Open Letter to BCACC and CCPA

BC health professionals act and new standards gives unprecedented powers to government appointees

May 28, 2023

New Legislation Introduced in B.C. for Regulation of Health Professionals - MLT Aikins - Western Canada's Law Firm

May 16, 2023

This document contains the opinions of counsellors collected by the authors and does not provide legal interpretation. This document is released for feedback and discussion and may be updated as further information becomes available.

The BC Association of Clinical Counsellors (BCACC), which has a membership of over 6000 counsellors, has proposed new Standards to govern counselling practice, dictating what kind of counselling patients throughout BC will receive, and what kind of practice counsellors will be compelled to undertake. Former practitioner and patient choice and freedom, bounded by the constraints of strong codes of ethical conduct, rigorous laws, and scientific practice, appears to be largely replaced by the dictates of postmodern, anti-therapeutic theories.

The proposed Standards contain orthodoxy that rejects reason, science, and reality, and compels counsellors to believe and promote such ideas as “identity and self-definition are fluid,” (self-identification), and to whenever possible use language in all professional communications that describe themselves and their patients in gender neutral terms, compelling counsellors to use sex-obscuring or invented language that does not define male or female. The proposed Standards then proceed to outline characteristics that counsellors are prohibited from discriminating against, a seemingly supportive section. Yet in this section the BCACC have removed from its apparent representation of the BC Human Rights Code, the word “sex” as a protected characteristic. The proposed Standards appear to attempt to erase, through sex-obliterating language, male and female categorizations.

Some Standards exclusively focus on diversity, equity, and inclusion coupled with anti-discrimination and anti-racism mandates to which all counsellors must comply. As BC counsellors, we are deeply committed to culturally sensitive, non-racist, and non-discriminatory practice. Likewise, we are committed to principles of liberal democracy such as the equality and human rights of all persons, and the principles of justice, freedom, and autonomy. However, when anti-therapeutic approaches as defined in the language of equity (not equality) and enforced anti-discrimination measures are enacted in healthcare, they hold that:

“[Healthcare professional] bias is to blame for different health outcomes among racial and gender groups. [They propose] to remedy this reality by forcing [healthcare] professionals to provide different levels of care to different populations. This includes offering and denying treatments on the basis of race, including potentially life-or-death decisions… Anti-racism… holds that racial discrimination is praiseworthy and necessary. It seeks to overcome different outcomes among racial and gender groups by actively discriminating in favor of some people and against others. Anti-racism is fundamentally at odds with… principles of equal treatment under the law and equal justice for all” (Do No Harm, 2023).

The Standards also compel counsellors to report on other counsellors who do not uphold the ideological tenets of the Standards, enforcing an unethical and frightening atmosphere of monitoring and reporting on peers who do not comply with governance directives. As BC Counsellors we are worried that ethical practitioners who serve their diverse patient populations will be targeted for their fair and just practice that reflects scientific and proven practice, an ethic of care, and alignment with our ethical code of conduct.

To complicate matters, the BCACC is attempting to compel counsellors to submit to these orthodoxies at the same time as they move counsellors to become licensed health care professionals under BC’s controversial new Health Professions and Occupations Act (HPOA), a 645-section Act that is widely criticized by health care workers for its over-reach and undemocratic nature, and for the harm it may do to patients and practitioners alike. Among the concerns, Davidson (2023) notes that the HPOA: grants a broad scope of powers to the provincial government to do such things as change the meaning of language, force or prohibit medical treatments, investigate any licensee at will (even with no complaint received), and suspend such licensees without evidence; allows sharing of patient files without their consent and allows for seizure of files without notice or warrant; allows the collection, use and disclosure of confidential information even “…for purposes…not covered by the Act” and information normally excluded from disclosure; contemplates applying for court orders exparte and in secret; imposes severe criminal penalties for non-criminal activity on health practitioners, such as non-compliance to a governing body’s guidelines; subjects counsellors to criminal liability and fines of between $200,000 (for individuals) and $500,000 (for corporations, directors or officers) and prison terms up to 6 months for individuals and 2 years for a corporation, director or officer of a corporation; defines that “a licensee commits an act of misconduct if the licensee engages in conduct that may bring the practice of a designated health profession into disrepute (s. 11); requires licensees to: “protect the public from harm and discrimination; (b) to take anti-discrimination measures”; and requires licensees to report other licensees believed to be “not fit to practice” or who present “a significant risk of harm to the public” including reporting any licensee believed to have committed an act of “discrimination.”

The HPOA enforces totalitarian requirements to report on one’s peers, other health professionals, and as we can interpret and require clarification, even on patients, for not adhering to the Act. Should a health professional perceive another practitioner as behaving in a discriminatory fashion, this health professional may be forced to take actions that may in turn be considered unfairly targeted and discriminatory. If health professionals do not comply with the Act, they face sanctions and criminal charges, fines, and jail time.

As BC Counsellors we are extremely concerned that there are risks to patient confidentiality under the new parameters of a health care worker’s duty to report and the ability of the government to seize and share patient records. We worry that patients may also be put at risk if they tell a health professional anything deemed unacceptable by the Act, and which a health professional must then report.

Historically counsellors have maintained a duty to report in clear circumstances that we must be able to describe to our patients, as a part of ensuring informed consent. This appears to have changed under the proposed Standards and HPOA requirements. Counselling, where people explore the most sensitive topics, can only exist as a legitimate practice if professionals can maintain the highest degree of confidentiality outside of rare and understood circumstances.

We outlined our concerns in an open letter to the BC Association of Clinical Counsellors and the Canadian Counselling and Psychotherapy Association (attached), two governing bodies of counsellors and psychotherapists in BC and Canada. We also sent our concerns to BC’s Minister of Health, Adrian Dix, and BC’s Premier, David Eby. In that letter, we asked for the BCACC to repeal the Standards and pause on licensing counsellors under the HPOA while they undergo an accountable, transparent, and genuinely inclusive process of creating Standards that reflect the diversity of BC and uphold the rights, autonomy, freedom, and dignity of all patients and counsellors.

All British Columbians should be aware and educated about these upcoming changes, so they can autonomously and freely make the best choices for themselves and their families as healthcare system users. Organizations and governing bodies that are enforcing laws and policies that impact all British Columbians have a duty to address the concerns brought forward by health practitioners across disciplines.

