The Registrar magazine - Issue 12 - Fall 2024

Issue 12 Fall 2024

MODERNIZING HEALTH REGULATION IN BRITISH COLUMBIA

TRENDING Artificial intelligence in licensing and professional regulation

GLOBAL INSIGHT Ahpra regulates against racism in healthcare

Issue sponsor:

Carin Plischke and Dianne Millette on the historic amalgamation and creation of two new colleges

THE REGULATOR The distinct attributes of regulating nurses in Canada's North

From the Editor's Desk Is it just me, or do we often get so swept up in the busy autumn months that we forget to pause and appreciate the beauty around us? The vibrant colours of the leaves, the refreshing crispness in the air, and that unmistakable pumpkin scent in nearly everything we consume. Meanwhile, our friends in the southern hemisphere are gearing up for summer—and let’s admit it, we’re a little envious!

Issue 12 — Fall 2024 Journalists and Contributors Damian Ali Oluwatoyin Aguda Dean Benard Paul Byrne Collette Deschenes Jayde Fuller M. Daniel Roukema Graphic Designer & Production Manager Allison Wedler Editor in Chief M. Daniel Roukema Photo credits Dean Benard Jayde Fuller Catherine MacIsaac Council for Licensure, Enforcement and Regulation (CLEAR) MDR Strategy Group Ltd. Adobe Stock The Registrar magazine is produced and published by MDR Strategy Group Ltd. 800-1701 Hollis Street Halifax, Nova Scotia Canada B3J 2T9

editor@theregistrar.ca www.theregistrar.ca

We're thrilled to bring you the latest edition of The Registrar Magazine! This issue features insights from regulators around the world. We’re touched that Jayde Fuller in Australia collaborated with us, and thrilled to have had an insightful conversation with Paul Byrne from the Irish Medical Council. Beyond that, there’s advice from our trusted contributor and friend, Dean Benard, and we feature a deep dive into the unique challenges of regulating professionals across two jurisdictions in the North.

It’s conference season, and we tip our hats to the organizers of three incredible regulatory conferences: the Annual Education Conference of the Council on Licensure, Enforcement and Regulation (CLEAR) in Baltimore this past September, the International Association of Medical Regulation Authorities (IAMRA), also held in Baltimore, and the Canadian Network of Agencies of Regulation (CNAR) in Ottawa. Huge congratulations to everyone involved. Your hard work delivered meaningful discussions, learning, and collaboration, and we’re thankful to have been there.

On a personal note, I was touched to accept the Regulatory Excellence Team Award from CLEAR in Baltimore, alongside my amazing colleagues Collette Deschenes and Melissa Peneycad. I’m so proud of the passion and commitment our team brings to the table every day. The impact of their efforts is clearly reflected in the difference we’re making in the licensing and professional regulation sector.

Looking ahead, we’re gearing up for an exciting conference on artificial intelligence, set for Toronto in February 2025. I’d like to see you there! We’re expecting engaging presentations from esteemed speakers around the globe, including experts from the European Union, the Washington Medical Commission, and regulators from across Canada, who will focus on the profound impacts of AI on regulation and how we can protect the public interest in this new age of machine-driven decision-making and problem-solving. You can find more details on this groundbreaking event in this issue.

We hope you enjoy this edition, and as always, thank you.

M. Daniel Roukema

www.mdrstrategy.ca © 2024. All rights reserved 2

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IN THIS ISSUE 5

TRENDING

Assessing the rise of artificial intelligence (AI) in the regulatory sector.

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THE REGULATOR

A tale of four professions in two territories.

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COVER STORY

Meet the two regulatory leaders overseeing a new era of modern health regulation.

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COMMUNICATIONS CORNER

Enhance your regulatory communications by build­ ing trust with stakeholders.

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GLOBAL INSIGHT

Highlighting the Australian Health Practitioner Regulation Agency’s commitment to eliminating racism from healthcare.

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CLEAR BALTIMORE: IN PHOTOS

CLEAR’s AEC in Baltimore and MDR Strategy Group’s award for regulatory excellence.

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INVESTIGATOR INSIGHTS

Dean Benard, President and CEO of Benard + Associates, on investigating illegal practitioners.

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DR 26

THE REGISTRANT

Alycia Hunte on her professional journey in understanding human behaviour.

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MDR BOAT CRUISE: IN PHOTOS

MDR Strategy Group's pre-CNAR conference sunset boat cruise.

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DEI in Trending Regulation

FROM THE INDUSTRIAL TO THE IMAGINATIVE Paul Byrne's deconstruction of AI and its impacts on licensing and professional regulation

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The Registrar

rtificial intelligence (AI) has transformed nuDistinct professional background merous industries by enhancing operational efficiency, driving innovation, and enabling Byrne has helped advance regulatory developments new business models. for several years throughout his storied career. He was In fact, AI was used to craft the introductory sentence first introduced to regulatory environments and developed a fascination for using tech to optimize workflows, above. through his work at the Commission for Regulation of Including AI in workflows has sparked debate. The Utilities (CRU), where he worked multiple roles in custechnology has slowly made its way forward in the tomer complaints, regulatory policy, compliance and regulatory sector, with regulators examining how to investigations. approach its use in operations. Paul Byrne, Executive Director of Regulatory Operations and Support Services at the Irish Medical Council, provides historical and contemporary insight on how AI could be applied in safe, legal, and ethical ways.

Making a big career shift, Byrne decided to work in health. Before moving to his current role at the Irish Medical Council in 2023, he worked as head of registration for three years at CORU, Ireland’s regulator for health and social care professionals. It was an abnormal

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milling technology, which eventually led to craftspeople revolting. The Industrial Revolution also demonstrated a shift in society’s response to integrating technology into [the consumer’s] life, but gradually allowed individuals to be reskilled.”

Paul Byrne, Executive Director, Regulatory Operations & Support Services, Irish Medical Council

“The point of contention with AI is that this shift is happening in just 10 years, which will develop across every segment of society,” Byrne says. “How, then, do we rescale and retrain people to address this? I’m not sure there’s an immediate answer, and, with respect to regulation, our risk is that professionals will have to keep operating with updated skills and expertise in their practise.”

start to his tenure at CORU, as the COVID-19 pandem- Byrne uses the example of COMPAS, or Correctional Offender Management Profiling for Alternative Sancic had just taken the world by storm. tions, a decision support tool used by U.S. courts to de“I came in just 10 days before COVID-19,” Byrne recalls. termine the likelihood of a defendant reoffending, to “Within the first week [at CORU] I had to very quickly highlight the need for careful training of AI platforms reconstitute how we did registration in 18 days, which to ensure objectivity in assessments of individual pronormally takes an unlimited budget and 18 months. files. “It was found, through bias-training data, that it Since then, I brought in new technologies such as SaaS disproportionately biased towards certain ethnicities. to help automate registration processes, a first for a Eu- This impacts people’s lives, and we need to look at these ropean country, and placed a renewed refocus on quali- historical examples so that the same mistakes aren’t rety management and technology.” peated, especially where the stakes are huge.”

