CCPA is a national professional association while BCACC is a provincial professional association. There are many similarities between the offerings of a provincial and national association. This includes professional development and networking opportunities, liability insurance and educational requirements for certification.

Being a member of a national association provides members with:

• an additional benefit of connecting with professionals across the country;
• having your needs advocated for by a highly reputable and nationally recognized association amongst municipal, provincial and federal government bodies, other health associations and external stakeholders such as insurers and;
• an excellent source of information for you if the laws and regulations regarding the profession change.

There is no certainty around which title will be used for regulation, or what the requirements to join the College will be. In other provinces, the government did not work with one association nor did it only accept one designation for entry into the College. Government discussions have led CCPA to believe that no decision has been made with regard to the title or entrance requirements. We also know that in most provinces, once regulation occurred, there were many practitioners who registered with the College that did not belong to any association. The government cannot deny access to the College for these practitioners.

The provincial government will decide which title is most appropriate based on their research and consultations. What is most important are the requirements for practice and this will determine entry more than a voluntary title that is used by a provincial association does. The requirements leading to the CCC and RCC designations are very similar and both of a high standard.

What we do know is that there will be at least two routes to entry: a legacy route and a regular route. The legacy route will be for existing practitioners and its requirements will most likely be different than those for the Regular Route (recent graduates). The requirements for each route will be determined by the government and articulated in the Registration Regulations developed by them.

CCPA is recognized nationally for its high standards when it comes to educational and practice standards for the Canadian Certified Counsellor (CCC) designation. In other regulated provinces, the Regular Route has required a master’s level of education. If you have your CCC you have met this requirement. The legacy route may also require a combination of education, years of experience, direct client contact hours, and supervision hours.

Many are wondering about the above title question given third-party insurance coverage. Upon regulation, insurance providers typically include the use of the provincially regulated title in their health benefit plans.

At this point there is no way of knowing for sure.

CCPA will continue to work toward influencing the government to declare Counselling Therapist as the regulated title as this is the title being recognized in other provinces (on a regulatory level – such as NS, NB, PEI, and AB – even if not yet proclaimed). In fact it was the BC Ministry of Health that first suggested Counselling Therapist as the title as this has been the one used in many other provinces.

Ensuring consistency as far as titles go for the profession nationally is important when considering issues related to mobility and public recognition of the profession. Doing so also supports our campaign to remove GST/HST from counselling services. This would help as the federal government has stated that it requires the profession to be regulated in 5 provinces. Recently this has been amended to require the titles to be the same in all provinces.  Supporting BC to be regulated under Counselling Therapist is another way for us to meet this requirement beyond our current campaign. (www.taxfreetherapy.ca)

It can be a tough decision to make at this stage and we recognize this. However, there are clear benefits to being a certified member of CCPA regardless of the status of regulation in your province. We stand by our members. We have your back. A college is there to protect the public, and we’re here to protect and support you.

When it comes to questions regarding ethical issues, professional standards of practice, liability insurance, professional development opportunities and an accessible national community to support you throughout your career – we’re the one entity you’re going to want to turn to. You might also see a benefit in gathering information now in preparation for regulation and having all of that on file after applying for and obtaining your CCC designation.

As we await regulation in the province, CCPA continues to advocate for recognition of the CCC designation by insurers and employers & we have made significant progress in this area. Examples include Veterans Affairs Canada, the Public Service Healthcare Plan & many private insurance plans. Recently we attended & presented at the Canadian Life & Health Insurance Association annual national conference, continuing to promote CCCs in unregulated provinces such as BC.

Holding this designation increases the likelihood that professional services will be covered and may open the door to job opportunities.

The HPOA provides the framework for the super colleges and is not specific to each college’s bylaws; this differentiates the HPOA from other provinces’ health acts. What is also not clear but expected is that the super college that will regulate the profession of counselling/psychotherapy will include psychology. The Ministry of Health is developing model bylaws that will be adapted by each regulatory college from which they will develop their profession-specific regulations.

Many requirements specific to a profession are set by the college or the profession-specific branch within a college.  As the government progresses through stages to regulate a profession, the expectations and requirements become more specific. Also, not all items in an Act are necessarily enforced in health regulations or make their way to profession-specific regulations.  While an Act cannot be easily amended or repealed, there may be ways to influence the college-specific regulations and bylaws. This is how the BCACC and the CCPA can contribute to this process.

It is not likely that counselling will be a protected activity right away.  Regulation can include a protected title, activity, or both. Currently, Ontario and Quebec have title and activity protection of psychotherapy. Nova Scotia has title and activity protection of counselling therapy. For title protection, only those who meet the college’s requirements will be licensed to use the protected title.  Those who do not belong to the college will continue to be able to practice so long as they do not use the protected title. It is possible that as time goes on, the government may decide to regulate certain profession-specific activities.  This understanding is based on what has been done in other provinces.

The BCACC and CCPA will continue to inform and educate the public and all relevant institutions regarding the difference between licensed (i.e. statutorily regulated) practitioners and non-licensed practitioners.

Counselling will likely be included under the new super college (The College of Health and Care Professionals of BC) when the HPOA is enacted. Regulatory colleges typically have a CEO and/or Registrar who run the college’s day-to-day operations (registration, inquiry, discipline).   We expect there to be profession-specific teams within the college to deal with the nuances of each profession.  A specific committee under the HPOA will oversee the discipline aspect of the college’s work.  This understanding is based on our high-level discussions with the Ministry of Health.

As the new HPOA is enacted, adjustments to the management of client information confidentiality may occur. Nevertheless, the regulatory authority overseeing complaints against practitioners will ensure compliance with privacy laws and bylaw provisions, maintaining the integrity of confidentiality measures.

All practitioners must apply to the regulatory college and meet the requirements to be licensed. No designations will be automatically ported.