Sincerely,

Carla Duda, Registered Clinical Counsellor, M. Couns. Psych. Email: dudac2050@gmail.com
W. Paul Erickson, Registered Clinical Counsellor, M. Couns. Psych. Email:paul@wperickson.com

May 5, 2023

BC Association of Clinical Counsellors
#109 – 1034 Johnson Street
Victoria, BC V8V 3N7
Via: Email & Registered Mail

Canadian Counselling & Psychotherapy Association
202-245 Menten Place
Ottawa, ON K2H 9E8
Via: Registered Mail

CC: The Hounorable David Eby, Premier; The Honourable Adrian Dix, Minister of Health
Via: Email

Dear Recipients,

Attached please find an Open Letter to the BC Association of Clinical Counsellors and the Canadian Counselling & Psychotherapy Association concerning the new BCACC proposed Standards of Practice and BC’s Bill 36 legislation. This letter is for distribution to your respective Executives, Boards, Ethics Committees, and Association Members.

Sincerely,

Carla Duda, RCC, M. Couns. Psych. Email: dudac2050@gmail.com
W. Paul Erickson, RCC, M. Couns. Psych. Email: paul@wperickson.com

Open Letter to the BC Association of Clinical Counsellors and the Canadian Counselling & Psychotherapy Association
Compromised: The Health Professions and Occupations Act (HPOA) and Counselling and Psychotherapy in BC

Registered Clinical Counsellors (RCCs) are members of the BC Association of Clinical Counsellors, forming a membership of over 6000 counsellors. The BCACC recently announced a partnership with the Canadian Counselling and Psychotherapy Association (CCPA), and indicators point to RCCs and BC Psychotherapists together becoming licensed under BC’s controversial new Health Professions and Occupations Act (HPOA), to be regulated by the College of Allied Health and Care Professionals. The Act forms the regulating of all licensed health professionals in BC. Health professionals across BC including members of the BCACC are deeply concerned that the Act exposes both health care professionals and the public to serious risks to their freedom, autonomy, and privacy by handing the government unprecedented and sweeping powers.

This document explores potential risks to counsellors and patients in BC. The BCACC has not disclosed the potential risks and harms of licensing to RCC members and the public. We believe RCCs, psychotherapists, and members of the public remain unaware of the risks that such broad and penalizing legislation could present. It appears that the HPOA gives unprecedented powers to government appointees to enter health care professionals’ premises without notice, seize patient files, and use those files as deemed necessary under the Act. Due to the broad and vague language in the Act, the impacts to patient privacy, confidentiality, and well-being are severely concerning.

Complicating matters, the BCACC has announced new proposed Standards of Practice for counsellors, which, if licensed, become part of our requirements at the College level. These proposed Standards are strongly indoctrinated with damaging orthodoxy that we are concerned could make fair, non-discriminatory, scientific, and proven practice almost impossible. RCCs are concerned about possibilities under the proposed Standards and Act that could harm patients if they disclose to a counsellor something that the Act deems reportable. Counsellor duties to report under the Act appear to exceed historical duties of counsellors to report what patients tell them, particularly for patients who are also other licensees. Counsellors who become licensees are also subject to oppressive and high-risk consequences under the Act. We believe most counsellors are not aware of the potential risks to their well-being. The Act defines criminal misconduct for actions that we understand are not criminal in nature. The Act subjects counsellors to criminal liability and fines of between $200,000 (for individuals) and $500,000 (for corporations) and up to 2 years imprisonment. We believe that the Act and Standards in combination will compel counsellors to actively carry out measures that we are concerned could result in significant breaches to our Ethical Code of Conduct. Under legislation that appears to compromise the critical foundation of counselling, confidentiality, we believe it entirely possible the integrity of the profession could not only be compromised, but collapse.

Introduction

The counselling profession’s reputation rests on the trustworthiness, honesty, ethics, and science-based and proven care of its practitioners. Such a base is the only foundation on which the counselling profession can uphold the integrity of a service that meets the diverse needs of British Columbians. The Health Professions and Occupations Act (HPOA) and the BCACC’s new proposed Standards of Clinical Practice (“proposed Standards”) (BCACC, 2023) are problematic for counsellors and patients alike, and appear to expose patients to serious risks to confidentiality and freedom, and counsellors to extreme professional and personal risks. Risks to patients and counsellors alike are not fully understood, constituting a need to know.

We have reviewed the BCACC’s proposed Standards, which we understand will become enforced at the provincial College level under the HPOA, and we have numerous concerns. These views include those of RCCs who requested their feedback be included anonymously. Jointly, our concerns are:

That the proposed Standards are not therapeutically based, but ideologically based on postmodern doctrine and questionable orthodoxy instead of exploratory, ethical, and science-based or proven approaches to counselling and psychotherapy;
That postmodern doctrine put into practice, results in counselling that may be harmful to patients;
That the proposed Standards compel counsellors to oral and written communications that compel use of language restricting counsellors from identifying themselves or their patients as male or female, impacting sex-based identity and rights by degrading or attempting erasure of sex-based characteristics of identity of both counsellors and patients;
That the proposed Standards limit or degrade patient and counsellor autonomy and freedom, both professionally and personally;
That the proposed Standards’ and the HPOA’s use of the terms “anti-racism” and “anti-discrimination” in describing practice mandates appears to differ from previous prohibitions on discrimination and racism and appear related to prescribed orthodoxy to which counsellors and all health professionals must agree and commit. “Anti-racism” and “anti-discrimination” when written into policy, must be understood at the practice level, because they may compel health professionals to practice in ways that may conflict with ethics and proven practice. This language is closely tied extreme, non-therapeutic ideology (Sanchez, 2021; Kissel, 2023; Do No Harm, 2023). When enacted, these approaches may mean that health professionals may justifiably enforce or even be compelled to enforce a discriminatory approach towards specific patients based on their unique characteristics of identity that we understand are prevented from discrimination under human rights law in BC (Human Rights Code, 2023), or may compel professionals to participate in healthcare acts they deem unethical or object to on the basis of conscience (Elbers, 2023);
That under the HPOA the proposed Standards may compromise patient confidentiality, and put patients at varying degrees of risk if they attend counselling; under HPOA enactment, we do not anticipate how counsellors can complete informed consent and ensure confidentiality to the degree we do currently and we ask for clarification;
That under the HPOA counsellors and other health professionals may be subject to extreme professional risks and criminal and financial penalties that most counsellors are not aware of and for which the BCACC and counselling governing bodies have a duty to investigate and transparently disclose to all members before proceeding with licensing;
That the HPOA and the proposed Standards contribute to a toxic culture of fear amongst counsellors who are afraid to voice their concerns for fear of reprisal;
That the proposed Standards are promoting a concerning orthodoxy and a science-denying ethos that may make it impossible for counsellors to follow their own BCACC Code of Ethical Conduct to practice in truth, integrity, confidentiality, and using proven therapeutic approaches, with an ethic of care.

