Last updated: July 4, 2024

On October 19, 2022, the Ministry of Health, led by Minister Adrian Dix, indicated their intention to regulate clinical counselling under the new Health Professions & Occupations Act (HPOA). On July 2, 2024, the BC Government designated Psychotherapy as a health profession under the Health Professions Act. The proposal received cabinet approval and was subsequently signed by the Lieutenant Governor. The official order can be viewed here.

With over 36 years’ experience regulating clinical counsellors and psychotherapists in BC, BCACC is confident that it has created the regulatory building blocks necessary to support the transition of the profession to becoming regulated under legislation and intends to work with the Ministry of Health (MOH) to enhance public protection and quality of care for British Columbians.

Considering the recent advancements towards regulation, we have created this FAQ for members, the public and stakeholders to answer questions being asked at our town hall meetings and on social media. BCACC has been working towards regulation of the clinical counselling and psychotherapy profession for almost three decades. This information is intended to clarify the regulatory process and how BCACC has made progress over the last two years.

This document will be updated as and when we receive new information and/or when things change.

FAQs

If the BCACC has been advocating for regulation under a regulatory college for decades, why didn’t the efforts work until now?

During that period, previous attempts to collaborate with the provincial government were unsuccessful for several reasons. BCACC was part of a joint initiative involving other mental health provider associations and within this consortium of associations, there were wide variations in the scope of practice, activities carried out, and educational qualifications among members.

The government declined to regulate the profession multiple times, citing the challenges posed by these differences:

Wide diversity amongst applicants in education and training and services provided
Scope of practice and activities carried out amongst applicants were too varied
Lack of effective leadership to support a change to regulation under statute

2. What has changed?

Simply put, there is now new political will, because the COVID-19 pandemic increased the need for mental health services.

However, it’s important to consider why the government declined to regulate the profession the last time and to evaluate what has changed. BCACC has worked tirelessly to provide information to the government that has showed them that:

There is agreement across the regulated provinces that the minimum education required for clinical counsellors and psychotherapists to enter the profession is with a master’s degree.
Registered Clinical Counsellors make up 80%+ of the profession in BC.
BCACC has collaborated with the CCPA, a national association providing the designation CCC. Looking at the combined member total, it is safe to say that 90% of clinical counsellors and psychotherapists in BC work under the same/similar scope of practice and perform the same core activity – Psychotherapy.
The BCACC regulates the profession under the Societies Act and is an effective leader, trusted by stakeholders across the province. The Association belongs to both the Council on Licensure Enforcement and Regulation (CLEAR) and the Canadian Network of Agencies of Regulation.

In addition, BCACC has spent a great deal of time to inform the BC government about the profession. BCACC has established regulatory building blocks and collaborated with the CCPA to produce a joint submission that helped the government understand the profession of clinical counselling/psychotherapy.

3. What are “regulatory building blocks” and why are these important to the regulatory process?

The formation of a regulatory college is a large undertaking, and many components need to be constructed to support a college’s infrastructure. These components are what BCACC refers to as the “building blocks”.

BCACC’s decision to create and update its own regulatory building blocks demonstrates that the association and its members are preparing to be regulated. BCACC has created several supports that may save the government and a new regulatory college time and ease the transition for members into a professional regulatory environment.

These components or building blocks include:

The creation of BCACC’s clinical supervision designation- RCC-ACS- program
The creation of entry to practice competencies and membership eligibility requirements for new registrants
A publicly viewable member registry that lists all current BCACC members
An updated Code of Ethical Conduct
Updated and new Standards of Clinical Practice including an Indigenous cultural safety, cultural humility and anti-racism standard developed to align with similar standards created by health regulators such as the BC College of Nurses and Midwives, the College of Physicians and Surgeons of BC and the College of Opticians (now part of the new College of Health Care Professionals of BC).
An updated Quality Assurance/Continuing Competence Program (launching 2024)

All these important components have been created with input and guidance from other regulatory bodies from across Canada and validated through feedback from members and stakeholders.

4. If Clinical Counselling/Psychotherapy is going to be regulated as a profession in BC, can you explain what the government means by “profession”?

The government defines this in section six of the Health Professions Act:

6. For the purposes of the Health Professions Act, a health profession has the following characteristics:

(a) persons who practice the health profession

(i) have sufficient education, training, experience and other qualifications to have a professional level of knowledge, skills, ability and judgment,

(ii) are personally responsible for determining the appropriate course of care for patients, and

(iii) provide health services that may present a risk of harm to the public;

(b) regulation of the practice of the profession is necessary

(i) to protect the public from harm, or

(ii) to protect or promote the public interest.

