The following elaborations are provided for your use in developing your own feedback:

Board Representation

• Not enough representation of School Psychologist Registrants

• A Licensed School Psychologist may better represent some of our concerns than a Registered Psychologist who has a declared specialty in School Psychology

Dual Roles 

(CPBC states “...some school psychologists may continue to provide services within the scope of another profession or occupation…”)

• Does “some” mean that this will not apply to all? 

• Will CPBC determine who is eligible to work in another profession outside of schools? 

• Does this apply to those working in unregulated areas, such as academic and behavioural intervention (e.g,. tutoring, ASD service providers, etc.)?

• How will this impact those with dual RCC roles who will likely be subject to a window during which they must be regulated by CPBC to retain employment in schools, but are not yet approved as a regulated health profession to maintain their private practice? 

Hybrid/Online Training Programs 

Section 46(5) →  “...grants the registration committee the discretion to consider whether an applicant’s knowledge, skills and abilities are substantially equivalent to the established standards of academic or technical achievement and competencies”

• How will this address the School Psychologist shortage?

• This still does not allow for new hybrid or online training programs, which would support recruitment of new School Psychologists in BC.

• This is likely to exacerbate gaps in service delivery as the lack of clarity will dissuade those considering the profession and those trained abroad from pursuing a career in School Psychology in BC.

Labour Mobility

CPBC states → “Currently, unregulated school psychologists are unable to make application for registration in another province or territory under those labour mobility agreements. Other jurisdictions may consider future eligibility on the basis of the scope and restricted activity statements in the regulation. CPBC cannot direct the decisions of other regulators in other jurisdictions regarding their obligations under these provisions.”

• This goes against the spirit of labour mobility, which requires the organizations to do their best not to create barriers to labour mobility when introducing a “new standard”

• This logic is inconsistent with CPBC’s acceptance of applicants with Master's level training from neighbouring provinces based on labour mobility. It is not just a question of allowing us to function within our areas of competency across our country of residence, but to be provided with a pathway to achieve a wider scope of practice within our province of residence as is permitted to incoming applicants from other jurisdictions. If there is an option to obtain registration elsewhere before returning to BC to apply as a Registered Psychologist within our area of competency, there should be a pathway to do the same without having to uproot your life. Defining such a pathway will be key to protecting and promoting the field of School Psychology in BC.

Pathway to Independent Practice

• We continue to advocate for a clear, reasonable, and achievable pathway to independent practice in our area of competency in community/private settings like what is done in Alberta and Ontario. 

• The CPBC could establish a pathway to independent practice that could allow Master’s level School Psychologist Registrants to work outside school settings in their declared area of competency (i.e., School Psychology/assessment)

Scope of Practice and Restricted Activities as per Psychologists’ Regulation

• How were the changes to the Psychologists Regulation determined? 

• Who was consulted? 

• We plan to advocate for changes

Expedited Registration Date

• Extending the date from August 1 to August 31, 2023 will allow the current University of Calgary cohort time to complete their internship and graduate, facilitating their acceptance into BCASP in time for the expedited transfer to regulation by CPBC

To advocate for the future of the profession of School Psychology in BC, we recommend the following action items:

1. Provide your own individualized feedback to the Ministry of Health and the CPBC by the deadline of March 9, 2023

2. Encourage others’ feedback. If you have previously contacted other interested or affected parties, including other School Psychologists, stakeholders, MLAs, unions, and Registered Psychologists, please reach out again and encourage them to provide feedback by the deadline. 

Contact Information

Ministry of Health, Executive Director Professional Regulation and Oversight 

Email: proregadmin@gov.bc.ca 

College of Psychologists of BC

Email addressed to the Registrar: feedback@collegeofpsychologists.bc.ca 

Ministry of Education

Email: educ.minister@gov.bc.ca 

UBC Proposed Revisions to Proposed Amendments College of Psychology by Laws

Concerns About Proposed Changes

New York bill seeks to license school psychologists to practice outside classrooms