CRPO Communiqué
February 2018
February 15, 2018


Message from the Registrar 
Deborah Adams Registrar


As the window for registration renewal is opening, I thought it would be a useful time to reflect on the value of professional self-regulation and to consider the supports that the College and the system can offer to assist members in providing excellent care to Ontarians.  
 
At a system level, I would suggest that ensuring safe, effective and sustainable care has three underlying supports: rigorous self-regulation, excellence in education and strong professional association. As you know, self-regulation serves to protect the public by defining competencies, setting practice standards and professional development requirements and addressing complaints and concerns about members. The other two supports are equally as important. Education provides a highly qualified, competent workforce. Professional associations provide professional support, represent the profession to funders and other stakeholders, offer opportunities for development, and can support relationships with other healthcare professions.
 
So what does the College provide members? Some of the specific offerings include:
  • A Practice Advisory Service that gives members access to practice advisors who have both extensive clinical and regulatory experience. These advisors are available to provide direct support for practice-related questions, ethical issues and compliance with standards and guidelines.
  • A growing list of Quality Assurance (QA) Program resources and access to QA Program staff to provide guidance on self-assessment, learning plans and professional development.
  • Opportunities to contribute input that informs how Council develops regulations; establishes policies, standards and guidelines; and works to advocate for needed changes to the system (for example, the current survey the College is conducting regarding members' services for people seeking gender affirmation surgery and upcoming engagement related to our work on the proclamation of the controlled act).
  • A means to demonstrate your commitment to professional, ethical, qualified and accountable practice. Being registered brings credibility to the profession since only registered College members who have demonstrated that they possess and continue to maintain the required skills, knowledge and judgement are allowed to use the titles "psychotherapist" or "Registered Psychotherapist" (including a variation or abbreviation); to hold themselves out as qualified to practise as a psychotherapist in Ontario; or (once the two year transition period ends in 2019) to undertake the controlled act of psychotherapy.
I would encourage you to complete your renewal before the deadline (ensuring you make the bank-to-bank payment with enough time for the renewal fee to be received by the College on time) and to continue to engage with the College through our support services, public Council meetings and ongoing consultations.
 Quick Links

In This Issue
Important Information About Renewal of Membership for 2018-19

CRPO members are required to renew their membership on an annual basis, before the end of March each year. The Renewal form for the 2018-19 membership is now available under the "Renewal" tab found in members' user accounts . In addition to the online Renewal form, members will find their membership fee invoice for the next year (April 1, 2018 to March 31, 2019) under the "Invoices" tab.
 
Members are advised to pay the membership fee early in the renewal period, but no later than March 27, 2018 to allow at least three business days for the bank transfer payment to clear before the deadline of 11:59 p.m. ET on April 3, 2018 (Please note CRPO's office will be closed on Friday, March 30, 2018 and Monday, April 2, 2018 for the Easter holiday). Once the payment has cleared, you must remember to return to the online Renewal form and click "Submit" to send the Renewal form to us before the deadline of 11:59 p.m. ET on April 3, 2018, or you will incur a late fee. 
 
It normally takes a regulatory body several months to review all membership renewals. Members can continue to practise as usual while their renewal is being processed.
 
Note: Please be sure to keep a record of your login information for your CRPO user account. We receive a high volume of requests for forgotten information and answering these inquiries is very time consuming for staff and takes away from processing renewals, thus causing a delay and ultimately costs the College and the members.
 
Registration staff will send a message through members' user accounts if there are questions about their renewal (e.g. about currency hours, or if more information is required). Members will not receive a new Certificate of Registration for every membership year (except for major changes to information such as a name change) but any changes to names, employers or practice sites will be updated on the Public Register.
 
Detailed instructions for completing your renewal can be found in the Guide to Completing Your Membership Renewal . If you have general questions about the renewal process, please visit the  Renewal page of CRPO's website or contact us using the "Messages" tab through your  CRPO user account .

Updating Practice Sites and Contact Information
Members must ensure that they have provided up-to-date information for their practice sites and personal contact information (e.g. home address, phone number, email address). This information is necessary to communicate with members, identify practice sites on the Public Register and establish eligibility to be nominated and vote in annual Council elections. 
 
Carefully review the information found in your Renewal form to ensure it includes any changes that may have been omitted, including any changes indicating your primary practice site.