We believe it is time for the BCACC to pause and assemble a diverse and scientific group of critical thinkers and representatives that reflect the diverse population of British Columbia to revise and create a set of Standards to serve our population. We believe counselling Standards must first reflect truth, integrity, and reality, and honor both counsellors and the people they serve as worthy, dignified, autonomous beings. We request that the BCACC and CCPA ensure their combined Standards are rigorously held up to the scrutiny of critical thinking, ethics, and the scientific process and accountability and assessment protocols and are fair and just for all British Columbians. We believe that before proceeding with licensing, the BCACC and CCPA should thoroughly investigate and report on the potential risks to the public as potential patients, and to practitioners, of becoming licensed under the HPOA so the profession of counselling is not further compromised.

Review of the HPOA and Proposed Standards for Clinical Practice

Postmodern Ideology as Background to the Standards

Much of the academic training for counsellors and psychotherapists took an extreme turn in past decades under a dominant postmodern narrative, which forms a caustic and cynical orthodoxy. Postmodernism maintains a radical and anti-scientific worldview that arose as a response to modernity’s rationalism (Duignan, 2023). Postmodernism suggests that there is no such thing as objective fact or reality, and that subjectivity is the only lens through which to view humans. “Postmodern sophistry [is] based on ideologically tinted opinion, illusion, and subjectivism” and replaces society’s former dominant focus on facts and reason. Postmodernism “dismisses Western meta-narratives, founded on reason and science, while socially constructing its own meta-narratives or ‘paradigms’ for its moral imagination, the basis for its professed moral authority… and has significantly degraded academic social science” (Young, 2015).

Many of postmodernism’s ideological outcrops are used to train student counsellors and psychotherapists and include but are not limited to such academic areas as social constructionism, social justice, cultural NeoMarxism, intersectionality studies, post-colonial studies, and gender studies. These ideologies need not be rooted in data or objective reality since their orthodoxy demands a rejection of such. Training under these ideologies therefore cannot adequately focus on the ethical requirements necessary to be practitioners within the health sciences. It is impossible to be a scientific practitioner when one wholly subscribes to ideologies that reject fact, reason, and the scientific process as leftovers of modernity. Through the postmodern lens, it is thoughts, narratives, and feelings that are considered the only “truths.” Should one veer into reason and objectivity, pointing to objective reality or truth itself, these ideologies may make an Orwellian accusation and label truth “discriminatory.”

Postmodernism maintains that all problems related to human nature and well-being are rooted in power imbalances and hierarchies and are systemic and not individual in nature, obscuring the true nature of individual autonomy, growth, and self-determination, but also obscuring realities of human motivation itself. This limited world view suggests that obtaining power is the dominant motivation of humans. Yet people make decisions and create society based on all kinds of motivations, including but not limited to power. People are also strongly motivated by the need for connection, cooperation, and belonging; by the desire for well-being; by the desire for recognition and positive reputation; and by the desire to demonstrate responsibility, amongst motivations.

Postmodern ideology presupposes that power is unjustly held by systems and maintained through boundaries, hierarchies, and structures. The aim of postmodernism is to “deconstruct” such so-called constraints, thereby defining the ideology’s destructive nature. The constraints postmodernism seeks to deconstruct may range from as micro as the couple or family unit to as macro as the systems that postmodernism suggests must be broken down to free what it defines as an oppressed individual or group.

When translated to the counselling endeavour, postmodernism risks becoming a “clinical” view that holds a child is oppressed by the family structure and should be “emancipated” from this protective unit; or it may hold that a marginalized group is oppressed by unjust laws or a historical narrative, which may reflect some aspects of reality, but not the complexity of modern-day power dynamics and self-determination. This view also suggests it is justifiable under “social justice” dictates and “critical theories” ideology, that someone who considers themselves as having been harmed may actively perpetrate or discriminate against others based on their appearance, and on characteristics they cannot change, such as sex or race. “Social justice” considers such targeted persons justifiable collateral damage under retributive, discriminatory views of “justice.” This toxic cycle of perpetration does not resemble any form of justice or healing. It contributes to harm and enables such destructive actions as former “victims” becoming “perpetrators” and former “perpetrators” becoming “victims,” potentially relentlessly continuing a cycle of shifting perpetration and trauma. This “bizarre and untested hypothesis [suggests] that you can fight fire with fire and cure discrimination with more discrimination, the illogical basis of Kendian anti-racism” (Wu, 2022). As counsellors, we do not see any contributive, societal good to this cycle, nor do we see any therapeutic healing of past or present wounds through this approach.

Postmodernism maintains that the scientific process itself, the checks and balances we require for ethical and non-harmful practice, is biased, and so should be displaced by alternative ways that are both undefined and cannot be held up to the scrutiny of the scientific method, thereby potentially rendering them unable to be considered safe, reliable, or legitimate therapies in the health sciences or counselling. Postmodernism suggests that logic and merit are oppressive and should be abolished.

In human development terms, postmodernism is a weakening ethos that translates into harm for people psychologically and emotionally, and even at times, physically.

Of course, any science-denying, discriminatory, or anti-human ethos should never be the lens through which we train counsellors to become effective psychotherapists and ethical health practitioners. At the academic level, fledgling counsellors have some limited degree of freedom, for example, to leave and attempt to find a school based on science, reason, and ethics, or to supplement their training with substantive therapeutic learning in non-harmful therapeutic modalities.

However, it is a wholly oppressive and destructive turn when their governing body subscribes to these ideologies and enforces them by fiat.

Practitioners in the field of counselling psychology, which is the scientific study of the human mind and behaviour, must be scientific practitioners. Within the therapeutic process, the scientific method is not just rigorous and iterative, helping patients test and retest their views of reality within reality, trying out new thoughts and behaviours, and reforming their lives in various ways, but the scientific method helps patients form new hypotheses and enter the process of investigation. This use of the scientific method of investigation is the basis of all good counselling and psychotherapy.

Legitimate counselling and psychotherapy are always couched in curiosity. As such, practitioners who work in counselling and psychotherapy examine objective reality, facts, data, history, context, and a patient’s subjective experience of reality, including individual thoughts and emotions. Patients are supported to make skillful decisions not simply from their feelings of the moment but from exploratory, contemplative, and rational investigation, assessing the impacts of their decisions on their present and future selves. Patients can be assured that counsellors with an exploratory and scientific approach will suggest that they are here to help patients discover the problem, and perhaps even remedy it, for themselves. These counsellors will assure patients they are not here to affirm (state as fact, assert strongly) or advocate (publicly support or recommend a particular cause or policy) for a patient’s experience or outcome. Affirming and advocating when suggesting one is doing counselling or psychotherapy may be manipulative and misleading at best. Worse, it is potentially paternalistic and colonizing, restricting patient autonomy and freedom, particularly when it involves any limitations on ensuring informed consent. Informed consent is an essential component of patient autonomy that ensures patients understand all the “purposes, risks, and benefits” of an intervention before proceeding (BCACC, 2010). Due to patient autonomy and ability to make decisions based on accurate and fulsome information, responsibilities for ensuring informed consent may increase significantly if professionals are involved in counselling that involves a patient potentially undergoing medically life-altering decisions.

