Until recently, we believed that psychotherapy was going to be a controlled act, and that only regulated professionals (Psychologists, Nurses, Occupational Therapists, Physicians, Registered Psychotherapists or Social Workers) would be able to perform it.
We believed that was the point of creating the new College of Registered Psychotherapists: To bring a previously unregulated group into the fold of professionalism, with expectations for their training, and rules and ethical guidelines governing their conduct, for the protection of the public.
The next step would be to make psychotherapy a controlled act, available only to the members of the new College, and the other Colleges whose members offer psychotherapy. And when that happened, the Wild West would be tamed: Only those whose credentials and training entitled them to perform the controlled act could do so.
Recently, we received an invitation from the College of Psychologists of Ontario to review a draft document entitled “Understanding when Psychotherapy is a Controlled Act,” which was developed by a coalition of five of the six colleges which regulate the professions which will have access to the controlled act of psychotherapy. We have also examined an education video designed to train professionals.
While we recognize that CPO suggested only that we provide input “as to whether these resources provide sufficient clarity,” there appears to be a new model for the regulation of psychotherapy upon which these materials are based. We wish to register our deep concern with that model.
The document indicates, “The controlled act of psychotherapy is a smaller aspect of the overall practice of psychotherapy.” To meet the criteria of the controlled act, the psychotherapy must meet all five of the following components:
The accompanying video makes clear that psychotherapy will be considered a broader category than the controlled act of psychotherapy: All activity falling under the five-pronged definition of the controlled act will be psychotherapy, but not all psychotherapy will meet the definition of the controlled act.
In other words, in this model, the practice of psychotherapy will frequently remain completely unregulated.
Here are some of the disturbing implications of this model:
We recognize the extraordinary difficulty of identifying a clear, universally applicable definition of psychotherapy. However, we believe this attempt to control the act of psychotherapy has, at best, failed to produce an improvement over the previous era in which psychotherapy was entirely unregulated:
We believe that it is entirely possible that the proposed model will be worse than no regulation at all.
We recommend the following solution:
All psychotherapy should be a controlled act, which, by definition, takes place only with the involvement of a regulated professional competent in the provision of psychotherapy.
In this context, the proposed definition would work, though we would recommend that the wording be adjusted so that not all five features must be present in the act of psychotherapy; the salient feature should be the involvement of a regulated professional, identified by their college as competent in the provision of the controlled act of psychotherapy. Each regulatory college will be able to define for their own members the adequate training and background for the provision of psychotherapy.
The most important targets for legislative control are the titles “psychotherapist,” “Registered Psychotherapist,” and “psychotherapy.” The circularity of the definition is less critical when the regulatory colleges control both the titles of the professions, and the right to hold oneself out as providing psychotherapy.
If mechanics are empowered to offer “30 minutes of free Psychotherapy with every oil change!,” an extreme example which does not appear to be illegal in the proposed model, the risk to the public is clear, whether or not the mechanic’s actions cross into the realm of the controlled act. The proposed model makes it improbable that the mechanic could be successfully prosecuted, with five kicks at the can to achieve reasonable doubt that the service crossed the line.
The title “Registered Psychotherapist” is already controlled. The term “psychotherapist” should be allowed colloquially to describe any registered professional who offers psychotherapy. And only authorized professionals should be allowed to hold themselves out as offering psychotherapy.
This solution is simple, elegant, and enforceable. It also recognizes the rights of the public to seek alternative practitioners if they so choose, provided they do not use the title “psychotherapist,” nor the term “psychotherapy” to describe the service. It honours the ability of each regulatory college to determine for their own members what constitutes adequate preparation for conducting psychotherapy within each profession.
Terms such as “counselling,” “coaching,” “treatment,” and even “therapy” remain unregulated, and can be applied freely—even by mechanics and hairstylists. As a result, there will be no imposition on those who intend to provide something approaching psychotherapy—they just won’t be allowed to use the word. As a result, “psychotherapy” will be recognized as, by definition, something that can only be provided by a regulated professional.
We urge that the Colleges and professional Associations unite in condemning the proposed model in which some psychotherapy will remain unregulated. We ask that they work with the Government to ensure that the citizens of Ontario are protected from psychotherapy provided by those with inadequate training or supervision.
Please, contact your MPP and let them know that you care about the regulation of psychotherapy in Ontario.