5. Is there a timeline for when the new regulations will become law?

The HPOA is not yet in effect. However, now that the process to amalgamate the existing health profession regulatory colleges in BC is complete, the government will prepare for the regulatory colleges to be HPOA compliant and put the processes in place to bring in regulation of new professions.

BCACC’s best estimate is that RCCs can start applying for licensure with the new regulatory college in 2026. Again, these are only estimates. Members will be updated on the answer to this question as new information is received.

6. Why isn’t this happening any sooner?

There are a lot of pieces to be put together; however, the most important is that the new amalgamated colleges need to be ready to take on the regulation of new health professions. Considering this, it is estimated that the HPOA will come into effect in May/June of 2025.

7. Which college will clinical counselling and psychotherapy be included in?

While we do not know for sure, the supposition is that the clinical counselling and psychotherapy professions will be included in the College of Health and Care Professionals of BC.

8. What other professions are regulated under the College of Health and Care Professionals of BC?

College of Dietitians of BC
College of Occupational Therapists of BC
College of Optometrists of BC
College of Opticians of BC
College of Physical Therapists of BC
College of Psychologists of BC
College of Speech and Hearing Health Professionals of BC

To learn more about this college visit their website: https://chcpbc.org

9. How will the proposed regulatory college system work under the HPOA?

Before we get into the BC health profession regulatory college system, we strongly encourage you to familiarize yourself with BC’s regulatory framework.

As seen in the image above, an oversight body will be led by a superintendent. And discipline panels operating through the oversight body will report to a director.

The six BC regulatory colleges will each continue to have a CEO/Registrar and staff to manage their respective registration, quality assurance, complaints and inquiry programs. The disciplinary responsibilities of the colleges will be supervised and eventually transferred to a designated committee under the HPOA. This understanding is derived from our ongoing conversations with the Ministry of Health.

10. What are the primary responsibilities of a regulatory college?

A regulatory college is authorized through legislation to:

Determine registration requirements for entry into the profession
Set standards of practice and ethical standards for the profession
Recognize education courses/programs that prepare someone to enter the profession
Maintain a public register that anyone can search, and
Investigate complaints about its licensees.

11. There are concerns clinical counsellors/psychotherapists may not be part of deciding important information about their profession. Will practitioners lose their ability to influence standards with this new form of governance?

It is important to note the division of responsibility across the regulatory framework.

A Regulatory college will put together common processes across all professions regulated by that college.

Components like registration requirements, standards of practice, ethical standards, quality assurance program activities, complaint and consent agreement processes will be decided on by committees which will include practitioners able to make decisions relative to their respective professions. When the regulatory college is ready to set up these committees, BCACC will encourage members to be involved.

12. Will I need to undergo a new training/certification process or meet new continuing competency requirements to gain or keep my registration with the new regulatory college?

The Continuing Competency requirements for the new college have not yet been established relative to the clinical counselling/psychotherapy profession. As mentioned previously, BCACC continues to prepare regulatory building blocks that will assist the government and the regulatory college to start regulating the profession and is proposing that BCACC’s new Quality Assurance/Continuing Competence Program framework be used.

13. Will RCCs automatically become registrants/licensees of the regulatory college?

No. There will be no automatic transition into the regulatory college solely based on holding an RCC designation. RCCs will have to follow the process required to apply for licensure with the new regulatory college and comply with those requirements. However, the BCACC will provide information and support to help members prepare for the transition.

14. What will the new professional designation be if I register with the new college?

Although it has not yet been announced, based on the use of titles across Canada, it will likely be Licensed Psychotherapist (LP). This response will be updated once new information is received.

15. Will my RCC designation change if I register with the new college?

If you choose to continue as a member of the BCACC, you will still be entitled to use the RCC designation.

To remain an RCC, you would continue to belong to the association, ensuring that your professional liability insurance, membership payment, continuing competency requirements, and other mandatories are up to date and in good standing with the BCACC.