Psychotherapy exists to help a patient explore and understand more deeply in as bias-free a way as possible in a safe, which at base also means confidential, environment (outside of clear duties to report). To suggest that counsellors should imbue counselling with radical postmodern ideology that affirms and advocates on social justice premises would not be psychotherapy or counselling. The entire profession could be rendered illegitimate by an ideological, advocacy-based ethos such as postmodern training and viewpoints entail.

Degradation or Erasure of Males and Females and Sex-Based Identity and Rights

In the proposed Standards the BCACC states that they are presenting “legal provisions” and below these “provisions” note that their expectations are also that counsellors’ actions align with the “British Columbia Human Rights Code.” These “legal provisions” appear written to replicate the British Columbia Human Rights Code. Yet, in BCACC’s apparent replication of the Code, it has removed the characteristic of sex as a basis of protection from discrimination.

We believe this step alone calls for a repeal of the proposed Standards, based on a perceived attempt at manipulation and misrepresentation of legal provisions. The proposed Standards also entail the use of “gender-neutral” language in all a counsellor’s “professional interactions (verbal, written, and online, including social media) including with patients, colleagues, students, supervises, research participants and others” (Standard 3). This appears to be an alarming attempt to manipulate language specifically to degrade sex-based human identification and rights.

The BCACC appears to be attempting to enforce the use of invented and/or sex-identity obscuring language. This means that as counsellors we are compelled whenever possible not to represent ourselves or our patients accurately if our true and experienced sex-based identities are that of man, woman, boy, girl, male, or female. However, we may presumably freely use terms to describe ourselves and our patients with neutral and/or invented language whether or not our patients identify this way, or as counsellors we ourselves identify with neutralized or invented language or not.

This exclusion of sex from so-called “legal provisions” degrades patient and counsellor autonomy and identity, and erases from common language descriptors of one’s immutable characteristics of being. This enforcement of neutralizing language also has striking similarities to a type of conversion therapy, albeit in a different way than one may think of hearing the term, but conversion, nonetheless. We suggest any remnant of an idea that counsellors should be required to neutralize our patients or ourselves through invented or obscuring language be swiftly and entirely removed.

A Failure to Respect Patient and Counsellor Autonomy

Due to legislative overreach and a prescribed ethos determining not only how we see patients and their problems but how we will be obliged in these proposed Standards to project onto patients how they should see themselves, this is disrespectful of patient and counsellor autonomy. Such overreach is woven into many areas of the document. This overreach exists when those with institutional power and privilege enforce in statute and practice, radicalized ideology, and then punish counsellors who do not comply with the prescribed orthodoxy. Counsellor freedom, autonomy, and safety is compromised when we risk becoming unfairly and unduly targeted by members of the public, peers, or others for “ethical violations” that actually constitute ethical practice, even criminalizing such actions under the HPOA.

A Toxic Culture of Fear

The authors have spoken to numerous RCC colleagues who are so worried about the impacts on patients and themselves respecting these Standards and the HPOA, that they are seeking alternative work, and are planning to leave the profession. This trajectory resembles that of the doctors, nurses, and other healthcare professionals in BC who are aware of the risks to professionals and the public of the HPOA, and for which we understand may be a significant source of BC’s recruitment problem in attracting healthcare professionals. Other counsellors are struggling under the weight of trying to imagine how they will continue to practice in truth, integrity, and respect for autonomy and well-being of their patients and themselves, while operating under the HPOA and the BCACC Standards.

It is a bizarre, inverted reality that practitioners are distressed because they want to practice responsible, ethical, rational therapy and because they refuse to be indoctrinated into radicalized ideology. They are fearful that they will be targeted by the BCACC or provincial government itself when they cannot in good conscience, as scientific and ethical practitioners, align with the new proposed Standards or demands of the HPOA. Counsellors are incredibly afraid of what this all means under the Act for both counsellors and the public. Further, as we understand it, and require clarification, under the Act even an illegitimate, anonymous (“identity protected)” accusation may be made to authorities about a counsellor, by anyone, and not by necessity a patient. Such a complaint may be made by a member of the public or another licensee and may have no relationship to the actual therapeutic work we are doing. We are unclear also and would like the clarification concerning that once an investigation is underway, this investigation will be published as taking place before the investigation is completed. If this is the case, and this complaint ends up being illegitimate, this publicity may have already seriously impacted a practitioner’s reputation and career. We also understand that this investigation will not be conducted by an elected body of similarly qualified peers who understand the complexities of our field of work, but by government appointees who need not be qualified counsellors, and can carry out these investigations under the broad and sweeping authority of the Act. We would like the BCACC and other governing bodies to clarify for their members exactly how and under what circumstances investigations may be initiated, by whom, what the investigative process entails, and the impacts on counsellors and the public of this new investigation process under the Act.

*Update 11/04/23: It is our understanding based on a presentation by in July 2023, by Brian Westgate, Director, Strategic Priorities for the BC Provincial Government at an online townhall to discuss the implications of the HPOA, that it is not the case that the practitioner will be named publicly as soon as an investigation is undertaken. In addition, we have since been made aware that the BC Government has released a brief outlining their answers to some common concerns about the HPOA. We do not provide any legal interpretation, only include it for reference so interested readers may cross-reference its statements with the content of the HPOA.

We note that the government brief specifies that the HPOA “does not allow government to copy or seize clinical records” but “only an independent Investigator, who is appointed by the regulatory college, at the request of an investigation committee can access private medical records.” Furthermore, the government brief notes, “this authority already exists under the current governing legislation, the HPA.”

While providing not legal interpretation, we encourage readers to view the content of the HPOA themselves, specifically Sections: 506 Search and seizure order, 507 Content of search and seizure order, 508 Content of things not described in the order, 509 Detention of seized things, 510 Detention of seized records, 511 Warrantless search and 512 Judicial review. Readers may wish to seek independent legal advice in this matter. We further direct readers to the HPA, Health Profession Act to review how search, and then seizure, of records is described and differentiated in various sections therein and to compare similarities and differences between the Acts (e.g. Sections 27, 28 and 29).

While we cannot provide legal commentary on the Acts it is our understanding that there are distinct differences between the two Acts in respect to seizure and that the differences in these sections require qualified legal review and reporting by the BCACC to determine and report to membership on how the subsequent potential differences may impact on practitioners and patients in BC under the new HPOA if counsellors are licensed. We further encourage readers to review commentary by Gail Davidson, LLB, retired, and by the Justice Centre for Constitutional Freedoms, which states that under Bill 36/HPOA, “the College [can] make “without notice” applications to the court to obtain orders of compliance, orders for entry into premises to search, seize or copy property, orders to secure premises and prevent an owner from entry, to order fines for non-compliance of up to $200,000, as well as to order jail time for up to six months if a healthcare worker is deemed to have made a false or misleading statement.” *End update 11/04/23.

