Consultations with the CRPO

Advocacy is one of the cornerstones of our OSRP mission.

One of the most important pieces of advocacy we undertook in 2019 was to write a letter to the CRPO regarding the Proposed Regulation Barring Sexual Contact with Former Clients for 5 Years.

OSRP President, Claire Watson, authored a letter on behalf of the PRPA, (Partnership of Registered Psychotherapist Associations) regarding this proposed regulation. We have posted the letter below for your reference. And we will let you know the CRPO response later this month. 

We’d love to hear your feedback, either in the comments section at the end of this post, or you can send your thoughts to

To make comments: click first on the April is for Advocacy title and then scroll down to the bottom of the page where you'll see the comment box.

February 11, 2019

Deborah Adams
College of Registered Psychotherapists of Ontario (CRPO)
375 University Avenue, suite 803
Toronto, ON M5G 2J5

Re: Proposed Regulation Barring Sexual Contact with Former Clients for 5 Years

Dear Ms. Adams,

We are delighted to be writing to you as the now officially established “Partnership of Registered Psychotherapist Associations” (PRPA).   We formalized our Terms of Reference on February 2, 2019 with our mission to respond to and advocate for issues pertaining to the practice of psychotherapy. The Member Groups are listed at the end of this letter.

We are writing in response to your invitation for stakeholders to comment on the Proposed Regulation “Extending Definition of Patient/Client in Relation to Sexual Abuse” as well on the related document “Policy on Sexual Contact with Former Clients within 5-years Post Termination of Care.”

We have chosen to do this in letter format rather than via Survey Monkey in order to offer more elaborate feedback with the benefit of combining comments and questions from our many associations.

Sexual abuse is an issue we take very seriously as helping professionals and particularly as psychotherapists whose work involves creating safe relationships within which growth and healing can take place.  We agree with your Policy statement that RPs “owe a duty of care to their clients and the general public to safeguard client well-being.” Therapist-client boundaries need to be made clear and be well maintained.  Unfortunately, violations of those boundaries will occasionally happen, thus we understand the need for Regulation to protect clients based on tenets of safe, effective and ethical care.

We acknowledge the work done by the CRPO to get the proposed Regulation this far and for sending it out for consultation.


We recognize that CRPO’s Regulations and Policies on sexual contact with former clients must adhere to the Regulated Health Professions Act (RHPA), revised in 2017 to prohibit romantic or sexual relationships between clients and members of any RHPA College for one year after termination of treatment – “or a longer period of time as may be prescribed.”  We recognize that the CRPO has proposed a 5-year post therapy period which we have questions about as you will read below.

We also acknowledge that the CRPO’s definitions of Sexual Abuse are those prescribed in the RHPA. As such, we have no issues with how the CRPO addresses Sexual Abuse during active therapeutic relationships. Our comments and questions pertain strictly to the proposed five year post care period.

Opinions on the length of the post therapy period vary considerably. From the survey feedback you’ve reported on the CRPO website, opinions range from a few months, to a few years, to never.  This range is also represented in the opinions and policies of our PRPA members. We are also aware anecdotally that the views of RPs on post therapy sexual contact vary by cultural background, modality, urban vs rural context, gender, sexual orientation and so on.

In general, our impression is that post therapeutic therapist-client romantic relationships are rare,

thus the majority of RPs have little firsthand experience of post therapeutic sexual relationships. Nor do we have any research information or training in this area. In fact, the proposed 5-year regulation is making us think for the first time about what this could look like.

Thus, we are not able to give you a collective “yes” or “no” to the 5-year time frame, as associations have varying policies.  Instead, we’re coming to you with questions that will help us better understand the proposed regulation. We believe that knowing more will help us understand the CRPO’s intentions, give us more information for discussion, and hopefully reduce anxiety about the disciplinary aspect of this regulation.   


