Policy and Political Action

Policy & Political Action

RNAO support of independent initiation of the controlled act of psychotherapy (Feedback to College of Nurses of Ontario, Anne Coghlan)

Anne Coghlan, RN, MScN
Executive Director and CEO

Re: RNAO support of independent initiation of the controlled act of psychotherapy

Dear Anne,

The Registered Nurses' Association of Ontario (RNAO) appreciates the Council's decision at their December 2018 meeting to circulate for feedback a draft regulation that would, if approved by government, enable the independent initiation of the controlled act of psychotherapy. RNAO strongly supports the proposed amendments to Part III (Psychotherapy) of Ontario Regulation 275/94 (General) under the Nursing Act, 1991.

As you know from our meetings and correspondence over the years, RNAO has grave concerns about RNs requiring an order from a physician or NP as detrimental to access to mental health services, disruptive to the continuity of care, and cost ineffective with its duplicative of scarce health human resources. Like other disciplines that already have the authority to perform the controlled act of psychotherapy, qualified registered nurses are best situated to assess their own knowledge, skill and judgment, a particular client's condition, appropriateness of intervention, and accept sole accountability for initiation. That is why then-Minister of Health and Long-Term Care, Dr. Eric Hoskins, asked the Council to revisit this requirement as he had "full confidence in a RNs' ability to make an appropriate assessment to initiate the act."

RNAO is proud of our members that have provided expert, safe, and compassionate psychotherapy services over the years and even decades. They have sought out and completed evidence-based training in psychotherapy that includes theory, practicum, and supervision in order to be competent as they entered practice and as part of ongoing professional development.

In keeping with the guidance received from these members and RNAO's Mental Health Nursing Interest Group (MHNIG), we urge the College to provide practice standards, guidelines, and tools equivalent to the other regulatory colleges whose members practise psychotherapy. As an example, the College of Occupational Therapists of Ontario has updated standards for psychotherapy and a decision tree to help their members determine when the standards for psychotherapy apply. This would provide clarity to novice nurses who are seeking direction in pathways to provide psychotherapy services, enhance public safety, and provide a common, congruent approach to this vital service.

Increasing access to nurses who are qualified to practice the controlled act of psychotherapy has the potential to help in the recovery of many individuals, families, and communities that are currently in distress. RNAO and MHNIG members who are experienced in the practise of psychotherapy reiterate a strong desire and willingness to work with CNO on this file.

Thank you again for the opportunity to provide feedback.

Warm regards,

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

CC:      Hon. Christine Elliott, Minister of Health and Long-Term Care
Helen Angus, Deputy Minister of Health and Long-Term Care

Resource Type: 
Letter