Business Practices

Business practice items look administrative and are not. They are where a therapist's financial interest and a client's welfare come apart, which is exactly the tension the exam is built to test. Expect these standards to appear inside clinical simulations rather than in a separate business scenario: the client who cannot afford the new fee, the client who wants to leave a five-star review, the practice you are closing while six people are mid-treatment.

Two renamings: 6.2 is Advertising, not "Advertising and Representing Yourself and Your Services". And keep 6.3 and 6.4 apart in your head. 6.3 states no notice period at all. The 30-day minimum belongs to 6.4, for closures and relocations. Candidates routinely import it into 6.3 and get the item wrong.

Competency links: 3.10a and 3.10b (comply with CRPO requirements in business practices, and explain limitations of service availability), 4.6 (refer client), 4.7 (conduct an effective closure process) and 2.1a (clear written communication).

6.1 Fees

The rule. Registrants publish a standardized fee schedule and disclose it before providing services, charge reasonable and non-exploitative fees, and do not charge for services that were not provided.

What it actually requires

• 6.1.1: establish a standardized fee schedule, make it available to current and prospective clients, and inform clients of it prior to providing services.
• 6.1.2: charge fees that are reasonable in relation to the services provided, fulfil the terms of client agreements, and provide itemized accounts on request.
• 6.1.3: do not offer discounts or incentives for pre-payment or prompt payment. This one surprises people. A ten percent discount for paying the block up front is prohibited.
• 6.1.4: do not charge for services that are not provided, with the exception of late cancellations, missed appointments, or deposits.
• 6.1.5: do not unduly restrict methods of payment, and do not provide discounts for preferred methods of payment. Cash discounts are out for the same reason.
• 6.1.6: registrants should not barter their services with clients, because of the risks of dual relationships and conflicts of interest.
• 6.1.7: block fees require a written agreement detailing the services covered by the fee, the total fee, the arrangements for paying it, and refund requests and procedures.
• 6.1.8: do not sell or assign debt owed for professional services.

The definitions to hold

• Fee schedule: a listing of the fees normally charged for specific therapies and procedures, and it also includes administrative fees such as record release and report writing, and fees imposed for missed appointments. Late cancellation fees must be reasonable in the circumstances.
• Block fees: an up-front payment where you agree to provide a set of services for a set price. This includes a set number of sessions for a price, and a time-based therapy "subscription" fee.
• Barter: exchanging professional services for anything other than monetary payment.
• Reasonable fees: CRPO does not set fees for registrants; it expects fees to be non-exploitative.

The one hard number: refunds. Registrants are expected to provide refunds within seven days of the decision to terminate services, with limited exceptions for extraordinary circumstances. It is framed elsewhere as within seven days of the initial request. Where a client terminates partway through prepaid sessions, you refund the fees for services not yet provided.

Sliding scale and equity. Payment on a sliding scale is permitted: a variable fee depending on ability to pay. Fee reductions are permitted in the interest of equity, in accordance with set policies. But you may not charge more than your usual fee for a service where a third party is paying for it. CRPO's manual shows where the line falls: an RP who posts one fee and routinely charges clients without extended health insurance a lower one is in fact charging insured clients more than his real fee, and his posted fee is not honest. Reducing a fee for an individual client's financial hardship is fine, decided case by case and with the reason recorded, not as a general policy that hides the true fee.

When to bill. CRPO does not regulate the amount of a fee unless it is excessive, for example high enough to exploit a client's dependence. Because you bill only for services provided, apart from clearly disclosed exceptions such as an established cancellation fee, RPs usually charge shortly before or after each session. Billing well ahead can be legitimate for a block fee, for a deposit disclosed in advance with clear terms for refund or forfeit (for example a place in a closed group that would be hard to fill), or where client and therapist both prefer it; it must never become a structure that pressures a client to continue because they have already paid.

Collection agencies. You may use a collection agency to recover unpaid fees. You may not sell or assign the debt.

