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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
- Do not perform a controlled act unless you are authorized, a legal exception or exemption applies, or you receive appropriate delegation (1.4.1).
- 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).
- 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.
