This Psychologist Says No: Why I Oppose Ontario Psychologist Registration Changes That Lower Training Standards

In response to the recent proposal by the College of Psychologists and Behaviour Analysts of Ontario (CPBAO) to lower education and entry-to-practice standards for psychology registration, I submitted a detailed response outlining my concerns.

I believe the proposed changes could seriously undermine public safety, ethical standards, and the professional integrity of psychological care in Ontario.

I’m sharing my submission here to inform clients, colleagues, and community members about the critical stakes involved and to invite thoughtful dialogue on this important issue.

The College’s questions appear in blue; my responses follow in black.

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The Submission:

Do you agree that the regulation amendments proposed by the College of Psychologists and Behaviour Analysts of Ontario are in the public interest?

No.

If no, what concerns do you have about the proposed amendments to the Registration Regulation?

Until a month ago, the CPBAO maintained that a doctoral degree is a fundamental non-exemptible standard for autonomous practice. This requirement, under the Regulated Health Professions Act, existed to safeguard the public interest by prioritizing patient safety, practitioner competence and ethical practice. Training models associated with this standard ensured a stepwise educational trajectory, including graduate-level coursework, extensive experiential training across multiple settings, and rigorous evaluation and feedback from registered Psychologist supervisors. Each component played a vital role in developing clinical knowledge and skills, professional socialization, as well as complex ethical reasoning, which, taken together, enable an entry-level competence to practice safely and effectively. 

I must express my profound dismay and disappointment that the CPBAO is considering departing from this foundational requirement. Such a reversal of principle risks diminishing the depth and integrity of psychological training and does not represent “progress”.  It is difficult to understand how this change aligns with the College’s legislated responsibility to serve and protect the public interest through maintaining competence and ethical integrity. 

Before outlining my concerns regarding the proposed amendments to the Registration Regulation, I will summarize the key areas where the changes risk undermining both professional standards and public protection. This submission is organized into four parts. The first part highlights the core training and supervision safeguards being eliminated. The second examines how these reductions threaten ethical reasoning, professional integrity, and public safety. The third addresses the broader regulatory implications of interprovincial mobility and the need for national coordination. The fourth considers the weakening of practitioner evaluation and accountability mechanisms, and offers specific recommendations and actions to ensure ongoing protection of the public and the integrity of psychological practice in Ontario. References are provided in parentheses [].

A. Loss of Core Training and Supervision Standards

First, there will be a significant reduction in pre-doctoral practica requirements. During my graduate training, I completed four practica - one at the Master’s level and three at the doctoral level - which together involved over 1800 hours of clinical practice in psychological assessment and intervention. This work took place in a university training clinic, as well as in two hospitals across Toronto and the Greater Toronto Area. In comparison, the proposed model will require only one practicum placement of 300 hours.

Second, there will be an elimination of a pre-doctoral internship (or its equivalent).  My graduate training included an 1800-hour internship at Lakeridge Health Oshawa, consisting of four unique rotations in the Inpatient and Outpatient Mental Health Program, Acute Care (Medical) Inpatient Program (including psychology and neuropsychology), and the Eating Disorders Program.  This requirement is completely absent in the proposed model. 

In addition to reducing these core training components, the changes also remove critical opportunities for evaluation and feedback by Registered Psychologist Supervisors. Throughout  each practicum and internship, I received weekly supervision (at least one hour per week), and my supervisors completed two formal evaluations - at mid-term and at the end of training.  Over the course of my pre-doctoral training, nine separate registered Psychologists evaluated my work across eight different mental health service placements/rotations. 

Finally, the changes will reduce the amount of continuous, formative feedback that is essential for professional development, socialization, teamwork and reflective practice.  During my training, Psychologist supervisors observed psychotherapy sessions (live), reviewed session reports and notes, listened to recordings of intern-client therapy sessions, evaluated case or skills presentations, and provided ongoing verbal feedback.  Moreover, interns exchanged feedback with peers in group supervision and progress meetings.  These processes were crucial to the early identification of training gaps and difficulties, as well as to receive timely coaching to adapt and improve training outcomes.

I will now turn to how these recent changes threaten the ethics and professional integrity of psychological practice in Ontario.

B. Impacts of the Proposed Shifts

My chief concerns are the narrowing of clinical experience, the weakening of ethical reasoning skills, the increased risk to public safety, and the erosion of professional integrity.

1. Narrowed Clinical Exposure and Competency

The proposed reduction in training requirements raises serious concerns about the lack of breadth and depth in clinical training, which is essential for developing competent practitioners. For instance, under the new standards, graduates may complete their training after working with only one population, in a single setting, under one supervisor, and within a narrow age range. This restricted scope raises legitimate doubts about their readiness to serve diverse populations or to address a wide range of psychological issues they will encounter in practice. 