Receipts must clearly state: the client's name; your name and title; your registration number; the name, date and duration of the service provided; and the cost and method of payment.

A silence to respect. Interest charges on unpaid fees are not addressed anywhere in 6.1. Do not assert a rule, and be wary of an option that states one confidently.

How it appears in a simulation. Two vehicles. First, a fee increase mid-treatment for a client who is already stretched. Second, a prepaid block that the client wants to stop partway through.

The +2 option on the block: "Tell the client she is free to stop, refund the sessions she has not used within seven days, and use the remaining time to plan an ending." The +2 on the increase: "Give the client reasonable notice of the new fee, discuss what is affordable for her, and set out the options including a reduced fee under your sliding scale policy."

The plausible -2 options:

• "Offer the client a reduced rate if she pays for the next ten sessions in advance." A discount for pre-payment, prohibited outright, and offered here with a kind motive.
• "Remind the client that she has paid for twelve sessions and encourage her to use them all so the money is not wasted." Pressure to continue because payment was made in advance is a named pitfall, and it also collides with 3.5.
• "Discontinue therapy at the end of the month because the client has not paid the last three invoices." Non-payment is a permitted reason to discontinue under 6.3, but you must first advise the client of alternative services accessible to them. Ending without doing so is the error, however much notice is given.
• "Add the credit card processing fee to the client's invoice." Passing processing fees through is a named pitfall.

A 0: "Email the client a copy of your fee schedule." Fine, and it does not answer the question in front of you.

The trap. The conscientious therapist uses fee flexibility as a clinical kindness, and reaches for the tool that feels most generous: a prepayment discount, a cash rate, a barter arrangement with a client who has skills but not money. Each of those is specifically restricted. The compliant generosity tools are the sliding scale and a documented fee reduction under a set policy, with the reason recorded in the financial record under 5.5.

The second trap is automated payment. Where a card is stored on a booking platform, registrants are expected to remind clients of upcoming charges, and a scenario in which a client is surprised by a late-cancellation charge is usually testing that, not the fee itself.

6.2 Advertising

The rule. Advertising must be truthful, accurate, factual and verifiable. Testimonials may not be solicited or used. No promises, superlatives, comparisons or appeals to fear.

What it actually requires

• 6.2.1: advertising is truthful, accurate, factual, and verifiable. Four words, all four testable.
• 6.2.2: do not request or solicit testimonials, and do not use them in advertising.
• 6.2.3: solicitation activities comply with applicable regulation.
• 6.2.4: do not promise results that cannot be delivered; do not use comparisons to others, superlatives, or suggest that your practice is unique; and do not appeal to fears.
• 6.2.5: paid advertisements must be identifiable or recognizable as an advertisement.
• 6.2.6: take reasonable steps to ensure advertising placed by others on your behalf meets College requirements. A marketing agency's copy is your copy.
• 6.2.7: advertise practice areas only where you have verifiable training.
• 6.2.8: be clear whether an advertisement pertains to psychotherapy or to different products or services.

The nuance that decides most items: online reviews. Soliciting testimonials is prohibited. Clients may independently post reviews, provided you do not request them and provided you do not influence which reviews or endorsements are published. So an unsolicited review that you leave alone is acceptable. Asking for it is a breach. Curating which ones appear, by hiding the poor ones or featuring the good ones on your site, is also a breach.

CRPO's own prohibited examples. Superlatives: "best psychotherapist in Toronto", "fastest path to stability". Promises and fear appeals: "you'll get the job you always wanted", "avoid being alone, come in for therapy".

Identity. Identify yourself using the name recorded in the Public Register of the College, on invoices, business cards and professional documents. Nicknames registered with CRPO are permitted. Title prominence in advertising is governed by 1.2.2: the regulated title sits above every other credential, including on promotional materials, letterhead, business cards and electronic media.

