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The CRPO path, by Canada Therapy & Wellness

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Controlled acts: performing, exceptions and delegation

CRPO's Standard 1.4: when RPs may perform a controlled act, the controlled act of psychotherapy, the RHPA's exceptions (students, counselling, Indigenous healers), receiving a delegation, and never delegating psychotherapy.

Study aid, not legal advice.Last verified against the official sources linked below on .

Standard 1.4

  1. Do not perform a controlled act unless you are authorized, a legal exception or exemption applies, or you receive appropriate delegation (1.4.1).
  2. RPs are authorized to perform the controlled act of psychotherapy, provided they have the competence to do it safely and effectively (1.4.2, Standard 2.1).
  3. RPs never delegate the controlled act of psychotherapy (1.4.3).

The controlled act of psychotherapy

  • It needs all five elements: treating, by psychotherapy technique, through a therapeutic relationship, a serious disorder of thought, cognition, mood, emotional regulation, perception or memory, that may seriously impair judgement, insight, behaviour, communication or social functioning (RHPA s. 27 (2)).
  • Five other professions may also perform it: nurses, occupational therapists, physicians, psychologists and psychological associates, social workers and social service workers.

The RHPA's exceptions (s. 29)

  • First aid or temporary assistance in an emergency (s. 29 (1) (a)).
  • Students meeting the requirements to register, under supervision: CRPO's version is clinical supervision by a qualified RP for the controlled act (s. 29 (1) (b)).
  • Treating by prayer or spiritual means under the tenets of the giver's religion (s. 29 (1) (c)).
  • Treating a household member or helping with daily living covers only certain other acts, not psychotherapy (s. 29 (1) (d), (e)).
  • A communication in counselling about emotional, social, educational or spiritual matters, unless it is one a profession's Act authorizes (s. 29 (2)).

Indigenous healers

  • The RHPA does not apply to Indigenous healers providing traditional healing services to Indigenous persons or members of an Indigenous community (s. 35 (1) (a)).
  • A healer who is a member of a College remains subject to it (s. 35 (2)).

Receiving a delegation

  • Only if the delegating professional works within their scope and standards and will take responsibility for your actions.
  • Only if it would not violate therapist-client boundaries.
  • Only if you can carry it out in a safe and effective way.
  • A separate exemption lets competent RPs perform acupuncture in an addiction treatment program within a health facility (CRPO).

Meeting the standard

  • Decline a controlled act that is beyond your competence or, in your judgement, counter-therapeutic.
  • Decline a delegation if the delegating professional is not supervising or will not take responsibility for preparing you.

Psychotherapy is a controlled act you may perform when competent, never delegate, and only receive others' acts by proper delegation.