COLLEGE CLOSURE/TITLE CONSULTATION – PLEASE REVIEW & RESPOND!

Good day OAPA Members,

I would like to first thank the membership for their patience in allowing the OAPA Board to put together a guidance document on the current College of Psychologists of Ontario closure/title consultation. We hope you will bear with us and review the entirety of this message, as it may have a substantial impact on your future practice within this province.

Those who have read the consultation may perceive that the process is already prepared to go through and that the logistics of this change is simply up for discussion. Let me assure you that this is not the case and that our meetings with Government and other key stakeholders have strongly suggested that a unified and strong response by the OAPA membership will stop closure for future Master’s prepared Ontarian’s. These parties have not conveyed concerns regarding shared title and improved international candidacy.

The OAPA Board is in agreement with the CPO and Government that a single title of Psychologist for all members of the College and an improved method of recognizing international candidates does serve the public interest. We do not agree that closure of the Master’s class for new applicants fits this required standard. Whether or not you agree with these interpretations, the OAPA encourages you to respond to the CPO’s consultation by February 26, 2016. Responses can be emailed directly to the CPO at this email address: registrationregulation@cpo.on.ca.

Over the next few weeks I will be sending a couple of mailings to the OAPA membership in order to show how you can help facilitate change through a few moments of your time. Today I wanted to provide you with a guidance document on what OAPA perceives as the key issues regarding the current consultation. We have also responded regarding some of the timelines posted by the College and their planned international candidate evaluations, only to highlight much of the shortsightedness that has gone into this issue.

I would also like to announce that we will be holding a few live online forums that you can join by internet or phone. We have a limit of approximately 20 members per meeting, but will add additional meetings if needed. We will also run these meetings with no minimum attendance, as we recognize that some Members can only attend at specific times. The purpose of these meetings it to respond to your questions and discuss issues regarding this consultation in greater depth. Currently meetings will be held on:

Friday January 15th at 12pm

Sunday January 17th at 4pm

Monday January 18th at 8:30am

Tuesday January 19th at 8pm

If you would like to receive information on how to connect to one of these meetings, please send your preferred date to oapa.ont@gmail.com. If none of these dates work for you, please feel free to suggest a time of week/day that works for you and we will set up a future meeting if we have enough interest in that meeting.

Thank you for your time and please continue reading below for a discussion on key issues regarding this current consultation. We have been informed by our lobby team that any response is supportive, but that personalized letters are essential – meaning there is little value in form mail for this matter. Even a brief response sharing some of these concerns would be appreciated.

Michael Decaire, M.A., C.Psych.Assoc.

OAPA, President

 

OAPA’s CLOSURE/TITLE CLOSURE GUIDE

The Ontario Association of Psychological Associates (OAPA) appreciates that the College of Psychologists of Ontario (CPO) has provided an opportunity for stakeholders to respond to their proposed regulatory amendments relating to the grandparenting of Psychological Associates to the title of Psychologist, the closure of Master’s level registration, and the inclusion of a mechanism for evaluating internationally trained applicants. We are concerned that Stakeholders have been directed to respond specifically to the logistics of implementing this plan, as opposed to voicing concerns regarding aspects of the proposed amendments themselves.

Regarding Grandparenting of the title Psychologist to all members of the College of Psychologists

OAPA appreciates that the CPO has again brought forward a proposed amendment to resolve the disparity that has been caused by the title of Psychological Associate. We are concerned that the implementation of shared title has routinely been tied to a proposed closure of Master’s level registration and we hope that the College will move forward on this issue regardless of the status of other aspects of the proposed regulation amendments.

Some key issues that we would highlight in this regard are:

  • The CPO and both professional associations, OAPA and the Ontario Psychological Association (OPA), have publicly stated their support for shared title, with no known opposition from any stakeholder of note.
  • The transition of a substantial number of Psychological Associates to the title of Psychologist by way of the Agreement of Internal Trade – Labour Mobility Act has led to increased confusion regarding title within the profession, with employers, and the public who accesses psychological services.
  • The use of multiple titles recognizing an identical scope of practice and years of training leads to confusion that is further exacerbated by the new regulated title of Psychotherapist.
  • The title of Psychological Associate has been abused by insurance companies as an opportunity to inappropriately deny coverage on the basis of poorly worded insurance plans.
  • The exclusive allowance of the term “Doctor” for members registered on the basis of a Ph.D or Psy.D is sufficient to differentiate manner of registration and provides a clearer.

Regarding the proposed Discontinuation of Master’s Level Registration

The OAPA would like to remind the CPO that the registration of Master’s level practitioners was motivated by the fact that Master’s prepared clinicians were providing direct client care through only a cursory supervisory relationship with a member of the CPO. While these unregulated individual’s were practicing throughout the province and directly interacting with the public, poor supervision was especially frequent in remote regions were psychological service needs were high and regulated clinicians were in short supply.

