And the Transitional Council

Monday, 4 November, 2013

Joyce Rowlands, Registrar,

and the Transitional Council,

College of Registered Psychotherapists and Registered Mental Health Therapists,

163 Queen Street East,

4th Floor,
Toronto, Ontario

M4J 1B9

Dear Joyce and Council Members:

Greetings! I hope you are well, in the midst of the ongoing march towards opening the College.

Ciaran McKenna has shared your October 23rd letter, Joyce; it essentially is a response to CASC-Ontario from my previous letter to you.

I write to continue the dialogue.

May I begin by reiterating the ‘orienting’ statement I’ve made before?: In as much as the College of Registered Psychotherapists is open to receive qualified chaplains and pastoral counsellors as we “come knocking”, there is really nothing more to ask of you. The thrust of my advocacy is about, and for, our profession which has to figure where and how it stands up in the midst of Ontario’s movement towards the College of Registered Psychotherapists.

Some of this “figuring” is done relative to legislation; and therein it relies on the best definition-of-terms currently available.

So I have two points of debate concerning your October 23rd letter, Joyce.

First: When referencing section 29, subsection 1 (c) of the Regulated Health Professions Act and holding “treat”/”treatment” to mean what you’ve known (and previously told me) to be the original framers’ intent concerning Christian Science’s practice in particular, please let us recognize there is room to argue the point. From existing cases of interdisciplinary practice, for instance … and here I shall demonstrate with a Welland hospital Emergency Room case: A patient presented with a constellation of stress-induced physical symptoms (including high blood pressure, GI problems, insomnia) and I was put forward by the E.R. Doc as the team member to treat the patient’s bodily experience of, and psycho-socio-spiritual responses, to stress (an application of short term psychotherapy and spiritual care, requiring two outpatient visits following upon the initial lengthy Emergency Room session, notably none of it “based upon the tenets of the religion of the person giving the treatment” but rather based upon the religion/spirituality/“meaning-making” of the patient). Another level-of-argument comes from the fact that the RHPA was amended and, in that re-wiring, its meanings necessarily broadened by the introduction of the controlled act of psychotherapy. Psychotherapy is a “treatment” and hence the aforementioned section 29, subsection 1 (c), cannot but become expanded. A parish clergyperson, acting true to her/his “pastoral care” training in seminary and therefore taking a Rogerian (“psychotherapeutic”) stance and offering her/his parishioner theological reflection plus client-centred spiritual direction plus prayer in order to address the parishioner’s “serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgment, insight, behaviour, communication or social functioning” is “treating” that parishioner, but is nonetheless exempt from regulation since it is done “according to the tenets of the religion of the person giving the treatment”.

As you know I’ve repeatedly noted, Joyce, the clergyperson described immediately above and the members of her/his flock are rightly protected by the division of church and state. But the general public and – in particular – the vulnerable public being cared for within public institutions must be protected from any person’s (beyond their own Faith Group’s representatives’) actions “according to the tenets of the religion of the person giving the treatment”. How the general public should be treated is with the protection offered them by an interfaith (or perhaps more clearly stated, “beyond-any-given-faith”) practice populated by spiritual caregivers in good standing (including regular peer review) within a professional spiritual caregivers’ association (e.g. CASC). When the jurisdiction in question has a College covering this scope of practice (i.e. “spiritual care” as a specialization of “psychotherapy”), then the protection of the public surely ultimately resides there.

My second point-of-debate responding to your October 23rd letter is that, in referencing section 29, subsection 2 of the RHPA, HPRAC’s definition of “counselling” which the Transitional Council consistently has put forward as our ‘working definition’ was not brought to bear. As you know, it reads, ¨The practice of psychotherapy is distinct both from counselling, where the focus is on the provision of information, advice giving, encouragement and instruction, and spiritual counselling, which is counselling related to religion or faith based beliefs.¨ As long as HPRAC’s framing is held up as true, section 29, subsection 2 only makes exception for the practitioner who (a) “[provides] information related to religion or faith based beliefs” or (b) “[gives advice] related to religion or faith based beliefs” or (c) “[provides] encouragement related to religion or faith based beliefs” or (d) “[provides] instruction related to religion or faith based beliefs”. If the practitioner steps beyond these religion-centred and faith-based-belief-centred acts of giving counsel, entering instead a client-centred realm where the client’s story is what matters even should the “religion or faith based beliefs” end up put aside, then my observation is that the practitioner (now acting in the manner in which a CASC chaplain or pastoral counsellor would act) is no longer excepted AND the practitioner really had better be fully trained (academically and clinically) plus accountable (i.e. professionally certified plus, wherever jurisdictions legislate it, registered) for the spiritual caregiving task underway.

The reason why the HPRAC definition must be brought into view is that, without it, a broader understanding of “counselling” may be read into the exception clause [provision 29 (2)] … indeed it is natural for most of us to do so … in which case it ends up sounding like all spiritual care is excepted. Application of the HPRAC definition yields focus which might be restated like this: religious care is excepted; spiritual care is not.

I hope this response, focused on these two key matters, is useful-and-helpful in both furthering the conversation and developing a base of understanding.

Peace to you.

Robert Bond