Some thoughts on the CPO Titles Regulation Survey

The OAPA Board would like to provide the membership with additional information that may clarify the nature of the survey being completed by the College of Psychologists of Ontario (Titles Regulation Development Survey; submission deadline November 10th, 2014). We encourage all members to respond to the survey, regardless of whether your opinion aligns with that of the Association.

While psychology is not regulated democratically, the responses of the CPO membership and other stakeholders will define the future of psychology in this province. The message has been clear during each meeting with government, a large and active response by OAPA’s membership and our peers will shape things to come.

To understand the nature of the current survey it is important to review recent consultations and motions that have been made at the College:

Over the last five years we have seen two attempts to eliminate future Master’s level registration. While both proposals have involved re-registering current Psychological Associates as Psychologists, that title has been paired with a guarantee that MA-level (and comparable) members of the College will become an increasing minority since future admission to the profession would be reserved for those with Doctoral degrees.

The CPO’s first attempt received a great deal of negative response from our membership and was blocked by the Office of the Fairness Commissioner (OFC) prior to it being considered by the Ministry of Health and Long Term Care. The OFC conveyed several concerns, but primarily anchored their opinion on the fact that this proposal would preclude registration of international practitioners, most of whom are not registered on the basis of a Doctoral degree.

The College’s response was to put forth an identical registration proposal, but to add on an undefined method to evaluate the competency of international candidates regardless of the nature of their degree. In other words, international practitioners could register on the basis of a non-doctoral degree, but Ontarians could not. Also, as Masters level registration is the standard through much of Canada, labour mobility laws would allow clinicians from other provinces to transfer to Ontario. In essence, only home grown practitioners would be excluded.

OAPA took issue with this proposal and subsequently met with all levels of government, political parties, and key stakeholders to present our concerns. While the general consensus has been that a profession unified under a single title of Psychologist serves the public interest, all parties relayed concern about closure and a return to a regulatory environment where a large number of unregulated clinicians are providing front-line care.

We know that this message has also been conveyed back to the College by government. While the motion for closure and shared title remains, the September 2014 Council meeting appeared to reflect an understanding that alternatives may need to be considered.

One alternative is to apply a “competency”-based model of regulation to future applicants. Instead of requiring a Doctoral degree (a “credential” approach to regulation), this model would include a series of “competencies” that all applicants to the College must demonstrate regardless of the degree-status of their academic program. This would bring equity to international candidates and would increase flexibility in how academic programs are designed in this country. These “competencies” may be based on the core-skills required of CPA accredited Doctoral program, but those requirements are relatively aligned with the core competency areas that Psychological Associates need to already demonstrate and are not directly related to the number of years in academia.

This model would also bring the College in line with regulatory trends nationally and abroad. It is also a method of regulation that is increasingly favoured by government and the fairness commissioner. If developed properly, a “competency” based approach to regulation could bring unity to our profession and will allow regulators to better shape what skills are necessary to practice psychology.

Unfortunately, building such a model will take time; as much as a decade. Moreover, the government has shown little interest in opening up a regulation that will be re-opened again in a few years. To them, it is a time and resource-consuming endeavour. They will likely oppose any attempts to open it for title alone and a transition to “Psychologist” for all CPO members will be further delayed.

The College recognizes this concern and are exploring a way to move us forward through an alternative approach to unifying title. This current survey reflects that approach. It would not require the Registration Regulations to be reopened twice, but would instead open the Titles Regulation.

The Titles Regulation refers specifically to the how members of the College are to refer to themselves to the public. Currently these “titles” are aligned with our registration certificates (e.g. a registration certificate for a Psychological Associate requires you to convey yourself in public and professional forums as a “Psychological Associate). However, these two regulations do not need to be linked. It could be worded to state, for instance, that all members of the College of Psychologists of Ontario are to practice under the title of Psychologist regardless of the nature of their registration certificate.

In other words, we would all be Psychologists, but we would still hold a registration certificate for Psychological Associate if we have not registered elsewhere by way of the AIT Labour Mobility Act. To many this may seem like a half-step solution. To a degree it is. It is, however, a half-step in the right direction and the first significant movement we have seen at the College-level on this issue that is not paired with closure. It is also the opinion of our advisors that it is a step that will inevitably lead to unification at both a registration and title level. It is also a step that can happen sooner rather than later and appears to be palatable to government.

Having been entrenched in this debate for many years, it is OAPA’s position that we should explore how to move this situation forward through the Titles Regulation. We recognize that it is not the end solution, but we also know that substantive shifts often come from smaller changes.

OAPA hopes that you will be supportive of the considerations being made in the current survey and we encourage each of you to contact us with any lingering questions you may have. Also, consider sharing any differing opinions, as the consideration of all sides only makes our message stronger.

It is hoped that this recap of the events leading up to the college sending out the survey will help you to put this survey in context. Please take a moment to respond to the brief CPO survey before November 10th, 2014: https://www.surveymonkey.com/s/CPOTitlesRegDev