Below are excerpts from documents obtained by SPT via a Freedom of Information request submitted to the Ontario Ministry of Health.

Note the admission by a Senior Policy Analyst that controlled acts are intended only for inherently risky activities.  As such, the 14th controlled act of psychotherapy has been nothing short of a flagrant abuse of the RHPA legislation.

By definition, controlled acts are those acts considered to carry an inherent risk of harm in the course of providing health care to a patient. Only those acts that are inherently dangerous are restricted, leaving as much health care as possible in the public domain.

It has never been the intention of that Act to regulate professionals who, while they may provide services that fall under the broad range of psychotherapeutic techniques, are not necessarily psychotherapists (e.g., marriage counsellors, etc.). Under the RHPA’s overlapping scopes of practice, there is no prohibition against an unregulated practitioner performing services within a regulated profession’s scope of practice.

And note the last-minute scramble to clarify for the public the meaning of the controlled act, which came into law 8 years ago (in June 2007) and awaits a mere signature to become enforceable.

From a May 2015 email:

I asked her, again, how she as the regulator plans on distinguishing between a non-psychotherapist’s performance of the CA and other practice, and she was unable to tell me. This is, I think, the salient point. What criteria will the College use to hold mental health services up against when fulfilling their legislated duty?

Click here to download the excerpts.