  1. Can you share your thinking on what influenced your determination of a 5-year post therapy period?
    • What is CRPO’s experience with post-therapy complaints regarding sexual contact?
    • Can you share any research that informed the establishment of this cooling off period?
    • Can you share how other psychotherapy regulating bodies in Canada and elsewhere address this situation?
  2. Given that the proposed new Mandatory Penalty will be a significant 5-years revocation of licence, we’re wanting to know what the CRPO might take into consideration when investigating a complaint of sexual abuse.

a) How might the CRPO account for the nuances of the therapist-client relationship, transference and power dynamic based on the therapy which took place?  Do you view that the power differential may vary greatly depending on modality and length of time with the therapist, for example:

  • Long-term in depth therapy vs single-session solution-focused therapy
  • Parent-child therapy
  • Group sessions vs one-on-one sessions
  • Couples counselling
  • On-line therapy

b) Has the CRPO sought opinions from practitioners in small towns or remote areas, LGBTQ practitioners, male vs female perspectives, culturally diverse perspectives?

3. Can you help us understand what is meant by “the mandatory penalty will be a reprimand and revocation of the member’s certificate of registration for five years, regardless of the circumstances?”

  • What “circumstances” are you referring to?
  • Will the circumstances be determined before any penalty is imposed?
  • Will an Appeal Process still be available?


As you can see, the PRPA is asking CRPO to help us become more informed on therapist-client relationships post therapy in light of the proposed regulation.  Your response to our letter will help us move this discussion into our respective associations with more understanding and clarity.

Secondly, are you open to continuing this exchange with PRPA on this matter?  We understand that your deadline for stakeholder feedback was February 8 and that unfortunately we only recently came together to give you our input. Once we receive your reply and have another round of discussion among ourselves, will there be time before the new regulation is passed for us to send you additional thoughts?

Again, to you Deborah and the CRPO Sexual Abuse committee, thank you for inviting our input and we hope to continue this discussion as you refine the regulation. There’s a lot to consider and we appreciate that you’re listening to RPs.

We look forward to receiving your reply and continuing the discussion.


Claire Watson

President, Ontario Society of Registered Psychotherapists

On behalf of

PRPA signatories (in alphabetical order)  

  • Canadian Art Therapy Association (CATA)
  • Canadian Association for Sandplay Therapy (CAST)
  • Canadian Association for Spiritual Care (CASC)
  • Canadian Counselling and Psychotherapy Association (CCPA)
  • Canadian Humanistic and Transpersonal Association (CHTA)
  • Music Therapy Association of Ontario (MTAO)
  • Ontario Art Therapy Association (OATA)
  • Ontario Association of Consultants, Counsellors, Psychometrists and Psychotherapists (OACCPP)
  • Ontario Association for Marriage & Family Therapy (OAMFT)
  • Ontario Expressive Arts Therapy Association (OEATA)
  • Ontario Society of Registered Psychotherapists (OSRP)
  • Professional Association of Canadian Christian Counsellors and Psychotherapists (PACCP)
Support Groups
  • Alliance of Psychotherapy Training Institutions (APTI)
  • CREATE Institute
  • The Living Institute

Click here for a PDF of the Letter to CRPO

Meet the other half of our board members!

We are ten passionate and inspired board members at the OSRP, working to bring you a stronger, more connected, more supportive professional association! We gave you five board members in our first blog post and now we give you the other five.

Sharlene FriedmanBFA, RP, Acting Treasurer

I have been treasurer on the board since I joined OSRP (then OSP)  in 2013. The funny part is, I often say: “I hate numbers.” I’m channeling my mother when I say that, who was a bookkeeper. It has taken me a while to accept this role as it is and to do so without grumbling.

I am often referred to as a renaissance woman who does many things. The arts in one way or another dominate my life - as an artist and Art Therapist. In my creative life, I have created hand-built ceramics, jewelry, mosaic, felting, painting, and I even knit once in a while. I also write poetry and will sometimes read at open mics. (For more about Sharlene’s professional background, please click here.)