The concern grows especially urgent when new registrants choose independent practice after licensure. If they decide to work as a solo practitioner, they may struggle to limit their caseload to the (more narrow) areas where they are competent.  From a public service perspective, this means that clients could encounter substandard care more frequently, while clinicians may lack the training and reflexivity needed to recognize when their services are inadequate or fall below acceptable standards.

In contrast, the comprehensive training model already in place equips Psychologists to deliver effective services across multiple settings - including hospitals, primary care, schools, forensic contexts, and private practice - ensuring they are prepared for the complexity and variety inherent in real-world clinical practice. 

2. Ethics and Professional Integrity

The proposed changes strike at the heart of what it means to practise psychology responsibly. Psychologists work with vulnerable individuals, and our primary instrument is ourselves. Our training is not merely the acquisition of knowledge, but it also involves the cultivation of judgment, patience, humility, self-reflection and self-awareness.  

Ethical reasoning, developed through both coursework and supervised clinical experiences, is a cornerstone of psychology training.  While courses will emphasize laws, professional standards, and jurisdictional regulations, the ethical reasoning process is primarily honed during practica and internships. Under the direct supervision of experienced Psychologists, trainees are guided through ethical challenges encountered in assessment, treatment, and client interactions. Supervisors provide critical feedback and model professional judgment, which allow trainees to integrate ethical principles with clinical skills [1]. This process cultivates not only knowledge but also moral sensitivity, humility, self-reflection and self-awareness.  Such supervised experiences prepare trainees to develop an awareness of one's biases and emotional responses, which influence ethical decision-making, and to navigate real-life ethical dilemmas involving confidentiality, dual relationships, informed consent, and respect for diverse client backgrounds.

Enhanced ethical reasoning, developed through sustained training and supervision, serves as a crucial safeguard against errors in clinical judgment. It is precisely a lapse in this ethical vigilance that is likely to have contributed to a recent incident in which a therapist covertly relied on ChatGPT (artificial intelligence, AI) during a therapy session—not for administrative help, but to generate verbal responses to the client because they “felt stuck” in their work [2].  While anecdotal, this instance of covert reliance on AI vividly illustrates how essential ethical responsibilities are, and how a single error in judgment can result in loss of public trust. It is my belief that many professional and ethical challenges lie ahead, particularly in relation to the use of AI in psychological care.

In this way, the significant reduction in the duration and intensity of experiential training in the proposed model will jeopardize vital opportunities for trainees to develop and refine their ethical reasoning. Without sustained and skilled supervision, future practitioners may lack the mentorship essential for recognizing complex ethical issues, applying ethical principles consistently, and cultivating the self-reflection necessary for responsible clinical judgment. This gap increases the risk of ethical lapses, potentially compromising client welfare and eroding public trust in psychological services. 

In summary, supervision is not just oversight; it is an interactive, educational relationship that supports both professional growth and the protection of the public by ensuring competent and ethical service delivery.  Reductions in supervision will curtail this safeguard and limit trainees’ ability to learn from experienced practitioners who help them identify blind spots, navigate uncertainty, and uphold the high ethical standards necessary to uphold public trust, safeguard clients, and maintain the integrity of the profession.

3. Public Safety Risks

   
   

In a province that has upheld the highest professional standards for psychological practice in Canada, it is difficult to point to instances of misdiagnosis and inappropriate treatment.  By way of analogy, one might consider that the high level of success in Ontario is similar to the protective effect of high vaccination coverage in preventing measles outbreaks. Just as widespread vaccination creates herd immunity that shields the population from disease, rigorous professional standards have served as a safeguard to ensure the psychological care delivered to Ontarians was competent, trustworthy, safe and ethical. 

Similarly, as we are seeing how measles outbreaks have become more frequent and severe when vaccine coverage declines, the lowering of professional standards and reducing supervision in training raises the alert that misdiagnoses, inappropriate treatments and substandard care may increase as well.  

Over my decade in practice, I have observed instances of harm to clients after their involvement with practitioners lacking sufficient training who had used ill-fitting intervention, and/or who failed to detect clinical signs of more serious mental health disorders.  The consequences of these harms are summarized in Table I (below), and this list is not exhaustive. 

Table I: Summary of Observed Consequences of Practitioner Error, Incompetence, or Negligence

• Psychological harms include psychotic episodes, heightened distress and symptom severity, emotional and interpersonal trauma, and profound hopelessness about the future.

• Clinical harms include hospitalization, extended or derailed treatment courses, misdiagnosis, and the use of inappropriate or ineffective interventions.

• Relational harms involve disruption of therapeutic relationships, prolonged difficulty forming trust with new therapists, persistent anger or mistrust toward mental health professionals, and premature termination of treatment.