Byrne attended University College Dublin in 2023, and earned his diploma, with distinction, in AI. He continues to study the impact of AI on the regulatory sector, having presented at numerous international conferences on the impact of technology on frameworks involving regulation.

Ethical impact of AI

Recently elected President-elect of the Council on Licensure, Enforcement and Regulation (CLEAR), Byrne also Chairs the organization’s Technology and Innovation Task Force. Despite his passion for AI in licensing and regulation, he notes that the rapid pace of AI development has outpaced short-term, solution-focused efforts by those advocating for regulation.

“We need to come up with a higher-level governance Byrne asserts that the rise of AI in recent years is a pow- principle here,” Byrne says. “In my role at the Task Force, erful force and compares it to other key moments in our team will be putting together a high-level approach history when technology significantly impacted society. to using AI, closer to Q4, which is rooted in ethics rath“In the late 18th century, employers brought in cotton er than the technological side of things.”

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A future-friendly technology?

Byrne emphasizes that proper prompting is essential for effective AI use. The main area to address, he adds, is that feeding data to AI platforms must be assessed and applied with the right intentions, so that the platforms can mitigate harms and expedite solutions.

He affirms that it’s so much more about the philosophy than the speed, “this [application of AI in the future] needs to be done iteratively until there’s an actual regulator for AI on a national or global level.”

“The point of contention with AI is that this shift is happening in just 10 years, which will develop across every segment of society.”

- Paul Byrne

Knowing that AI will continue to change how regulators operate, Byrne stresses how important it is to understand how the systems are trained, how data is used, and how data will be audited. While certain standards and methodologies applied to assess data isn’t universal currently, he opines that it’s fundamental to create conversation spaces to discover applicable solutions.

“Sharing information and insights, and creating that sense of community among regulators internationally, will allow us to collect the right knowledge at the table so that informed decisions can be made from a fully dynamic and developed framework.”

Paul Byrne will be one of two in-person keynote speakers at the AI in Licensing and Regulation Conference in Toronto, Canada on February 11, 2025.

Paul Byrne will be one of two in-person keynote speakers at the AI in Licensing and Regulation Conference in Toronto, Canada on February 11, 2025.

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G N I CE M N O E C R P U FE N O C

Global perspectives and local leadership

Industry leaders in AI, government, and the licensing and regulation sector from Canada and abroad will meet in February 2025 to discuss, discover, and determine the impacts and approaches to protecting the public interest in the new era of computer-generated reasoning, decisionmaking and problem-solving.

This critical meeting of Canadian regulatory bodies intends to provide a deeper understanding of AI’s use in regulation and its impact on professional standards, investigations, jurisprudence, communications, and complaints and discipline.

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FEBRUARY 11, 2025 TORONTO

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Contact MDR Strategy Group for sponsorship opportunities or more information.

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October 31, 2024!

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The Regulator

REGULATING NURSING IN THE NORTH CANNN's vision for greater inclusion in public protection and nursing support

T

The Registrar

he Canadian North is a large, remote region, ulations in the north. A dual-mandate regulator, CANcharacterized by towering mountain ranges, NN also serves as the voice of nurses in its jurisdictions. vast boreal forests, icy coastlines along the Arctic Ocean, and the majestic Northern Lights painting The Registrar Magazine spoke with CANNN’s Executhe night sky with vibrant colours. tive Director and Registrar, Megan Wood. A Registered

Nurse raised in Prince Edward Island and now longCommunities are small and dispersed, with many restime resident of NWT, she describes the organizational idents in the region having deep, cultural ties to the land. Integral to the health care system in the Canadian structure, transformation, and vision for the future. north is the College and Association of Nurses of the Northwest Territories and Nunavut (CANNN), whose A tale of four professions in two work is essential in maintaining the well-being of these territories communities across the landscape.

As the regulatory body for nursing in the territories, CANNN is responsible for ensuring that nursing professionals are competent, ethical, and able to meet the health care needs of the diverse and often isolated pop10 THEREGISTRAR.CA

CANNN has undergone several changes over the last four decades, with the organization originally established in 1975 as the Northwest Territories Registered Nurses Association (NWTRNA).

In 1999, the NWTRNA became the regulatory body Establishing a solid foundation and professional association for both the Northwest Territories and Nunavut, before becoming the Registered Nurses Association of Northwest Territories and A name change was one of many new experiences for the organization in recent years, Wood says. After beNunavut (RNANT/NU) in 2004. coming executive director and registrar of CANNN New legislation in 2023 saw the creation of two new in June 2024, she says that adjustments to leadership Nursing Profession Acts: The Nursing Profession Act included updating Board structure and prioritizing Diof N.W.T. and the Nursing Professions Act of Nun- versity, Equity and Inclusion (DEI). avut and was renamed CANNN. The organization now regulates and speaks for Licensed Practical Nurses, “With the amalgamation of four designations, it also Nurse Practitioners, Registered Nurses, and Registered means that we want to bring them into the fold in the new board structure,” Wood says. “It’s a high priority for Psychiatric Nurses.

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Megan Wood, Executive Director and Registrar of CANNN

“Not only are we looking at a person’s scope of practice in two jurisdictions, but there was also a requirement to consider what is included in both Acts for enforcement purposes, when it comes to professional conduct in those jurisdictions.”

