. 2, s. 12.

听Application

(3) This section applies to every person, other than a patient, who employs or offers privileges to a member or associates in partnership or otherwise with a member for the purpose of offering health services.听 1993, c. 37, s. 23.

Once again it does not appear that you would have a reporting obligation unless you are the colleague鈥檚 employer and due to concerns of incapacity you terminated their employment or revoked, suspended or imposed restrictions on their privileges to practice or you dissolved a partnership, a health profession corporation or association with them.

Hopefully, with your collegial support, this individual will be able to mitigate the risks to themself and their clients and find relief from their distress. If it appears advisable for your colleague to obtain professional services, then you should consider referring them to an appropriate mental health professional, to avoid becoming involved in a dual relationship.

It is appropriate for private practitioners, including contractors, to be compensated based on time spent and the complexity of services provided. If providing additional听incentives to treatment providers could be reasonably expected to lead to decisions about service planning that are motivated by factors beyond client needs this could be problematic. For example, this could be problematic if compensation rather than client needs lead to practicing the profession while in a conflict of interest and/or providing services which are not likely to benefit the client; both of which are considered acts of听. 听Members are advised to support their staff and contractors in ensuring that client need is the primary consideration in service planning.

As required by Standard 4 of the听Standards of Professional Conduct, 2017, members supervising anyone who is not a member of the College and any member with a Certificate of Registration Authorizing 听Supervised Practice must co-sign all psychological reports and formal correspondence related to psychological services prepared by their supervisee.

The term 鈥渇ormal鈥� has not been officially defined so members must use their professional judgment based upon the particular circumstances of each situation.

In generally, formal documents would likely include printed or electronic communications which ordinarily require the person responsible for the information to provide their endorsement of the information in the form of a signature. This might include letters, reports, official memos, and emails about a client which would reasonably be expected to provide information about a client to anyone outside of the organization in which the supervision is occurring.

When in doubt about whether to co-sign a document, it may help to consider that a supervisor鈥檚 signature is meant to provide an assurance to readers of the information it has been endorsed by the professional responsible the service.听 Even if not strictly required to co-sign a document, supervising members may do so if they wish to inform readers that they endorse the contents.

No. If you are retired, inactive or no longer a registrant (resigned), you cannot provide any psychological or applied behaviour analysis services of any kind. This includes direct client care, whether independently or under the supervision of another registrant. It also includes, but is not limited to, activities that require application of graduate-level education, training and experience relevant to the profession, such as:

• Consultation
• Program development and evaluation
• Supervision
• Research
• Education and training
• Scholarly activities
• Administration

However, you may still provide information about services you provided while you previously held a Certificate of Registration Authorizing Autonomous Practice.

For example, you may be able to:

• hold yourself out as an expert at a trial involving a former client if they are not providing any new services,
• provide a summary report of past services you delivered while holding an autonomous practice certificate for a third party (without adding any new information/conclusions),
• do administrative work for your practice that does not require application of graduate-level education, training and experience relevant to the profession,
• Respond to access to information requests from former clients.

The answer to this question requires interpretation of legislation and College staff are not qualified or authorized to provide legal advice. Members who are considering refusal of a specific request for information may wish to obtain independent legal advice, given that release of confidential information, or the refusal to do so, can be a high-stakes decision for all concerned. The following information may be of assistance in obtaining legal consultation.

The sets out the applicable rules to be considered when addressing a request for personal health
information.

Personal Health Information is defined, in section 4.(1)(a) of the Act, as information that 鈥渞elates to the physical or mental health of the individual, including information that consists of the health history of the individual鈥檚 family. . .鈥�

Section 1 (b) of PHIPA states that one of the purposes of the Act is 鈥渢o provide individuals with a right of access to personal health information about themselves, subject to limited and specific exceptions set out in this Act鈥�. The Act also provides that information an individual is entitled to access can be provided to another party, with the consent of the individual or of the individual鈥檚 authorized substitute decision-maker.

Whenever faced with a decision about whether to provide access to information contained in a client record, it is a good idea to review the list of exceptions to the requirement to do so. These exceptions are set out in in Section 52(e) of the Act where one is not required to allow access to information if,

(e) granting the access could reasonably be expected to,

i. result in a risk of serious harm to the treatment or recovery of the individual or a risk of serious bodily harm to the individual or another person,
ii. lead to the identification of a person who was required by law to provide information in the record to the custodian, or
iii. lead to the identification of a person who provided information in the record to the custodian explicitly or implicitly in confidence if the custodian considers it
appropriate in the circumstances that the identity of the person be kept confidential;

The Act, section 52(2) goes on to say that a health information custodian may provide only parts of a person鈥檚 record 鈥渢hat can reasonably be severed from the part of
the record to which the individual does not have a right of access鈥�. When a decision is made to sever part of a file before releasing the record, section 54 of the Act provides
specific guidance about how to do this.

The Information and Privacy Commissioner of Ontario recently considered a complaint about an agency鈥檚 refusal to grant one family member access to the entirety of a family鈥檚 therapy records. In , the Commissioner found that the Personal Health Information (PHI) of each family therapy participant is theirs alone and not PHI of the other therapy participants. They went on to say that family therapy records may contain 鈥渃ommunal鈥� or 鈥渟hared鈥� information that can form part of each participant鈥檚 PHI. Communal or shared information was described as information about family health history, overall family relationships or dynamics, as well as general themes that arose in the course of family therapy.

The Commissioner ultimately decided that the complainant鈥檚 right of access under PHIPA was limited to only to PHI that can reasonably be severed from the records. The Decision explains that the Act is intended to enable individuals to access information about their family health history allowing them to make informed decisions about their own health care but that anything beyond shared or communal information, may have been collected with an expectation that it would remain confidential.

The Decision further explained that this best respects the confidentiality of that information; fosters trust between family therapy participants and custodians; promotes participant autonomy over access to their own personal health information; and promotes candid discussion and unguarded participation in family therapy sessions.

The Decision indicated that the right of access to information is limited by section 52(3), of the Act, which provides that an individual will only have a right of access to an entire record if the record is 鈥渄edicated primarily鈥� to their personal health information. The following examples of factors to consider in determining whether a record is 鈥渄edicated primarily鈥� to the personal health information of a requester are provided:

• the quantity of personal health information of the requester in the record;
• whether there is personal health information of individuals other than the requester in the record;
• the purpose of the personal health information in the record;
• the reason for creation of the record;
• whether the personal health information of the requester is central to the purpose for which the record exists; and
• whether the record would exist 鈥渂ut for鈥� the personal health information of the requester in it.