Transferring to the Inactive Category
Inactive members are practitioners who are not currently engaged in the practise of the profession, or who need to take an extended leave from active practice, but wish to maintain membership with CRPO.

A member should carefully weigh their options before applying to transfer into this category since Inactive members are prohibited from:
  • providing or supervising direct client care;
  • providing supervision; and
  • making any claim or representation to having any competence in psychotherapy.
Members in the Inactive category must use the appropriate title: Registered Psychotherapist (Inactive) or the acceptable abbreviated form, RP (Inactive).

* Qualifying members and RP (Temporary) members cannot transfer to the RP (Inactive) category.
 
Note: Transferring to the Inactive category of membership is different from resigning membership. If you resign your membership with CRPO, and wish to return to active practice at any future date you will be required to submit a new application for registration, pay all associated fees and demonstrate that you meet all registration requirements at the time of re-application. Thus, if you are only planning to leave for a short time and/or think you might ever want to return to active practice in Ontario, transferring to the Inactive category would be a better choice than resignation. More information about resigning membership can be found further on in this Communiqué.
 
Fees
The annual membership fee for a member who transfers into the Inactive category before the renewal period is $286 +HST.
 
Note : The College does not provide any credit, refund or reimbursement to a member who moves from RP status to Inactive at any point during the membership year, which runs from April 1 - March 31.
 
Professional Liability Insurance
CRPO requires that Inactive members carry liability run off coverage (sometimes called enduring or tail coverage) for a minimum of two years since last practising in Ontario. Review the Professional Liability Insurance page of CRPO's website for more information about insurance requirements. Contact your insurance provider to discuss your options.
 
Note : Members who are covered by employer liability insurance should contact their employer for more information about coverage during leave. The onus is on the member to ensure they have liability coverage which meets the criteria stipulated by CRPO.
 
Renewal of Membership in the Inactive Category
If you would like to switch to the Inactive category for the upcoming 2018-19 membership year, you must upload the Transfer form and notify CRPO in writing by March 2, 2018 and everything needs to be complete with your renewal all by April 3, 2018 to avoid incurring a late fee. To have everything complete with your renewal, the following steps need to be met:
  1. Complete and upload the Transfer form to your CRPO user account by March 2, 2018.
  2. A new Inactive category invoice will be issued. Pay this invoice, allowing at least three business days for funds to clear the banking system.
  3. Complete and submit the online Renewal form.
For more information about the Inactive category or to complete the Transfer form , please visit the Renewal page of CRPO's website and read the "Transferring to the Inactive Category" section.
 
Resignation of Membership
Any CRPO member who wishes to resign their membership should understand what it means to resign. Resignation means your membership with CRPO ceases. Annual renewal and participation in other College programs, such as the Quality Assurance Program, would no longer be required.
 
A non-member may not:
  • Use the title "psychotherapist", "Registered Psychotherapist" or any abbreviation or variation thereof in any language.
  • Hold oneself out as qualified to practise as a psychotherapist in Ontario (no matter what title one uses).
  • Perform the controlled act of psychotherapy* once it is in effect (January 1, 2020).
* Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual's serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual's judgment, insight, behaviour, communication or social functioning.
 
A former member wanting to return to practice at any future date must submit a new application for registration and pay all associated fees. The former member would also need to demonstrate that they meet all registration requirements at the time of re-application. Specifically, those members who were initially registered through the grandparenting route would not necessarily meet the regular route requirements. No refunds of membership or other fees will be made. If any fees are owed by you to CRPO, you will need to be in good standing with the College before re-applying.
 
Resignation and Quality Assurance
Former members, who resigned at any point during a Quality Assurance review process, including the Professional Development tool review and Peer and Practice Review, should expect to resume these processes in the event of re-registration with the College.
 
Resignation and Outstanding Investigations
  • If a member resigns during, or as a result of a complaint/investigation into their conduct, a notation to this effect will be made on the Public Register.
  • If the former member then re-applies for registration with the College, the outcome of re-application may be affected by the decision to resign.
  • If re-registered as a member, the complaint/investigation process may resume.
  • If a complaint or report is received after a member has resigned, the College can still investigate and prosecute conduct that occurred while the person was a member.
Professional Liability Insurance
Former members are advised to maintain run off liability insurance coverage for a reasonable time period after the last date of practise (please consult with your insurance provider for more information).
 