Four more traps from CRPO's guidance. A ranking or award, such as "top three psychotherapists in the city" or "voted best clinic", is a testimonial and usually a superlative, even when a third party gave it, and linking your advertising to a review site can amount to using testimonials; never ask clients to review you or vote for you. Directory profiles are advertising: ticking every condition in a drop-down menu claims competence, and CRPO's example is a new RP (Qualifying) listing eating disorders, borderline personality disorder, suicidality and self-harm, which need training and supervision beyond an entry-level program. You answer for what others publish for you: when a group practice's website shows a contractor's title wrongly, the owner who failed to brief the web administrator and the contractor who did not ask for a correction are both responsible. And you may not use CRPO's logo in advertising, because it suggests endorsement by the College.

How it appears in a simulation. A practice-building scenario: you are launching a website, or a marketing consultant has produced copy, or a grateful client offers to write something for you.

The +2 option when a client offers a testimonial: "Thank the client, decline the offer, and explain that you are not permitted to request or use testimonials." A second +2 with the marketing consultant: "Review the copy yourself before it goes live, and remove the claims you cannot verify."

The plausible -2 options:

• "Accept the client's offer, since the words are entirely her own and she was not asked for them." Soliciting is prohibited, and so is using a testimonial in advertising, however it arose.
• "Ask the three clients who have completed therapy successfully to leave a review on the practice's listing." The clearest breach, and a routine piece of practice advice outside regulated professions.
• "Ask the platform to remove the two lowest reviews because they are unfair." Influencing which reviews are published.
• "Describe yourself as offering trauma-focused therapy, since you have read widely in the area and much of your caseload involves trauma." 6.2.7 requires verifiable training.

A -1: "Add a line saying that most clients see improvement within eight sessions." Unverifiable, close to a promise, and drawn from nothing.

The trap. The conscientious therapist distinguishes between soliciting a testimonial and gratefully accepting one, and assumes the second is fine. The standard prohibits both requesting and using. The narrow permitted space is a review the client posts independently on a third-party platform, which you neither asked for nor curate.

6.3 Discontinuing Services

The rule. Registrants discontinue professional services only when appropriate, never on Ontario Human Rights Code grounds, make reasonable efforts to provide referrals, and clearly communicate and document both the reasons and the conversation with the client.

What it actually requires

• 6.3.1: discontinue professional services only when appropriate.
• 6.3.2: do not refuse or discontinue treatment based on grounds protected by the Ontario Human Rights Code: race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, gender identity, gender expression, age, marital status, family status or disability.
• 6.3.3: where clients are interested in further treatment, make reasonable efforts to provide referrals to other providers.
• 6.3.4: clearly communicate and document the reason or reasons for discontinuing and the conversation you have with the client. Both the reason and the conversation.

Permitted reasons for discontinuation:

• You lack the necessary competence
• The client will not benefit from continued therapy
• You face a serious risk of harm from client threats or assault
• Practice closure or a reduction of hours
• A change in client population or therapy modalities
• A fixed-session agreement has concluded
• Client non-payment of agreed fees

Pitfalls CRPO names. Claiming incompetence when the actual reason is something else is specifically called out, and it is the polite lie that therapists reach for when the real reason is discomfort. Discontinuing on the basis of personality incompatibility, or because a client uses "foul language", is not permitted. Neither is discontinuing over a client's political views, or over a disability without attempting accommodation. And you must document the transition to other services where applicable.

No notice period appears in 6.3. If an option cites 30 days for discontinuing an individual client's therapy, it is importing 6.4's closure rule. Do not follow it there.

How it appears in a simulation. A client who is difficult in a way that is not dangerous: hostile, boundary-testing, contemptuous of the work, or holding views you find repellent.

The +2 option: "Bring your difficulty with the work into supervision, and consider with the client whether the therapy is still offering a reasonable prospect of benefit." Notice how the good option routes through 2.1 and 3.5 rather than reaching for termination. A +2 where discontinuation is genuinely appropriate: "Tell the client plainly why you are ending the work, make reasonable efforts to provide referrals, and record both the reasons and the conversation."