The following 鈥渂est practices鈥� are suggested within the Decision:

1. At the outset of therapy, establish ground rules for what can be discussed, what information will be recorded, and who will have access to the records;
2. Document this understanding in the health record;
3. Identify documents (including chart notes) that relate to one participant and those that relate to all participants; and
4. When considering requests to access family or group therapy records, refer to documented informed consent and other records to identify participants鈥�
   expectations, and categorize records as communal or relating to one or more participants before granting access to any records.

Following the successful completion of an Oral Examination, and after you are issued a Certificate of Registration authorizing Autonomous Practice, you will no longer require supervision in your authorized areas of practice and client populations. Although formal supervision is no longer required, consultation and other forms of peer support can be of great value throughout your professional career.

Under Supervised Practice, your supervisor was responsible for your adherence to the Legislation, Regulations, Standards and Ethical Guidelines applicable to your practice. If you have been issued a Certificate of Registration authorizing Autonomous Practice you are now fully accountable for the discharge of your own professional and ethical responsibilities.

While the applicability of various statutory and ethical obligations can be straightforward when taking on new clients, taking on the management of professional responsibilities with clients who were initially seen under supervision often leads to questions about such matters as informed consent, fees and billing, and clinical records.

Continuing to Work with Clients you had Previously been Supervised with听

If you will be continuing to work with individuals who you worked with during your period of Supervised Practice, it is important consider the changes your new Autonomous Practice registration entails. It鈥檚 important to:

• Ensure that clients who wish to continue working with you as an autonomous practitioner, know that you will now be solely responsible now for their care, that your supervisor no longer considers them to be their clients and that you are no longer under supervision;
• Engage in an independent informed consent process with clients, outlining your new, autonomous professional responsibilities and confirm agreement with respect to what services you will be providing, and on the fees you will be charging;
• Clarify that the personal health information collected during your period of Supervised Practice must remain with the person or organization who was the Health Information Custodian during your supervision;
• If you are to be considered the Health Information Custodian going forward, you may obtain a copy of records made to date only with the client鈥檚 consent; information about who is the Health Information Custodian can be found here: Who 鈥淥wns鈥� the Clinical Record? In a group practice comprised of members authorized for autonomous practice, who can access, contribute to, and hold copies of the clinical record?

The answer to this question depends upon who has been identified as the Health Information Custodian. Under the, it is possible that either a health care practitioner or a person who operates a group practice of health care practitioners can act as the Health Information Custodian (HIC). While either is possible, only one must be established at the onset of services. Generally, this will be the particular individual or entity they authorize to collect their Personal Health Information.

If, in this scenario, the operator of a group practice is not the HIC, then, the following Standard is applicable:

4.1 Responsibility of Supervisors of Psychological Service Providers
If members are supervising psychological services provided by a member holding a certificate for supervised practice or any other unregulated or regulated service provider who is not an autonomous practice member of the College, the clients are considered to be clients of the supervisor鈥�

It then follows that the records are considered to be the records of the supervising member. This is supported by the following additional Standard:

9.1.2 Members Responsible for Supervising Supervised Practice Members and Non- Members
Members supervising Supervised Practice members and non-members are responsible for the security, accessibility, maintenance, and retention of records.听

If the organization is not the HIC, at the end of the engagement, in most case it is the supervising member who is the HIC and the records must remain with them for the required retention period.

In order to answer this question, it is important to consider what is meant by 鈥渃onsulting鈥� as it can be understood to mean different things in different contexts.听 Consultation is defined in the Standards of Professional Conduct, 2017 as:

the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.

If this describes the nature of the relationship with the agency, then the organization is generally considered to be the client. In the case of an organizational client, the member providing consultation is required to maintain records in accordance with the following Standard:

9.3 Organizational Client Records
1. Members must keep a record related to the services provided to each organizational client.
2. The record must include the following:
a) the name and contact information of the organizational client;
b) the name(s) and title(s) of the person(s) who can release confidential information about the
organizational client;
c)the date and nature of each material service provided to the organizational client;
d) a copy of all agreements and correspondence with the organizational client; and
e) a copy of each report that is prepared for the organizational client.

The 鈥渘ature of each material service provided to the organizational client鈥� in c) above, should likely include sufficient information to address queries about the quality of the particular consultation, should that information ever be needed.

An organizational client record must be retained for at least ten years following the organizational client鈥檚 last contact. If the organizational client has been receiving service for more than ten years, information contained in a record that is more than ten years old may be destroyed, if the information is not relevant to services currently being provided.

It is the responsibility of the individual providing services to ensure that proper client consent is obtain for the service being providing. A person acting as a consultant to a service provider would not likely be in a position to seek consent from the person receiving services from the consultee. The consultant may, in fact, never come into contact with the person receiving services from the consultee. In some cases they may not even know their name.

If a member is identified as a 鈥渃onsultant鈥� but they are personally providing the psychological assessment, diagnosis, opinion or intervention, as opposed to 鈥渃onsulting鈥� to or supervising another service provider, this would likely be听 considered a direct service. In this case, all of the Standards relevant to direct service provision, including those pertaining to consent and record-keeping, would be applicable.

In circumstances where it is unclear whether one is providing direct service or consultation, it may be useful to ask: Is this a service I would provide autonomously to an individual or family in a clinical practice, or is it providing advice to another autonomous service provider who is simply looking for the input with respect to clinical decisions they must make themselves?

This is a situation that requires some definitional framing, before looking at the issue of feedback.

The听Standards of Professional Conduct, 2017听define a 鈥渃lient鈥� as:

听an entity receiving psychological services, regardless of who has arranged or paid for those services. A client can be a person, couple, family or other group of individuals with respect to whom the services are provided. A person who is a 鈥渃lient鈥� is synonymous with a 鈥減atient鈥� with respect to the administration of the听.听

This means that the person who has been assessed is, from the perspective of the College, the client. Members are expected to be proactive in ensuring that clients are aware of their rights, including the right to access information about themselves, in accordance with the following听Standard:

3.2 Clarification of Confidentiality and Professional Responsibility to Individual Clients and to Organizations

In situations in which more than one party has an interest in the psychological services rendered to a client or clients, members must, to the extent possible, clarify to all parties, prior to rendering the services, the dimensions of confidentiality and professional responsibility that must pertain in the rendering of services.听 The provision of psychological services on behalf of an organizational client does not diminish the obligations and professional responsibilities to individual clients.