- Megan Wood

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me to get LPNs and RPNs and have distinct legislative acts being prestheir voices heard. There is also the ent was an initial challenge once critical cultural aspect to the work CANNN was established. we do, and if we don’t hear the voices of the public that we’re serving, “Not only are we looking at a memthen we’re not making informed ber's scope of practice in two judecisions.” risdictions, but there was also a requirement to consider what is The unique dual mandate structure included in both Acts for enforceof CANNN allows the organization ment purposes, when it comes to to also expand team responsibilities. professional conduct in those jurisShe says that a search is current- dictions,” she reveals. ly underway for a new director of quality practice, to enable CANNN Unlike most Canadian provinces, to handle the volume of associa- the North relies on nurses from othtion-related responsibilities, while er jurisdictions to fill their health also engaging with the public to ef- care needs. Culture shock may take fectively protect the public interest. some from other provinces by surprise Wood emphasizes the need for those coming up north to be Addressing unique well-informed about the landscape, complexities so that their practice can ultimately be successful. “When someone’s Wood notes that the addition of two registered and they want to come new nursing professions and two up here to work, we want to ensure

they are aware of the landscape they’re coming to and ensure they are in-the-know,” she adds.

working on the frontline before this position, it [COVID-19] impacted my fitness to practice and ability to provide care,” Wood says. “Now that The COVID-19 global pandemic re- I’m at CANNN, it’s crucial to focus quired many regulatory authorities on member education, and how well to institute new policies and prac- they are being prepared before they tices for registrants to abide by to walk into a community health cenensure public safety, and CANNN tre with just one nurse responsible was no different. As a member of for the entire population.” one of CANNN’s committees prior to assuming her existing role, Wood Traditional and reflects that the pandemic disruptnew technologies to ed their ability to find nurses due to ommunicate travel restrictions.

Previously working in mental health and addictions recovery, and applying principles of public and cultural safety from past roles, she notes that creating opportunities for learning about the North was crucial. “In my personal experience

CANNN is committed to developing resources for members to stay engaged. This includes the quarterly CANNN newsletter which provides information on organizational activities, trends and issues in the North. Additionally, opportunities "Now that I’m at CANNN, it’s crucial to focus on member education, and how well they are being prepared before they walk into a community health centre with just one nurse responsible for the entire population."

-Megan Wood

CANNN Staff (L-R) - Amelia Manuel, Director of Professional Conduct. Megan Wood, Executive Director and Registrar. Amelie Duval, Deputy Registrar

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such as becoming National Council Licensure Exam- out that radio is just as integral to communicate. ination (NCLEX) RN writers and reviewers, enable registrants to contribute to their profession beyond their “One of the unique parts about being in the North is that a lot of small, underserved communities don’t have clinical roles. bandwidth, with a large amount of information being NCLEX tests the competency of nursing school gradu- distributed by radio,” she reveals. “A big part of modernization at CANNN specifically, is making sure that ates in the U.S. and Canada. if something noteworthy or important is going on, we It's a key component of CANNN’s modernization efforts, air it on the public radio station while being creative and Wood says that it’s important to have those work- and asking listeners for feedback or suggestions on what ing in the North to have a better lens of both territories. they want to hear.”

Critical to the organization’s communication strategy is keeping members engaged with its media platforms.

Ambitions of becoming a leader in She adds that member education on areas like fees, for nursing regulation example, will demonstrate how certain standards contribute to a sustainable practise in both territories.

Despite having a small number of staff having to cover “Part of our communications-focused work will be to a large portfolio of work in four different nursing prostart getting more members engaged,” she explains. fessions, Wood is positive that CANNN is equipped to “It’s important for nurses to know what to expect in the stay on top of new developments and establish itself as north when working at CANNN, but also bring more a prominent regulatory leader in the field. members, volunteers and more eyes. This ultimately drives more public awareness, especially in nursing, “I’m most excited about bringing us to the forefront of where changes in healthcare, technology, and societal the sector, and ensuring that education for the public is needs can significantly affect professional practice and just as engaging as education for our members,” Wood standards.” says. “CANNN is here as a resource to help nurses, and bringing awareness to who we are as an organization in While CANNN is active on social media platforms like this particular location will allow us to become a reguFacebook, LinkedIn, X, and Instagram, Wood points latory leader in this space.”

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Cover Story

PROTECTING THE PUBLIC THROUGH MODERNIZED HEALTH REGULATION Through the lens of B.C.’s new regulatory college leaders

M

odernizing licensing and professional regulation has been at the forefront of the health sector in recent years. Regulators are continually adopting new practices to update operations, streamline registration processes and enhance public safety, all to better fulfill their public protection mandate.

The Registrar

tablished by amalgamating several legacy regulatory colleges, with the goal of strengthening transparency and accountability within health profession regulation.

The Registrar Magazine spoke with the leaders of these two new colleges: Registrar & CEO of the College of Health and Care Professionals of B.C. (CHCPBC), Dianne British Columbia has long led the Millette, and Registrar & CEO of modernization of regulation in Can- the College of Complementary ada, with many regulatory colleges Health Professionals of B.C. (CCHrevising their practices. On June PBC), Carin Plischke. Both respect28, 2024, two new colleges were es- ed leaders with decades of experi-

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ence in the sector discussed how the new colleges were created, and what the public can expect in this new era of modern health regulation.

Years in the making The idea of amalgamating multiple health regulators in B.C. into two separate colleges was part of an exhaustive process years in the making. In 2018, B.C.’s Ministry of Health (MOH) began a multi-year initiative to modernize regulatory frameworks ensuring health profes-

Cover Story CCHPBC Ambassadors Group: Volunteers came together to welcome staff to the new office space and help them navigate it

CHCPBC Coast Salish blanketing ceremony

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Cover Story In a priority setting session, the CCHPBC leadership team identified areas that will be the College’s main focus for the upcoming 6-8 months.

sions were regulated more consistently.

In March 2019, an inquiry into the College of Dental Surgeons of British Columbia was spearheaded by the Ministry. Harry Cayton was directed to do the investigation by the minister, eventually leading to amalgamation being legislated.

Committee on Modernization of Health Professional Regulation issued recommendations to update the province’s health professions regulatory framework.

Significant findings from the Cayton report and public consultations highlighted the need for health profession regulators to:

“Voluntary amalgamations weren’t new, such as when the College of Registered Nurses of British Columbia amalgamated with two other nursing professions a year prior, before inevitably amalgamating with the midwifery profession,” Millette says. “Our colleges’ particular amalgamation, however, were mandatory.”

• Commit to cultural safety and humility • Improve governance • Improve efficiency by reducing the number of regulatory colleges from 20 to six • Strengthen oversight • Simplify complaints and discipline processes • Share information to improve patient safety and public trust

Plischke, the former registrar, CEO, and previous board member of the now-defunct College of Occupational Therapists of B.C., recalls that the pre-planning phase of amalgamation was meticulous.

“Going to numerous events and hearing about the vision for modernizing health regulation, pre-COVID-19, was inspiring,” she says.

