The Question of Regulation
Having completed my training at the Centre for Training in Psychotherapy in Toronto, my thoughts turned again to the whole issue of regulation (or the lack thereof) in Ontario, and other provinces. It has become a rather vexed issue, with multiple and compelling arguments for and against, from diverse organizations. It is also clear that there are certain fundamental issues about psychotherapy which ought to be raised during this time - with the government and with all the parties involved: professional organizations, consumers etc.
In 2001, The Health Professions Review Advisory Council made a series of recommendations relating to the Regulated Health Professions Act. Most of these documents deal with professions other than those involving psychotherapy, but there were a series of recommendations made which would, if implemented, affect the careers of thousands of practitioners, including psychotherapists (who are not psychologists or psychiatrists), counsellors, crisis workers, ministers, rabbis, hostel workers and probably many others. The relevant documents can be found here , the site of the Health Professions Review Advisory Council Website. Of special interest is the document entitled, Weighing the Balance .
The specific recommendations in question are as follows:
• possible restriction of psychotherapy to RHPA professions, or the College of Psychologists adding "psychotherapy" to its list of controlled acts
• adding the element of "psychological harm" to the harm clause
• removing the word "serious" from the harm clause
• removing the word "emotional" from the exemptions for counselling
• reserving the terms "registered", "regulated", "licensed" or "certified" to health professions regulated under RHPA.
The idea being that only those practitioners recognized by this legislation could practice psychotherapy, since the act of psychotherapy or counselling can cause "psychological harm" if not performed competently. It would also make illegal any professional conversation that dealt with emotional issues by someone other than, according the to the recommendations as they stand, a psychologist or psychiatrist.
Not surprisingly, the self-regulating bodies affected by these recommendations have had something to say about it all. I won't list them all here, but you can find some material at the Ontario Association of Consultants, Counsellors, Psychometrists and Psychotherapists website , the Ontario Association of Marital and Family Therapy , who has a very thoughtful set of responses . You can also look at the Ontario Society of Psychotherapists , and the Canadian Counselling Association (in the Advocacy section under letters- including a wonderful letter from someone at an organization called Career/Lifeskills Resources). A number of these groups have formed a coalition to lobby the Council and the Ministry of Health and Long Term Care. The list of members of this coalition will give you an idea of the scope of who might be affected by the proposed changes.
What I have gleaned from the above (among other things) is the fact that should these recommendations become law, then every psychologist, psychiatrist and general practice psychotherapist (MD"s) would be instantly swamped. Psychiatrists themselves are mostly overbooked and many have closed their practices to new patients already. Not to mention that every women's shelter, youth hostel, community mental health centre would have to immediately stop doing any kind of counselling that might involve emotional issues -assuming they didn't have a psychiatrist or psychologist on site at all times who would be prepared to see each and every client that came through the door. You see where I'm going with this - it's absurd. I can't imagine any one group wanting to shoulder this burden.
The most important point about all of this is not that these organizations are against regulation, but the fact that they stand the chance of being left out of a process that would see them legislated out of business. Most would agree that the lack of regulation in Ontario is a problem and is, if nothing else, confusing for someone seeking psychotherapy or counselling. At worst, the fact that anyone can wake up one day and call themselves a psychotherapist in Ontario can lead to all kinds of abuse and shoddy practice. Clearly some kind of regulating legislation and governing body is required, but it is also the case that no one group should be able to lay claim to legitimacy.
There seem to be two main points to be considered. One is making "psychotherapy" a controlled act. The other is how the word "emotional" is used in the recommendations, and presumably in any resulting legislation.
The first problem then is to define psychotherapy. Who will define it? Based on what criteria? What sort of training is required of someone practising psychotherapy? If this process is to be fair and inclusive, any definition would have to satisfy all the groups involved. What is true, is we all have different training and expectations of training. Some groups require their members to have had psychotherapy themselves, some do not. Some train from a strictly behavioral model, some from a psychodynamic model. There would need to some kind of agreement about what constitues adequate training. From what I can see, all of the self-regulating groups adhere to a code of ethics (much like this one ) of some kind, as do the Ontario Psychological Association (through the College of Psychologists ). The phenomenon of a code of ethics seems a good place to start, since we can all agree, I think, on what constitutes ethical practice. As for training, this may prove difficult, as each group tends to believe that theirs is "right".
The second problem is far more difficult. The case could be made to say that any conversation between people involves emotional issues, and thus, if stretched, would be illegal under the proposed guidelines. Even if the idea that this is a fee for service is taken into account, then every lawyer, credit counsellor, hairdresser would have to go back to school. I don't see how the inclusion of the word "emotional" in this context can be reasonably considered.
We do need some kind of regulation. A governing body and a college to implement the regulations, administer examinations, assess training programs would all be necessary as well. In the interests of everyone seeking psychotherapy and counselling, the process which would lead to this must be multi-lateral and free from the various professional biases and proprietary zeal with which our professions are rife.
So, as I start my own practice, I will look on with great interest as all of this unfolds and hope that calm and thoughtful heads prevail, as I think we all do.
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