Practical Application:听The need for clarification may arise, for example, in the provision of an assessment of a claimant in an insurance matter, where the insurer has retained the assessor.听Regardless of the wishes of the insurer, members are under all of the obligations that pertain to a client within these Standards and the relevant privacy legislation.听听听This includes providing access to the individual or their authorized representative to their personal information and any reports or records which members have in their possession听unless prohibited by law or they are otherwise permitted to refuse access.听听

The requirement to provide feedback, upon request by the client, is addressed in Ontario Regulation 801/93 Professional Misconduct:

The following are acts of Professional Misconduct:

鈥�
13. Failing to provide a truthful, understandable and appropriate explanation of the nature of an assessment, intervention, or other service following a client鈥檚 request for an explanation.

鈥�
21. Failing, without reasonable cause, to provide a report or certificate relating to a service performed by the member, within a reasonable time, to the client or his or her authorized representative after a client or his or her authorized representative has requested such a report or certificate.

Similarly, 听members are required to make information, including assessment results, available to all clients and authorized representatives, under the following听Standard:

8.2 Access by Client or Client鈥檚 Authorized Representative

Members are responsible for ensuring that access to an individuals鈥� personal or personal health information is provided to the individual and/or their authorized representative unless prohibited by law or the member is otherwise permitted to refuse access.

While it may at first seem possible to find a technical 鈥渙ut鈥� to providing feedback to someone who has not actually requested it, the听)听specifies that consent to disclose information must be obtained from the person who has been assessed (or an authorized Substitute Decision Maker),听 and only if they have knowledge of the purposes of the disclosure. The consent must also be related to the information to be disclosed. In other words, there is a positive responsibility on the part of the Health Information Custodian to ensure that the client has been provided with an opportunity to make a free and informed decision about the disclosure of the information that would be disclosed.

The College has not identified 鈥減arents鈥� as a specific population to whom one needs particular authorization to consult to or otherwise work. The answer to your question then is:听听It depends upon the specific focus of the consultation.

If the parenting work involves psychoeducation, that is, providing parents with information about child development and advice about how they can address childhood difficulties, then it would make sense that a practitioner has been deemed to have the requisite knowledge, training, and experience required to understand the developmental factors at play with children/adolescents being 鈥榩arented鈥�. In this situation, authorization to work with children and adolescents would be expected.

If the focus of the work is to help parents improve their relationship with their child, then specialized knowledge, skill, and experience in the area of family dynamics is important. For this reason, authorization to work with families would be necessary.

Similarly, if the focus of the work is helping the parents work together as a couple, then authorization to work with couples, would be appropriate. Likewise, if the work involves assisting an individual parent who for personal reasons experiences challenges in interacting with a child and this requires them to receive individual therapy to address their own difficulties, authorization to work with individuals within that parent鈥檚 own age group would be required.听 Since you are authorized to work with adults, assuming that the parents are adults, then this would not be problematic.

Basically, one size can鈥檛 fit all, and the system of authorized populations allows for flexibility because of all of the possibilities with this kind of work.

Although there are no specific requirements identified with respect to formal notetaking in a consultation relationship, there are specific requirements with respect to services to Organizational Clients. The听Standards of Professional Conduct, 2017听define an Organizational Client as: 听an organization, such as听a business, community or government that receives services that are directed primarily at the organization, rather than to the individuals associated with that organization.

If the social worker is thought of as operating听a business,听it is the business (as opposed to the social worker鈥檚 clients) to whom you are providing consultation. This would mean the records are Organizational Client Records. The听Standards of Professional Conduct, 2017听set out the following requirements for Organizational Client records as follows:

9.3 Organizational Client Records

1. Members must keep a record related to the services provided to each organizational client.
2. The record must include the following:
3. the name and contact information of the organizational client;
4. the name(s) and title(s) of the person(s) who can release confidential information about the organizational client;
5. the date and nature of each material service provided to the organizational client;
6. a copy of all agreements and correspondence with the organizational client; and
7. a copy of each report that is prepared for the organizational client.

Although the 鈥渘ature of each material service provided鈥� is not described, it can be reasonably understood that this means information about the issues discussed and advice given should be recorded. This would apply to any consultation, including those involving members of other professions.

The Standards of Professional Conduct, 2017听 require that supervising members must be authorized to autonomously provide services to the specific populations before supervising others in that work. Furthermore, the Standards also requires that

Supervising members must assess the knowledge, skills and competence of their supervisee and provide supervision as appropriate to the supervisee鈥檚 knowledge, skills, and competence, based on this assessment;

Unless a supervisor has sufficient information about a client and the client鈥檚 difficulties, they would not be able to provide adequate supervision appropriate to the supervisee鈥檚 knowledge, skills and competence.

It is the responsibility of a supervisor to be sufficiently familiar with the client鈥檚 demographics and needs before permitting their supervisee to commit to provide services. 听The adequacy of the supervision could be in question if a supervisor reviews and signs off on reports without having been involved in a direct or supervised intake process, or does not actively supervise the work leading up to any final reports.

Even though the Standards do not require supervisors to meet and interact with clients receiving services under their supervision, a supervisor should only permit a supervisee to work with a client after they have satisfied themselves that the client is within their authorized areas of practice and belongs to a population with whom they are authorized to work.

If the client 诲辞别蝉苍鈥檛 respond to repeated attempts to contact them, you may consider this a withdrawal from services. In this scenario, you should document your outreach attempts and send a final notice advising them that if they don鈥檛 respond, you will consider them to have withdrawn from services.

If a client asks to discontinue services, services end immediately. This is similar to a client withdrawing consent for services.

In cases where services end due to a fee increase, and the client is unable or unwilling to pay the new fee, you and the client may determine together the best approach to 鈥榳ind down鈥� services. Ideally, services would continue until a transfer to another provider is secured.

See above for more information on expectations and resources for referrals when discontinuing services.

Reflection questions:

• Have I documented the attempts made to contact the client?
• Have I notified the client that I am considering them to have withdrawn from service?
• Have I worked with the client to determine whether a referral is needed?

We鈥檝e heard about this incorrect position from enough people to assume that, at some time in the past, it must have been promulgated widely. While the legislation permits one to refuse access to personal health information in some limited circumstances, including raw data from psychological tests, it does not prohibit one from allowing access to it. In many cases, it is expected that raw data will be provided, even with non-members.

A list of exceptions to the right of access to personal health information can be found in section 52 of the Personal Health Information Protection Act (PHIPA), 2004. Most of the exceptions relate to the expectation of serious risk associated with the disclosure.