In August 2020, the MOH-led Steering 18 THEREGISTRAR.CA

As a result, in April 2023, the Deputy Minister sent a letter to the boards of each legacy regulatory bodies announcing that two colleges —one overseeing seven professions and the other four— were to be established in June 2024. Alan Seckel was appointed by the ministry as the amalgamation lead to support boards

of the transition.

In 2024, months of hard work came to fruition with the names of both colleges confirmed and Dianne and Carin appointed registrars and CEOs in February. Boards for both colleges were appointed in March, with consultations on required bylaws running from April until early

Timeline of the multi-year initiative to amalgamate multiple provincial health regulators

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Cover Story

during the transition. In September 2023, Seckel appointed Joanie Bouchard, former registrar of the College of Dietitians of British Columbia, as chief transition officer. Bouchard worked with a project consultant team and some staff from the amalgamating colleges to develop project charters and assist with various aspects

Cover Story

June before the CHCPBC and CCHPBC were legally amalgamated and formally opened on June 28.

safety, humility and anti-racism,” Plischke says.

Measuring public impact

Millette explains that her passion in the new position stems from a deep interest in licensing and professional regulation. With over 20 years of experience in regula- A key area of focus for Millette and Plischke is culturtory roles in both Canada and the U.S., she saw leading al safety, humility, and anti-racism, where each college the CHCPBC as a rare opportunity. “I really saw this prioritizes eliminating racism from policies, while acas a once-in-a-lifetime opportunity” she says. “To lead tively working to create conditions that promote greater an organization like this was an unprecedented oppor- inclusion, equality and justice. tunity, being committed to public service and safety as long as I have.”

“We’ve established an office for social accountability, Plischke echoes a similar sentiment, explaining that her enthusiasm for role stems from the opportunity to collaborate more directly with other health regulators.

“We typically don’t work in isolation within this sector,” Plischke notes. “The delivery of safe health services from licensees presents a unique opportunity to show how team-based care can be done through consistent, enhanced collaboration.”

which embeds diversity, equity, inclusion (DEI), decolonization and justice principles into our work,” Millette says. “Our relationships with Indigenous Elders and Knowledge Keepers ensure board activities remain aligned with Truth and Reconciliation efforts already established by legacy regulators pre-amalgamation, such as territorial acknowledgements and approving guidelines for working with Indigenous Elders.”

Both Millette and Plischke sit on the Executive Committee of B.C. Health Regulators, which brings togethPrioritizing the public er B.C.’s health regulatory colleges to collaborate on improving regulation and regulatory practice across When it comes to governance, both Millette and their organizations. Plischke highlights that this colPlischke emphasize the importance of having a bal- laboration is crucial, so that mechanisms can be shared anced split of members of the public and regulated pro- that will help to eliminate racism and discriminatory behaviours from the health care system to improve pafessionals on the boards of both colleges.

“Our college’s board involves fifty per cent public members, with the other fifty per cent coming from legacy colleges,” Millette says. “Public service will be the main objective of our board and committees, instead of representation, as profession-specific expertise is embedded in our staff and committees.”

Plischke says that fifty per cent public representation on the board allows regulators to create new methods of fulfilling their public protection mandate. “As we continue building out our operations and outreach, our goal is to eventually have a governing board of directors, along with fulfilling our commitments to cultural 20 THEREGISTRAR.CA

CCHPBC employees participated in a fun scavenger hunt activity to celebrate a successful amalgamation and to acquaint them with their new office and its location.

Cover Story

The vision ahead CHCPBC is an amalgamation of seven legacy colleges and regulates nine professions, with one legacy college regulating three distinct professions. Millette notes that this raises several important questions that CHCPBC is eager to address.

“First, how does the regulator hear from the various publics that are CHCPBC Registrar & CEO, Dianne Millette being served? It’s fine to have pub- CCHPBC Registrar & CEO, Carin Plischke lic representation on our board, but tient care and ultimately achieve to hear from the broader public, it’s safety.” public safety. important to learn from our international colleagues who’ve overseen With new legislation - the Health Millette explains that collecting multi-disciplinary jurisdictions for Professions and Occupations Act registrant data will be crucial for a long time. The other important set to come into force in 2025, both CHCPBC moving forward. Draw- task ahead is to find a way of re- Millette and Plischke are thrilled ing on her experience supporting sponding to compliments, instead to continue supporting licensees in the development of Ontario’s Col- of just concerns. We have a lot to transitioning to the requirements of lege Performance Measurement learn from people who just want to this new Act. Plischke emphasizes Framework (CPMF), she notes that share an experience, good or bad, as the evolving importance of demonCHCPBC is collaborating with the this is crucial for modernization ef- strating how well multi-disciplinary Canadian Institute for Health In- forts.” regulators can work under one formation to identify what’s approframework with measurable outpriate and ethical to collect, and Ultimately, Plischke’s vision as reg- comes, a perspective Millette shares. how data will be integrated into istrar & CEO is to have a multi-disregulatory standards and processes. ciplinary, team-based health care “There’s a lot of work to be done.

“We’re aiming to become more informed about our registrant population as a start, so that we can ensure that we’re both inclusive of those working across these various health professions and able to measure impact down the line,” she says. “Once we get through the initial phase of harmonizing our processes, the next step will be to really assess the measurements of those outcomes,” she adds.

regulator that supports a mandate of ensuring health professionals practise in a way that is safe for the public. “It’s really about decreasing confusion for the public and being efficient in the little, but important things,” she says. “For example, how do we get consent to provide services? As a modern regulator, I’m excited about CCHPBC demonstrating leadership in this area, which inevitably encourages public

However, the future is bright and, in time, we will demonstrate to the public what is possible with modern health regulation,” Millette concludes.

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Communications Corner

IS YOUR COMMUNICATION BUILDING TRUST OR CREATING BARRIERS? Kindness in regulatory communications

I

Collette Deschenes

magine you’ve missed the deadline for your annual renewal with a regulatory body.

You receive an email informing you and the tone of the communication is severe, filled with jargon.

Collette Deschenes, Director, Communications Strategy, MDR Strategy Group

Now imagine the same scenario except you receive the notification written in plain language, with an understanding tone, clearly outlining the steps you need to take to remedy the situation.

The difference in your response was

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likely significant. The first scenario, receiving a communication with a stern tone, may leave you anxious and defensive. The second scenario likely leaves you feeling more supported and compelled to address the situation.

