*Question: I practise in Ontario but have a client outside of Ontario who wants to work with me.*
Whether a client resides in Ontario or in another jurisdiction, registrants may provide services using communications technologies as long as:
- they are able to do so competently and in a manner that abides by the Professional Practice Standards;
- there is no law, regulation or standard in the other jurisdiction that would restrict or prohibit the registrant from providing services to a client located in that jurisdiction; and
- they have appropriate liability insurance coverage considering the particular technologies used to provide services, the risks these technologies may present, and the possibility that the registrant’s practice will cross into other jurisdictions.
Registrants who provide psychotherapy using communications technologies (e.g. phone, video conference, etc.) have an electronic practice. Professional Practice Standard 3.4: Electronic Practice and the accompanying Guideline set out expectations for registrants who engage in electronic practice, some of which are highlighted below.
Registrants who wish to work with a client located in another jurisdiction must determine whether any law or regulation in that jurisdiction that would prevent them from providing therapy to the client. This might require, for example, that registrants investigate whether the practice of psychotherapy or counselling is regulated in the client’s jurisdiction and if so, that the registrant makes inquiries with the regulatory body there.
To an extent, a communications platform is its own therapeutic milieu that influences the therapeutic relationship and the therapy itself. Being able to leverage this therapeutic milieu safely and to the benefit of clients is an important skill. Familiarity and comfort with the technologies that are used in electronic practice can help registrants meet their obligations with respect to confidentiality and enable them to resolve technical issues that might arise during a session.
Before any therapy is provided, registrants must first evaluate the appropriateness of therapy, given the nature of the client’s concerns, their ability to access technologies safely and privately, and their overall comfort and capability with communications technologies. Therapists must also consider whether providing therapy in this manner would present a risk of harm to a client in light of the client’s symptoms and individual risk factors, for example safety in the home or possibility of adverse reaction during therapy.
There are added considerations for the informed consent process. For example, registrants are expected to enter into a contract with clients before providing services. In addition, therapists must inform clients of the technologies that will be used and discuss the risks to confidentiality that these technologies may present.
*Can I be registered with CRPO but be located in another jurisdiction?*
Residence in Ontario is not required in order to register with CRPO.
If a therapist who is regulated with CRPO is located outside Ontario, they will need to assure there is no law, regulation or accepted standard in that jurisdiction that would prevent them from offering services while in that jurisdiction. This applies whether the therapist is working with Ontario-based clients or clients in another jurisdiction.
*Question: I am not in Ontario but I have a client in Ontario who wants to work with me.*
CRPO does not require practitioners who reside in another jurisdiction to become registered in order to work with a client in Ontario providing:
- the therapist does not intend to advertise or otherwise promote their services in Ontario; and
- Ontario-based clients do not form a substantial proportion of the therapist’s workload
If any of these factors were to change, CRPO would revisit the facts and consider whether the therapist should apply for registration, even on a temporary basis.
In Ontario, non-registrants cannot use the title “psychotherapist” or hold themselves out as a psychotherapist. If you use the title or hold yourself out as a psychotherapist in your home jurisdiction, and your connection to Ontario is insignificant, CRPO will not take the position that you are using the title or holding out in Ontario. However, if your connection to Ontario is substantial (e.g. your advertising focuses on Ontario, a significant number of your clients are in Ontario, or you are regularly physically present in Ontario), you would not be able to use the title psychotherapist or hold yourself out as a psychotherapist unless you become regulated in Ontario.
In addition, non-registrants cannot perform the controlled act of psychotherapy in Ontario, defined as:
Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgement, insight, behaviour, communication or social functioning.
Non-registrants cannot perform this act on clients in Ontario, except in cases of emergency or where another exception applies (e.g. indigenous or spiritual healing). For information about the controlled act, see our web site.
For more information about registration please contact the Registration Department.
If you have other practice-related questions please contact practice@crpo.ca.
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