A concrete path to regulation for BCACC members
The BCACC is very committed to the protection of the public and to upholding the value and established trust enshrined in the Registered Clinical Counsellor (RCC) designation. It is indeed this commitment to public protection which has been the impetus for the BCACC to consider other strategic alternatives to facilitate regulation of its members under the Health Professions Act.
While it is everybody’s belief that protection of the public will be further enhanced when the profession is regulated under the Health Professions Act, it is also true that Registered Clinical Counsellors are practicing professionals who meet master’s level education and verified supervision entry requirements, adhere to a code of ethics and standards of practice, and who deeply care about the well-being of their clients.
There is a current narrative that the public is not being afforded any protection and that only through regulation under the Health Professions Act will that be remedied. That is absolutely not true in the case of Registered Clinical Counsellors. The reality is that BCACC does ensure that only those qualified enter the profession and it has a well-established complaint, inquiry, and disciplinary process to hold its members accountable to the public.
By enhancing its public protection measures in consultation and collaboration with the Colleges which will make up the new regulatory College for Allied Health and Care Professionals, and by working with the Ministry of Health and other mental health stakeholders to improve the regulatory aspects of the mental health sector, BCACC and its members will be better placed when the profession is regulated. Regulatory alignment with the members of the new regulatory College and more specifically with the College of Psychologists will be key to this endeavor.
The end goal being that the BCACC regulatory framework will be indistinguishable from those of the professions in the new regulatory College for Allied Health and Care Professionals, thereby offering a ready-to-be-governed, 5600+ strong, professional RCC membership for consideration by the responsible oversight body.
On August 27, 2020, B.C. Health Minister Adrian Dix announced the release of a report outlining final recommendations for changes to the province’s health profession regulatory system. The report, Recommendations to Modernize the Provincial Health Profession Regulatory Framework, has implications for all health profession regulatory colleges in BC.
The report describes specific recommendations for modernization within the following key areas:
- Commitment to cultural safety and humility
- Improved governance
- Improved efficiency and effectiveness through a reduction in the number of regulatory colleges
- Strengthening the oversight of regulatory colleges
- Complaints and adjudication
- Information sharing to improve patient safety and public trust
The modernization plan recommends significant changes to current regulatory organizational structures. Specifically, the plan calls for a reduction in the number of colleges from 20+ to six, as outlined below:
Even without any new legislation, the affected Colleges are already moving forward with regulatory modernization. On August 31, 2020, the College of Physicians and Surgeons of British Columbia amalgamated with the College of Podiatric Surgeons of British Columbia. The amalgamated colleges will continue under the name: College of Physicians and Surgeons of British Columbia (CPSBC).
September 1, 2020, marked the establishment of the BC College of Nurses and Midwives (BCCNM), created by amalgamating the BC College of Nursing Professionals and the BC College of Midwives. BCCNM is now Canada’s first nurse and midwife regulator and western Canada’s largest health professional regulator.
The four colleges that regulate BC’s dental professionals are making progress toward the formation of a new College of Oral Health Professionals that will oversee all six regulated oral health professions: certified dental assistants, dental hygienists, dental technicians, dental therapists, dentists, and denturists.
Going forward, any newly regulated health profession will be brought under one of the six regulatory colleges within the new structure. For example, the recommendations explicitly provide for diagnostic and therapeutic professions to be regulated in the future under the new umbrella regulatory College for Allied Health and Care Professionals. This is where the Counselling profession will likely end up as well (instead of having its own college).
Implications of Regulatory Modernization
With the advent of the Regulatory Modernization initiative, there will no longer be uni-profession colleges (no single profession will have its own college). Many of the obligations of a regulator will be defined and determined by the new umbrella colleges, their profession-specific councils and/or their oversight bodies.
This will diminish the relevance of any organization advocating for a uni-profession college or trying to pre-empt the work that will be done by the new umbrella colleges, especially if said work does not support increased public protection and is not aligned with the practices of the affected new umbrella college – the essence of the Regulatory Modernization initiative.
Alignment with the Ministry of Health
The Steering Committee on Modernization of Health Professional Regulation noted the opportunity to consider improvements to how clinical counsellors are regulated and suggested that upon the establishment of an oversight body, the review of clinical counselling be prioritized under the Health Professions Act.
The Ministry of Health has clearly stated that regulation of any new profession will not be considered until this oversight body is in place. Any consideration of legal strategies against the government only serves to undermine working partnerships and collaboration. Furthermore, formal filing against the government can only be seen as an attempt to thwart their modernization initiatives and this does not serve the public. The government’s modernization initiatives are clearly laid out and the BCACC wants to work constructively and collaboratively with them to:
- a) protect the public’s interest and to
- b) demonstrate the readiness of RCCs to be regulated.
The BCACC will work within the Ministry of Health’s timeline to prepare its members for regulation. It anticipates working more pro-actively with the Ministry of Health and other mental health stakeholders to support the new regulatory College for Allied Health and Care Professionals in fulfilling its obligations, especially within the sphere of mental health.
Enhanced Public Protection
As the largest self-regulating organization for clinical counsellors, with 5600+ members representing 70% or more of the profession, the BCACC has a responsibility for ensuring that public protection is paramount and to lead by example.
A health regulator’s obligation is to protect the public through the regulation of their registrants by:
- determining registration requirements
- setting standards of practice and a code of ethics
- recognizing education programs
- maintaining a Members Register that everyone can search, and
- addressing complaints about their registrants
The BCACC will undertake multiple projects to revisit and enhance these core obligations in consultation with the seven existing colleges which will comprise the new regulatory College for Allied Health and Care Professionals.
Some concrete examples of the work being done or is planned include:
- Standard for Family Law – the highest number of public complaints relate to high conflict family matters. To support its members in their service to the public, a new family law standard will be released in February 2022 followed by regional and virtual workshops to further prepare our members.
- Clinical Supervision – a new program is being launched to accredit clinical supervisors as they are a key component in maintaining the high-quality standards expected of RCCs.
- Member Registry – as done by all regulatory bodies, a publicly viewable Members Register is being developed and will be launched as part of BCACC’s new website in 2022.
- Continuing Education Credit – the current program will be enhanced to provide a more structured method of fulfilling professional development requirements with the goal of eventually having a mandatory number of credits every year or two years.
Alignment and Collaboration with the College of Psychologists
The College of Psychologists of British Columbia (CPBC) has decades of experience regulating within the mental health sector under the Health Professions Act. Within the allied health professions, the practice of psychology is the most closely related to clinical counselling and the CPBC regulatory standards and processes can inform our own work in specific and important ways. The BCACC has always maintained a beneficial working relationship with CPBC on public protection and other matters of common interest, and we will build on that relationship as a critical element of our plan to move forward.
Public Protection and Trust
The BCACC plans to expedite its enhanced public protection measures, align its practices with those of the regulatory College for Allied Health and Care Professionals and, more specifically, with the College of Psychologists, prepare its membership for regulation, all while maintaining the high standards of qualifications and practice excellence set out by the BCACC.
The BCACC believes the ultimate balance of public safety and quality of practice for Counselling in BC is the regulation of its 5600 + members by the BC government under the regulatory College for Allied and Care Professionals. Until regulation is timely for the BC government, the BCACC will ensure that those best practices are implemented and upheld to the best of its ability in the interest of public trust.