The regulatory college will set a mandatory quality assurance framework requiring practitioners to maintain their professional skills and demonstrate ongoing competency based on their practice area.  The number of professional development or continuing education credits varies, typically 30 to 40 hours every two years. This information is based on what is currently being done in the provinces that regulate the professions of Counselling Therapists and Psychotherapists. The BCACC has created a Quality Assurance program like what might be expected of the regulatory college to familiarize its members with the process, which will be launched in May 2024.  The CCPA has a similar framework for Continuing Education Credits that has existed for many years.

In addition to this, we expect there to be standardized practices around supervision and supervisory practice requirements.

We do not know for sure, but we can speculate based on what happened in the other regulated provinces. This includes a master’s degree in counselling psychology or related field, requirements for minimum direct client contact hours and supervision hours and possibly being required to pass a jurisprudence examination.  Those who do not meet the educational requirements and have many years of experience may be able to obtain a license under a grandparenting route if the college decides to offer this. The grandparenting requirements have not been defined yet.

The Standards of Practice (SoP) to be used by the new college is to be determined. In the CCPA/BCACC joint regulation application to the government, both associations’ SOPs[1] [2]were referenced. Through the [1] CCPA Standards of Practice &[2] BCACC Standards of Practice.

process of regulating a profession done by the BC government, other professional associations have also been consulted.

In other provinces that have undergone regulation, such as Ontario, documents like this were used as initial “building blocks” for the College, creating its Standards of Practice document. Some standards developed by associations may be helpful to practitioners in enhancing their practice, but they are not directly related to the college’s purpose and the protection of the public. Thus, in forming colleges in other provinces, some standards were adopted that were quite similar to existing SoPs from associations. In contrast, other Standards were significantly modified or even removed. Others are entirely new and different, reflecting what the College views as important toward its primary purpose and jurisdiction: the public’s protection.

As mentioned previously, BC is the first province to regulate under the framework of “Super Colleges” (which has been a commonly used framework in the UK and EU to regulate due to being seen to increase centralization and efficiencies), so we have no way of knowing what the not yet formed College will determine. The CCPA, BCACC and other professional associations are in regular contact with the government and will continue to engage with all relevant regulatory bodies when formed to advocate for the needs of both our members and the public.

Even after the College is formed, it will be more critical than ever to maintain membership in associations, ideally such as both CCPA and BCACC, as membership plays a vital role for professionals, which is outside the College’s aim to provide. Each association has a different focus, providing unique value to its members. The CCPA has a national and provincial focus, offering a variety of member benefits that include a national voluntary professional designation of Canadian Certified Counsellor (CCC), a long history of supporting unregulated provinces to seek regulation, a national annual conference, a national designation for Supervisors and provincial and federal advocacy suchthe elimination of tax on counselling and psychotherapy services.

BCACC has a provincial focus, hosting a provincial conference, providing regional events, and the publication of INSIGHTS magazine for members, provides a, and advocates for members with provincial stakeholders on important issues like rates of pay.

The two associations also overlap, including a web-based tool to help the public find counsellors, member events in BC, professional development opportunities and advocacy work with national and provincial insurers.  The associations also combine resources, such as hosting a Student Research Conference at a host university in BC in November 2024 and, working together towards regulation in a province to align with national standards of competencies for counsellors that allow labour mobility and recognition across provinces. Furthermore, a partnership was formally established between BCACC and CCPA in February 2023, enhancing their collaboration. Without sufficient members paying member dues to the associations, the benefits provided by the associations would be massively reduced. Given its public protection role, it is not the college’s job to provide these services to professionals.

Note that the fees members pay to a college only allow them to use the protected Title/perform the Activities (if applicable) the college designates and maintain their “good standing” in said college so they can legally practice. However, no part of the fee paid to a college goes towards the associations.

When the profession is regulated and title protection begins, insurance providers will be encouraged to include coverage for the newly regulated title, and both associations will advocate with insurers in this regard. Some insurance providers may include additional mental health professional titles other than the regulated title. Yet, this will not be guaranteed across all providers. By choosing not to become regulated by the regulatory college, practitioners will face significant uncertainty of having their services covered by private insurance, which will differ from client to client.

The professional title the government will choose at this point is unknown. Currently, the title of Registered Psychotherapist is regulated in Ontario and Quebec. The title of Registered or Licensed Counselling Therapist is regulated in Nova Scotia, New Brunswick, and Prince Edward Island.

BCACC and CCPA submitted a joint application to the government with the proposed professional title of either Clinical Counsellor or Psychotherapist on May 18, 2023.

Currently Newfoundland, Saskatchewan, Manitoba, and Alberta are working towards regulation proposing the professional title of Counselling Therapist.

Regardless of the government’s choice, the trademarked title of RCC will remain with the BCACC and the trademarked title of CCC will remain with CCPA.

Counsellors in all disciplines and with all levels of education will be able to continue to practice so long as they do not use the “protected” title and do not perform any “restricted acts” if the government enacts a controlled act for counselling.

The CCPA has long advocated for the removal of GST and HST on mental health services provided by Counselling Therapists and Psychotherapists, as they are regulated professionals providing counselling and psychotherapy services.

In November 2023, the federal government committed to passing legislation to remove the tax on these services. Currently, the proposed changes are to be discussed that the House of Commons Standing Committee on Finance in April 2024.

You can find detailed information about this bill on the official parliamentary website: Bill C-59

While the legislation is not yet finalized, and therefore, it is unclear exactly how it will be applied across the provinces, if the BC government chooses the title of Counselling Therapist or Psychotherapist, practitioners holding this title may be exempt from charging tax on counselling therapy and psychotherapy services (pending the details of the federal government legislation).

To learn more about this, visit www.taxfreetherapy.ca.