The college is under pressure to make changes:

1) to be included in “as of right” legislation (for inter-provincial mobility of goods and services), which aims

• to allow mobility of professionals between provinces, including those who do not have the same standards of education and licensing requirements

• to create more access to psychologists without increasing public funding of quality services

2) The Office of the Fairness Commissioner, which

• wants the profession to be more accessible to marginalized individuals who have traditionally been shut out of pursuing advanced (e.g., doctoral) graduate degrees

Note: In recognition of biases, in recent years the Canadian Psychological Association (a body that makes accreditation standards across Canada) and various educational institutions have taken action to ensure graduate programs better reflect the diversity of the Canadian public. Training takes time but substantially more psychology practitioners from diverse backgrounds are being trained currently than ever before.

In the absence of making such changes, the college has been informed it could be placed under a supervisor and possibly dissolved if the ‘independent’ regulatory college of psychology does not make changes

For decades, Ontarians could be confident psychology practitioners registered with the CPBAO would provide high quality therapy and assessment services. Our psychology practitioners develop and hone skills through years of education and supervised services. The CPBAO’s proposed changes threaten to destroy the training and licensing processes that help to make sure psychological services are delivered ethically and competently.

Many people can wait months, and even years, to receive publicly-funded psychological services, particularly for services for children. Waitlists sometimes exist in private psychological practices, but they tend to be much shorter. Unfortunately, services at private practices are paid for by clients and only reimbursed if clients have private insurance coverage.

Psychologists and psychological associates rigorously trained to (a) provide care to those with severe or very complex mental health concerns (e.g., multiple co-occurring conditions, personality disorders, reality-testing concerns, such as psychosis) and (b) diagnosis of mental health conditions. While there is not a shortage of psychotherapy providers (the College of Psychotherapists in Ontario regulates various professionals who can provide therapy), there is a shortage of affordable options for psychological diagnostic assessment services.

“access issues stem from a lack of funding for training competent psychology professionals and a lack of public funding for psychological services”

Low access to psychological care is not due to red tape from our regulatory body. Rather, access issues stem from a lack of funding for training competent psychology professionals and lack of public funding for psychological services. Assessments by psychologists or psychological associates are generally not well funded in hospitals and few psychological services are available in schools. For example, at one high school where I completed a training rotation, only 5 assessments were allotted across the entire student body of 2000+ students. Additionally, many exceptional candidates for graduate studies in clinical psychology are rejected due to a lack of funding to train them.

As a profession there is agreement that we need more well-trained psychology practitioners. This is not a problem unique to Ontario. Even provinces with a much lower standard of entry into the profession struggle with access to psychological care. Ask an Albertan who has struggled with mental health or whose child has struggled, they will tell you it was next to impossible to find a psychologist with services covered by public funding, and it is challenging to find one in the private sector—particularly in remote areas—as well.

There are more practical and less radical and risky solutions than lowering standards—solutions that will maintain the standard of care while increasing access. Across Canada,

1. we need change in coverage of services so more people can access high quality psychological care.

   • Psychology services should not just be for people with private insurance or larger incomes. Like changes made to increase access to dental services, more funding for lower income individuals could provide greater access. We need more federal and provincial funding to support more psychology positions in hospitals, community clinics, and schools so private care is not the only option for people and their families.

2. we need increased investments in training, both federally and provincially.

   • We need to train more students to become highly competent practitioners who can meet the growing mental health needs of the population.

   • Chronic underfunding and limited resources in post-secondary programs mean we exclude excellent graduate applicants because of an insufficient number of seats in grad school.

   • Most graduate studies programs can only accept 3-6% of applicants to clinical psychology programs (compared to an acceptance rate as high as 18% of medical school applicants)

3. we need standardization regarding the training and experience that is considered acceptable for entry into the profession.

   • Consistency in standards across provinces and across countries (e.g., United States), like in the medical profession, will create common understanding of and expectations around psychological services.

   • Consistent with the ethics code for psychologists, we should encourage others to act in a manner consistent with the code (which includes a duty to society). In this case, rather than lowering our bar for training, we need to inspire others to raise the bar of training to maintain a consistent standard that protectors those receiving our services.