The plausible -2 options:

• "Tell the client that her presentation is outside your competence and provide a referral." The soft exit, and the pitfall CRPO names by name. The referral does not cure the false reason.
• "End the work because the therapeutic relationship is not a good fit." Personality incompatibility is not a permitted ground.
• "Decline to continue with the client who has become unable to attend in person because of her mobility, and suggest she find someone closer to home." Disability, without attempting accommodation.

A 0: "Review your practice's termination policy."

The trap. The conscientious therapist ends a difficult therapy honestly in their own mind and dishonestly on the record, because "this is outside my competence" is kinder to the client than "I find this work very hard". CRPO treats that substitution as a breach in itself. The permitted route, where the work genuinely is not benefiting the client, runs through 3.5.2: involve the client in the judgment, then discontinue with clear reasons, referrals, and a documented conversation.

Non-payment, safety and former clients. CRPO's manual has an RP who stopped seeing a client at once when payments stopped; the client was badly distressed and missed ten days of work, and the ICRC cautioned the RP, who should have given notice that non-payment would end services and offered help finding alternatives, such as a publicly funded agency, a crisis line or the emergency department. Not being paid does not end the duty to a client at risk. For your own safety, CRPO describes an escalating path: careful intake, setting limits and explaining expected behaviour, bringing the behaviour into the therapy, consulting a peer or supervisor without naming the client, then discontinuing; where you have been harmed, you may contact police, disclosing only the minimum. A former client is owed a response to an emergency or imminent risk, to a request for records or a report, and, if asked, to the right to complain; communication that is plainly harassment may be ignored, ideally after legal advice.

6.4 Closing, Selling, or Relocating a Practice

The rule. Registrants give appropriate notice of closure or relocation to each client for whom they have primary responsibility, hold a contingency plan for unexpected interruption, keep the College informed about who would take custody of their records, and maintain records securely for the full retention period even after closure.

What it actually requires

• 6.4.1: give appropriate notice of an intended closure or relocation to each client for whom you have primary responsibility.
• 6.4.2: have a contingency plan to promote continuity of care in the event of an unexpected interruption to your practice. This one is prospective: the plan must exist before it is needed.
• 6.4.3: health information custodians provide the College with up-to-date information about who would take custody of the records in their care in the event of the registrant's death or long-term inability.
• 6.4.4: custodians maintain records securely for the period set out in Standard 5.1 (ten years, or ten years past the client's eighteenth birthday, whichever is later) even after the closure of the practice, unless the records are transferred.

The numbers.

The notice sequence. Attempt direct notice first: appointments, telephone calls, letters, emails. Where that does not reach everyone, add at least two forms of indirect notice: website postings, email auto-replies, voicemail updates, or newspaper publication. All attempts must be documented.

Record handling. Each client record must be either retained securely by you, transferred to your successor, or transferred to another practitioner at the client's request. Once retention periods expire, records are disposed of in a secure manner.

Successor obligations. Successors must be informed of their obligations under the law, and that they may be contacted by clients for copies of their clinical record.

Choosing a successor and a designate. CRPO's guidance: name the successor in writing with their consent, on the annual renewal form; you may name more than one. The successor need not live or be registered in Ontario, but think about clients' access to the records; choose someone competent to act as custodian, ideally another registrant or at least a member of an Ontario regulated health profession or a health care institution. With no successor named, the estate trustee becomes responsible for a deceased registrant's records. Clients are notified of an actual transfer. The contingency plan names one or more designates who would contact clients, give referral information and arrange the records if you suddenly could not practise, and it can ask the designate to tell CRPO, which uses the custodian's details only to help clients reach their records. CRPO's manual describes exactly that: a client whose RP died years earlier asks CRPO how to get her record, and staff contact the successor named on the RP's last renewal.

How it appears in a simulation. You are relocating in six weeks, or closing a practice for health reasons, and your caseload includes clients at different stages, one of whom has not responded to two messages.

The +2 option: "Tell each client in session, at least 30 days before the closure, what is happening and what their options are, and offer referrals to those who want to continue." For the unreachable client: "Add two forms of indirect notice, such as the website and voicemail, and document every attempt to reach her."

