Dear Minister Jones:
Protecting the public’s interest is at the heart of the Regulated Health Professions Act, 1991. Each of us are current or former members of a professional health college and understand the critical role they play in protecting patients, maintaining trust not only in our health system but in our democratic system of government to protect people especially at their most vulnerable moments.
We are writing today to express our deep concern with significant changes that the College of Psychologists and Behaviour Analysts are poised to adopt after their board meeting this Friday December 12, 2025.
We understand that labour mobility is an important principle for our economy, but weakening Ontario’s standards for psychologists to amongst the lowest in the country is both unnecessary and not in the public’s interest.
The College is poised to:
- Replace the title Psychological Associate with Psychologist for Master’s level registrants
- Reduce by 75% the supervised practice hours required (i.e., removal of the 4-year supervision requirements for those with a Master’s degree)
- Eliminate the oral competency exam
- Move away from National Accreditation of graduate programs in favour of “Council-approved” programs
This is in addition to the changes that they have already recently approved and have begun to implement:
- Eliminate the exam on ethical practices and legal frameworks to be replaced with an online “low stakes, on-demand, learning module and no-fail examination”
- Eliminate client populations and collapse competency areas into either Health or Industrial/Organizational options
- Allow applicants to take the general knowledge exam unlimited times, up from the current limit of four times.
In a letter from the Centre for Addiction and Mental Health registering their concerns with these proposed changes, they remind us of the unique and consequential role psychologist play in Ontario:
“Psychologists perform highly specialized work that includes the diagnosis of complex mental health, neurodevelopmental, and neurological conditions, as well as delivering effective interventions, consultation, supervision, research, and program development. At CAMH, this includes neuropsychological, psychoeducational, and forensic assessments, differentiating complex conditions, and making recommendations with direct implications for legal, medical, educational, and funding outcomes, alongside profound impacts on the daily well-being of vulnerable populations. Mistakes or errors in these contexts can have serious consequences for patients and the broader system.”
Your government also appears to recognize the unique role of clinical psychology in its integration of science with practice when this fall it decided to consult on allowing psychologists to prescribe medications (with a postdoctoral Master’s of Science degree in clinical psychopharmacology (MSCP).
We recognize that you have a statutory mandate to ensure “appropriate standards of practice are developed and maintained” as well as ensure “individuals have access to services”, but we agree with the Centre for Addiction and Mental Health that “lowering standards will also not meaningfully increase access to care in Ontario, given that there are already over 50,000 master’s-level clinicians able to provide psychotherapy and other services.”
One of the biggest barriers to diagnosis and care is the cost which in most cases is not covered by OHIP. Average costs for assessments often exceed $2,000 while hourly care ranges from $175 to $300/hour. Increasing publicly funded access to psychotherapy and to psychological assessments and treatment will help address longstanding issues of equity.
Equally concerning is the proposed shift from independent third party accreditation of doctoral programs to “Council-approved programs”. In practice this means the governing board itself will be able to determine which education institutions have acceptable doctoral programs. This would be a concern at any time, but to do this while the board is moving towards a governing body that is composed of 50% public members, with fewer than half of its governing Council being clinical psychologists is not in the public interest.
This rationale for this change may have been revealed in the College’s June 2025 board meeting minutes: “Approved programs as opposed to primarily relying on third-party accreditation will be particularly important in Ontario, as a private Doctor of Psychology program (ineligible for CPA accreditation) will be graduating its first cohort of students in the summer of 2025 and new private institutions might serve an important role in increasing the supply of professionals”.
According to the CPBAO, the consultation period yielded over 7,000 responses. This included over 4,000 members of the public, with 89% of respondents opposed to these changes. Those raising concerns include CAMH, the Hospital for Sick Children, Holland Bloorview Kids Rehabilitation Centre, the Ontario Nurses Association amongst other important health care institutions.
As the Minister of Health, it is important that you are aware of these deep concerns with respect to these proposed changes and that you take necessary action to ensure the quality of training and care for patients. It is time to get to work on a transparent and comprehensive consultation process, to work with other provinces and partners like the Canadian Psychological Association to increase access and ensure alignment with evidence-based standard to protect the public.
We are confident we can do both, we just need the political will to make it happen.
Sincerely,
Lee Fairclough, MPP Etobicoke-Lakeshore, Liberal Critic for Hospitals, Mental Health, Addictions, Homelessness
Tyler Watt, MPP Nepean, Liberal critic for Long Term Care, Colleges and Universities
Dr. Adil Shamji, MPP Don Valley East, Liberal Critic for Housing, Primary Care, Urgent Care and Public Health
c.c. Tony de Bono, Registrar & CEO, Ontario College of Psychologists and Behaviour Analysts
Ian Nicholson, Board Chair, Ontario College of Psychologists and Behaviour Analysts