The BCACC has written into its proposed Standards that its counsellors must report on each other. Its members must “be aware of the legislative requirements and expectations to report the unethical, unsafe, or incompetent practice of a regulated healthcare professional to the appropriate regulatory body.”

The proposed Standards’ mandates are then backed up by the HPOA’s oppressive overreach that likewise compels licensees to report on other licensees. We would like to know how our duty to report under such broad terminology as deeming licensees “not fit to practice” or as presenting “a significant risk of harm to the public” (s. 85, a, b) would correspond to reporting on our own patients, many of whom are licensed health professionals themselves. It appears we are to report the type of information that is outside any historical duty to report.

The HPOA defines acts of misconduct and criminal offences for actions Davidson defines as legally illegitimate (2023). The HPOA does not properly define the acts themselves so an act cannot be avoided or defended (Davidson). For example, such illegitimate charges for licensees would define “providing false or misleading information to patients or the public” as both an act of misconduct (s. 70 (2) (g)) and a criminal offence (s. 514(2) (b)); likewise would “conduct that may bring the practice… into disrepute” (Davidson). We would like to understand what is being defined as “false information.” If this punitive language is related to healthcare providers offering non-government-sanctioned approaches to care, then given the ideological content of the upcoming directives and proposed Standards, this could prove deeply problematic. Further, conduct of “disrepute” must be clarified, given the possibility of using this language to shut down free discourse or legitimate criticism of a profession and its practices.

If RCCs and psychotherapists were to understand specifically at what risks the BCACC is putting them with such verbiage, in combination with the HPOA, we find it inconceivable that ethical and science-based practitioners will feel safe or able to practice with integrity if they remain a member of the BCACC and become licensees.

It is also important to note that all the concerned RCCs we spoke to were unwilling to sign their names to this document for fear of reprisal. This muzzling of freedom of thought and suffocation of the integrity, diversity, and rationality of voices that is already impacting our profession is unacceptable. What happens when counsellors become governed by an Act that enforces criminal penalties for non-criminal activity?

BCACC’s body of counsellors are of diverse faiths, races, sexes, ages, sexual orientations, socio-economic statuses, and other markers of identity. Yet this diversity of BCACC members is not only not equally represented by the proposed Standards, but many of those who do not agree with the proposed Standard’s orthodoxy are too frightened to voice their disagreement for fear of punishment, loss of reputation and income, and public humiliation. We are concerned that such a controlling and overreaching institutional policy may be creating a psychologically oppressive environment for BC’s counsellors. We do not understand how counsellors regulated by these proposed Standards and the new Act will fulfill their ethical duties towards patients, or their duty of self-care and individual autonomy, when working under such oppressive conditions.

The Health Professions and Occupations Act (HPOA)

We again reiterate that these are our opinions and not legal commentary. A full review of concerns regarding the HPOA is beyond the scope of this report. The Act is massive and sweeping, containing 645 sections that will govern health professionals. Davidson (2023) and Elbers (2023) note that the HPOA was pushed through without appropriate debate by health care workers or the public.

It is our understanding, and we ask the BCACC and other governing bodies to confirm and report back to their members that as defined by Davidson (2023), and in reference to the HPOA (HPOA - Bill 36 - 2022) that the Act:

Enables the non-consensual imposition of global regulations into BC law, without consultation and due process, and grants a broad scope of powers to the provincial government to do such things as change the meaning of language, force or prohibit medical treatments, investigate any licensee at will (even with no complaint received), and suspend such licensees without evidence or hearing (Davidson);
Does not mandate health professionals to complete informed consent, the primary duty of any such professional, but does allow appointed government representatives to make rules about informed consent and does not require respect for rules of such consent as established by Canadian law and international treaties to which Canada is a State Party (s. 72 (3) (b);
Allows investigation of licensees based on anonymous complaints (“identity protection” ss. 237-239);
Allows sharing of patient files without their consent and allows for seizure of files without notice or warrant (ss. 502(1) and 503 (1) and 511);
Allows the collection, use and disclosure of confidential information even “…for purposes…not covered by the Act” (s. 530) and information normally excluded from disclosure (ss. 491 and 492);
Allows investigators to enter premises and make copies of confidential records (s. 131);
Contemplates applying for court orders exparte and in secret (ss. 502(1) s. 503 (1));
Imposes severe criminal penalties for non-criminal activity on health practitioners, such as non-compliance to a governing body’s guidelines (S. 517; S. 518);
Imposes penalties for acts of misconduct that include summary suspension of licenses before hearing (ss.122(1), 152, 153, 225, 259) and without notice (260),” fines between $200,000 and $500,000, imprisonment up to 2 years (s. 518) and additional penalties for each day that the offence continues (s. 517);
Defines that “a licensee commits an act of misconduct if the licensee engages in conduct that (a) may bring the practice of a designated health profession into disrepute (s. 11);
Requires licensees to: “protect the public from harm and discrimination; (b) to take anti-discrimination measures” (s. 72);
Requires licensees to report other licensees believed to be “not fit to practice” or who present “a significant risk of harm to the public” (s. 85) and to report any licensee believed to have committed an act of “discrimination” (s. 86)”.

The requirement that licensees report on one another appears to be applicable at a cross-College level. For example, we understand that not only are counsellors obliged to report on other counsellors, but it appears that a nurse may be required to report on a counsellor, a counsellor on a medical doctor, and so forth. We remind the readers that many of these licensees are also each other’s patients. Counsellors in BC must understand how their duty to report conflicts or interacts with patient confidentiality, and other mental health, privacy, confidentiality, and constitutional laws in such situations. We need to know specifically how the HPOA will impact patient privacy and confidentiality and practitioner responsibilities for informed consent.

We understand that under the HPOA counsellors may be subject to criminal penalties for advancing opinions deemed not in favour of the College since it may be deemed as putting the practice into disrepute. We would like the BCACC and other counselling governing bodies to investigate this and to notify all members of their findings.

If true, this is an incredible risk every practitioner should be informed of and thoroughly understand before consenting to practice as counsellors when the HPOA is in force. Individual rights and freedoms may be not just limited, but exercising such rights may be severely punished.

The HPOA mandates that licensees must protect the public from harm and discrimination and, further, take “anti-discrimination” measures. This involves reporting acts deemed “discrimination” under the Act or by an individual licensee, with broad room for interpretation and misuse.

Does this mean counsellors must report not only on other licensees for what they perceive are acts of discrimination, but also on patients who tell counsellors something an individual counsellor deems constitutes discrimination? If so, what specifically is reportable? It is essential for counsellors, health professionals, and the public to understand the duty to report in detail. We must be able to explain to patients, so they understand before disclosure, what fits within our duty to report. We foresee many unfortunate situations not just based on what penalties patients may incur for sharing information truthfully, but also risks to patient health care when they may choose to restrict what they share with a health care provider based on those risks.

