Registered Clinical Counsellors in BC Raise Concerns over the New Health Professions and Occupations Act (HPOA) & Standards of Practice

The rise of postmodern antitherapeutic theories

In May of this year, I published an open letter written by Carla Duda, RCC, M. Couns. Psych., and W. Paul Erickson, RCC, M. Couns. Psych., to the British Columbia Association of Clinical Counsellors and the Canadian Counselling and Psychotherapy Association. Carla and Paul were concerned about the BCACC’s “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.”

Indeed, their concerns stem from the stark reality that the new BCACC standards, which seem designed to push Social Justice doctrine (not improve patient outcomes), are a departure from the traditional practices “bounded by the constraints of strong codes of ethical conduct, rigorous laws, and scientific practice,” and that “appears to be largely replaced by the dictates of postmodern, anti-therapeutic theories.”

Paul and Carla, and a few of their colleagues, are back with an update on the BCACC file. It appears things have been moving in the wrong direction since May, in spite of the well articulated and sensible concerns of Registered Clinical Counsellors in B.C.

James Pew

Registered Clinical Counsellors in BC Raise Concerns over the New Health Professions and Occupations Act (HPOA) & Standards of Practice

November 1, 2023

The British Columbia Association of Clinical Counsellors (BCACC) is moving Registered Clinical Counsellors (RCCs) towards licensing under the Health Practitioners and Occupations Act (HPOA). They have also announced new Standards of Practice effective November 1, 2023. 

Concerned RCCs:

·       Have communicated to the BCACC some potential risks of licensing and ethical issues with the Standards of Practice that will impact both the public and practitioners;

·       Have requested that the BCACC undertake an extensive, rigorous, and transparent investigation of the risks and benefits of licensing under the 645-section HPOA, and convey such risks and benefits thoroughly and accurately to BCACC membership — before proceeding with further licensing efforts; 

·       Have requested that the BCACC Board of Directors not implement the new Standards of Practice, and instead subject them to a substantive critical review through a panel of diverse and representative reasoners;

·       Have requested that the BCACC provide a transparent report to all members on the reasons for announcing new Standards of Practice and a new Ethical Code of Conduct, and details of the process of how they were created;

·       Suggest that the HPOA and new Standards of Practice have created a new counselling paradigm for British Columbian clients and practitioners that risks shifting therapy from a predominantly ideologically neutral practice that equally serves the health needs of all British Columbians, to agenda-driven counselling that risks using therapists and clients for ideological ends.

Concerned RCCs have contacted the BCACC with grave apprehensions related to the HPOA including:

·       Enforcement of non-therapeutic ideologies;

·       Powers of the minister of health, Cabinet, the public health officer and numerous political appointees to arbitrarily force vaccinations of all health practitioners as a condition of licensing and employment;

·       Potential risks to clients;

·       Potential risks to RCCs, if licensed, of criminal charges, fines and imprisonment under the HPOA for overly broad and vague offences that offend principles of legality and predictability and therefore cannot be avoided or defended. 

The BCACC's plan is to give control over the new regulatory college that will govern RCCs to bureaucrats, contractors, or political appointees. These people will implement the Act and impose undemocratically created binding rules, regulations, and bylaws. RCCs support appropriate governance and standards of practice to protect the public, along with enforcement of accountability structures for RCCs, not only to prevent unsafe practice but to appropriately respond to RCCs who would present a danger to the public. Currently the RCC profession maintains an extremely low complaint rate, only half of one percent, and these complaints are mainly related to realities associated with conducting family therapy. RCCs already practice to a high standard of ethics and are therefore concerned that ethical practice will be negatively impacted rather than improved when the new Standards of Practice and HPOA are enforced. 

History:

The counselling profession has been pursuing licensing for its practitioners for many years, in an appropriate attempt to protect the public and advance the interests of the profession. These efforts began when health professionals were licensed under the former Health Professions Act. Under the new HPOA, and in combination with new Standards of Practice by the BCACC, the requirements demanded of counsellors have changed radically and therefore, so has the counselling terrain, politicizing an environment that should remain a safe, politically neutral, and private and confidential place to support all British Columbians equally. 