The plausible -2 options:

• "Post a notice on the practice website and update the voicemail, since the clients who need to know will check." Indirect notice used first, rather than after direct notice has failed.
• "Transfer all client records to the practitioner buying the practice without telling the clients." Transferring records to a successor is permitted, but PHIPA s. 42 (2) requires reasonable steps to notify each client before the transfer, or as soon as possible after it where that is not reasonably possible, and under Standard 6.4 a client who asks must be able to have their record transferred to another practitioner instead.
• "Arrange for the records to be securely destroyed once the practice closes, since you will no longer be seeing clients." Retention survives closure, and destruction before the retention period expires is a clear breach of 6.4.4.

A 0: "Update your voicemail greeting with the new office address."

The trap. The conscientious therapist plans the clinical ending well and forgets the record. Closure obligations are as much about custody as about clients: the contingency plan must already exist, the College must know who would take the records if you died or became unable to practise, and the ten-year clock keeps running after the door closes. The second trap is inverting the notice sequence, because a website notice is easy and a difficult conversation is not. Direct notice comes first, and indirect notice, in at least two forms, only after direct notice has failed.

Practice names, corporations, contracts and tax

Names. A practice name is advertising, so it must be factual and verifiable. CRPO's examples: "Harmony Family Counselling Centre" is acceptable; "Best Therapy Services", "Guaranteed Results Psychotherapy Clinic", "M. Jones and Associates" with no associates, and a name implying a municipal service are not. On invoices and when identifying yourself to a client, use your name as it appears on the public register, with any business name.

Professional corporations are optional. Practising through one requires a Certificate of Authorization from CRPO, renewed every year. The name includes "Professional Corporation", the profession and at least one shareholder's surname, and is never a number; only CRPO registrants may hold shares; and the corporation offers only psychotherapy and related or ancillary services. Incorporating does not shield you from professional liability, and the College's powers reach the corporation as they reach you. An RP employed by a hospital or agency practises personally.

Leaving a group practice. You cannot always take clients with you. The client decides, once told who has primary responsibility for their care and record, the benefit a self-referral brings you, and the alternatives. The record usually stays with the practice unless custody is transferred; the client may request a copy for the new practice, and otherwise a new record is opened. The practice owner and the departing RP share responsibility for continuity of care. Before signing a contract, avoid terms that would stop you meeting the standards, and take legal advice; since 25 October 2021, Ontario employers may not put non-compete clauses in employees' contracts, though that rule does not cover independent contractors.

Tax. Since 20 June 2024, psychotherapy services provided by psychotherapists are exempt from GST/HST under the federal Excise Tax Act, including couple, family and group psychotherapy, and CRPO's view is that closely related services, such as clinical supervision that enables client care and reports about psychotherapy, are part of psychotherapy. Registered Psychotherapists are listed as authorized medical practitioners for the medical expense tax credit, subject to its conditions. Specific questions go to an accountant or the Canada Revenue Agency.

High-yield facts

Ten-point recall list

1. Fee schedule before services, and it includes administrative and missed-appointment fees.
2. No discount for paying early, in advance, or in cash. Sliding scale and documented fee reductions are the compliant tools.
3. Block fees need a written agreement covering services, total, payment and refunds.
4. Refunds within seven days. That is the one hard number in 6.1.
5. Use a collection agency if you must; never sell or assign the debt. And interest charges are simply not addressed.
6. Never request or use a testimonial. An independent client review you neither asked for nor curate is the only permitted space.
7. Advertise only practice areas backed by verifiable training, and own the copy an agency writes for you.
8. Discontinuation is never on Human Rights Code grounds, and never dressed up as incompetence when the real reason is different.
9. 6.3 states no notice period. The 30-day minimum belongs to 6.4.
10. Closure is a records event as much as a clinical one: direct notice first, two forms of indirect notice after, everything documented, and the ten-year clock keeps running.