This is one of many examples highlighting how regulatory communications can either build bridges or create barriers. The language, voice and tone we use can help cultivate a sense of support, openness, trust

and transparency. On the other hand, it can create logue with stakeholders – one that helps build trust and evoke the opposite reaction and lead to negative per- strengthens relationships over time. ceptions of the regulator.

Know your stakeholders

Review your organization’s voice and tone

As a communications professional, one of the first things that comes up when crafting messaging that helps to build bridges is the principle of “knowing your audience.” This has been ingrained in me since my days in public relations school where they consistently emphasized this critical part of PR practice.

As we review communications, we closely examine the voice and tone of a regulatory body’s communication to identify any inconsistencies and ensure alignment with its mission, vision, and values. This review also helps to ensure the voice and tone is approachable, supportive and reflects kindness.

Within the context of regulatory communications, and particularly when we talk about kindness in your organization’s communications, we often need to think beyond target audiences. We’re typically communicating with individuals and groups who have a vested interest in and varying levels of influence over the regulator’s decisions, changes and policies. In this case, we want to “know your stakeholders.”

First, consider this: Does your organization have a cohesive voice? Your voice should be consistent across all communication and should align with your mission, vision, and values. For example, if your organization values transparency, your voice should always reflect this by being open and clear. This means that your communication will provide accessible information without jargon and aim to ensure that stakeholders understand your organization’s decisions, initiatives and policies.

This starts with identifying your stakeholders but it’s critical to go deeper. Recognize that each group and individual will have their own perceptions and relationships with your organization. Aim to understand what they care about and what challenges they may be facing.

Our team frequently supports regulatory bodies by auditing the organization’s communication using our regulatory lens and expertise. We thoroughly examine all communications and engage comprehensively with stakeholders to understand their needs and identify any gaps or challenges.

Your tone adjusts based on the context of the communication. For example, the tone of a professional conduct communication will vary from a social media post highlighting your organization’s latest newsletter. Regardless of the context, the tone should convey a commitment to helping stakeholders, like registrants, navigate their responsibilities and challenges.

So how can you ensure your organization’s voice remains consistent, that the tone adapts appropriately, and that they both reflect kindness and empathy? AfThe audit is a foundational step as it provides crucial ter reviewing your organization’s communication and insights into stakeholder perceptions. This understand- identifying gaps or inconsistencies, decide on the key ing is typically the starting point for ensuring that the characteristics of your voice. Use those characteristics regulator’s communication is strategic, aligned with to develop voice and tone guidelines to apply across all their mandate and reflects kindness. communications.

But this isn’t a one-time engagement effort. We also Remember that trust is built not only through what we provide recommendations that encourage ongoing dia- say but also how we say it. How you communicate will

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either reinforce trust and build re- Are you ready to enhance your regulatory communications? lationships with stakeholders or create barriers that can lead to confu- MDR’s regulatory communications expertise can support sion, frustration or disengagement. your organization in building trust, improving stakeholder

relationships, and achieving your communication goals.

Identifying stakeholder communication needs and creating consistent Join other regulators who choose the MDR solution to voice and tone principles are just deliver their messages with meaning and purpose. two actionable ways to shift to kind, connection-driven communication.

As you know, this shift takes time. It requires alignment and agreement on a unified approach across the organization. It’s never a one-time efwww.mdrstrategy.ca fort but it’s an effort that reinforces your organization’s commitment to regulatory excellence, continuous improvement and most of all, kindness.

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SMART SOLUTIONS FOR REGULATORS

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Global Insight

AUSTRALIA IS REGULATING AGAINST RACISM IN HEALTHCARE Jayde Fuller, National Director, Australian Health Practitioner Regulation Agency (Ahpra)

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public, by selecting which communities are worthy of protection and safety and ignoring or failing to take action to protect or redress harm to those who aren’t.

This serves to maintain the status quo by upholding power within non-Indigenous structures, systems and stakeholders.

White supremacy culture poses a threat to our regulatory remit of protecting the

I work at the Australian Health Practitioner Regulation Agency (Ahpra) in partnership with the National Boards and accreditation authorities, and we’ve gone against the tide of white supremacy culture by remaining committed to eliminating racism from healthcare for

lobally, there’s been an escalation of white supremacy culture which seeks to silence dialogue and discredit thought leadership around racism, diversity, equity and inclusion.

Jayde Fuller, National Director, Australian Health Practitioner Regulation Agency (Ahpra)

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Aboriginal and Torres Strait Islander Peoples.

The Australian context Australia has a total population of 25.69 million people, with the total Indigenous population accounting for 3.8%, just under 1 million people, drawn from 500 separate nations with different languages and histories.

There are two distinctly separate First Nations groups in Australia, Aboriginal people who inhabit the mainland and Torres Strait Islander people who are custodians of the chain of islands in the Torres Strait region which is positioned between the state of Queensland and Papua New Guinea.

We have occupied Australia for 65,000 years, and have one of the longest, continuing cultures in the world. The country was colonised by the English 254 years ago.

Colonisation in Australia was justified by the false legal status of ‘terra nullius’ meaning ‘nobody’s land’ in Latin justifying claims that territory may be acquired by a state's occupation. The history of colonisation included seizure of land, massacres, removal of children from their families, displacement from tribal lands onto reservations, unpaid labour known today as Stolen Wages of which many hospitals and health infrastructure was built from, assimilation, and more recently reconciliation.

average 10 years less than the non-Indigenous population, have higher suicide rates and are impacted by a higher burden of disease in relation to mental health, cardiac-related and chronic disease. The population is largely a younger one with a significant proportion being under 29 years old.

On October 14th 2023, we had a referendum in Australia seeking to establish an Indigenous voice to Parliament to be enshrined into our constitution, a mechanism that would allow Indigenous Peoples to advise the government on matters that affect us.

60% of Australians voted against this "Although progressing cultural and the state I reside in of Queensland, safety and anti-racism work had the highest ‘no’ vote of all the states is a challenging space to be and territories in the country. in, you need to understand that this work is life-long and

Resulting in a resounding message to must be self-determined by Aboriginal and Torres Strait Islander us as Indigenous Peoples. " Peoples that we are not viewed by the – Jayde Fuller majority of Australians as valuable citizens who should be able to have a say over decisions that impact our lives. Racism is inherently about power within society—wielded collectively by those who have it - against those who don’t.

Faced with these results, how could one not accept that Australia is indeed a racist country?

