First, I must apologize to our behaviour analyst registrants. Much of what you see written here, and much of what the College Council has been focussing on in recent months, has been about psychology registration. Much of that discussion has little to do with the regulation of behaviour analysts. The focus of this column will mostly be on psychology.
I do want to thank the psychology registrants (and other, such as graduate students in psychology) for their ongoing, strong involvement in discussing these issues. I am glad that we work in an environment where such strong discussions and debates can occur openly. Many of these discussions have been thoughtful, clear, concerned, and passionate. I am grateful for the feedback that we have received to date.
« I am glad that we work in an environment where such strong discussions and debates can occur openly ».
There are a couple of pieces of misunderstanding (or “myths”) that I would like to address, however.
First misunderstanding is that some of the discussion has focussed on the government’s interest in increasing access to mental health services. The argument is that with the increase in psychotherapists, that should mean there is less of an issue. That has two misleading points. First, part of the initial concern with the government even regulating psychotherapy as a profession is that it would decrease access to care by only allowing some people providing “psychotherapy” to get registered with the new College. That is part of regulation and public protection to ensure that only competent people can provide that care. These people were providing psychotherapy services before, but without accountability to a government regulator. In effect, any government’s increasing accountability for services actually reduces access to those services. It is a natural by-product of new regulation. The government was aware of this and wanted to increase accountability by making psychotherapy a controlled act and regulating those providing it.
The other point on this issue is the equating of registered psychotherapists with psychologists. That is, some of the arguments that we have heard is that, if someone wants to get registered to provide mental health services with a master’s degree, then that person can get registered as a psychotherapist rather than our College’s reducing the number of hours of supervision for a master’s provider. The government is not wanting our College to increase the number of mental health providers, per se. It is about our College enhancing the public’s ability to access regulated psychology providers. As I wrote in the last column, the Regulated Health Professions Act, 1991 states that the goal of any College is to ensure “that the people of Ontario have access to adequate numbers of qualified, skilled, and competent regulated health professionals“(Sched. 2, s. 2.1). In other words, it is about increasing access to psychology providers, not generic mental health providers.
Another second misunderstanding that I have read is that we should, instead of making the changes we are proposing, work with the universities to have them increase their numbers and increase how they select students to increase their diversity. Registrants should be aware that the College has no direct influence on how the universities determine how to train their students or who they should be selecting for training. For many years, we have regularly met with the Directors of Clinical Training for Ontario doctoral programs and internships. We have apprised them of the need for the College to make changes to increase access. When we have suggested that changes in their systems would assist the College in meeting its goals, they have indicated that there is limited incentive for them to be making these changes in their models. Their accountability is not to the College. Many do have an accountability to the Canadian Psychological Association through accreditation, but that is a very different system and those decisions are independent of our regulatory requirements. Or, as one university director said at a recent meeting: “There is nothing in it for us (to change)”. And, we also need to realize that universities are not accountable to the Ministry of Health (that we are accountable to) but to the Ministry of Colleges, Universities, Research Excellence, and Security which has different sets of accountabilities. In other words, if there is an interest in changing how psychologists are trained in Ontario and who they select for training, then it is up to the programs to make those changes, not the College.
A third common misunderstanding is that we would be automatically registering “incompetent” providers. Through the Mutual Recognition Agreement, all provinces and territories in Canada agree to assessing candidates according to the same five competencies: Assessment and Evaluation, Intervention and Consultation, Research, Ethics and Standards, and Interpersonal Relationships. Only when they meet all five competencies at a level considered appropriate for independent practice, do we register them for independent practice. We are not removing these competencies. We are, however, proposing making changes to who can apply to be assessed with these competencies. At this time, the Ministry of Health has made us aware of instances were people have trained in Ontario, moved to another jurisdiction where they can be assessed more quicky, are determined to be competent in these five competencies by that jurisdiction, are then registered for independent practice, and then return to Ontario to practice as a psychologist. By reducing the requirements to allow for someone to be evaluated more quickly in Ontario, then it is expected that these types of situations will no longer be necessary. However, just because someone applies to be evaluated to be competent, does not mean they are competent. Applying for registration does not mean automatic registration for independent practice. In other words, they will still have to demonstrate the same five competencies as any Canadian psychologist must demonstrate.
There are other areas of misinformation but, given the limitations of this type of column, I can’t respond to them all. And I am not saying that all of the feedback has been based on these misunderstandings. But, there are myths out there about what is being proposed by the College and I wanted to respond to the three myths I am seeing most commonly.
And, please don’t take this as concerns for the feedback we are receiving. I truly am glad for the suggestions, concerns, and passion that we have been hearing from those who have reached out to us. Thank you.
Ian Nicholson, Ph.D., C.Psych.
President