Guidance:
- Standard 4: Supervision, Standards of Professional Conduct, 2017
Making case specific recommendations to behavior therapists, advising with respect to the development of processes, and discussing general issues, are activities which are consistent with the role of a consultant, so long as it is understood that the recipients of the recommendations and advice are fully responsible for deciding whether to implement your recommendations.
If you are in a relationship with the behavior therapists that is educational, evaluative, and hierarchical, and they are required to comply with your direction, you would be considered to be supervising them.
Consultation is defined in the Standards as:
… the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.
Supervision is defined as:
…an ongoing educational, evaluative and hierarchical relationship, where the supervisee is
required to comply with the direction of the supervisor, and the supervisor is responsible for the actions of the supervisee.
In providing exclusively training and advice to other professionals, it is more likely that you are providing consultation than supervision. If this is the extent of your involvement with these individuals, adherence to the requirements under section 4.1.5., which involves clarification of the limits of your involvement as a consultant, would be sufficient and appropriate.
Your question indicates that you ‘have some input into the administration of tests and counselling’. If your input involves only making recommendations to other practitioners who take responsibility for the decision about whether to accept the recommendations, this would be consistent with the role of a consultant. If, however, “input” means directing which tests and counselling interventions will be used, and the recipients of the input are required to follow your directions, it may be that you are providing supervision and would be bound to adhere to the Standards regarding supervision of non-regulated professionals. If you are interpreting test results yourself, then you are considered to be actually providing a psychological service to the clients, and you are expected to adhere to all of the Standards which apply to the direct provision of psychological services.
Providing training does not necessarily make a relationship supervisory. A relationship in which you have been specifically asked to provide training, or a consulting relationship which may have a training component, only becomes a supervisory relationship if it becomes evaluative and hierarchical and when the person receiving information from you is required to do as you instruct. In the kind of consultation situation, you have described it is particularly important to ensure that an agreement makes it clear that you are not taking on responsibility for client care and that that responsibility is exclusively the consultee’s.
Consultants are typically in the role of an external contributor to case discussions, where the recipients of the consultant’s ideas are free to either accept or reject them. If you are in the role of a consultant, while you may be providing advice to those making decisions about client care, you should not actually participate in making the decisions (e.g., “have a vote”), even when the responsibility for decision-making is shared.
Consultation is defined as:
… the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.
If this description fits your role with respect to the treatment team then it is likely that you would be considered a consultant and are required have a clear and formal agreement delineating responsibility for client care which spells out that the person receiving your consultation retains full responsibility for client care, in accordance with Standard 4.1.5.
If you are a participant in the actual clinical decision making with respect to the clients, as opposed to being simply a resource for the decision-makers, then you are more than a consultant and have the same obligations as any member of the College providing services to a client, in a way that is analogous to an assessor or file reviewer who does not provide intervention but must comply with all of the Standards with respect to client care.
There is no reason you cannot have an agreement that multiple parties can sign onto, so long as it includes everyone with whom you require an agreement. You could update this agreement whenever someone joins or leaves the team.
If all members of the discussion are simply exchanging ideas, and you were not designated to make specific recommendations to others by virtue of your specialized expertise, it would not be considered “consultation”, which is defined as:
… the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.
Rather, it could be simply understood as team discussion or team development.
If, however, a relationship is established with specific individuals or groups, where you are identified as a person who is designated to provide advice or information regarding psychological matters, and there were plans for you to meet with them to provide advice or information more than once, then it would be considered to be formal, ongoing consultation.
Because of the diversity of supervision and consultation arrangements members are involved in, the College could not possibly provide examples or templates of agreements that would cover every situation.
We encourage you to design agreements that make sense for your own particular practice that contain at least the minimum information specified in the Standards. You are also free to add any additional elements you consider important in an agreement and may use any kind of language you wish to use.
If it would help to see how some similar agreements are structured, here is a link to a few sample supervision contracts online: https://www.cfalender.com/supervision-contracts.html. These may or not be relevant or appropriate for all kinds of relationships but may provide a sense of what others’ agreements look like.
It would be reasonable to understand “formal” in this context to mean that contacts with the consultee(s) have been arranged, or are expected to occur in the future, specifically for the purpose of consultation, where consultation is defined as:
… the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.
This would be different than the regular discussions which frequently occur between professional peers on either an ad hoc basis or at team meetings or case conferences. It would be reasonable to consider a consultation arrangement to be “ongoing” if the participants expect to have future contact for the purpose of consultation.
In order to answer this question, it is important to consider what is meant by “consulting” as it can be understood to mean different things in different contexts. Consultation is defined in the Standards of Professional Conduct, 2017 as:
the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.
If this describes the nature of the relationship with the agency, then the organization is generally considered to be the client. In the case of an organizational client, the member providing consultation is required to maintain records in accordance with the following Standard:
9.3 Organizational Client Records
1. Members must keep a record related to the services provided to each organizational client.
2. The record must include the following:
a) the name and contact information of the organizational client;
b) the name(s) and title(s) of the person(s) who can release confidential information about the
organizational client;
c)the date and nature of each material service provided to the organizational client;
d) a copy of all agreements and correspondence with the organizational client; and
e) a copy of each report that is prepared for the organizational client.
The “nature of each material service provided to the organizational client” in c) above, should likely include sufficient information to address queries about the quality of the particular consultation, should that information ever be needed.
An organizational client record must be retained for at least ten years following the organizational client’s last contact. If the organizational client has been receiving service for more than ten years, information contained in a record that is more than ten years old may be destroyed, if the information is not relevant to services currently being provided.
It is the responsibility of the individual providing services to ensure that proper client consent is obtain for the service being providing. A person acting as a consultant to a service provider would not likely be in a position to seek consent from the person receiving services from the consultee. The consultant may, in fact, never come into contact with the person receiving services from the consultee. In some cases they may not even know their name.
If a member is identified as a “consultant” but they are personally providing the psychological assessment, diagnosis, opinion or intervention, as opposed to “consulting” to or supervising another service provider, this would likely be considered a direct service. In this case, all of the Standards relevant to direct service provision, including those pertaining to consent and record-keeping, would be applicable.
In circumstances where it is unclear whether one is providing direct service or consultation, it may be useful to ask: Is this a service I would provide autonomously to an individual or family in a clinical practice, or is it providing advice to another autonomous service provider who is simply looking for the input with respect to clinical decisions they must make themselves?