16. What are the pros and cons of legislative regulation?

Pros for the public:

Enhanced public protection. For example, resignation of membership during an investigation will not stop the inquiry process.
More informed public choice
More trust in the profession
Enhanced care due to improved information sharing amongst regulated professionals

Pros for the practitioners:

Ability for practitioners to increase fees to be more in line with other regulated health professionals
Increased credibility/recognition
Addition to more extended health plans
Ability to provide services to federally funded programs
Potential GST exemption
Improved labour mobility across Canada
Ease of information sharing with other professionals regulated under statute
Potential for restricted activities (e.g. diagnosis) to be delegated to the regulated practitioner

Possible cons for practitioners

Increased costs (association membership fee + regulatory college licensing fee)
More government oversight through legislative acts/regulations/bylaws
Potential scope of practice changes
Changes to entry and continuing competency requirements
Increased expectations and accountabilities of the profession
Controlled use of protected titles
Different regulatory oversight structure

17. What are the concerns that some practitioners have specific to the HPOA and what is BCACC doing to address these?

Some of the concerns specific to the HPOA that practitioners have voiced include:

Board composition – will practitioners be able to serve as a Board member?
Inquiry processes that enable access to client information
Vaccination mandate
Fines
Free speech

The BCACC is working with the Healthcare Professionals Associations of BC to have lawyers review the HPOA, get clarification and advocate where appropriate.

The BC government has addressed and clarified a number of these concerns in their own FAQ which we encourage you to read here

18. What does the grandparenting path to registration/licensure with the new regulatory college look like?

None of the registration requirements have been set by the regulatory college yet. However, BCACC is hopeful that the regulatory building blocks it has developed can help influence work to determine the process and the requirements.

We can look at the grandparenting process that was used in other provinces which included:

Master’s degree in counselling psychology (or equivalent/related masters)
Successful completion of a jurisprudence exam
Demonstration of a minimum number of hours of practice
Demonstration of a minimum number of hours of clinical supervision
Ongoing quality assurance/continuing competence program participation

19. What about the regular path to becoming a regulated health professional?

Again, the new regulatory college will decide on the registration requirements, but we can speculate that it will include the following:

Master’s degree in counselling psychology (or equivalent)
Successful completion of an entrance exam
Successful completion of a Jurisprudence exam
Demonstration of a minimum number of hours of practice
Demonstration of a minimum number of hours of clinical supervision
Ongoing quality assurance/continuing competence program participation

20. What does a jurisprudence exam look like?

While we have no way of knowing what it will look like, we can tell you a bit about what this kind of exam typically contains. Often jurisprudence exams are open book exams that may contain questions pertaining to:

Professionalism & Professional Accountability:

Responsibility and accountability
Ethics, Standards, Professional Misconduct, Incompetence, Incapacity

Client-Psychotherapist Relationship:

Informed consent
Boundaries
Sexual misconduct
Billing
Collaboration

Law:

Health Professions Act (HPA) and Health Professions and Occupations Acts (HPOA)
Profession-specific regulation, scope of practice, bylaws
Other applicable provincial and federal laws

21. What happens after regulation of the profession comes into effect? Will the BCACC disappear? What about the RCC designation?

When the new regulatory college is ready to start registering psychotherapists as registrant/licensees, RCCs can begin to apply to become a Licensed Psychotherapist.

Often practitioners are registered/licensed with a regulatory college and continue to belong to a professional association. The association develops resources to support the work practitioners do and assists them to fulfill their professional obligations and requirements.

BCACC’s role will not change much after regulation of the profession occurs. As the professional association for clinical counsellors/psychotherapists in BC, BCACC will continue advocating for our members and the profession; however, there will be a few functions that will look a little different to members. After regulation, begins the functions and processes related to registration, setting standards of practice, quality assurance and inquiry will be the domain of the regulatory college that regulates Registered/Licensed Psychotherapists.

The RCC designation is a registered trademark of the BCACC, and it will not go away once regulation of the profession occurs. It carries with it a recognizable stamp of authority and quality across the province and is the de facto professional standard for clinical counsellors and psychotherapists in BC. The RCC designation will continue to be prominent in BC and BCACC will continue to regulate its RCCs.

22. What will registration/licensure with the new college cost? What will my fees be?

We can only speculate by looking at what registration with other regulatory colleges and associations costs. Our best guess is that it could cost between $600 – $800 per year to be registered with a regulatory college while BCACC’s membership fees would be between $200 – $400 depending on the category of membership one holds.

23. How will the Regulatory College stay accountable to its members?

A regulatory college is not accountable to its registrants/licensees, but instead to the public, its Board of Directors and government. Its ethics, standards, and other profession-specific matters are informed by practitioners on different committees.

24. What will I be allowed to do or not do if I don’t register with the college?

Not everyone will choose to register with the college.