Members who have insufficient cause to withhold raw data may have concerns about the risk of releasing the information to those who are not sufficiently trained to interpret it. In such cases, members are advised to attach a statement to the raw data indicating that raw data from standardized tests can lead to incorrect conclusions, and that this information should only be interpreted by those who are regulated psychological service providers with adequate training and experience in the interpretation of test results.

Detailed further information about the release of raw data can be found on the College鈥檚 Professional Practice FAQ pages.

It is a client鈥檚 right to decide who their personal health information may be shared with, subject to some exceptions set out in the Personal Health Information Protection Act (PHIPA), 2004. The Office of the Information and Privacy Commissioner of Ontario has published some helpful information about the , a colloquial term describing how one may rely on implied consent and the , the colloquial language used to describe how a client may 听limit what can be shared where one could ordinarily have relied upon implied consent.听 All members who have not yet reviewed these documents, should familiarize themselves with these concepts and rules.

While there may be an argument that a member is not technically violating PHIPA if they provide information based upon implied consent, it isn鈥檛 really in the spirit of the legislation to do so, particularly if one believes a client who understood their rights, might capably choose to limit disclosure of their personal health information.

If there is reason to believe that a client would not want their personal health information shared, even if they have not sought to have the information 鈥榩laced in a lock box鈥�, one should consider the impact of sharing the information on the therapeutic alliance or on the client鈥檚 trust of other health care professionals, if the client believes their privacy has not been respected.

This question has been answered by the Office of the Information and Privacy Commissioner of Ontario听 and can be found in the , on page 31 of the document.

The answer reads as follows:

Yes. PHIPA permits the disclosure of personal health information without consent, if permitted or required by another law. For example, this means that PHIPA does not interfere with the Workplace Safety and Insurance Act (Act), where that Act requires a hospital or health facility, which provides health careto a worker claiming benefits under the insurance plan, to give the WSIB such information relating to the worker as the WSIB may require. This requirement also applies to a health care practitioner who provides health care to a worker or is consulted with respect to a worker鈥檚 health care. When requested to do so by an injured worker or the employer, the Act requires a health care practitioner treating the worker to give the WSIB, the worker and the employer prescribed information concerning the worker鈥檚 functional abilities.

This can be the case with respect to such factors as age, language, 听race, culture, or gender diversity and is a 听legitimate concern. In the absence of appropriate norms, one would need to use clinical judgment to interpret the client鈥檚 response to items 听and, in accordance with the following Standards:

A member must render only those professional opinions that are based on current, reliable, adequate, and appropriate information.

A member must identify limits to the certainty with which diagnoses, opinions, or predictions can be made about individuals or groups.

An American Psychological Association听听about assessing people who are transgender provides one example of how to conduct an assessment where听 no appropriate norms have been identified. In the absence of specific guidance concerning an identified group, registrants are advised to document their approach to interpreting test responses. This can be helpful in the event that assessment results are challenged and, of at least as much importance, the exercise of writing out a rationale can help make the activity as objective as possible.

Most of the queries we have received related to this problem have been asked in the context of an individual who is transgender, where a client may be capable of making their own decisions may not be in a position to effect a legal name change, due to age or an institutional or family situation. Ideally, such issues should be discussed as part of the informed consent process, as early as possible and preferably before beginning the assessment. If the client agrees to have both their legal and preferred names in the report, that would avoid any confusion to readers of the report with respect to who the report is about. If the client does not provide permission to note both names and there is a need to include the client鈥檚 non-preferred name, or to indicate that the name used in the report is not the same as the client鈥檚 legal name, this will require careful navigation, in order to protect the client鈥檚 dignity and to avoid making a potential misrepresentation. 听In such a case, it would be prudent to obtain independent 听legal advice before proceeding.

When addressing issues related to a trans person鈥檚 identify, the 听Ontario Human Rights Commission听provides the following 听guidance:

1. 
   2.听
   3.听

This听听provides some guidance for how to determine when treating two 鈥榬elated鈥� individuals could become problematic.

In summary, the decision about whether or not to take on individual clients who are related either through family, friendship or are involved with each other in any other way will depend on a critical evaluation of the circumstances, nature of that relationship and the potential for cross involvement at any time.

We recognize that 鈥榳ord of mouth鈥� is often how clients find their therapists, so it is likely that many members have clients who know each other. Each situation will likely present different risks and degrees of risk. When separately treating individuals who are friends with each other, there is a possibility that one client may want to discuss the other client for a variety of possible reasons. This could be problematic if the information they want to share is related to the issues you are treating the other person for and that information 听may be relevant to 听your formulation of the other case, regardless of whether or not it is verifiable information. In other words, this could be seen as a problem with respect to protection of both confidentiality and objectivity. Working with clients who you know to be friends with each other should be avoided whenever possible due to the complications that can arise. and increase the possibility that you may contravene the following Standards of Professional Conduct:

8.1 Collection, Use and Disclosure

Members are responsible for ensuring that consent is obtained with respect to the collection, use and disclosure of personal information and personal health information in a manner required by legislation applicable to the relevant service.

10.5 Freedom from Bias

Members must provide professional opinions that are clear, fair and unbiased and must make best efforts to avoid the appearance of bias.

13.1 Compromised Objectivity, Competence or Effectiveness Due to Relational Factors

Members must not undertake or continue to provide psychological services with an individual client when their objectivity, competence or effectiveness is, or could reasonably be expected to be, impaired. This could be due to the members present or previous familial, social, sexual, emotional, financial, supervisory, political, administrative, or legal relationship with the client or a relevant person associated with the client.听 This prohibition does not apply if the services are delivered to an organizational client and the nature of the professional relationship is neither therapeutic nor vulnerable to exploitation.

This听听provides an example of the difficulties which could arise when treating two 鈥榬elated鈥� individuals could become problematic.

A decision about whether to take on individual clients who are related either through family, friendship or are involved with each other in any other way will depend on a critical evaluation of the circumstances, nature of that relationship and the potential for cross involvement at any time. While treating individuals who are associated with each other is not strictly prohibited, if the community is large enough, it would be better听 to find another practitioner who would not be in such a potentially challenging situation.

As you likely know, dual relationships are not strictly prohibited but should be avoided, unless the client is unable to find another competent and available service provider.

Before agreeing to provide the service, you may wish to think about whether your previous professional relationship could lead to any concerns that this听 assessment was anything less than highly objective. While you are likely to听 work hard to remain objective, this can be difficult if you do hope for a particular outcome for a client you have supported through their struggles. Even if you can be perfectly objective, if your findings were to be challenged,听 it could be alleged that you weren鈥檛, due to听 your previous alliance with the client.