If you would like to resign your membership with CRPO, you may do so at any time by completing and uploading the  Membership Resignation form to your CRPO user account and notifying the College through the "Messages" tab in your CRPO user account. To avoid receiving late notices, incurring a late fee and having your membership suspended for non-payment of fees, your Membership Resignation form needs to be submitted no later than March 27, 2018. No matter when you resign your membership, no refunds will be given for any fees already paid
Suspension and Revocation for Non-Payment of Fees

CRPO members must renew their membership by the renewal deadline each year. For the upcoming 2018-19 membership year, the deadline is April 3, 2018. Any member who does not meet all of the renewal requirements within the stipulated deadlines risks suspension of their membership with CRPO. After the stated renewal deadline, any member who has not completed the requirements for renewal incurs a late fee and is given an additional 30 days to complete outstanding requirements (e.g. pay fees in sufficient time for the payment to clear ahead of the new deadline, submit the online Renewal form, etc.). Periodic reminders are sent, however, if the outstanding requirements are not completed in time, the member is suspended.
 
Note: Any member who does not maintain professional liability insurance in the form and amount required in CRPO's By-laws may also be suspended. Under this circumstance, unlike suspensions or revocations for non-payment of fees, if/when the member is reinstated, the former suspension notation remains visible on the Public Register.
 
What are the implications of suspension and will it affect my practise of the profession?
In effect, the suspension means that a member has forfeited their good standing with the College, is no longer a member of CRPO, and so is not permitted to use any restricted title, practise or supervise the provision of psychotherapy for the purposes of registration with the College, nor hold themselves out as qualified to practise as a psychotherapist in Ontario. In other words, if a member sees clients or provides clinical supervision to other practitioners who see clients, these services must cease effective from the date of the suspension, as must use of the restricted title. In the interest of public protection, the suspension is also reflected on the Public Register.
 
How do I return to good standing?
To return to good standing, any member who is suspended needs to submit the online Renewal form or any other documentation as required, pay any outstanding fees (i.e. the annual membership fee, late fee and the additional penalty fee levied by the Registrar to lift a suspension). The Registrar will lift the suspension if they are satisfied that the former member has paid the outstanding fees, has professional liability insurance coverage in the amount and form required under the By-laws, and will be in compliance on the anticipated date on which the suspension is to be lifted with any outstanding requirements or orders issued by CRPO's statutory committees (e.g. Inquiries, Complaints and Reports Committee, Discipline, Fitness to Practise or Quality Assurance Committees).
 
When the outstanding items are completed and conditions satisfied, the member is reinstated to good standing, details of the suspension are removed from the Public Register and the member is permitted to resume practice of the profession and use of the title.
 
Revocation and Reinstatement
If the Registrar suspends a Certificate of Registration and the member does not take the steps outlined above to lift the suspension, the Registrar has authority to revoke the member's certificate two years after the day it was suspended. Again, this status will be reflected on the Public Register.
 
If a former Member, whose Certificate of Registration was revoked because they failed to pay a fee that is required to be paid in accordance with the By-laws, wishes to return to active practice, the Registrar has the authority to reinstate the certificate if certain conditions are met. The former member will have to satisfy a panel of the Registration Committee that they are competent to safely practise psychotherapy, will pay the outstanding fees, have professional liability insurance coverage in the amount and form required under the By-laws, and will be in compliance on the anticipated date on which membership is to be reinstated with any outstanding requirements or orders issued by CRPO's statutory committees (e.g. Inquiries, Complaints and Reports Committee, Discipline, Fitness to Practise or Quality Assurance Committees).
 
For more information about the conditions associated with suspensions and revocations, see sections 23 - 27 of the Registration Regulation .
 
If you have any questions about suspension, please contact us using the "Messages" tab in your CRPO user account
CRPO's Professional Liability Insurance Requirements

CRPO's By-laws require that all members, other than Inactive members,* maintain professional liability insurance (PLI) coverage  in the amount and in the form required under  CRPO's By-laws . Members must provide the College with written details within two days of becoming aware of not having PLI as required under the By-laws. The Registrar may suspend a member's membership if they do not have the coverage required.
*Inactive members are required to carry run-off coverage for a minimum of two years in relation to incidents that occurred while they were practising.
Applicants and members are responsible for determining whether their coverage meets the requirements as stated in CRPO's By-laws.
 