In May 2023, two RCCs published an Open Letter outlining potential problems associated with the draft Standards of Practice and HPOA. In October 2023, several RCCs co-signed a second letter reinforcing concerns and outlining the actions they want the BCACC to take. RCCs are appealing to the BCACC Executive and Board of Directors to do their duty to protect their approximately 7000-person membership and the public by pausing and undergoing the transparent processes noted in this document’s introduction. To date there has been no substantive response by the BCACC to the many issues raised in either letter. This lack of responsiveness raises some very serious ethical questions about both the process and the direction of this member organization.

After the May publication of the Open Letter to the BCACC, CCPA, and government outlining concerns about both the draft Standards of Practice and Bill 36/the HPOA, the authors sent follow up questions to the BCACC addressing issues of the process and BCACC's lack of transparency. 

Since the publication of the May Open Letter many RCCs have contacted the authors with their concerns and have noted that many have also directly contacted the BCACC and do not believe their concerns have been addressed appropriately. The BCACC has not provided a transparent, accountable response addressing the concerns brought forward by many practitioners.

In July 2023, the BCACC released the finalized, revised set of Standards of Practice and a new Ethical Code of Conduct, with the indication that they would be implemented in November 2023. While several of the egregious ideological requirements had been removed from the Standards of Practice, serious concerns remain about numerous areas that will impact the ethics of counselling. Additionally, the lack of transparency throughout many parts of the process raises concerns of its own.

In July 2023, the BCACC brought Brian Westgate, Director, Strategic Priorities for the BC Provincial Government to an online townhall to discuss the implications of the HPOA. During the townhall meeting, the BCACC failed to address the main concerns raised by many members in advance of the meeting. The unanswered concerns submitted by RCCs were about the ideologically-driven content of the HPOA, risks to clients, and risks to RCCs, if licensed, of criminal charges, fines and imprisonment under the HPOA for overly broad and vague offences that offend principles of legality and predictability and therefore cannot be avoided or defended. 

On October 16, 2023, numerous RCCs signed the aforementioned joint letter to the BCACC board members and executive, the CCPA (with which the BCACC announced a pending partnership), and BC’s Premier and Minister of Health, once again outlining serious concerns with the Standards of Practice and HPOA, and opposition to the BCACC proceeding towards counsellor inclusion under the HPOA before carrying out its responsibilities to address outstanding concerns appropriately and accountably.

Problematic areas of the Standards of Practice remain, including the imperative that counsellors agree to and promote non-therapeutic theories, which risk perpetuating trauma and discrimination rather than contribute to healing, fair treatment, and client-centred therapy. The vagueness of language used in the HPOA directing professionals is subject to abuse, including penalties for spreading "false" or "misleading" information and being held liable for charges of discrimination or racism without clear professional guidelines. Additionally, the intrusion of professional regulations into counsellors' personal lives and personal health decisions is deeply concerning.

Many RCCs suggest that the combination of the new HPOA and Standards of Practice create a threatening practice environment. The new HPOA grants law making powers to the minister of health, Cabinet and many unelected, unaccountable political appointees to create, adopt and enforce rules, bylaws and regulations to prohibit or restrict the right and duty of RCCs to provide individualized, confidential and ethical treatment. 

Requirements under the HPOA and Standards of Practice conflict with the principles of liberal democracy, which include the fair and equal treatment of all humans regardless of their characteristics, equal opportunity, and the protection of individual and human rights. Of equal concern are the potential risks to client confidentiality and privacy under the HPOA, coupled with RCC Standards of Practice indicating that RCCs must “comply with relevant legislation.”  

Concerned RCCs have urged BCACC leadership to consider the principles of liberal democracy when evaluating the Standards of Practice and the HPOA, considering these are fundamental principles that should guide the counselling profession. This includes considering individual rights and freedoms of clients and counsellors and the duty of counsellors to respect the rights of clients and assist, where possible in the protection of those rights when a client is unable to do so. These principles are crucial for protecting human rights, promoting justice, and maintaining equality, non-discrimination, freedom of choice and the dignity of clients. 

By embracing these principles, counsellors can create inclusive, respectful, and growth-oriented therapeutic environments for all residents of the province who may seek counselling.

W. Paul Erickson, RCC

Carla Duda, RCC

Rhonda Marriott, RCC

Christie Harrison, RCC

Michelle Mackness, RCC

David Minor, RCC

Stéphanie Giguère, RCC

Sue Banyard, RCC

Barb Lloyd, CCC

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Thanks for reading. For more on the incursion of Social Justice ideology into the medical industry, read Manichean medicine: patient-saint, patient-sinner

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