In 2020, we released the National Scheme’s Aboriginal and Torres Strait Islander Health and Cultural Safety Strategy 2020-2025 – which set the strategic and operational priorities to move us towards the elimination of racism.

Aboriginal men and women live on

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The most impactful actions in this strategy can be broadly categorised under the following verbs - define, legislate, educate, participate and govern.

Define: language matters In 2019, we standardized the definition of ‘cultural safety’ through a six-week community consultation which was decided upon by the Aboriginal and Torres Strait Islander Health Strategy Group and peak Indigenous body the National Health Leadership Forum.

Having a common, cross-profession (we regulate 16 health professions), definition aligned with our core purpose as a regulator of patient safety and asserts that cultural safety is self-determined by Aboriginal and Torres Strait Islander Peoples, families and communities.

Working in partnership with our National Boards and accreditation authorities, it allowed us to change practitioner’s codes of conduct and accreditation standards at scale and pace, driving accountability around cultural safety to measure performance using a number of regulatory mechanisms.

Legislate: landmark decision

Jayde Fuller, National Director, Australian Health Practitioner Regulation Agency (Ahpra)

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Leveraging off the definition, in October 2022, we passed the expectation of it into law in relation to service provision, access and workforce capability. This time explicitly mentioning through the guiding principle that the workforce needs to ‘contribute to the elimination of racism.’ It was the first time the word ‘racism’ has been featured in healthcare legislation in Australia.

We’re now able to hold practitioner’s accountable at tribunal for the most serious misconduct relating to racism against Indigenous health consumers and practitioners.

This includes practitioners experiencing racism from other practitioners.

Medical Board of Australia vs CDA – landmark decision

Last year, we had a landmark tribunal decision on anti-Indigenous racism made in the medical profession - resulting in a non-Indigenous doctor’s behaviour being constituted as professional misconduct.

He was prohibited from providing any health service and cannot apply for registration for 12 months.

A racially offensive email was sent to Prof Rallah-Baker, former Australian Indigenous Doctors Association and highly respected, Yuggera, Warangoo and Wiradjuri ophthalmologist. The Tribunal found that he was treated less favourably than other persons because of his racial background and had the potential to bring the medical profession into disrepute.

The Chair of the National Medical Board, Dr Anne Tonkin said, ‘this ruling is a clear message that racist and culturally unsafe practice and behaviour is unlawful and carries substantive penalties, including disqualification from registration.’

Educate: how to practice cultural safety Between 2021 and 2023, an Indigenous owned consultancy PricewaterhouseCoopers Indigenous Consulting delivered Moongmoong-gak cultural safety training to almost 1,800 Board, committee

and staff members. This education program was the first of its kind globally for health regulators and aimed to really plant the seeds of what culturally safe practice means for regulatory administrators – the start of a lifelong commitment.

It sets an important precedent that we’re willing and able of practicing what we preach in requiring ongoing learning in culturally safe practice for Aboriginal and Torres Strait Islander Peoples. In the near future, it’s very likely we will expect all practitioners to commit to learning on cultural safety throughout their learning and practice years.

Importantly, it also begins the unlearning process, challenging the lies and preconceptions of who we are as Indigenous Peoples – the ideologies developed and reinforced through the colonial project. This directly impacts how we’re treated.

duct or racism in the workplace.

In 2021, we established the Aboriginal and Torres Strait Islander Health Strategy Unit (HSU) and it’s 100% Indigenous led and staffed.

We also established an Aboriginal & Torres Strait Islander Support and Engagement Team (Indigenous registrations) who assist Indigenous practitioners with registration and broader workforce issues.

They’re a front door to Ahpra, often the first contact. They help to redirect practitioners to the right place in the agency in a responsive way.

Importantly, we've increased our representation on Boards and committees.

Govern: selfdetermination in action Culturally safe regulatory decision-

Participate: representation matters Having an Indigenous employment strategy has been critical for us and has increased the level of participation of Aboriginal and Torres Strait Islander Peoples in Ahpra. However, more work needs to done with the agency still needing to improve its understanding of what attracts us to work in regulation, the nuance of Indigenous recruitment, how to retain us and address unsafe con-

making

Changes to governance structures that places us at the centre, in a self-determining way is most evident in the larger reform project deliverables of the Culturally Safe Notifications Project and the Culturally Safe Accreditation and Continuing Professional Development Project. Both projects are informed by working groups comprised of Aboriginal and Torres Strait Islander health practitioners, leaders and community members.

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accreditation framework and strategy for all the practitioners we regulate.

We hired Weenthunga Health Network to deliver the project milestones, a Victorian based Aboriginal and Torres Strait Islander owned and run organisation, that supports the upholding of health sovereignty and progressing health justice.

It's a big paradigm shift for non-Indigenous allies to give up power in regulatory spaces, and accept that just because it's their way of doing business, it's not the only way of doing business, and to trust we are fully capable of achieving meaningful change if we're supported to lead.

Jayde Fuller, Ahpra (left), Kym Ayscough, Ahpra (centre), Linda Renouf, Medical Board of Australia, (right)

We’ve successfully established a medical and nursing and midwifery regulatory decision-making committees comprised of Aboriginal and Torres Strait Islander Peoples who decide on whether to take regulatory action on all matters that involve an Indigenous person.

Another key project milestone has been the recruitment of the Aboriginal and Torres Strait Islander Peoples to support Indigenous complainants through the process and to provide cultural advice to investigators.

We know that collecting data is important for quality improvement and measuring cultural safety effectiveness – we engaged Yardhura Walani an Indigenous led and governed research centre at the Australian National University to undertake focus groups with Aboriginal and Torres Strait Islander Peoples who've gone through our complaints process.

Cultural Safety Accreditation and Continuing Professional Development Project

In regulation, ideally we’d like to prevent harm from occurring. In taking a preventative lens, we've committed to develop a sector-wide national cultural safety and

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Although progressing cultural safety and anti-racism work is a challenging space to be in, you need to understand that this work is life-long and must be self-determined by us as Indigenous Peoples. We’ve had enough of being told by non-Indigenous Peoples how we can be ‘fixed.’ I urge you to appreciate that trust and relationship building with Indigenous Peoples will take time and you’ll inevitably get it wrong, but if you respond with humility and you take the time to critically self-reflect on your discomfort, this will set you up for success as you embark on your anti-racism regulatory journey.

Click here to find out more about the National Scheme’s Aboriginal and Torres Strait Islander Health and Cultural Safety Strategy.