• Financial and social harms include financial strain or exploitation, as well as reduced engagement with healthcare and community support systems.

• Ethical and legal harms encompass acts such as sexual assault, harassment, and other abuses of professional power.

Given that Psychologists provide professional services to the Justice system and their opinions are utilized in high-stakes decisions, instances of inadequate or incompetent care could have far-reaching impacts.  For example, Psychologists are integral to the decision-making and legal processes of custody and access assessments, disability accommodations, return-to-work planning, and capacity evaluations.  Psychologists who serve as expert witnesses in court must uphold the highest standards of professional competence, providing opinions only within their areas of expertise and being prepared to rigorously defend their conclusions under examination and cross-examination. This role demands not only comprehensive knowledge and clinical skill but also unwavering integrity, as expert opinions can significantly influence legal decisions in addition to client well-being.  In these contexts, errors in judgment, whether through lack of experience or inadequate reflection, will have serious consequences for clients and the Justice system.

In summary, the analogy to vaccination highlights the critical importance of maintaining high standards as a form of ‘herd immunity’- protecting clients and the public from harm through collective competence and ethical vigilance.  Both the Canadian Psychological Association (CPA) and American Psychological Association (APA) have underscored the necessity of prolonged, high-quality supervision to develop core competencies such as case formulation, diagnostic accuracy, risk assessment, and ethical decision-making. Supervised clinical training in psychology is essential to ensure practitioner competence and public safety.  A reduction in the quality of clinical training, supervision and evaluation raises the risk of harm to vulnerable clients and to weaken trust in the profession.  At a time when mental health needs are growing, these changes risk a worsening of clinical outcomes and could increase the burden on health care system and on vulnerable populations.

C. Interprovincial Mobility is a National Challenge Requiring National Coordination

While the recent decision of the CPBAO might allow Ontario to claim compliance with interprovincial mobility legislation, it simultaneously places the province’s registration standards out of alignment with those of most other Canadian jurisdictions that retain a doctoral-level (or equivalent) entry requirement. Provinces such as British Columbia, Quebec, Manitoba, New Brunswick, and Prince Edward Island continue to uphold this doctoral benchmark as essential for autonomous practice.

Once the CPBAO’s proposed model is enacted, new registrants in Ontario would not be eligible for licensure in any of these provinces. In practice, this means the CPBAO’s initiative, rather than fostering labour mobility, will effectively limit Ontario-trained practitioners from moving elsewhere - a reversal of the very goal the policy purports to achieve. Far from harmonizing professional mobility across jurisdictions, this change risks deepening fragmentation in Canada’s regulatory landscape.

Interprovincial mobility remains a national challenge that demands coordinated and unified strategies. Unilateral regulatory changes, implemented in one province to satisfy local interpretations of labour mobility requirements, inadvertently reshape professional regulation at the national level without the benefit of broader consultation or impact assessment.

This trend raises pressing questions about the absence of interprovincial planning and the urgent need for leadership—both provincial and federal—to establish a coordinated approach to professional regulation. Such leadership is necessary to ensure that national standards protect the public, maintain professional integrity, and genuinely enable mobility, rather than create further barriers for qualified practitioners and confusion for the public they serve.

In 2020, Nova Scotia implemented a policy tool- an Exemption to Labour Mobility (2011) - that explicitly recognized discrepancies between its regulatory standards and those of other provinces (such as Alberta and the Northwest Territories), as well as the potential risks these discrepancies posed to public safety [3]. The province issued a Notice of Measure to inform applicants of corrective requirements necessary to meet Nova Scotia’s regulatory standards. It also established an individualized assessment process and, where required, additional supervised practice or education to address identified competency gaps.

Ontario would be well advised to consider adopting a similar mechanism, particularly in the absence of a broader national framework. Such measures could preserve the integrity of Ontario’s regulatory standards while still allowing for mobility that upholds competence and public trust.

Labour mobility is a legitimate concern for all Canadians, but the strategies, tools, and processes used to implement it must take into account the scope of psychological practice within each jurisdiction. Above all, these measures must ensure that public safety and consumer protection remain the guiding principles in any policy aimed at promoting workforce mobility.

Labour mobility policy must never come at the expense of public protection; the two goals are not mutually exclusive but must be achieved in concert through careful national coordination.

D. Practitioner Evaluation and Accountability Mechanisms

Two major concerns arise regarding practitioner evaluation mechanisms in the CPBAO’s proposed changes. 

First, it lowers training requirements - removing the doctoral standard and reducing supervision - while simultaneously dismantling essential evaluation and competency assessments. This dual weakening of education and evaluation is, quite simply, reckless.