“Anti-discrimination” and “anti-racism measures,” in combination required under the proposed Standards and the HPOA, must be understood as concepts and what they mean to practice. They are closely tied to harmful, non-therapeutic, “critical theories” (Wu, 2022; Kissel, 2023), which, when enacted in healthcare hold that:

“[Healthcare professional] bias is to blame for different health outcomes among racial and gender groups. It proposes to remedy this reality by forcing [healthcare] professionals to provide different levels of care to different populations. This includes offering and denying treatments on the basis of race, including potentially life-or-death decisions [and] may violate federal… [and constitutional] law.

Anti-racism… holds that racial discrimination is praiseworthy and necessary. It seeks to overcome different outcomes among racial and gender groups by actively discriminating in favor of some people and against others. Anti-racism is fundamentally at odds with… principles of equal treatment under the law and equal justice for all.

Within healthcare, anti-racism is making race and gender a determining factor in who gets certain [healthcare] treatments. That includes the denial of treatments for patients based on their skin color. It is also turning medical students and professionals into political activists by training them to care more about identity politics than caring for individual patients” (Do No Harm, 2023).

We can conceive of many ethical scenarios that could put patients and counsellors at great risk, should a patient tell a counsellor something that is now considered private and confidential, but which a counsellor under the HPOA appears could have a duty to report. We would like to know what counsellors are obliged do under the Act, when we run into these representations of a host of common and related counselling scenarios:

A mother attends counselling to discuss her 12-year-old child’s gender identity confusion and her daughter’s declaration after attending a recent school training that she “doesn’t feel like a girl” and “doesn’t feel real.” The parent opposes pharmaceutical and surgical transitioning for her child and would only like to discuss non-transitioning options to support her child through this adolescent period of change. Does a counsellor deem this parental view reportable under “anti-discriminatory” laws under the HPOA? If this counsellor reports the parent, how will this parent’s files be shared with other governing bodies? What actions could potentially be taken against this parent for disclosing to the counsellor an action that this counsellor has deemed reportable?

A counsellor’s patient is another licensed health professional, a medical doctor, who is attending counselling to discuss his personal stress over his disagreements with aspects of the HPOA. He describes his unwillingness to comply with specific harmful and unethical components of the Act, although, he explains, none of his patients are harmed and are instead protected by his medical duty to do no harm. Does the counsellor have a duty to report this healthcare professional for non-compliance with the Act? If so, how may his counselling files potentially be shared and what punitive actions could potentially be taken against this medical doctor based on what he disclosed to the counsellor?

Any legislation that has the potential to be destructive means that we must treat every situation like the worst-case scenario. BC counsellors must not be placed in a compromised position to do the work they are ethically obliged to do, nor must patients be put at risk of harm by their disclosures that fall outside the historical duty to report.

We are aware of countless more ethical scenarios presented by the HPOA that counsellors must, according to their ethical code, understand fully before proceeding as licensees. This means counsellors must first clearly understand their duties under the Act. Right now, most counsellors do not. The BCACC has a duty to ensure they accurately inform counsellors and the public on such issues, and counsellors a duty to inform their patients under the rigors of informed consent. We remind the readers that the purpose of counselling is to discuss complex and sensitive information in a safe environment of confidentiality, outside of clear duties to report. The counselling forum is uniquely impacted by the HPOA in ways counsellors need to understand.

How, under the HPOA, are counsellors to voice our concerns about such important regulations like the concerning orthodoxy of our proposed Standards, when it appears that doing so may deem us as engaging in activity that could be considered to put the profession in disrepute and may subject us to criminal punishment? How can any counselling governing body, including the BCACC, support a law that muzzles and threatens professionals and their ability to be scientific, rational, critical-minded practitioners?

Due to the complicated and contentious nature of the HPOA, we believe that the BCACC should pause licensing efforts, and create a formal body of diverse, critical reasoners to investigate and report thoroughly on the implications of the Act for counsellors as potentially regulated health professionals.

Self-Identification, Critical Theories, and Practitioner Liability

The proposed Standards advocate for a practice that some Indigenous people report they find harmful — self-identification. Under the proposed Standards, counsellors are compelled to uphold that “identity and self-definition are fluid.” When applied to protected groups, this may cause harm. For example, self-identification has enabled “pretenders,” people who self-identify as Indigenous to gain access to benefits not rightly theirs (Obed, 2022). The BCACC’s advocacy for self-identification may harm Indigenous people and other groups whose immutable and protected characteristics may be appropriated and colonized by anyone at will. Included in this group are women. Marginalized or vulnerable women are harmed the most. We ask how it can be reasoned to be fair or just outside of rare and specific circumstances, to uphold or condone, self-identification for some group’s protected characteristics of identity, but not for other groups?

Further, the proposed Standards contain objectionable orthodoxy, related to various critical theories, which is harmful, non-therapeutic, and may be discriminatory. These orthodoxies could result in discrimination and harm to people in BC because the orthodoxies oppose fundamental principles of liberal democracy (Kowalsky, 2022). Anti-racism supports discrimination through the delivery of “so-called ‘anti-racism,’ [and] “diversity, inclusion, and equity,” programs (Randall, 2021).

It is important for health professionals and patients to understand if and how their duties and liabilities change when the language directing requirements changes from essential requirements that prohibit discrimination and racism, and ensure equality, to obligations to enforce measures that health professionals must take as actions determined by anti-discrimination, anti-racism, and enforcing of equity requirements.

We ask the BCACC to clarify how the nature of our requirements as counsellors changes subsequent to the requirements defined by these terms, and to ensure that the use of such terms cannot potentially lead to discriminatory actions aimed at particular patients, or to forcing health professionals to engage in activities that conflict with scientific practice, conscience, or a duty to do no harm and uphold an ethical code of conduct.

Beyond the damage enforcing extreme, non-therapeutic ideology may do to people based on their unchangeable and protected characteristics, it further punishes people who want to engage in a critical debate about the ideologies woven into the proposed Standards. These people may be accused of disagreeing with the ideology because they are racist and are demonstrating a moral and psychological failure related to denial and fragility.

We offer that addressing historical and present discrimination can never ethically and therapeutically be done through a theoretical or practical lens that suggests that there are some humans who are inherently worth more or less than other humans, or that discrimination is justifiable towards some people to “balance the scales” or “right the wrongs.”

