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Generally, dietetic counselling is not psychotherapy unless a dietitian is using recognized psychotherapeutic techniques or interventions to treat clients who are impaired by serious disorders. The Regulated Health Professions Act, 1991, is very specific in defining the controlled act as “Treating, by means of psychotherapy technique, delivered through a therapeutic relationship, an individual’s serious disorder of thought, cognition, mood, emotional regulation, perception or memory that may seriously impair the individual’s judgement, insight, behaviour, communication or social functioning.” 

As shown in the image below, the controlled act of psychotherapy is a subset of psychotherapy. Dietetic treatment can include counselling, psychotherapy which is not the controlled act, and it can also include psychotherapy which is the controlled act.

THE FIVE COMPONENTS OF THE CONTROLLED ACT OF PSYCHOTHERAPY

There are five distinct components to the controlled act of psychotherapy. All five must be present for psychotherapy to be considered a controlled act. If one of the components listed below is missing, then the dietetic counselling or psychotherapy is not a controlled act:
 

1. Treatment: As defined in the Health Care Consent Act, 1996, a treatment is “anything that is done for a therapeutic, preventive, palliative, diagnostic, cosmetic or other health-related purpose”.

2. Psychotherapy Technique: This means that the treatment would involve one or more interventions or methods based on recognized psychotherapeutic theories, models or frameworks and/or empirical evidence.

3. Professional Therapeutic-Client Relationship: This relationship is integral to the treatment and based on clear professional boundaries.

4. A Disorder: While a client does not necessarily need to have a diagnosis of a particular mental disorder, the individual must have a serious disorder.

5. Impairment: The judgment, insight, behaviour, communication or social functioning of the client receiving treatment must be impaired by their disorder.

See College of Nurses of Ontario, Understanding When Psychotherapy is a Controlled Act. (2016)

AUTHORITY TO PRACTICE THE CONTROLLED ACT OF PSYCHOTHERAPY

As of December 31, 2019, anyone performing the controlled act of psychotherapy must be registered with one of the six health professions authorized to practice the controlled act of psychotherapy in Ontario — psychotherapists, psychologists, social workers, nurses, occupational therapists and physicians. The titles “psychotherapist,” “registered psychotherapist” and “registered mental health therapist” are restricted, meaning that only members of these colleges can use these titles verbally and in writing. Dietitians are not one of the six professions authorized to practice the controlled act of psychotherapy.

 

Dietitians who identify themselves as therapists, or describe their work as therapy, must ensure that they are not performing psychotherapy as defined in the controlled act, unless they are also a member of one of the authorized professions mentioned above.  If you have any concerns about your practice and psychotherapy, we recommend that you contact the College of Registered Psychotherapists of Ontario to help determine whether you are practicing psychotherapy as defined in the controlled act. 

Click here for more information about registration with the College of Registered Psychotherapists of Ontario.