Policy and Political Action

Policy & Political Action

Email response to posted proposed regulatory change re psychotherapy

Thank you for the opportunity to provide feedback on the proposed regulatory amendments to Ontario Regulation 275/94 under the Nursing Act, 1991 to enable the initiation of psychotherapy by registered nurses (RN). The Registered Nurses' Association of Ontario (RNAO) is the professional association representing RNs, nurse practitioners (NP), and nursing students in all roles and sectors across Ontario, including those working in mental health. We strongly support these regulatory amendments to RN scope of practice.*

Since 2005, RNAO has advocated for psychotherapy as a controlled act and for independent initiation of psychotherapy by RNs. Further, we continue to urge approval of the proposed regulation before the current exemption ends in January 2020 in order to avoid unnecessary barriers to care – such as RNs requiring an order from a physician or NP to perform the controlled act of psychotherapy. Such a barrier is detrimental to access, disruptive to care, and an ineffective use of a skilled health provider. 

Across Ontario, access to mental health services is limited. The issue of access is particularly acute in rural and underserviced areas of Ontario. Ensuring that the initiation of psychotherapy is within the scope of practice of an RN is necessary to address the shortage of such services in Ontario.  

While RNAO is supportive of the proposed regulatory amendments, we urge the government to address restrictions on RN initiation by setting. The Public Hospitals Act, 1990, for example, restricts RNs from initiating psychotherapy in hospital settings, which can include remote nursing stations and community settings attached to hospitals. Removal of practice restrictions by setting would ensure that the intent of this regulation is fully realized and access to our health system expanded for those in need of mental health services. 

Please find attached Next Steps to Expanding RN Scope of Practice that further details the additional changes needed to move forward on this important scope change.
Thank you for considering our feedback.

Warm regards,

Doris Grinspun, RN, MSN, PhD, LLD(hon), Dr(hc), FAAN, O.ONT
Chief Executive Officer, RNAO

*Note: A summary of the proposed regulatory amendments were posted in lieu of the proposed regulation. Please note that while RNAO supports amending the regulation as summarized, we may have future feedback with respect to the amended regulation itself.

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