Numerous ideologies in the proposed Standards appear to perpetuate cycles of abuse and trauma rather than the healing and repair that should be the aim of therapeutic practice. They directly conflict with all four principles of our Code of Ethical Conduct: respect for the dignity of all persons, responsible caring, integrity in relationships, and responsibility to society (BCACC, 2014). At the institutional level, if a counselling organization embraces these extreme ideologies, they risk perpetuating institutional trauma, not only on their practitioners, but also through them, on the patients they serve. We take seriously BCACC’s organizational mandate, which is “making mental health and well-being a health priority” (BCACC, 2023), presumably for everyone. On an ethical and moral basis, an organization with this mandate should reject extreme ideology from being written into practice Standards.

Counsellors support culturally informed practice. Counsellors uphold non-discriminatory, non-racist practice that upholds the equality, dignity, and human rights of all people. Counsellors uphold and honor the importance of supporting efforts for Indigenous people, who are disproportionately negatively impacted by racism, to be served, supported, treated fairly, and for societal discrimination against them to be addressed and mitigated. Likewise, counsellors support approaches that help all marginalized people to be served and treated fairly and for discrimination against them to be addressed and mitigated. Counsellors agree that addressing historical legacies of discrimination against Indigenous people requires an accurate historical understanding of colonization and its impacts.

At the same time, counsellors are not clear what the reasoning behind the BCACC mandating that all counsellors exclusively train in perpetuity in one area related to Indigenous people with a specific focus on colonization, is, and we request more information. On what precepts is this proposed Standard requirement based? What is the content of the mandated training? Who will pay for the training? What is the reasoning behind mandating the training ongoing and exclusively for one marginalized group to the exclusion of all others? The BCACC have excluded from their mandated educational focus many marginalized and diverse groups in BC, such as Japanese and Doukhobor Canadians who were impacted by the historical legacy of harm they experienced through governmental misuse of power; children and families who currently live in poverty and the need to address this dire circumstance; femicide and the lack of safe, single sex spaces for women; and support for all those who have been affected by the addictions crisis in BC. This list is not exhaustive. Counsellors are working in many fields and serving many populations. Counsellors are unclear what has prompted the BCACC to enforce exclusive, mandated, and ongoing training that may limit counsellor’s capacities to serve the diversity of our patients.

We submit that it is vital that the BCACC and CCPA should demonstrate that they hold equally valuable the protection of human rights and maintain objection to discrimination based on identifiable characteristics, regardless of one’s protected group, such as for the immutable characteristics of sex and age, or such as faith or family status, amongst many examples. If there is to be ongoing, mandated training, then it should be fairly representative of many diverse and marginalized groups in BC.

The BCACC has introduced practitioner liability using broad and ambiguous language to describe obligations of counsellors to undertake “anti-racism” measures and to “[report] acts of racism to leadership, the BCACC and/or the relevant health profession regulatory college.” The BCACC will then take action against counsellors even for “unintentional” acts of discrimination, including for interactions outside of “patient interactions.”

Nowhere are these measures or acts clearly defined. Without such definitions, neither can counsellors understand what specific anti-racism measures they must undertake, nor can BCACC's definition of unintentional racism be avoided. Neither does it seem possible for counsellors to defend themselves against accusations when they do not know what specific practices they are to be accountable to.

Additionally, it appears that under the HPOA, not undertaking the HPOA’s or the proposed Standards' undefined actions, or undertaking the wrong undefined actions unintentionally, may also involve counsellor criminal liability. We believe the BCACC must specifically outline what counsellor duties and obligations are for anti-racism measures and specifically what actions would define a counsellor as engaging in racist or discriminatory practice.

Omissions of Ethical Concern

Part of our concern rests with what is omitted by the proposed Standards. We do not see empirically based assessment and diagnostic protocols. We do not see any mention of the importance of supporting family relationships along with child-centred approaches. We do not see the immense duty of informed consent covered at all rigorously, particularly now that counsellors are involved with life-altering situations such as pharmaceutical and medical transitioning, abortion, and medical assistance in dying.

We believe the proposed Standards should be reviewed by a body of critical thinkers not only for what they contain but for what they miss. This is the only way counsellors can ensure their duty for informed consent and not involve themselves in malpractice. This is a serious concern when counsellors are involved in any aspect of the process of counselling that involves life-altering medical decisions and requirements for informed consent exceed those of typical counselling situations (Levine et al., 2021).

Failure to Comply with BCACC’s Ethical Code of Conduct

Many of the proposed Standards are directly in conflict with the BCACC’s Ethical Code of Conduct (2014), for example, our duties listed in sections (1), (1.5), (1.6), (1.8), (1.9), (1.11), (3.1), (3.6) (4), (4.3), (4.5), (4.7), (4.8), (4.9), and (4.12). The Standards appear to attempt to force counsellors to abandon their duties as scientific and ethical practitioners in favour of prescribed orthodoxy and indoctrination that has no place in a governing College or a therapeutic practice. We have already discussed one extreme example, wherein the BCACC appears to have misrepresented the BC Human Rights Code to exclude an immutable characteristic of identity, and one protected by many human rights codes worldwide. However, there are numerous instances where these proposed Standards conflict with the BCACC’s Ethical Code of Conduct, and we suggest the Standards be held under the scrutiny of a diverse set of reasoners who reflect on the proposed Standards’ interaction with the Ethical Code of Conduct.

Should the BCACC enforce these proposed Standards, counsellors in BC would be unable to fulfill our duties and obligations under the BCACC Ethical Code of Conduct. We suggest that any obligation that counsellors abandon their Ethical Code of Conduct and practice under these proposed Standards would present risks to the public.

Amongst ethical duties, counsellors are obliged under our Ethical Code of Conduct to fulfill our duties as ethical practitioners to protect patients from discriminatory, unfair, or unsafe conditions. We are obliged by our Ethical Code of Conduct to address the problematic and unethical nature of the proposed Standards and the potential for detrimental impacts of the HPOA, which appears to be an Act with destructive potential. If such Standards as the BCACC proposes are enforced by our own College, they would most certainly ensure RCCs could not serve the majority of their diverse BC’s patients in integrity and competence, nor ensure patient autonomy and dignity. Such misguided practice would not only be potentially dishonourable and questionable conduct, it would undoubtedly reflect adversely on the integrity of the counselling profession and undo much of the hard work the BCACC and counsellors have done in trying to establish counselling’s professional legitimacy.

Conclusion

On the grounds of conscience and our commitment to ethical practice and to upholding the integrity and reputation of the field of counselling, we object to both the proposed Standards and counsellor licensing under the HPOA as written. The potential risks of both have not been disclosed to either BCACC counsellors or the public. We believe that the BCACC should pause on licensing efforts while a thorough examination and transparent report is completed.