Sonya Gotziaman, RP, Member-at-large

I have an enduring passion for learning. This draws me to the OSRP board, to the myriad issues we investigate on a regular basis. It also leads me to work on a Masters of Marriage and Family Therapy for "fun". Luckily, I also love flying, because I am currently travelling back and forth regularly between Winnipeg and Toronto, while I complete my Masters and see clients in both cities.

Since I do love to travel, I’ve been to China, Hong Hong, and many cities in Europe, with many future plans in the works. When I’m not catching up on my reading for my Masters or travelling, I relax with my husband by the fire at our cabin, preferably after canoeing or snowshoeing. In the city, I love music and art of any kind, but especially musical theatre, non-musical theatre and opera. (For more about Sonya’s professional background, please click here.)

William McLaughlin: MA, RP, Member-at-Large

I have been operating a private practice for eleven years, with a focus on providing trauma-informed psychotherapy to professionals diagnosed with post-traumatic stress disorder. A long time student of anthropology, then psychoanalytic theory, I have been studying human consciousness for thirty-five years. In addition to being an accredited psychotherapist, I am a certified iRest instructor. iRest (integrative restoration techniques) is a meditation designed specifically to support people to manage and recover from PTSD. My current clinical and theoretical interest is applying the concept of ambivalence as a metric to examine both client and therapist resilience.

Beyond direct clinical work, I provide clinical supervision to psychotherapists. I am also a registered provider with the Ontario Medical Association. As a member at large, my work on the OSRP board has included working with the RPIC committee (Registered Psychotherapists Insurance Committee, currently in negotiations with the WSIB to make RPs registered providers), helping with strategy, and supporting board members with portfolios.

My hobbies include coaching rugby football, working out, meditating daily, and a deep love for the art form of the novel. Still enchanted by last year’s award winning Lincoln in The Bardo, I am looking forward to finding new enthralling reads. (For more about Bill's professional background, please click here.)

Eric Pierni, CSAT, RP Acting Member-at-Large

My initial childhood dreams were to be an architect or pilot.  Things quickly changed when I realized that mathematics and I were not the best of friends, nor was I a fan of heights.  I moved towards my other passion (business) and created a wonderful career for myself in the corporate world.

Always introspective, I became more and more fascinated by my interior world.  I learned how difficult the change process has been for me. Then I became more interested and curious about the interior world of men.  It began with long exploratory conversations with my father about our lives, and that of his father. That spurned the creation of Men Therapy Toronto which is a psychotherapy practice I created to support men.

My intention for being on the OSRP board is to help provide genuine value to Registered Psychotherapists in Ontario so that they have an additional resource to do their work successfully. (For more about Eric’s professional background, please click here.)

Richard Lowery, MSW, Ph.D. (ABD), RP, Acting Member-at-Large

I blew in to Toronto on a wind from the Prairie about 100 years ago, it seems; an introvert, dedicated to saving my dysfunctional family and myself, and, therefore, humanity. A cacophony of therapeutic methods, both professional and personal, brought me to a better and a more modest place! I continue to be excited and grateful about my work in private practice in The Beach in this complex, demanding and rewarding time. Beyond that, I look at my neophyte position with our OSRP organization and Board as a dynamic place for development - interacting with a group of colleagues who are not just open to change, but committed to it. The test is being proven by the experience. I find that the more we work together, the more it informs me in how we can best move forward in these times of  such uncertainty and opportunity. I need  to unwind, and I find that best in privacy. I find it in my deep love of any and all sorts of music, and in the constant writing and rewriting of a novel that tends to go on like War and Peace, without any of the assurance of its ultimate public recognition! (For more about Richard's professional background, please click here.)

To make comments: click first on the April is for Advocacy title and then scroll down to the bottom of the page where you'll see the comment box.




Categories: Advocacy


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