It would also be important to consider whether there is any possibility that the client may seek intervention from you听 in the future, and whether your role as an assessor might prevent them from doing so. This could be the case听 if they were unhappy with the outcome of the听 assessment and this prevented them from returning to therapy with you, causing them to have to 鈥渟tart all over again鈥澨� with another therapist.

Although听 multiple relationships are听 not strictly prohibited, the College has observed that members trying to be helpful by having multiple different service relationships with the same clients have inadvertently entered into challenging situations.

If you decide to move to a retired certificate and you are the Health Information Custodian (HIC), you must arrange for the secure storage and maintenance of client records in the event of your incapacity or death, and inform 91视频 of these arrangements before you stop providing services. If possible, your designate should be another 91视频 registrant or another health professional (Standard 9.6).

You are not required to maintain liability insurance when holding a retired certificate. However, you should understand how your insurance coverage works, as many plans are 鈥渃laims-based鈥�. This means that registrants must be insured at the time that a complaint is filed, which may be after you stopped providing services.

You may wish to consult with a legal professional before ending your coverage to help you assess the likelihood that a complaint may be filed, as the risk generally decreases over time.

Reflection Questions:

• Have I appointed a designate for your health records and notified 91视频?
• Do I have the appropriate liability coverage for my situation?

The first thing to do in this situation is make a decision about whether the client has the capacity to give direction concerning the release of their personal health information. As you likely know, capacity is not directly tied to IQ scores and must be made solely on the 鈥渦nderstand and appreciate鈥� test which is explained in section 21 of 听. It鈥檚 important to note 听that the threshold for capacity is lower with low-risk decisions. The understand and appreciate test was constructed for a wide range of situations covering 听all of the health professions and for a wide range of situations with more complex information and higher risk decisions to be made, like invasive surgeries.

If the client is not capable of making the decision regarding parental access to the assessment results, it might be better not to give the client the false impression that they have control here and then ignore their wishes if they are deemed incapable and parents are eligible to act as substitute decision makers. 听Even in situations like this, it is still important to involve an incapable person in the process to the extent possible.

If 听the client 听has an understanding of what the relevant information is and means, and also has an understanding of the consequences of sharing or not sharing the information, or in other words is found to be capable, 听then based upon your own clinical judgment, it could be very helpful to engage the three of them in discussion, with the client鈥檚 听capable consent, of course.

If the client is not capable, the client听 would have the right to appeal the decision by the Consent and Capacity Review Board.

Having a discussion with the parents about how to deal with the results, 听without disclosing the results, would also require the consent of the client and this would require a determination of whether the client has the capacity to grant consent to that. This is a different decision, with perhaps a lower threshold for capacity, than the decision to share the actual results. If the client 听is capable of granting consent to a discussion of that nature, it could possibly help identify a helpful path forward.

This is a difficult situation. If you agreed to such a request, please contact the Quality Assurance team at the College. Depending on the circumstances, they will do their best 听to assist in finding a creative solution.

The College has the authority to obtain a file in the absence of 听client consent. This is set out in legislation and is non-negotiable. In obtaining consent to collect personal health information, which must be done before collecting the information, it is important to avoid giving the false impression that the client has any control over whether the College exercises it鈥檚 legislated duty 听to obtain information in procedures designed to protect the public interest, in this case, to ensure that members are practicing competently and ethically.

While it is understandable that clients want to have control over who has access to what is often their most private 听information, careful framing of the issue 听may be help听 avoid at least some difficulties of this nature. It may be best to let clients know that in order to provide the services they are seeking, you must 听maintain a file in accordance with the College鈥檚 requirements (available on the College鈥檚 website) and that, while you will protect their confidentiality where client consent is required before disclosing their personal health information, there are some situations, legislation mandates disclosure, even in the absence of consent. This is the case when review of information is required 听in order to protect clients and others from harm. In other words, the question is: do you agree to engage in services with the knowledge that I must keep a clinical record and that in rare circumstances 听the law allows access to the file without consent. It may also help to advise that this 听applies to any service by a regulated health professional in Ontario who is practicing ethically and lawfully.

You may also like to know that the College and all of it鈥檚 agents and staff have a strict duty of confidentiality and that in Quality Assurance matters, where the College Assessor and Reviewer may have access to the client鈥檚 identity, the College staff and Committee members reviewing the results of a Quality Assurance procedure are not given any identifying information about the clients whose files have been reviewed. The focus of the procedure is the registrant and whether the review indicated that the registrant is practicing competently and ethically.

As regulated health professionals Behaviour Analysts are now regulated by the听听which require practitioners to assess clients鈥� ability to consent to treatment.

The听Act听states that:

A person is capable with respect to a treatment, admission to a care facility or a personal assistance service if the person is able to understand the information that is relevant to making a decision about the treatment, admission or personal assistance service, as the case may be, and able to appreciate the reasonably foreseeable consequences of a decision or lack of decision.

There are no published procedures that we are aware of for performing such an assessment. The same test applies to all health care providers in Ontario and each practitioner who intends to provide the service must conduct the assessment themselves.

While there is no formal procedure set in legislation, here are some general guidelines registrants may wish to consider when determining whether a client is capable of making a treatment decision:

1.听听听听听听听听听听 Review the relevant legislation:听.

2.听听听听听听听听听听 Provide the information that is relevant to making an informed decision regarding treatment, including the:

鈥⑻� 听 Nature of the patient鈥檚 condition
鈥⑻� 听 Nature and purpose of the patient鈥檚 treatment
鈥⑻� 听 Risks and benefits of the proposed treatment
鈥⑻� 听 Risks and benefits of alternative treatments including the option of no 听听听听treatment at all

3.听听听听听听听听听听 Determine whether the patient understands the information

鈥⑻� 听 听Ask the patient to explain what they have been told, in their own words

4.听听听听听听听听听听 Determine whether the patient appreciates the situation and its consequences

鈥⑻� 听 Ask the patient to describe the condition, proposed treatment and the likely outcome

If the patient passes the 鈥渦nderstand and appreciate鈥� test, they may make the decision to either accept or refuse treatment themselves. If the client does not pass the test, the health professional will need to obtain the consent of the appropriate substitute decision maker before anything other than emergency treatment, as set out in the听Act, subject to any other circumstances described in the听Act听as exceptions.

