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Welcome to our Inter-provincial Practice information guide. CCPA has created this page to help you better understand, navigate, and answer your questions for working across provinces and borders.  

Please note that this section is to provide members with a summary of relevant information regarding interprovincial practice. It is each members’ responsibility to verify the information and seek clarification of questions directly with each regulatory body. CCPA is not responsible for decisions made by members based on their interpretation of the information included below. 

What is Inter-Provincial Practice? 

Inter-Provincial Practice is the provision and administration of ethically based counselling and/or psychotherapy between a practitioner and client; where the client lives/is visiting in one province or territory and the practitioner is in another province or territory. This cross-province practice occurs in a virtual setting.  

Interprovincial practice has been around for years; however, the COVID-19 pandemic highlighted the need and constraints in regards to counsellors/psychotherapists being able to provide services to those in need, especially to those who may not have been located in the same province as their clients. This has led to a complex and confusing landscape for members. 

In Canada, psychotherapy is regulated at a provincial level, but not all provinces are regulated. As of August 2023, Quebec, Ontario, Nova Scotia, New Brunswick, and Prince Edward Island that have regulated psychotherapy. In Alberta, the bill for regulation has passed but the college is not yet open. The other provinces and territories are unregulated. 

Curious to learn more about regulation?  

What Practitioners need to know

Regulated Practitioners

Regulated Practitioners are those who are registered and in good standing with the regulatory colleges in Ontario, Quebec, New Brunswick, Nova Scotia and Prince Edward Island.  

If you reside in a regulated province and intend to provide the act of counselling and/or psychotherapy, you must become regulated in that province to use the restricted title of that regulatory body, for example Registered Psychotherapist in Ontario. 

If you are currently registered in one regulated province, and your client resides/is moving to another regulated province, you can work with that client without additional credentialling from that regulated body. 

Unregulated Practitioners

Unregulated Practitioners are those who reside in an unregulated province or territory which includes, British Colombia, Alberta, Saskatchewan, Manitoba, Newfoundland, Yukon, Northwest Territories and Nunavut. 

If you currently live and practice counselling and/or psychotherapy in an unregulated province or territory, CCPA encourages you to become a Canadian Certified Counsellor. This is of benefit to you as the requirements for certification align closely with the application criteria required of the regulatory colleges to date. For more information on certification visit our certification page found in the home menu.  

If you are currently a Canadian Certified Counsellor and your client resides/is moving to a regulated province, there will be additional requirements to satisfy with the regulatory body of that province or territory. 

Steps for inter-provincial or cross-border practice

Practitioners must verify the following requirements before working inter-provincially or across borders (in another country) with a client. 

Cross-border practice is defined as a practitioner residing in one country, and their client lives in another country.  

Practice Requirements of Client jurisdiction

The practitioner must verify, understand and adhere to the counselling and/or psychotherapy requirements of the location where their client lives. 

 

Based on your current credentials and the practice requirements of the client’s location, do you meet the criteria for practice? 

Liability Insurance

The practitioner must verify that their professional practice insurance covers inter-provincial or cross-border practice.  

 

Does your insurance provider allow you to work with a client in a different province or country? 

Client insurance coverage

The practitioner is encouraged to first speak with the client to determine if they have benefits coverage for the services provided.  

 

Does the client’s insurance cover service for practitioners who reside in a different province or country from that of the client? 

Virtual practice security

The practitioner must ensure that the virtual telehealth platform provider they are using meets the cybersecurity and local legislation around the privacy and storage of personal health information. For example, the Personal Health Information Protection Act in Ontario. 

 

What are the legislative requirements of the client’s jurisdiction? And does my virtual platform meet these requirements? 

Supervision

If the practitioner is under supervision, they are required to inform their supervisor and discuss any potential concerns. For example, assessing risk or managing a safety plan for a client in a different location from the practitioner. 

 

Are there any potential problems that may arise from working inter-provincially with this client? 

Summary of Inter-provincial Practice Guidelines by Regulatory Colleges 

The information below is quoted directly from the regulatory colleges outlined below

Nova Scotia College of Counselling Therapists
  • RCTs and RCT-Cs Providing Service Outside of Nova Scotia As licensed registrants of the College, RCTs and RCT-Cs are permitted to provide counselling therapy services to clients who reside outside of Nova Scotia when all the following conditions are met:  
  • That clients are advised of where you are located, that you are regulated by NSCCT, as well as the website, email and phone number of the College. 
  • That your liability insurance coverage extends to counselling out-of-province clients.  
  • That your videoconferencing platform is PIPEDA compliant and that the servers are located in Canada (the college cannot recommend or provide advice on the use of any platform).  
  • That, if you are an RCT-C, your candidacy supervisor indicates their agreement to supervise you while counselling clients out-of-province.  
  •  That you have obtained confirmation from the regulator in the province in which the client resides that their rules permit you to counsel clients in their province. And that you abide by any guidelines or limitations they set upon your practice in their province.  
  • Click here to visit the college website
College of Registered Psychotherapists of Ontario

I am not in Ontario but I have a client in Ontario who wants to work with me

Whether a client resides in Ontario or in another jurisdiction, registrants may provide services using communications technologies as long as: 

  • they are able to do so competently and in a manner that abides by the Professional Practice Standards; 
  • there is no law, regulation or standard in the other jurisdiction that would restrict or prohibit the registrant from providing services to a client located in that jurisdiction; and 
  • they have appropriate liability insurance coverage considering the particular technologies used to provide services, the risks these technologies may present, and the possibility that the registrant’s practice will cross into other jurisdictions. 