Second, while many registrants might agree that the profession must evolve to meet contemporary societal demands, the rapid pace and manner of these changes raise serious concerns.  A colleague recently likened this to solving a housing shortage by hiring unlicensed tradespeople with no apprenticeships to build homes quickly- anyone would expect those houses to collapse. This analogy clearly highlights how cutting corners on training and ethics threatens not progress but structural failure.

Until now, CPBAO has recognized the doctoral degree as a fundamental safeguard for autonomous practice that protects public safety and ensures high professional standards. If the College chooses to lower this standard, it must provide clear, evidence-based assurances that public protection, competence, and ethical integrity will remain intact. The responsibility lies with the CPBAO to show how these changes will maintain or improve the quality of psychological care for Ontarians.

To address concerns about public safety and professional standards, the CPBAO should take concrete, transparent steps to monitor, evaluate, and strengthen the impact of these proposed changes. A list of key actions to safeguard Ontarians’ mental health is provided in Table II (below). 

Table II: Recommended Actions to Demonstrate Public Protection Under the Proposed Regulatory Standards

A. Non‑Negotiable Safety Requirements: 

1. Develop supervision models that prioritize essential educational outcomes to offset reduced experiential learning for new registration candidates.

   
   

2. Enhance continuing professional development and quality assurance programs to compensate for lowered academic qualifications among new registration candidates.

   
   

3. Conduct a detailed risk analysis identifying potential impacts on patient safety and clinical outcomes from reduced educational thresholds, and specify clear mitigation strategies.

   
   

4. Provide empirical data demonstrating that Master’s-level practitioners (with one year of supervised practice) consistently achieve clinical, ethical, and competency outcomes comparable to those of practitioners who met the doctoral standard.

B. Ongoing Monitoring and Accountability Recommendations:

1. Clearly articulate how the proposed standards fulfill CPBAO’s mandate to regulate in the public interest and to ensure safe and effective practice;

   
   

2. Compare the revised standards with those of other Canadian provinces and international benchmarks, and clarify the implications for interprovincial mobility and public expectations of entry-level autonomous practitioners.

   
   

3. Establish a transparent plan to monitor, evaluate and mitigate unintended negative consequences of the lowered standards, including how these impacts will be identified and addressed.

In summary, the proposed training reductions threaten to erode the safeguards that have long protected Ontarians from harm. Upholding high standards is not a matter of prestige or tradition - it is a moral and professional obligation essential to the ethical, competent, and safe delivery of psychological care.

E. Conclusion

The CPBAO has a statutory and ethical duty to uphold competence, ethics, and safety as core pillars of public protection. While modernization and mobility are worth pursuing, they cannot be achieved through the erosion of long-standing safeguards that ensure safe, ethical, and effective practice. The College should demonstrate, with data and transparency, how any new regulatory model will match or exceed current standards in protecting the people of Ontario.

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I encourage all psychologists, community members, clients, and policymakers to engage deeply with the Public Consultation process. Your voices matter in advocating for mental health care that prioritizes safety, quality, and ethical integrity.

The CPBAO consultation period is open until December 9, 2025. Please take this opportunity to review the proposals, submit your comments through the College’s official channels, and reach out to your local representatives.

Together, we must ensure that progress in expanding access to care does not come at the cost of compromising professional standards or public protection.

➤ Read more about the proposed changes:

• This site: What You Need to Know About the Changes Proposed for Psychologist Registration in Ontario (Link: https://www.drpaulamiceli.com/post/what-you-need-to-know-about-the-changes-proposed-for-psychologist-registration-in-ontario)

• College website: https://cpbao.ca/wp-content/uploads/Consultation-Amendments-to-Registration-Regulation-under-the-Psychology-and-Behaviour-Analysis-Act-2021-5.pdf

➤ Submit comments to the CPBAO consultation portal: https://www.surveymonkey.com/r/BZ5SB8Q

➤ Contact your local MPP to express your concerns about maintaining professional standards and public protection. Use this link to locate your MPP: https://www.ola.org/en/members/current.

Together, we stand stronger—united in diversity and committed to better mental health care for all Ontarians

References:

1. Falender, C. A., & Shafranske, E. P. (2017). Supervision essentials for the practice of competency-based supervision. American Psychological Association. 

   
   

2. Clarke, L. (September 2, 2025). Therapists are secretly using ChatGPT. Clients are triggered. MIT Technology Review. https://www.technologyreview.com/2025/09/02/1122871/therapists-using-chatgpt-secretly/

   
   

3. Nova Scotia Board of Examiners in Psychology (November 16, 2011). Notice of Exception to Labour Mobility to Meet a Legitimate Objective under Chapter 7 of the Agreement on Internal Trade: Psychologist, Government of Nova Scotia. https://novascotia.ca/lae/RplLabourMobility/documents/Psychologist.pdf