We call for the proposed Standards to be subjected to a thorough, critical, rational, and transparent revision process. We want assurance that such a process would be directed by a group of what psychologist Steven Pinker (2021) describes as intellectually cooperative but diverse reasoners. We wish to see reputable, respected scientists and scientific practitioners in their fields related to the study of psychology, such as human biology, neurology, and evolutionary psychology take part. We wish to see practitioners who practice traditional psychotherapeutic modalities like Jungian analysis, existentialism, psychodynamic approaches, and other long-standing therapeutic approaches, as well as gold standard treatments like Cognitive Behaviour Therapy. We wish to see medical ethicists take part. We wish to see representatives from diverse racial and ethnic groups including diverse voices of Indigenous people themselves. We wish to see a selection of faith-based representatives. We wish to see representatives of different sexual orientations along with gender identity and expression, sex-based human rights protection representatives, and child protection representatives. We wish to see fair representation of the diverse population of BC. We wish to see proponents of reason and logic. Within such a diverse group, it is less likely critical thinking, reason, and facts of reality itself will be discarded while those creating such governance standards become swept up in a postmodern ethos. This ethos is discriminatory in nature towards any counsellor who practices from a place of care, ethics, science, reason, and accountability, follows their Ethical Code of Conduct, and honors the autonomy of the many diverse patients whom they serve.

We submit that Standards of Practice must reflect ethical, scientific, and proven practice and that extreme ideology has no place in a governing body that represents diverse counsellors and patients. The absence of logic, reason, trustworthy epistemology, and science-based and proven practice has done, and will continue to do harm to the psychological community and to all communities they are in contact with.

We believe it is time for the BCACC and CCPA to pause for sober reflection on the true risks to counsellors under the HPOA. Counselling governing bodies have an ethical duty to do their due diligence, and accurately represent potential risks to counsellors under the Act. We would like to see a critical group of diverse reasoners work together to review all 645 sections of the Act in detail and present its findings to all members and the public.

We further suggest that the entire process of these investigations should be transparent, including the committee selection process, committee representation of diverse groups and specific members, the assessment process and membership feedback inclusion and exclusion criteria used to review the Standards and the HPOA, accountability processes for committee work, and how appropriately representative qualitative reports are created and distributed for wide review of members and the public. All procedural accountability, transparency, and reporting protocols should be created before undertaking these investigations. Investigations and the reporting of results to all members should be completed before proceeding to licensing or creating new proposed Standards.

We look forward to your response.

Sincerely,

Carla Duda, RCC, M. Couns. Psych. Email: dudac2050@gmail.com
W. Paul Erickson, RCC, M. Couns. Psych. Email: paul@wperickson.com

References:

BCACC (2010). B.C. Association of Clinical Counsellors Standard for Informed Consent to Clinical Counselling. Retrieved from https://bcacc.ca/wp-content/uploads/2022/10/1BCACC-Standards-Informed-Consent-2010.pdf

BCACC (2014). BC Association of Clinical Counsellors Code of Ethical Conduct. Retrieved from https://bcacc.ca/wp-content/uploads/2022/10/BCACC-Code-of-Ethical-Conduct-2014.pdf

BCACC (2022). Bill 36 - Health Professions and Occupations Act & Regulation of Clinical Counsellors. Retrieved from https://bcacc.ca/wp-content/uploads/2022/12/Bill-36-HPOA-Regulation-Communique-December-2022-Final.pdf

BCACC (2023). About Us. Retrieved from https://bcacc.ca/about-us/

BCACC (2023). BC Association of Clinical Counsellors Standards of Clinical Practice Draft Version 3. Retrieved from https://www.pivotalresearch.ca/wp-content/uploads/2023/03/BCACC-DRAFT-Standards-of-Clinical-Practice-V3-Feb-2023.pdf

Davidson, G. (2023) CCCA Round Table: Bill 36, Say No to the Health Professions and Occupations Act of British Columbia. Retrieved from https://rumble.com/v2fshfu-against-democracy-bill-36-the-health-professions-and-occupations-act.html and https://drive.google.com/file/d/16kUMDtorKc717v2J8dM5uedBAiQTOqfE/view

Davidson, G. (2023). Say NO to Bill 36 - A slide presentation by Gail Davidson explaining some dangers posed by the BC Health Professions and Occupations Act (Bill 36), 27 March 2023.
https://drive.google.com/file/d/16kUMDtorKc717v2J8dM5uedBAiQTOqfE/view?usp=share_link

Do No Harm (2023). Retrieved from https://donoharmmedicine.org/

Duignan, B. (2023) Postmodernism Philosophy. The Editors of the Encyclopaedia Britannica. Retrieved from https://www.britannica.com/topic/postmodernism-philosophy

Elbers, Nicholas. Catholic Doctors Speak Out Against Bill 36 as a Violation of Conscience Rights. Retrieved from https://bccatholic.ca/news/catholic-van/catholic-doctors-speak-out-against-bill-36-as-a-violation-of-conscience-rights

Health Professions and Occupations Act – Bill 36: 2022 - Health Professions and Occupations Act. Retrieved from https://www.leg.bc.ca/parliamentary-business/legislation-debates-proceedings/42nd-parliament/3rd-session/bills/first-reading/gov36-1

Human Rights Code (2023). Retrieved from https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/00_96210_01

Kissel, A. Universities are Not Colorblind—That’s a Big Problem. Retrieved from https://www.mindingthecampus.org/2023/01/20/universities-are-not-colorblind-thats-a-big-problem/

Kowalksky, B.M. (2022). The Dangers and Delusions of Critical Race Theory. Retrieved from https://c2cjournal.ca/2022/09/the-dangers-and-delusions-of-critical-race-theory

Levine, S.B., Abbruzzese, E. & Mason, J.W. (2022). Reconsidering Informed Consent for Trans-Identified Children, Adolescents, and Young Adults. Journal of Sex & Marital Therapy, 48:7, 706-727, DOI: 10.1080/0092623X.2022.2046221

Obed, N. (2022) We Must Adopt Policies that Require Proof of Indigenous Status and End Self-Identification. Retrieved from https://www.cbc.ca/news/opinion/opinion-indigenous-self-identification-must-end-natan-obed-1.6624157

Pinker, S. (2021). Rationality: What it Is, Why it Seems Scarce, Why it Matters. Penguin.

Randall, D. (2021). Laws Against Critical Race Theory are Only the First Step. National Association of Scholars. Retrieved from https://www.nas.org/blogs/article/laws-against-critical-race-theory-are-only-the-first-step

Sanchez, R. (2021). An Anti-Racism Manifesto. Retrieved from https://www.mindingthecampus.org/2021/05/29/an-anti-antiracism-manifesto/

Wu, W. (2022). Regulatory Capture of Diversity, Equity, and Inclusion in Higher Education. Retrieved from https://www.mindingthecampus.org/2022/03/25/regulatory-capture-of-diversity-equity-and-inclusion-in-higher-education/

Young, W.H. (2015). Academic Social Science and Postmodernism. National Association of Scholars. Retrieved from https://www.nas.org/blogs/article/academic_social_science_and_postmodernism

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