     1. The bar for working with people who may be at their most vulnerable should not be so low that it can be tripped over.

   • Eroding the standard will create further variability within the profession and confusion for the public.

     1. What will the term “psychologist” mean to the public if all practitioners have such varied training and education?

4. we need to help the public navigate access

   • many private practitioners do not have lengthy waitlists for diagnostic services (although waitlists can be longer for child-focused services).

   • There are insufficient public channels for services

   • There is no public directory to help clients access appropriate and available private services

   • Many clients who find their way to a psychology clinic express frustration about navigating what mental health practitioner does what services. Frequently my clients ask, “What is the difference between a psychiatrist, a psychologist, a psychological associate, a social worker, and a psychotherapist?”

     1. This confusion will increase if our standards are eroded: There will be limited experiential and educational differences between psychotherapists and those who can register as psychologists at the master’s level without completing the thousands of hours of hands-on learning and skill development under supervision and the rigorous licensing examinations.

     2. Clients will now not even know to ask, what is the difference between a master’s level psychologist (under the new proposed standards), a psychologist previously known as a psychological associate, and a doctoral psychologist? They will think all psychologists and psychologist-provided services are created equally—and, that will be far from correct. It risks the profession of psychology being dismissed by the public and the other professionals with whom we collaborate (e.g., psychiatrists, physicians, nurse practitioners).

In my first training placement, I worked with seniors assessing possible dementia and providing therapy in long-term care homes. In my time at that placement I could not learn nearly as much as was needed to practice independently. And, yet, my first practicum was nearly 200 more hours of supervised training than the 300 hours that will be required for new master’s-level grads to apply for supervised practice as a psychologist. After completing my first practicum, I could not fathom being ready to practice as a psychologist with such little, narrowly-focused experience. This was the same for each member of my graduate class.

Instead, of hanging a shingle in the quickest way possible, I completed hundreds of hours more supervised clinical work across three different practicum settings and worked as a psychometrist before I completed a one-year residency of over 2000 more hours. These experiences gave me further breadth and depth of training and experience, with children, adolescents, adults, and seniors who had a range of complex mental health needs and physical health conditions—they taught me essential skills, including how to recognize the limits of my skills and knowledge. Then I registered for supervised practice with the CPBAO and completed yet another 2000+ hours of supervised clinical work.

My first training placement focused solely on work with older individuals, with dementia, health concerns, and acquired brain injury. I did not see children, adolescents, young or middle-aged adults. I did not work with clients struggling with ADHD, learning disorders, depression, anxiety, OCD, trauma, etc.

But, under the proposed changes to the college standards, it is not clear whether a substantial lack of experience would matter for newly minted master’s program graduates. Under the proposed changes, new grads could still apply to register with the college. While they are responsible to ensure they practice in their scope of competence, they could decide to work with any and all of these populations - with no oral exam to ensure they know what they need to know and they know what they are not knowledgeable enough to do.

In just one year of supervised practice, new master’s level grads with fewer hours of hands-on training than I had in my first practicum, may self-determine whether they feel competent to work with any age group with any mental health conditions—all without the college (through lengthy supervision, vetting of competency areas, and the oral exam) providing any particular oversight about their scope of practice and skill—not until or unless a complaint is made a review is required

Supervision Has Multiple Benefits

1. skill and knowledge development in trainees

2. maximizing output with checks and balances on quality

3. access to low-cost care

Each supervisor gives 1-2 hours of their time weekly to each trainee so trainees can see many more clients (and at reduced rates) than the supervisors would have been able to see in those 1-2 hours of their time. Simultaneously, because supervisors have overall responsibility for the clients trainees see under their supervision, they ensured trainees are delivering services competently. The skills and knowledge of trainees grow from exposure to multiple supervisors with different approaches and theoretical lenses. Trainees gain hands-on experience with a range of clients, helping them to guide their chosen areas of practice (and determine areas of practice that were outside of their scope of abilities).

While working as a trainee, supervisees put in thousands of hours of work in clinical settings. They deliver services at a reduced rate and filling in gaps in healthcare at longterm care homes, hospitals, schools, and community mental health clinics. The years psychology trainees spend in supervised clinical work is not idle time that prevents Ontarians from accessing care: Supervised training improves access to care at a low cost to clients and governments. Lowering standards for training threatens access to these services