I practise in Ontario but have a client outside of Ontario who wants to work with me

Practice Matters

CRPO does not require practitioners who reside in another jurisdiction to become registered in order to work with a client in Ontario providing: 

  • the therapist does not intend to advertise or otherwise promote their services in Ontario; and 
  • Ontario-based clients do not form a substantial proportion of the therapist’s workload 

If any of these factors were to change, CRPO would revisit the facts and consider whether the therapist should apply for registration, even on a temporary basis. 

Click the link above for more information.  

Out of Province Registrants

Out of Province Registrants

As a new regulatory college, CRPO is not permitted to impose residency or citizenship requirements on individuals who apply to CRPO. Hence it is possible for an individual who resides in another province, or anywhere in the world, to become registered with CRPO. 

Click the link above for more information.

The College of Counselling Therapists of New Brunswick
  • Counsellors from other provinces are not prohibited from providing counselling to clients in New Brunswick as long as this is permitted by their own regulator. In New Brunswick, “Licensed Counselling Therapist” and its derivatives are protected and can only be used by CCTNB registrants.  
  • Therapists who are not regulated in New Brunswick should provide clear and succinct information to potential NB clients that details their licence number, in which province they are regulated and the name and contact information for the College with which they are registered.  
  • Therapists who are not CCTNB registrants should also clearly inform clients how and where they should report any concerns or complaints and advise them that the College of Counselling Therapists of NB would not be involved in the process. 
College of Counselling Therapy Prince Edward Island
  • This policy is for those practitioners that use the term Counselling Therapist and who wish to work with clients in PEI but are not members of the CCTPEI.  The public is free to choose any practitioner with whom they wish to work.  If a practitioner using the title of Counselling Therapist from another jurisdiction is providing services in PEI, they do not need to register with the CCTPEI if:  
  • 1. They do not advertise their services in PEI;  
  • 2. They do not maintain more than 3 clients at any time; and 
  • 3. Their PEI clients do not form a substantial portion of their client base (less than 20 %). 
  • If a practitioner from another jurisdiction is providing counselling therapy services in PEI and they do not meet the above conditions, they may register with the CCTPEI in one of the following ways:  
  • 1. As a New Applicant applying for general or provisional registration;  
  • 2. As a Labour Mobility Transfer; or  
  • 3. As a Special Registrant (1 month short-term non-renewable registration). 
  • To apply as a Labour Mobility transfer or Special Registrant, the applicant must have current registration in good standing in another Canadian jurisdiction and 2M in professional liability insurance.  Any practitioner who is not a registrant of the CCTPEI  who is working with clients in PEI is expected to disclose the following:  
  • 1. That the client will not be able to bring any complaints to the CCTPEI as it will be outside of the CCTPEI’s jurisdiction;   
  • 2. The name of the College and/or association to which complaints may be brought (or that there is no College or Association to which complains may be brought); and  
  • 3. The method by which complaints may be brought forward.  
  • Practitioners in other provinces who wish to expand their work in PEI are welcome to apply for registrant status with CCTPEI. Benefits for practitioners in other jurisdictions of joining the CCTPEI include:  
  • 1. Registrant status in the CCTPEI including access to our registrar and use of our logo on your website.   
  • 2. Use of the title Counselling Therapist in working with and advertising to clients in PEI  
  • 3. No limit on the number of clients you can work with in PEI 
Ordre des Psychologuess du Québec

The Ordre des psychologues du Québec (OPQ) does not provide information on their website regarding interprovincial or cross-border practice. Below is information received from the Administrative Assistant to the General Secretariat. 

A psychotherapist located outside of Quebec can offer online services to clients located in Quebec. We recommend that the person located outside of Quebec who offers online services to the Quebec population be legally authorized to practice the profession of psychotherapist in his or her jurisdiction.  

This person must also be covered for professional liability. It is also required to notify clients that any disciplinary action must be brought before the regulatory body in the jurisdiction where the professional is registered, if applicable. 

For more information, please call OPQ directly. 

 

From BMS, CCPA’s insurance provider partner

1. BMS’s liability insurance is Canada-wide; however, they advise practitioners to follow the rules and regulations in their jurisdiction, in addition to the client’s jurisdiction (wherever they might be located).  

2. They advise that each counsellor/psychotherapist talk to the relevant regulatory bodies to make sure they can practice.  

3. BMS is only Canada-wide, so if you are seeing clients outside of Canada you are not covered. 

4. If you decide to counsel people in other provinces, then you need to make sure that you let your clients know about:  

The college that you are part of, if applicable 

5. Where you are located  

6. How to contact your regulator  

7. Your video-conferencing platform is PIPEDA-compliant  

8. Additionally, if you are under supervision, you should only be counselling people in other provinces if your supervisor agrees to it.