The impact of regulation varies across provinces. In some provinces, legislation only regulates the use of a protected title, preventing unregistered practitioners from using the professional designation/title granted by the regulatory college. Others have legislation in place that regulates both protected title and the activities a regulated professional is authorized to perform. In BC, it is not clear exactly what or how the BC government will specifically regulate clinical counsellors/psychotherapists.

25. If I don’t register with the college, can I still use my RCC designation to continue practising?

BCACC members may choose not to join the college and instead continue to practice as an RCC. What could impact an RCC’s practice is whether the government introduces a profession-specific regulation that restricts certain activities that can only be carried out by regulated professionals.

As previously mentioned, the BCACC will remain the professional association for RCCs and Licensed Psychotherapists in BC. BCACC will provide the RCC designation and a lighter form of oversight under the Societies Act, if it makes sense, and the association is permitted to do so.

26. I am an RCC and a School Psychologist. My previous regulatory college has already been amalgamated into the new College of Health and Care Professionals of BC (CHCPBC). What do I need to do as a dual registrant?

At this point in time, you don’t need to take any action as an RCC. If RCCs want to acquire a new professional title as a school psychologist and be licensed as such, they would need to apply to CHCPBC directly and abide by the college’s rules concerning dual registrations.

27. In Alberta, I could be registered as a psychologist with my master’s in counselling psychology. Will that ever be an option here?

Alberta differs from other jurisdictions across Canada. BCACC’s discussions with the College of Psychologists of BC- now part of the amalgamated CHCPBC- would indicate that this is not likely to occur in BC.

28. What will happen to the RCC-ACS designation?

There is no change anticipated here. The RCC-ACS designation belongs to the BCACC and will continue to exist for as long as it makes sense, and the association is permitted to do so.

29. How will regulation of the profession impact the fee scale that BCACC members in private practice charge?

Regulation will not impact the fee scale of private practitioner RCCs. Guidance for fees will still be provided by the BCACC.

30. What other ways could RCC practice be affected?

Here are a few areas which could be impacted by regulation. Please understand that some of these are estimations and may be subject to change. BCACC will update its members when new information is received.

Direct Billing: It may become easier if you are a regulated professional, but RCCs can already do some direct billing
MSP Billing: This is not directly tied to being a regulated professional as many regulated professions are not covered under MSP. No changes are anticipated.
Business Licensing: No immediate change is anticipated
Billing through BC Health Insurance: This is not directly tied to being a regulated professional as many regulated professions are not covered under MSP.
Becoming a clinical supervisor and taking on interns: This may depend on any requirements set by the regulatory college. The RCC-ACS designation will be proposed by BCACC as the standard for clinical supervisors.
Techniques/modalities/notes and record-keeping/length of sessions: No change is anticipated.
Renewal of BCACC membership: No change to registration renewal with the BCACC is anticipated.
Consultation versus supervision: This may depend on any requirements set by the regulatory college.
Insurance Companies Coverage: It is anticipated that this will improve. However, RCCs continue to be accepted by more and more companies, already.

31. Will a profession-specific regulation permit psychedelic-assisted therapy?

Regulation will not support the provision of psychedelic assisted therapy directly. Practitioners will have to continue to abide by federal and provincial laws, and other restrictions regarding the prescription, dispensing and administration of drugs as set out in legislation.

32. Will I be able to see clients in other regions/provinces once clinical counsellors/psychotherapists are regulated?

Even today, RCCs can see clients across Canada, if your insurance provides national coverage. If the profession is unregulated in the province or territory where your client is located, you can see clients from that province.

For provinces and territories where regulation of a protected title exists, you can provide services to clients who are located there; however, you must not use the title granted by the regulatory college in that jurisdiction.

For provinces and territories that regulate restricted activities/reserved acts/controlled acts, you should check with the regulatory college in that jurisdiction to determine if you’ll be carrying out any activity that only regulated practitioners in that province/territory are authorized to perform.

33. I am a student on track to becoming an RCC. What changes can I expect with regulation?

Nothing at all right now! The RCC title will remain with the BCACC and is still a recognizable stamp of authority and quality across the province and is the de facto professional standard for clinical counsellors and psychotherapists in BC.

With regulation under the college anticipated sometime in June 2025, we advise you to continue pursuing the RCC designation and use the BCACC’s resources and 36-year legacy to learn, upskill, and grow your professional circle through our 7,200-member network. You can be sure as an RCC, you are guaranteed BCACC’s support and advocacy throughout your career.