In deciding whether one is authorized and competent to provide a service, the nature of the client鈥檚 presenting difficulties will generally determine whether the member has the appropriate and required authorization. In this case, the initial presenting problems did not include the difficulties associated with the traumatic brain injury. It may, however, be difficult to intervene effectively without the knowledge and experience necessary to understand the complexities of central nervous system dysfunction.

As long as the focus of your intervention is the challenges associated with a personality disorder, you may be able to continue to work within your established clinical relationship with the client, if you obtain consultation from a member authorized in clinical neuropsychology, who can help to tailor the interventions to take into account the client鈥檚 new challenges. If the task becomes one of helping the client address these new challenges as well, then it may be appropriate to consider a referral for someone authorized in both clinical psychology and clinical neuropsychology.

This is a difficult situation. If you agreed to such a request, please contact the Quality Assurance team at the College. Depending on the circumstances, they will do their best to assist in finding a creative solution.

The College has the authority to obtain a file in the absence of client consent. This is set out in legislation and is non-negotiable. In obtaining consent to collect personal health information, which must be done before collecting the information, it is important to avoid giving the false impression that the client has any control over whether the College exercises it鈥檚 legislated duty to obtain information in procedures designed to protect the public interest, in this case, to ensure that members are practicing competently and ethically.

While it is understandable that clients want to have control over who has access to what is often their most private information, careful framing of the issue听may help avoid at least some difficulties of this nature. It may be best to let clients know that in order to provide the services they are seeking, you must 听maintain a file in accordance with the College鈥檚 requirements (available on the College鈥檚 website) and that, while you will protect their confidentiality where client consent is required before disclosing their personal health information, there are some situations in which legislation mandates disclosure, even in the absence of consent. This is the case when review of information is required in order to protect clients and others from harm. In other words, the question is: do you agree to engage in services with the knowledge that I must keep a clinical record and that in rare circumstances the law allows access to the file without consent?

It may also help to advise that this applies to any service by a regulated health professional in Ontario who is practicing ethically and lawfully. Additionally, the College and all of it鈥檚 agents and staff have a strict duty of confidentiality and that in Quality Assurance matters, where the College Assessor and Reviewer may have access to the identity of a client whose file is under review, the Committee members will not be provided with identifying information.

When deciding whether to discontinue services, the client鈥檚 needs and best interests should always come first. That said, there may be valid reasons you can鈥檛 continue, such as retirement, closing your practice, if you can no longer remain objective (Standard 12.1) or if the service is no longer likely to benefit the client ().

However, even when there is a valid reason, you cannot discontinue services unless at least one of the following applies:

• the client requests the discontinuation,
• the client withdraws from the service,
• reasonable efforts are made to arrange alternative services,
• the client is given a reasonable opportunity to arrange alternative services, or
• continuing to provide the services would place you at serious personal risk.
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You should give clients reasonable notice before discontinuing services and referral options for alternate services (Standard 2.3). Sources for referrals could include:

Psychological services

• Transfers to known referral sources
• Referral to other psychologists/psychological associates searchable through the
• Referral to the Ontario Psychological Association鈥檚 electronic 鈥溾��
• Referral to the Ontario Association of Mental Health Professionals

Applied behavioural analysis services:

• Transfers to known referral sources
• referral to other RBAs searchable through
• Referral to Autism Ontario鈥檚
• Referral to
• Referral to the (鈥极狈罢础叠础鈥�)

Reflection questions:

• Is discontinuing services in the client鈥檚 best interests?
• Have I given enough notice based on the length or nature of each specific case/treatment?
• Have I made a reasonable effort to arrange for alternate services or provide the client with referral options?

No. You鈥檙e free to decide whom to provide services to and are not obligated to accept every new client referral. There are many reasons why you may not be able to accept a client, including scope/competence, caseload, waitlist length, or proper 鈥渇it.鈥�

Yes. You鈥檙e free to responsibly use technology, including AI, as a support tool for service delivery. Even with the use of AI, you continue to be fully accountable for the services you provide, and therefore, the use of technology should be actively monitored, and all notes or reports should be reviewed.

As part of the informed consent process, clients should be aware and understand how technology is being used to assist the registrant and the risks to privacy and of technological error.

Registrants should use their professional judgement to determine the appropriateness of AI use for their context. Standard 17: Use of Technology provides additional guidance regarding the responsible use of technology.

Reflection questions:

• Have I assessed the potential risks and mitigated these before employing the use of AI?
• Am I competent in the use of AI?
• Am I reviewing AI-generated data for accuracy?
• Have I included information about the risks of AI use in my consent process?

Registrants should regularly assess the client鈥檚 progress to determine if virtual care continues to be appropriate and beneficial for the client.

When providing virtual care, follow Standard 17: Use of Technology by ensuring:

• You are competent in the technology used and understand its risks
• You obtain informed consent from the client, including communicating how the technology is used and any associated risks
• The virtual platform protects client privacy

The Canadian Psychological Association鈥檚 and the American Psychological Association鈥檚 may also be helpful resources to consider.

The certificate is valid for one year and must be renewed annually on the date of authorization. Registrants will be emailed a renewal package approximately 6 weeks prior to this date.

If you are licensed in another Canadian jurisdiction, you may be eligible to provide services under the . All other practitioners must obtain a Certificate of Registration from 91视频 to provide services to a client who is physically located in Ontario.

Temporary registration for limited telepsychology practice is available to individuals licensed to provide psychological services in other jurisdictions. Learn more or apply for this type of registration.

It depends on the jurisdiction. You should receive permission from the regulatory authority in the jurisdiction where the client is located before providing services.

Some exceptions enable Ontario registrants to service clients in other jurisdictions with their Ontario licence. Details are outlined in the following resources:

• Memorandum of Understanding with Nunavut

If there is uncertainty regarding jurisdiction, for example, in military or diplomatic situations, you may wish to seek independent legal advice before providing services.

If you鈥檝e received permission from another jurisdiction to provide services, you should be aware of the standards, regulations and legislation specific to that jurisdiction. You should also confirm that your professional liability insurance covers the services you intend to provide.

Your client鈥檚 best interests should always be a priority. This includes considering whether in-person or virtual services are most appropriate.

Yes, you can continue to see your clients virtually if you are travelling or working abroad and if your client(s) are in Ontario.