This article is a contribution from Jayde Fuller, National Director, Aboriginal and Torres Strait Islander Health Strategy Unit Strategy, Policy and Health Workforce from the Australian Health Practitioner Regulation Agency (Ahpra).

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Investigator Insights

INVESTIGATING ILLEGAL PRACTITIONERS: STRATEGIES, CHALLENGES, AND INSIGHTS Understanding the issue

Dean Benard, President and CEO Benard + Associates

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llegal practitioners are individuals who offer professional services without the necessary licenses or credentials, posing significant risks to public safety.

Dean Benard, President and CEO, Benard + Associates

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equate healthcare, physical harm, financial exploitation, and substandard construction that poses public risk. Illegal practitioners not only endanger public safety but also undermine trust in the professions These unlicensed professionals op- they impersonate. They often prey erate across various fields, including on the most vulnerable segments of a multitude of healthcare profes- society, including new immigrants, sions, law, engineering, social work, economically disadvantaged groups, and the list goes on. They will em- and those who may not have the ploy a variety of deceptive tactics knowledge or resources to verify the to avoid detection. Most will use credentials of their providers. occupational titles such as “doctor,” “lawyer,” or “psychologist,” which are Investigation challenges interpreted by the public as a sign of special expertise or qualification.

These cases can pose many chalThe consequences of illegal practice lenges and investigators need to can be severe, ranging from inad- think carefully about the approach

they take, not only to get the evidence, but to avoid sue, but not until that illegal practitioner provided making the challenge greater by alerting the subject “care” to hundreds of people over two years, shockingly they are being watched. without being detected.

Illegal practitioners often exploit community ties or create complicit networks that make it difficult to detect their activities. For example, some illegal practitioners operate exclusively within their ethnic communities or rely on personal referrals, which reduces their exposure to the authorities. In one case, an unlicensed dentist was able to operate for an extended period by only accepting clients through community referrals, thereby avoiding detection. These scenarios can lead to non-cooperation as witnesses, employers, or community members may be unwilling to cooperate, due to fear of repercussions or legal implications, or even because they want to protect the practitioner because, like it or not, it is all they (individual or community) have available.

Finding where an illegal practitioner is operating can be difficult, especially when they are mobile or working across multiple jurisdictions. In another instance, a woman with revoked nursing registration forged documents to gain registration / licensure in multiple jurisdictions, demonstrating the lengths to which some of these fraudsters will go, to bypass regulations. So now we are investigating a person who is practicing illegally but appears to be legal and hops for province to province and even other countries to keep going, trying to stay one step ahead of the investigator, who might not have the authority to investigate in all jurisdictions.

This means regulators must work cooperatively and share information, as well as involve other agencies including immigration and the police.

Some illegal practitioners are hiding in plain sight, by making use of fabricated references, fake backgrounds, or identity theft. I once investigated an illegal practitioner who assumed the identity of her dead sister and openly practiced as a nurse in a hospital with no nursing education whatsoever. It was by pure luck, that a distant friend of the deceased sister discovered the is-

Investigative tactics and strategies The investigation of illegal practitioners requires a creative and multifaceted approach. The goal is to obtain evidence that shows the individual is engaged in one or all the following behaviours: • Holding themselves out as qualified to practice.

• Using a protected title or designation.

• Performing acts restricted to licensed professionals.

Evidence can be gathered from documentation such as advertising, client files, or human resources records. Interviews with coworkers, employers, and clients, as well as surveillance and undercover operations, are also a key component to the evidence gathering process.

Additional strategies involve: • Following suspects and observing their activities.

• Engaging suspects by requesting their services.

• Infiltrating agencies where the suspect may be working.

• Other tactics we won’t share in this article, to keep what little tactical advantage we can.

The extent of undercover operations can be significant.

In one case several years ago one of our investigators (the author) posed as a tourist to catch a healthcare provider practicing in a small tourist community in northern Ontario. This involved staging an accident so locals would bring the investigator to the practitioner for treatment. This allowed the investigator to obtain firsthand evidence, which was captured on hidden audio and video recorders. Had the investigator just showed up looking for treatment, it would have been highly suspicious.

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Legal considerations and prevention The options available to combat illegal practice include cease and desist orders, criminal or quasi-criminal prosecution, and injunctions (civil court orders). Cooperation agreements, like memorandums of understanding (MOUs), can facilitate information sharing and resource allocation across jurisdictions and between agencies, but this is also surprisingly challenging in many cases.

Prevention strategies focus on making it harder for illegal practitioners to operate. This includes moving away from physical licensure cards (forcing online verification instead), educating prospective employers, and publicizing the identities of known offenders through press releases following successful prosecutions or civil injunctions.

Many regulators are assertive in this regard and creating greater public awareness. However, despite these efforts the problem runs deep and rooting out these bad actors will take an extreme level of effort, which arguably most regulators are not resourced enough to undertake.

To address the investigative challenges, investigators So, prevention efforts and reactive investigations when may need to exercise the powers available to them, illegal practitioners are identified through complaints, such as obtaining search warrants (not always easy to remains the primary approach to managing this probdo) or leveraging the influence of other agencies (e.g., lem. insurance companies, or public health organizations).

Appealing to employers’ sense of morality or reassuring Another consideration is the fact that despite prosecuthem about their legal standing can also help gain co- tion or court orders, these illegal practitioners must be monitored to ensure they don’t start practicing again. operation.

To determine where an illegal practitioner might be working, investigators might use pretext calls, surveillance, social media searches, determining the geo-tagging of photographs can also help identify the location of suspects. It is a range of approaches that must be employed to complete these investigations successfully.

This article is not meant to explore these strategies at length, as some level of discretion is important, so our tactics are not widely known.

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The need for vigilance and cooperation Investigating illegal practitioners requires persistence, creativity, and strategic collaboration between regulatory bodies, communities, and law enforcement.

Successful investigations depend on a combination of innovative tactics and the ability to adapt to evolving challenges. Public awareness and engagement are also

critical in safeguarding against these fraudulent activities, making it essential for everyone to stay informed and vigilant.