34. Why should I hold on to my RCC designation after regulation of the profession begins? What benefits will I have access to?

There is a great benefit in retaining your BCACC membership. Part of the BCACC’s mandate is to come alongside members who are also registrants/licensees of the regulatory college and support their practice. This is done by providing benefits and assistance to members in fulfilling their professional obligations and requirements as regulated professionals.

For example, the regulatory college will outline quality assurance/continuing competence and registration requirements one must meet.

For example:

College Requirements	BCACC would Offer
Requires registrants/licensees to engage in QA/ Continuing Competence activities regularly.	Provides multiple professional development opportunities for members to meet the College requirements at discounted prices.
Requires applicants seeking registration/licensure to hold professional liability insurance to a level of coverage established by the Board.	Provides access to competitively priced professional and commercial liability insurance coverage.

In addition, the BCACC’s role is to advocate on behalf of members and the profession with stakeholders in the community and with the government on broader issues affecting the profession.

The BCACC will continue to perform the following functions

Advance the profession through its Public Relations and Advocacy work
Support the interests of mental health practitioners
Support BCACC members’ clinical practice
Provide professional development opportunities
Provide discounted member benefits/programs
Serve the public interest through education and improved access to mental health care
Provide access to Professional Liability Insurance coverage

In other words, BCACC will continue doing what it is doing for members and prepare them for regulation of the profession.

As well, BCACC members will continue to enjoy a wide array of other tangible member benefits, such as:

Discounted cellphone plans
Tailored financial services
Home and auto insurance plans
Discounted gym memberships
Car share programs
Exclusive workshop offers
Discounted yoga products

35. Will the BCACC and CCPA offer a joint membership in the future?

A joint membership is not currently in place; however, i a joint BCACC/CCPA membership may be explored in the future. This might follow the norm for other professions where members belong to the provincial association (BCACC) and the provincial association is affiliated with the national association (CCPA).

36. Is the First Nations Health Authority (FNHA) going to increase their financial support for RCCs like the Crime Victims’ Assistance Program (CVAP) did?

The BCACC continues to meet with the FNHA on this topic and currently, nothing is planned by FNHA due to budget constraints.

37. Will clinical counselling and psychotherapy services be exempt from charging GST/HST?

On December 20, the Canada Revenue Agency (CRA) has officially confirmed that Registered Clinical Counsellors in BC are now exempt from collecting GST on their psychotherapy services.

The confirmation from the CRA states: “The information in the letter can be used by members of your association who hold the RCC designation to confirm that they are practitioners for GST/HST purposes, in respect of supplies of psychotherapy services made in provinces that do not regulate the profession of psychotherapy.”

What This Means for You

Effective immediately, RCCs in British Columbia are no longer required to collect GST on psychotherapy services.

BCACC will expand on this in our January 13 Town Hall (the recorded session will be made available to all members on the member portal a few weeks after the event) but the chart below is a basic look at what services will be exempt from GST and what services will not:

We are committed to maintaining the high standards that have led to this recognition. The BCACC will continue to work with CRPO to maintain substantial equivalency for tax purposes and keep our public registry up-to-date for CRA access.

38. What actions can I/should I take right now as an RCC?

Stop Collecting GST: As of today, cease collecting GST on GST-exempt psychotherapy services. Members will not be required to pay back GST that has been collected before this announcement.
Your GST Account: We will be bringing you valuable information in January, in the Town Hall, on what this means for your GST account. If you offer other taxable services, maintain your account but adjust your billing practices accordingly.
Client Communication: Inform your clients about this change in billing for GST-exempt psychotherapy services.
Ensure you renew for 2025: This exemption is specific to RCCs.
Do you need to request the letter? No. RCCs can request copies of the necessary documents from BCACC Head Office if they are audited but otherwise do not require them to be exempt from charging GST.

39. Does this mean I’m automatically included in extended health insurance plans now?

The RCC designation is an identified service provider under many extended health insurance plans, and more are being added all the time. It is important for members to have their clients check their coverage prior to seeing them to ensure that RCCs are an included service provider.

40. Will the BCACC require RCCs to get vaccinated?

No. The BCACC does not require its members to be vaccinated nor will it in the future.

This document will be updated as and when we receive new information and/or when things change.

NAVIGATING THE REGULATORY LANDSCAPE IN BRITISH COLUMBIA – FAQs

FAQs