Percentage-based or fixed-fee arrangements may be an acceptable financial arrangement for a shared practice (e.g. for administrative overhead or supervision services) as long as:

• Fees are based on the time spent and complexity of services provided (Standard 15.1 (b)) and
• Financial arrangements are fair and not influenced by differences in authority within the practice. Registrants should not use their professional knowledge, title, or position to gain an improper advantage or benefit, or to exploit any person. (Standard 12. 6 鈥� Avoidance of Exploitation)
• Clients鈥� needs are the primary consideration for service planning.

Additionally, under , registrants cannot:

• Receive or offer a rebate, fee or any other benefit in exchange for client referrals (Section 1.26)
• Provide a service unlikely to benefit the client (Section 1.9)

Reflection questions:

• Do the fees collected constitute a referral rebate or benefit to the provider?
• Are the fees based on time spent and complexity of services provided?
• Do the fees charged or received between registrants constitute exploitation?

Yes, registrants may charge a fee for providing access to, or copies of, an individual’s personal health information. The fee must be for reasonable cost recovery. , provides guidance on determining what is a reasonable cost recovery, considering the time required to review records and the complexity of the information. For example, more complex records require more time to review, which may result in a higher fee. Simple records require a quick review and, therefore, typically result in a lower fee.

Please refer to the for more detailed guidance when determining fees.

Reflection questions:

• Have I considered the nature, time and complexity required for review in my fees?
• Would my fees be considered 鈥渞easonable鈥� considering PHIPA Decision 133?

No. Registrants cannot withhold reports for non-payment of fees (Standard 15.2). Registrants must provide a report or certificate within a reasonable timeframe when requested by the client or their authorized representative ()

If you鈥檙e concerned that the client may not pay for a service, you can implement a prepayment plan. You may also use collection agencies and other legal means to obtain payment.

Registrants can request prepayment for a service if the funds can be returned if not used. Prepayments for a group session/series are common. Registrants should document that the client has agreed to prepay for the service and when the service is provided. Accepting a retainer for unlimited, on-demand service is not acceptable. (Standard 15.2)

Reflection questions:

• Am I able to identify the amount used and return the funds if required?
• Has the client consented to prepayment of services?
• Is the prepayment for a fixed number of sessions versus an unlimited or on-demand therapy arrangement?

Interest may be charged on an overdue account, provided appropriate consent has been obtained. Interest charged should not be excessive or used in a way that exploits the client. 91视频 诲辞别蝉苍鈥檛 provide a specific amount or interest rate. The sets legal limits on the interest rate to help guide what is appropriate.

Reflection questions:

• Am I charging an interest rate that could be considered excessive?
• Have I researched what a normal interest rate is for the charge?
• Have I obtained legal advice, and would the charge be defensible?

Ontario Harmonized Sales Tax (HST) requirements are outlined by the (CRA).

Many healthcare services are HST-exempt, including psychology services. This means that registrants providing psychotherapy, assessment, or treatment of mental health conditions do not charge HST. In contrast, ABA services are generally subject to HST requirements, except for services designed to assist individuals with autism. .

Some services that fall outside a health treatment plan, such as teaching, administration, consultation, or research, are not HST-exempt. . You are encouraged to consult a financial professional to determine whether HST applies to the services you provide.

Clients must be informed of any fee increases before services are provided, as part of the informed consent process. This allows clients to consider the increased fees when deciding whether to proceed with a service. Providing adequate notice is also important, as a fee increase may affect the client鈥檚 ability to continue services and could require termination of services and a referral. (Standard 15.1)

You should use your professional judgment when deciding whether to offer virtual care. You鈥檙e expected to consider both the risks and benefits, as well as the needs of each client. For example, consider:

• Whether the client may be more comfortable and likely to engage virtually;
• potential loss of visual cues and other sensory inputs;
• increased risk of privacy breaches;
• accessibility/boundary issues.

Virtual care should only be used when clinically appropriate, with the client鈥檚 best interests as your top priority (Standards 17.1, 12.7). If in-person service is clinically needed and you do not wish to provide it to an existing client, you should support a referral to an appropriate provider.

If you offer only services virtually, consider which populations and conditions can be appropriately addressed without in-person contact.

Reflection questions:

• Is virtual care the most appropriate option for this client?
• Is the client able to engage effectively in virtual care?
• Can the client access a private space to receive virtual care?
• Are there other ethical considerations that may be relevant for the client?

A: There is no mandatory reporting requirement for IPV outside of the requirements in the when it is suspected that a child is at risk and in need of protection. That said, there may be situations that would warrant a provider to disclose confidential information if an individual may be at risk. See FAQ: Must I report suspected harm to self or others? for more information on how to determine whether to breach confidentiality in cases of suspected harm.

The Office of the Information and Privacy Commissioner of Ontario (IPC) has developed a to assist professionals to make informed decisions about privacy, confidentiality, and public safety, particularly around assessing and reducing IPV risk.

If you determine there is no significant risk of serious bodily harm, you should then consider risk of recurrence by assessing the presenting risk factors and/or using the appropriate . Your findings that inform decision-making on next steps should be documented.

Standard 9.2 – Individual Client Records states:
Registrants must keep a record regarding the services they provide to each client. Each record must contain…
d. Relevant information about every material service activity that is carried out by the registrant or under the responsibility of the registrant, including, but not limited to: assessment procedures; assessment findings; diagnoses; goals or plans of service; reviews of progress with respect to goals and/or of the continued relevance of the plan of service; activities related to crises or critical incidents; and interventions carried out or advice given;
… and
l. Any other documents that provide information relevant and material to service that is not included elsewhere in file, and which is relevant to the opinions, recommendations and decision making with respect to client service.

If a client presents with indicators that suggest they may have a diagnosable disorder, you should consider whether the assessment should be conducted by a Clinical Psychologist. Beginning to work with a client who may need to be transferred could be disruptive.

Registrants who practice Counselling Psychology have the ability to formulate and communicate a differential diagnosis to develop an appropriate counselling intervention and to identify clients who must be referred.

Reflection Questions:

• Are the presenting issues related to 鈥�fostering and improving human functioning by helping individuals solve problems, make decisions and cope with stresses of everyday life鈥�?
• Does the intake assessment of the client indicate there are other potential disorders or presenting challenges regarding “the application of knowledge about human behaviour to the assessment, diagnosis and/or treatment of individuals with disorders of behaviour, emotions and thought鈥�?
• If the client is presenting anxiety or depression, are the conditions relatively mild and related to the stresses of everyday life?
• How long has the client been experiencing the presenting challenges?
• How severe or debilitating are these issues?
• Is it in the client鈥檚 best interests for me to treat their presenting issues, or would it be less disruptive to refer them now?
• Have I treated this case presentation in the past?
• Do I have the necessary knowledge, skills and training to provide the services being requested?
• Are there challenges that might arise that could fall outside of my competence or require specialization that I do not possess?

