I have some questions about my application for registration, who should I contact?
I’d like to send some registration information / documents / forms to the College, how should I do that and who should I send it to?
Please note that College of Psychologists office is currently closed to visitors. All office functions are being handled remotely with a full complement of staff. Emails and telephone calls continue to be answered as normal. Regular surface mail is being received, however we are unable to accept courier packages. Where possible, please send any materials to the College by email: cpbao@cpbao.ca.
Are the College’s Oral Examinations cancelled?
Due to the coronavirus pandemic, the College is unable to offer the in-person Oral Examinations as we normally would. The College does not wish to cancel the Orals but rather has decided to move them to a virtual administration for those candidates who wish to participate in this way.
I need to take the EPPP , are the testing centres open?
UPDATE: The College is aware that some Pearson Vue testing centres in Canada have re-opened with limited availability. Candidates are reminded to be aware of the possibility that Pearson Vue may be required to cancel and re-schedule an exam appointment as a result of local social distancing requirements and/or other COVID-19 related concerns.
Pearson Vue continues to update its website with information as it becomes available. Check Pearson Vue’s website for updates: https://home.pearsonvue.com/coronavirus-update
Please also visit the Association for State and Provincial Psychology Boards (ASPPB) https://www.asppb.net/page/pearsonCOVID19updates
I have not yet received my wall certificate. When can I expect it?
As staff have been working remotely since mid-March 2020, the College has been unable to produce wall certificates for new members and corporations. These certificates require special printing and original signatures. We will be sending these out at the earliest opportunity, however we do not have a date when they will be available.
How will the Jurisprudence and Ethics Examination (JEE) be taking place?
The College is very pleased to announce that arrangements have been made to move the JEE to an on-line proctored examination. Eligible candidates will be able to take the JEE from their own computer under the supervision of an on-line proctor.
For more exam information and to to see the dates for the next administration please click here.
Private: Must masks be worn in the office, particularly when it’s possible to maintain a physical distance of at least 2 metres?
Originally published in HeadLines Volume 1 Issue 2
Regulated Health Professionals are subject to Directive #2 of the Chief Medical Officer of Health. This directive states that: In the gradual restart of services, Health Care Providers must comply with the requirements as set out in “COVID-19 Operational Requirements: Health Sector Restart” (May 26, 2020 or as current), including, but not limited to, the hierarchy of hazard controls.
The hierarchy sets out the following measures, in order of priority:
- Elimination and Substitution – examples include not having patients physically come into the office/clinic, use of telemedicine, etc;
- Engineering and Systems Control Measures – examples include physical barriers like plexiglass partitions;
- Administrative Control Measures – examples include active screening, passive screening (signage), and visitor policies;
- Personal Protective Equipment – examples of PPE include gloves, gowns, facial protection (including surgical/procedure masks and N95 respirators), and/or eye protection (including safety glasses, face shields, goggles, or masks with visor attachments).
As noted previously, the Ministry recommendations must be general enough to apply to all health care providers. As a result, some of the examples provided may not be applicable to psychological services.
The Ministry is clear that PPE controls, such as masks, are the last tier in the hierarchy of hazard controls. Accordingly, they should not be relied on as a stand-alone primary prevention program. The Operational Requirements clearly state: Given community spread of COVID-19 within Ontario and evidence that transmission may occur from those who have few or no symptoms, masking (surgical/procedure mask) for the full duration of shifts for HCPs and other staff working in direct patient care areas is recommended.
Some local areas have enacted by-laws requiring mask use in indoor public settings, with exceptions to this requirement for health care providers. It is likely that such exceptions have been made in order to enable some health care procedures which cannot be performed while a mask is being worn.
The College continues to recommend that services should be provided virtually when possible. When in-person services are required, members should wear masks and require clients to do so in enclosed spaces, unless this is clinically contraindicated.
What can be done if an employer refuses to provide supplies, like plexiglass screens, that a member deems necessary to use when testing clients?
Originally published in HeadLines Volume 1 Issue 2
This can be a difficult situation to navigate and we are advising members to make best efforts to negotiate resolution of such problems.