Case study • A person (later identified as having some experience as a veterinary assistant) is reported to be advertising a mobile service where they can come to peoples’ homes and spay or neuter people’s cats and dogs • This person advertises within a narrow community in in their native language • When this is reported and the advertisement is examined, searches of public registers in several provinces is undertaken, and the person in question is not registered as a veterinarian • A translator is engaged and given a script to engage the person by phone (call recorded). The script conveys that she operates a daycare in her home and can’t have him to her home to spay her cat… she asks if she can bring the cat to him • The illegal practitioner agrees and offers the service and advises of his home address, the cost of the service, and a date and time to attend • The investigator arrives at the home of the illegal practitioner and says his mother will arrive with the cat in five minutes • A prearranged call is made to the investigator that he answers in the presence of the subject. The investigator reports to the illegal practitioner that his mother was in a minor car accident and won’t be able to attend • The investigator asks if they can reschedule and offers to pay half the 200-dollar fee now and the rest when they return another day • All of this is captured on an audio recording • While at the home the investigator gathers photographic evidence of the coffee table which is set up as an operating table with scalpels, retractors etc.

• All this information is used to apply for

a search warrant, which is granted • On the date scheduled to return with the cat*, the investigator brings the police to keep the peace and safety, and executes the warrant, gathering all the evidence needed to prosecute the illegal practitioner • There was no sterilization equipment on site and some instruments had stains on them • The illegal practitioner was charged under the Veterinary Act and was also brought to civil court, where an injunction (court order) was obtained ordering him to cease and desist *No cats or any animals were involved or harmed in the investigation ☺

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The Registrant

FROM RECE TO RP: THE INTERSECTION OF HUMAN BEHAVIOUR IN TWO DIFFERENT CAREERS Meet one of the College of Registered Psychotherapists of Ontario’s newest registrants

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The Registrar lycia Hunte's journey from early childhood ed- gig became a quarter-century-long professional metaucator to registered psychotherapist has been morphosis. an evolving journey of a passion for under-

standing human behaviour.

A resident of the Ottawa region, Hunte was born in Montreal and spent her adolescent years in Toronto.

Her career began unexpectedly when she took a tem- Now, a mother of two, she worked worked at several porary role in childcare while her then-husband tran- childcare centres over the years, gaining experience sitioned to a new career. What started as a short-term 38 THEREGISTRAR.CA

with various age groups and refining her ability to sup-

Alycia Hunte, former Registered Early Childhood Educator, now Registered Psychotherapist

port children’s emotional and developmental growth, psychology and desire to work more closely with indiin addition to teaching. Eventually, she transitioned to viduals on an emotional level led her to pursue a career home childcare, taking on a supervisory role where she in psychotherapy. focused on policy compliance and provided guidance "The part I enjoyed most in my previous roles was into other childcare providers. teracting with people, learning about their lives, and Despite the rewards of her role, Hunte found that the helping them navigate their challenges,” Hunte reflects. growing administrative responsibilities began to over- Moving into therapy felt like a continuation of that shadow the aspects of the job she enjoyed most: in- journey.” teracting with children and families. Her passion for

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a stage that she describes has a tremendous impact. "This phase seems to be a turning point for many women,” she says.

“It’s a pivotal time in their lives as they start coming to terms with what they Registered with the College of Psy- want to do next. They’ve gone through chotherapists of Ontario (CRPO) since their youth and now want to shift toMarch 2022, Hunte completed her wards healthier choices."

Counselling Psychology Masters from Yorkville University in November 2022, She observes that it’s an interesting dyholding the title of (RP Qualifying). In namic with men who are less frequent April 2024, she became a fully licenced clients in her practice. "When men do Registered Psychotherapist (RP) with seek therapy with me, it's often because "The part I enjoyed most in my the CRPO. In practice in downtown Ot- they have a strong relationship with previous roles was interacting tawa, Hunte sees a range of clients, in- their mother, which makes them more with people, learning about cluding children, adolescents, and adults. comfortable talking to a woman, or they their lives, and helping them She explains that working with chil- feel uneasy discussing their issues with a navigate their challenges,” dren, particularly those aged seven to fellow man. There's often a hesitation to Hunte reflects. Moving ten, presents unique challenges as they open up in therapy. Even male colleagues into therapy felt like a navigate important developmental tran- in the field say they don’t see many male continuation of that journey." sitions. While she also works with ado- clients. It seems to be rooted in the belief – Alicia Hunte lescents, she notes that their engagement that men should be able to figure things with therapy tends to be less consistent. out on their own, without needing help.”

Confronting challenges of stigma and demographic nuances

Hunte’s practice also includes a signifi- Although the stigma surrounding thercant number of women in their thirties, apy has lessened over the past decade, Hunte notes there's still a pervasive idea that seeking therapy means admitting an individual can't handle things by themselves. This mentality she admits, although prevalent among men, is also present in women. “Many people delay seeking therapy because they believe they should be able to solve their problems alone. For many men, expressing emotions, especially to someone outside their family, can be challenging. The notion of showing vulnerability in front of someone who isn't close can be particularly difficult for them."

Alycia Hunte, Registered Psychotherapist

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As she transitioned into psychotherapy, Hunte embraced a client-centred ap-

in the province of Ontario are required to take a set number of professional development training hours annually. Hunte looks forward ensuring she remains informed about the latest treatment methods and research. "Supervision is key,” she says about learning to manage complex cases and maintaining high standards in her practice. “We have guidelines to ensure continuous education and supervision, particularly for challenging cases. Therapists are naturally curious. We're constantly reading articles, exploring new modalities, and discussing approaches with peers.”

Hunte’s career shift from early childhood educator to psychotherapist is testament to her commitment to understanding and supporting others. Her experiences Alycia Hunte, former Registered Early Childhood Educator, now Registered have shaped her client-centred approach, allowing her Psychotherapist to provide meaningful guidance and support to indiproach, focusing on tailoring solutions to meet the individuals across various life stages. vidual needs of each person. “When I first meet a client, I ask them what they’re looking for,” she says. “We work “I love where my life has taken me,” says Hunte. “We all together to find an approach that resonates with them, have a past we would like to change, but this journey because therapy isn’t one-size-fits-all.” has been right, and I’m thrilled.”

Title protection As a CRPO registrant, Hunte explains that professionals in her field in Canada practice under protected titles.

This ensures that professionals are trained to a high degree of competence, allowing clients to feel safe when their needs are addressed.

“You can’t just get someone to open up their trauma and then leave them [after a couple of sessions],” Hunte says.

“There are certain procedures present to keep people safe, especially when you’re dealing with highly traumatized people who are, for example, homebound. Is the professional on the other end exposing their client to certain safety protocols and standards, as well as ensuring they are being kept safe? Sometimes, that doesn’t always happen which could unintentionally result in harm.”

As with most professions, registered psychotherapists

Alycia Hunte, Registered Psychotherapist

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