Services Delivered via Technology

The College has adopted the Association of Canadian Psychology Regulatory Organizations (ACPRO) Model Standards for Telepsychology Service Delivery.  The Model Standards define Telepsychology as “the use of information and communications technology to deliver psychological services and information over large and small distances”. Practice within psychology using this modality would include all client-centered services, consultation, supervision of students/professionals/colleagues, and the education of the public and/or other professionals delivered to individuals outside of Ontario.

A telephone (landline or mobile) would be considered “communications technology”. While some of the items within the “Use of Technology…” section of the Standards may not be relevant to simpler, older technologies, some items would be relevant and applicable to even ‘lower-tech’ devices, including a corded or land-line telephone. Examples of requirements applicable to the use of all technologies in service provision would include the need to obtain authorization from the relevant jurisdiction before providing services to someone who is located outside of Ontario, ensuring the privacy of the person you are communicating with, and having contingency plans in the event of a technological failure.

In Canada, the practice of psychology is regulated at the provincial/territorial level.  That is, each province/territory is responsible for the regulation of psychological services delivered within its borders.  Within the United States, psychology is similarly regulated.

At this time, most jurisdictions regulating psychology in Canada and the US, including the College of Psychologists and Behaviour Analysts of Ontario, view services to be delivered in the province/territory/state in which the client is located whether such service is provided in person or through telepsychology.  That is, the service is deemed to be provided where the client is, regardless of where the psychologist or psychological associate may be located.  Given this, many regulatory bodies expect the practitioner to be registered/licensed in the jurisdiction in which the service is being provided.

At this time, there is some variability in the expectations of the various Canadian jurisdictions with regard to what is required of a practitioner providing services by telepsychology into their province/territory.  Some may have temporary or courtesy registers which permit a member to practise within their jurisdiction for a limited period of time without formal registration with them.  For members considering providing service by telepsychology into another jurisdiction, it is recommended that they contact the regulatory body of the jurisdiction into which they may be considering practising to determine what may be required of them in terms of registration/licensing or formal notification of the regulatory body for psychology. The College of Psychologists and Behaviour Analysts of Ontario has adopted, as advice to members, the Model Standards for Telepsychology developed by the Association of Canadian Psychology Regulatory Organizations (ACPRO).  In addition, a joint task force of the Association of State and Provincial Psychology Boards (ASPPB), the American Psychological Association (APA) and the American Psychological Association Insurance Trust (APAIT) has recently developed Guidelines for the Practice of Telepsychology.  The Canadian Psychological Association has also published Draft Ethical Guidelines for Psychologists Providing Psychological Services Via Electronic Media.

Members considering providing telepsychological services will find these documents very useful as they provide guidance on a variety of issues related to this type of service.  This includes ensuring one is legally entitled to practise in another province, territory, or state and one is familiar with the relevant laws and regulations applicable within that jurisdiction.

With the relaxation of pandemic-related restrictions on in-person services, some members are exploring whether to return to in-person service delivery or to continue providing all services virtually. There is no specific prohibition against offering online services.

Members must use their professional judgment in deciding whether to offer in-person vs. virtual services, taking into consideration the needs of each individual seeking services and the available evidence regarding efficacy.

Members are expected to provide services in a safe and effective manner. If a member wishes to restrict their practice to virtual services, they must decide which populations and problem areas can be effectively assisted without in-person contact, and under what circumstances this would be appropriate.

There is no ‘one size fits all’ when it comes to planning service delivery in psychology. It may be that some clients are more comfortable with on-line services and might be more likely to engage in services provided via technology and some intervention models may lend themselves to on-line delivery more than others. Members should also consider some concerns that have been raised about services delivered via technology. These include:

• loss of many visual cues and other sensory inputs which are less accessible via the computer screen or telephone than when physically present with a client;
• increased risk to breaches of confidentiality;
• increased need for vigilance concerning professional boundaries and personal privacy; and
• issues of equity, as some clients will not have access to technology, sufficient familiarity and/or competence in using it, and/or the necessary adequate privacy.

Members providing virtual care must adhere to all of the Standards of Professional Conduct, 2017 including, but not limited to, Standard 15, Use of Technology in the Provision of Psychological Services. An additional resource members may find useful is the American Psychological Association’s Guidelines for the Practice of Telepsychology. This is a helpful guide in reflecting upon the delivery of services via technology. Some of the areas addressed in the article are the need to: regularly monitor and assess the progress of the client/patient to determine if the continued provision of telepsychology services remains appropriate and beneficial; discuss any concerns with the client/patient; and appropriately terminate remote services and provide assistance in arranging alternative services, if necessary.

If a member initially agreed to provide in-person services to a client; transitioned to on-line services during the pandemic; and wishes to continue with on-line services beyond the point at which it seems necessary, this can be problematic if the client wishes to return to in-person services. In such a situation, a member may decide to terminate services against a client’s wishes, but should be mindful of the section 1.8 of O. Reg. 801/93: Professional Misconduct Regulation which sets out the manner in which one can do so that would not be considered professional misconduct.

The Standards of Professional Conduct directly address the use of technology in the generation of assessments, reports and statements:

10.7 Use of Computer-Generated Reports

Information obtained from computer-generated assessments, reports or statements must not be substituted for a members professional opinion.

Members are free to responsibly use technological advances as an adjunct to their own assessments and interventions, however, it is the position of the College that these professional activities must always be actively mediated by members who are authorized to provide the services and that members must remain fully accountable for services provided in their names.

To date, there is insufficient scientific evidence to demonstrate the effectiveness and safety of using ChatGPT or other Artificial Intelligence (AI) to assess or treat mental health conditions and the risk to clients may outweigh any potential benefits. Anyone considering the use of AI to assist or augment their services should ensure, as part of the informed consent process that clients understand how technology is being used to assist them, what the risks are of technological error, and also what risks there are to their privacy when personal information is being used in an AI context.