The Standards of Professional Conduct, 2017 require:
2.1 General Conduct
A member must conduct himself/herself so that his/her activities and/or those conducted under his/her direction comply with those statutes and regulations that apply to the provision of psychological services.
and,
3.1.2 Employment Settings
A member must assume responsibility for the planning, delivery, and supervision of all psychological services he/she provides to a client. Members working as employees must make best efforts to ensure that their work setting adheres to the Standards of Professional Conduct, 2017 in the planning, delivery, supervision and billing practices of all psychological services provided.
The College is not authorized to regulate workplaces, only the conduct of individual members. As stated above, members are required to make best efforts to ensure that the work setting adheres to the Standards. This may involve escalating the issue within their organization and seeking outside assistance where necessary. Hopefully, in most cases, collaborative communication will help to resolve any “standoffs”.
Members may wish to advise those with the authority to grant their requests that Directive #2 has been issued to all Regulated Health Providers under Section 77.7 of the Health Protection and Promotion Act, 1990 and requires Health Care Providers to consider which services should continue to be provided remotely and which services can safely resume in-person with appropriate hazard controls and sufficient PPE.
Must all clients be actively screened, even in a setting such as a school or social service agency?
Originally published in HeadLines Volume 1 Issue 2
The COVID-19 Operational Requirements: Health Sector Restart indicates that health care professionals should perform active screening, although we understand this can be assigned to a staff person. Screening should be done with the client. If it is believed that a client is unable to answer the screening questions reliably, it should be done in discussion with a person’s parent or caregiver.
The Operational Requirements state: Patients should be screened over the phone for symptoms of COVID-19 before coming for their appointments. If possible, any visitor accompanying a patient to an appointment, should also be screened prior to the appointment. The latest COVID-19 Patient Screening Guidance Document on the MOH COVID-19 website should be used and may be adapted as needed and appropriate for screening purposes. If a patient screens positive over the phone, the appointment should be deferred if possible and the individual referred for testing.
If an assessment is conducted virtually, instead of in-person, may members violate the standard administration protocols for tests. Will norm-based scores be applicable and what effects will the stressful context of the pandemic have on test performance?
Originally published in HeadLines Volume 1 Issue 2
The College’s expertise and role is limited to professional regulation. It is beyond the purview of the College to provide clinical guidance to members. The College trusts that members practicing the profession have the knowledge, skill and judgment required to make appropriate clinical decisions.
With the large number of tools, techniques and tests in use, members should obtain current guidance from the test publishers about the administration procedures and the applicability of norm-based scores. At those inevitable times when answers are not clear, members may find it helpful to discuss these issues with other clinicians who they believe have relevant expertise.
As in all cases, interpretation of test results includes consideration of the context in which an assessment is conducted. The Standards of Professional Conduct, 2017 which guide members in making such judgments include:
10.1 Familiarity with Tests and Techniques
Members must be familiar with the standardization, norms, reliability, and validity of any tests and techniques used and with the proper use and application of these tests and techniques.
Practical Application: At times, a member may provide services in what would be considered an emerging area of practice. In such situations, a member should inform clients that the services being offered may not, yet, have been subjected to extensive research and validation. As with any informed consent process regarding the provision of services, clients would be informed of the risks, benefits and alternatives available.
10.2 Familiarity with Interventions
Members must be familiar with the evidence for the relevance and utility of the interventions used and with the proper use and application of these interventions.
10.3 Rendering Opinions
A member must render only those professional opinions that are based on current, reliable, adequate, and appropriate information.
10.4 Identification of Limits of Certainty
A member must identify limits to the certainty with which diagnoses, opinions, or predictions can be made about individuals or groups.
We have become aware from members that test publishers are providing guidance about how measures which rely on standardized administration procedures may be utilized. It is a member’s responsibility to ensure that they are using the tools properly, based on empirical evidence and good clinical judgment.
Is there an obligation to release a client’s name and contact information to public health if a client attends a session in-person and soon after tests positive for COVID-19? What information (if any) should be disclosed to other clients or professionals who may have crossed paths with the infected individual in our workplace?