Some key issues that we would highlight in this regard are:

  • Despite multiple attempts to implement closure of Master’s level practitioners, the CPO has failed to provide any data regarding the purpose of closure or how it serves the public interest.
  • Federally, Psychologists were listed in 2015 as one of the top 20 in demand careers with shortages being reported nation wide.
  • Ontario has the lowest number of psychology practitioners per-capita, with the exception of Prince Edward Island; Some provinces have double to quadruple the number of psychology practitioners as Ontario.
  • The CPO’s own Task Force on this matter found that Psychological Associates and Psychologists generally work in different positions, with Master’s prepared members of the College working disproportionally with children and adolescents who face further under-servicing through closure.
  • Master’s prepared practitioners are disproportionately employed within school boards as psychological assessors, meaning that a transition to the College of Registered Psychotherapist of Ontario will not be an alternative route to registration for Master’s-prepared graduates.
  • The CPO’s Task Force also learned that limited Doctoral positions and internship sites will prevent an increase in Doctoral graduates and programs.
  • Forcing a Doctoral only route to registration puts an increased burden on students, decreases governmental income through taxation during supervision years, and drains provincial funding for graduate programming.
  • The inclusion of Psychotherapists in Ontario will not meet the shortage demand, with Employment and Social Development Canada’s most recent job outlook study stating that  there will be a combined 77,000 job postings between 2011 and 2020 for psychologists and other mental health professionals but only 69,000 job seekers in these areas.
  • As an issue of fairness, the mobility act and international candidacy inclusions would allow non-Ontario Master’s-based psychology practitioners to registered in Ontario as autonomous Psychologists, but would relegate Ontario residents to low cost assistant positions.
  • The proposed closure will return Psychology to a primary supervisory role where client contact is too often completed by non-regulated professionals, which is contrary to the purpose of the Regulated Health Professions Act.

Regarding Developing a Mechanism for Evaluating Internationally Trained Applicants’

The OAPA is encouraged that the CPO has begun considerations of developing a more thorough manner of evaluating international candidates. We believe that this is an important step towards fairness in registration practices that should be completed regardless of whether other aspects of the proposed registration amendments are implemented.

Some key issues that we would highlight in this regard are:

  • A model of registration through “competency” over “credentialing” is in keeping with international trends and provides the fairest manner of considering all who would be appropriately registered as a Psychologist in this province.
  • Ironically, the competency+credential model proposed here is identical to the current registration standards for Psychological Associates.
  • Using the EuroPsy model provided, current Psychological Associates meet all listed criteria.
  • The curriculum and training requirements of Psychological Associates also mirror the core competency areas of accredited doctoral programs.

In essence, this portion of the consultation appears to be a clear endorsement of the current training and registration regime for Psychological Associates.

Regarding Timelines for Implementation of Proposed Amendments

Timelines for Ceasing to Accept Master’s Level Applications

Some key issues that we would highlight in this regard are:

  • The limitation of completing a Masters degree within 2 years is clearly insufficient. While this is the minimum time for completing such a degree, lengthy dissertations and course/practicum availability, all of which are rarely under the control of the applicant, leads to degrees frequently requiring three years. Include factors such as health complications, part time studies, reduced course loads due to disability, and pregnancy, and it is readily apparent that a two year window is impractical and unfair.
  • The recommended date examples of November 2019 to August 2023 for the completion of four years post-masters supervised experience, while noted to be an example, is less than four years. Even with the extra year provided as an additional opportunity to obtain four years of experience, this presumes that an individual degree was granted within a narrow time window, that they obtained full time employment immediately upon graduation, that they were able to maintain full time employment for the entire four years, and that they did not miss clinical hours due to pregnancy, disability, or health concerns. Clearly, this implementation window is significantly concerning and not forgiving of reasonable life circumstances.

Timelines for Registering all Psychological Associates as Psychologists

Some key issues that we would highlight in this regard are:

  • OAPA supports the provided wording that the title of Psychologist would be granted “on the date that this section of the regulation is proclaimed”. We are hopeful that this proposal will remain worded as is if the proposed closure amendments are abandoned by the CPO or struck down by Government.

I would like to formally thank each of you for reviewing this response to the CPO Closure/Title Consultation. In the past, some members have shared their responses on our ListServe. As we have seen reduced access of the forums, I would like to offer to share your responses through this mailing list as a secure (member only) link to our website. Also, if you have any specific questions regarding the consultation please consider attending one of our online sessions or email me directly at michael.decaire@gmail.com.

Thank you for your attention at this important time.

Michael Decaire