The 鈥�Definition of Practice Areas鈥� is included in the Registration Guidelines.

Clinical Psychology is defined as: “the application of knowledge about human behaviour to the assessment, diagnosis and/or treatment of individuals with disorders of behaviour, emotions and thought鈥�.

Counselling Psychology is defined as: fostering and improving human functioning by helping individuals solve problems, make decisions and cope with stresses of everyday life. It addresses difficulties that may cause distress to an otherwise well-functioning or psychologically healthy individual, including challenges related to work/career/education, family and social relationships, mental health, and physical health. Some common examples are bereavement, unemployment, marital separation, or bankruptcy, etc.

鈥淧arents鈥� are not identified as a specific client group. The required competency will depend on the specific services being provided to parents, for example:

• To provide psychoeducation to parents about child development and advice on addressing childhood difficulties, you must be authorized to work with children to understand the developmental factors at play with children/adolescents.
• To help parents improve their relationship with their child, you must be authorized to work with families and have the specialized knowledge, skill, and experience in family dynamics.
• If the service is intended to help the parents work together as a couple, you must be authorized to work with couples.
• If the work involves assisting a parent who experiences challenges in interacting with a child and requires them to receive individual therapy to address their own difficulties, you must be authorized to work with clients within that parent鈥檚 age group.

Reflection Questions:

• Does the focus of the intervention relate to a client group I am authorized to provide services to?
• Am I competent to provide the service for its intended target/purpose (ie. to support parents with child development concerns, the parent-child relationship, couple dynamics, or to provide individual therapy)?

There may be situations where it鈥檚 appropriate to involve a client鈥檚 family member to support their treatment. Providers may involve family member(s) to support the client鈥檚 treatment, but the family member(s) wouldn鈥檛 be the object of the intervention. For example, family member(s) may be involved in facilitating changes in the client鈥檚 environment or trained to reinforce part of a behavioural intervention program. A family member may also attend sessions with a person who requires support, and to help the client obtain optimal benefit from therapy.

However, if the purpose of involving family members is to facilitate changes in family dynamics or the way family members interact, you must be authorized in families and have specialized knowledge and training, as this would be viewed as a family intervention. For example, targeting a client鈥檚 symptoms or behaviours by addressing the patterns of interaction between family members.

Reflection Questions:

• Who is the recipient of services?
• What is the purpose of the intervention, and who is it targeted towards?
• Am I working with members of the family to affect change in the family dynamics? If so, am I authorized for the client group of 鈥渇amilies鈥�?

Registrants are expected to use their professional judgment to determine whether a client falls within the population(s) they are authorized to serve. When trying to determine if a client at a border age falls within your client group, you should consider whether the person鈥檚 abilities, life circumstances and challenges are consistent with population group norms you are authorized to work with.

To determine whether you are authorized and competent to provide a service, the reason for the initiation of services should determine whether you have the required competency.

If the service is unrelated to a client service, you may provide general services without a specific authorization or client group, such as:

• act as an administrator of an organization that serves various populations;
• conduct a research study; or
• teach an undergraduate course.

See Standard 5.1 鈥� Authorized Areas and Client Groups for more information and examples.

Reflection Questions:

• Have I conducted a comprehensive intake assessment to ensure I understand the client鈥檚 challenges and complete case presentation?
• Are the client鈥檚 presenting issues consistent with issues within my authorized client groups and authorized area(s) of practice?
• Do I have the necessary knowledge, skills and training to provide the services being requested?
• Have I treated this case presentation in the past?
• Are there challenges that could arise that would fall outside my competence or require specialization that I do not possess?
• Would it be in the client鈥檚 best interests to refer them to someone with specific skills or training in this area?
• Should I consult with other colleagues to seek further clarification?

91视频 诲辞别蝉苍鈥檛 specify hard borders between age ranges for the different population groups. The approximate ranges for each population group are the following:

• Children up to ages 12 or 13;
• Adolescents up to age 19;
• Adults to 65 or 70;
• Seniors 70 and above.

You must submit enough information for the Client Relations Committee to confirm your eligibility. This includes detailed information on the dates you were a client of the registrant and a description of the alleged abuse.

You will be asked to provide details of your chosen therapist or counsellor to 91视频 staff. Once approved, 91视频 will pay your therapist or counsellor directly.

You may be eligible for funding if it鈥檚 alleged that you were sexually abused by a registrant while you were their client or while you were a client of someone supervised by a registrant. In some rare situations, funding may also be available if the Client Relations Committee has sufficient information to determine whether the eligibility criteria have been met. If you believe you may be eligible for funding, we encourage you to contact the Client Relations team at clientrelations@cpbao.ca to discuss your situation.

The maximum amount of funding available per person is equal to the amount the Ontario Health Insurance Plan (OHIP) would pay for 200 half-hour sessions of individual out-patient psychotherapy with a psychiatrist on the day the person becomes eligible.

The current maximum amount is $20, 470. If OHIP or a private insurance plan provides partial coverage, 91视频 will only pay the portion not covered.

Yes. Funding must be paid directly to the therapist or counsellor and used only for therapy or counselling. It can鈥檛 be applied for any other purpose, such as missed appointments, travel, accommodation, or other incidental costs.

Funding is available for up to five years from:
(a) the date the Client Relations Committee approves your application; or
(b) the date your eligible therapy began, if you started therapy for sexual abuse before your application was approved.

No. You may choose any therapist or counsellor, as long as they
(a) do not have a family relationship with you; and
(b) have never, in any jurisdiction, been found guilty of professional misconduct of a sexual nature or been found civilly or criminally liable for a similar act.

No. The Client Relations Committee only reviews documents.

The Client Relations Committee requires sufficient information to be satisfied that the criteria for eligibility have been met. The College recognizes however, that the information provided is very personal and sensitive. To this end, the Client Relations Committee will access only the minimum amount of information required to adequately undertake its review. An applicant鈥檚 surname will not be shared with the Committee and will be known only by College staff presenting the application to the Committee and processing the payments.

Yes. Decisions about your funding eligibility are not public and are not shared with registrants or other College Committees. The application details are reviewed only by a panel of the Client Relations Committee.

To apply for funding, please contact the Client Relations Team at clientrelations@cpbao.ca. Staff will work with you to determine the best way to provide the required information to the Client Relations Committee.