Originally published in HeadLines Volume 1 Issue 2
If someone has tested positive, the local Public Health agencies are expected to follow appropriate protocols with respect to notifying those who must be notified.
There does not appear to be a requirement for a member of the College to make a mandatory report of someone who has identified themselves as, or is suspected of being, COVID-19 positive. There are, however, provisions in the Health Protection and Promotion Act, 1990 that authorize the Chief Medical Officer of Health to make an Order requiring the release of confidential information, as specified in that Order. If ordered to provide information, the College would not expect a member to put themself in contempt of the Order. To date, we have not heard about any members receiving such Orders. If one is unsure of the nature of such an Order or the information it may require by released, one should seek legal advice.
If concerned about individuals who may have crossed paths with an infected person, it would be permissible and reasonable for a member to provide general de-identified information to other clients and suggest they may wish to be tested. One should, however, take care not to provide any information that could identify the other person.
Confidentiality provisions under the Personal Health Information Protection Act, 2004 (PHIPA) prohibit the disclosure of personal health information without authorization by the client, other than in specified circumstances. Exceptions to the duty of confidentiality are set out in sections 39 (regarding certain health programs) and 40 (regarding risk of serious bodily harm). It is important to remain aware that these exceptions permit one to make disclosure but do not require this. When one uses the discretion to make a disclosure without a client’s permission, only that information which is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons should be disclosed. Additionally, such information should only be disclosed to a person who is in the position to eliminate or reduce the risk.
If unsure about whether a disclosure is permissible, it may be useful to obtain the opinion of a qualified legal professional. Many professional liability insurance policies entitle the policy holder to pro-bono legal advice.
May I require that clients provide proof of vaccination before providing in-person services?
Ontario has recently mandated that individuals must be vaccinated before entering specified high-risk settings. These settings are listed in O. Reg. 364/20: Rules for Areas at Step 3 and at the Roadmap Exit Step under the Reopening Ontario Act, 2020. It appears that this requirement does not apply with respect to entering a place for the purpose of health care.
The Ontario Human Rights Commission recently published a policy statement which provides guidance with respect to COVID-19 vaccine mandates and proof of vaccine certificates. It states, among other important things, that:
While receiving a COVID-19 vaccine remains voluntary, the OHRC takes the position that mandating and requiring proof of vaccination to protect people at work or when receiving services is generally permissible under the Human Rights Code (Code) as long as protections are put in place to make sure people who are unable to be vaccinated for Code-related reasons are reasonably accommodated. This applies to all organizations.
Members considering implementing such policies may find useful information about how to proceed in the Ministry of Health’s Proof of Vaccination Guidance for Businesses and Organizations under the Reopening Ontario Act, Version 2, September 27, 2021. If additional information is required, members may wish to seek independent legal advice.
May I provide a client with a letter recommending an exemption to vaccination requirements?
It is our understanding that the criteria for an official “medical vaccination exemption” are very narrow and that these do not include psychological reasons. As well, only a physician, registered nurse or nurse practitioner may certify such an exemption for settings mandated to require proof of vaccination. It does not appear that members of the College of Psychologists are authorized to provide such certification. It is important that a client making a request of this type be aware of the limits of the member’s authority. Further information may be found in the Ministry of Health’s Questions and Answers, Version 2, September 28, 2021.
If the business or organization is not covered by the mandatory vaccination legislation, members could provide a professional opinion concerning a client’s need for accommodation. In doing so, as with any professional opinion given, they must be prepared to present a rationale for such an opinion.
Should a member proceed to provide a letter related to a vaccination exemption, members should clearly indicate that it is for psychological reasons and that, in keeping with Principle 10.3 of the Standards, “ must render only those professional opinions that are based on current, reliable, adequate, and appropriate information.” As well, it is important that members recognize they could be held accountable should an employer or other party mistakenly accept their letter as a valid official “medical exemption”, and remember that making a record, or issuing or sign a certificate, report or similar document that they know or ought to know is false misleading or otherwise improper, is an act of professional misconduct.
