Psychotherapy and the controlled act component of psychotherapy
The component of psychotherapy that is considered a controlled act was proclaimed on December 30, 2017. Although this act was proclaimed, there will be a two-year exemption until the end of 2019 before the controlled act is enforced. The following addresses questions nurses have about psychotherapy and how this affects their nursing practice:
What is psychotherapy?
Psychotherapy is defined as “an intense client-therapist relationship which often involves the examination of deeply emotional experiences, destructive behaviour patterns and serious mental health issues.” (Health Professions Regulatory Advisory Council, 2006).
It involves a deep examination of life processes that focus on modifications of behaviour, thinking patterns, cognition, emotional response and social functioning. In order to competently practise psychotherapy, nurses need in-depth knowledge, skill and judgment.
What is the component of psychotherapy that is considered a controlled act?
The controlled act is the component of psychotherapy considered to be the highest risk to the client. It does not include all psychotherapy practices and is not defined by a technique. The Regulated Health Professions Act, 1991 (RHPA) restricts the controlled act component of psychotherapy to certain regulated professions, including nursing.
The controlled act is defined in the RHPA as:
“Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgment, insight, behaviour, communication or social functioning.”
How will I determine if I’m performing the controlled act of psychotherapy?
Based on the RHPA definition above, there are five components in the controlled act and all must be met for you to be performing the controlled act:
1. You are treating a client
2. You are applying a psychotherapy technique
3. You have a therapeutic relationship with the client
4. The client has a serious disorder of thought, cognition, mood, emotional regulation, perception or memory
5. This disorder may seriously impair the client’s judgment, insight, behaviour, communication or social functioning
It is possible you may be performing psychotherapy but not the controlled act of psychotherapy. For example, if only four of the above components apply, you are not performing the controlled act.
You are in the best position to determine whether or not you are performing the controlled act according to the criteria.
The diagram below highlights that the controlled act is one element in the wide ranging practice of counselling and psychotherapy. Many of the activities that nurses frequently engage in share some common traits with psychotherapy but they are not psychotherapy. For example, activities such as health teaching, providing information, encouragement, support or instruction are not psychotherapy.
Do I require an order to perform the controlled act of psychotherapy?
During the exemption period an order is not required.
Following the exemption period, RNs and RPNs will require an order to perform the controlled act component of psychotherapy, just as they require an order to perform most other controlled acts they have access to. For example, administering a substance by injection.
It is important to remember that after the exemption period, an order is not required if it does not meet the threshold of the five criteria within the controlled act of psychotherapy unless sector-specific legislation (e.g. the Public Hospitals Act) or organizational policy requires it.
The College will review its position on the initiation of psychotherapy by RNs and RPNs. We will continue to request member feedback to determine if the need for an order for the controlled act of psychotherapy remains the right regulatory mechanism to ensure public protection.
Who can perform the controlled act of psychotherapy in practice?
In the case of the controlled act of psychotherapy, the RHPA authorizes members of 6 Colleges. These include members of:
- The Ontario College of Social Workers and Social Services Workers
- The College of Nurses of Ontario
- The College of Occupational Therapists of Ontario
- The College of Physicians and Surgeons of Ontario
- The College of Registered Psychotherapists of Ontario
- The College of Psychologists of Ontario
Are nurses able to use the title “psychotherapist”?
Yes, and you must adhere to specific regulatory requirements if you choose to use the "psychotherapist" title.
- When speaking to clients you may only describe yourself as a “Psychotherapist” if you also use your restricted nursing title .
For example: "I am an RN, psychotherapist." Or, "I am an NP and a psychotherapist."
- When describing yourself in writing, you must provide your full name as it appears on the College's Register (Find A Nurse), your protected title, and the title, "psychotherapist."
For example: Jane Goode, RN, Psychotherapist
I’m a nurse and I perform psychotherapy. Should I also register with the College of Registered Psychotherapists of Ontario?
Ultimately, this decision is up to you. As a nurse, if you have the knowledge, skill and judgment to do so, you may perform psychotherapy in your practice.
If you register with the College of Registered Psychotherapists of Ontario, this must be reported to CNO. To learn more about new reporting requirements, read our article in the June Standard.