The College will accept professional liability insurance coverage provided through an applicant's or member's employer. Coverage must meet the requirements set out in CRPO's By-laws. However, the College strongly encourages members to obtain individual PLI coverage, even if their employer's insurance coverage protects them as employees. A member with employer-specific PLI must not practise the profession in any other setting unless they obtain PLI that covers the other setting.
 
PLI Coverage Audit
The College may conduct audits seeking proof of members' PLI coverage. During such an audit, and upon request, the member must provide proof (generally a copy of their insurance certificate or a letter from their employer), which must include the following information:
  • policy number;
  • name of the insured that matches the name of the member;
  • address of the insured;
  • policy period; and
  • coverage details.

Any member who does not maintain professional liability insurance in the form and amount required in CRPO's By-laws may be suspended. Under this circumstance, unlike suspensions or revocations for non-payment of fees, if/when the member is reinstated, the former suspension notation remains visible on the Public Register .
 
For more information, visit the Professional Liability Insurance page of CRPO's website.
CRPO Updates
  1. Member Survey - Gender Affirmation
  2. Information Session - Learn More About Your QA Requirements
  3. Practice Advisory FAQ - Dual Practice
  4. New Recognized Education and Training Program - Centre for Training in Psychotherapy
  5. Update on the Controlled Act of Psychotherapy
1. Member Survey - Gender Affirmation
The Ministry of Health and Long-Term Care made changes in 2016 to expand the roster of service providers who could make referrals for those seeking medically necessary gender affirmation surgery. CRPO is confident that our members can contribute to further reducing barriers to much-needed care for this often vulnerable population. Our position is that adding Registered Psychotherapists (RPs) to the list of health professionals who are authorized to provide secondary referrals for gender affirmation surgery will be an effective step in further improving the services that our province's health care system can provide.
 
In our work to support this much-needed and positive development, CRPO is gathering information regarding the skills, knowledge and experience needed to work with transgender and gender nonconforming clients as well as the qualifications needed to sign secondary referral letters for those seeking gender affirmation surgery.
 
If you have been involved in this way, CRPO would be very interested in hearing from you through this short survey .
 
The survey, which should take less than 10 minutes to complete, will be open until March 14th. Your participation is greatly appreciated.

2. Information Session - Learn More About Your QA Requirements
In the fall, we announced fairly significant changes to the Quality Assurance (QA) Program participation deadlines. As a member, you need to know how these changes will affect your participation in the Professional Development (PD) component of the QA Program. You can learn more about these changes by reviewing the Quality Assurance Program page of CRPO's website, or by attending the upcoming information session taking place via webinar on March 2, 2018 starting at 11:30 a.m. These sessions generally last an hour and a half.

3. Practice Advisory FAQ - Dual Practice
CRPO offers a practice advisory service to respond to enquiries related to professional practice, ethics and practice standards. This service provides information and resources to members to assist with challenging practice situations.
 
The Practice Advisory service will also continue to provide answers to frequently asked questions on various topics. This month's topic is Dual Practice . We hope members find it to be helpful.

4. New Recognized Education and Training Program - Centre for Training in Psychotherapy
One of the main registration requirements to become an RP is completion of a Recognized Education and Training Program, or a substantially equivalent program. Applicants who have successfully completed one of CRPO's Recognized Education and Training Programs will be deemed to have met CRPO's education and training requirement. If you would like to see if a program you have taken, or one that you are considering, is recognized by CRPO as satisfying the education and training requirement, please review the Education Programs page of CRPO's website for an up-to-date list - you will see that a total of 11 programs have already been recognized, with The Centre for Training in Psychotherapy being recently added to this list.
 
Education program providers are encouraged to consider completing and submitting an application for recognition of their program by CRPO. You can read more about the Review and Recognition process for education and training programs by visiting the Education Programs page of CRPO's website.

5. Update on the Controlled Act of Psychotherapy
As noted in the January Communiqué, the College has been directed by the Minister of Health and Long-Term Care to undertake work related to the proclamation of the controlled act of psychotherapy. In order to meet the Minister's July 1, 2018 deadline, the College has established a Controlled Act Task Group. This task group will be part of a larger Ministry working group to provide clarification that will be useful to Registered Psychotherapists as well as to other individual providers, organisations and institutions that are engaged in the system that provides mental health services in the province.
 
Given the tight timelines, CRPO will be seeking input from stakeholders using a variety of forums. Please monitor this communiqué for upcoming opportunities to provide feedback over the coming months.
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