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October 6, 2025

What Happens When We Lower the Bar?


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What Happens When We Lower the Bar?

A Psychologist’s Call to Protect Mental Health Care in Ontario

By Dr. Bev Walpole, C.Psych — Health & Clinical Psychologist


For over a decade, I’ve worked in hospitals, private practice, and academic settings, helping vulnerable people: kids, adolescents, adults with mental health struggles and concerns.

This work is sacred. It is also high-stakes. When you sit across from a psychologist, you’re placing your mind, your memories, and your safety in their hands.

That’s why what’s happening right now in Ontario should send a chill through anyone who cares about mental health.

The Quiet Crisis You Haven’t Heard About

Our regulatory body — the College of Psychologists and Behaviour Analysts of Ontario (CPBAO) — is under political pressure from the Ministry of Health to gut the very standards that have protected Ontarians for decades.
Here’s what’s on the chopping block:

  • Eliminating the PhD requirement for independent practice — meaning individuals with only a master’s degree could hold the same protected title.
  • Cutting supervised clinical training hours for graduate students by more than half — reducing real-world learning to a fraction of what’s needed for competent care.
  • Reducing post-degree supervision from four years to as little as one — stripping away the mentorship and oversight that build expertise and ethical judgment.
  • Abolishing the oral exam, our profession’s most crucial, final safeguard against incompetence.
  • Removing oversight for specialty designations, so anyone could claim expertise in high-stakes areas like neuropsychology, forensic assessment, or child development — without advanced training.

If these proposals pass, Ontario could become one of the least regulated provinces in Canada for psychological care. Anyone with partial training could legally call themselves a “psychologist” and treat complex trauma, suicidal ideation, or psychosis — without ever having been fully tested.

This is not reform. It’s a quiet dismantling.

What’s Driving These Proposed Changes?

There are three main forces behind the proposed changes. Each has some legitimate concern, but the solutions being proposed are deeply problematic.

Driver

Labor mobility & “as-of-right” legislation

Pressure Being Applied

Psychology may be added to the list of professions eligible for interprovincial mobility.

How It’s Used to Justify Change

Psychologists licensed elsewhere in Canada — sometimes under lower standards — could practice in Ontario with fewer hurdles. CPBAO is using this to justify lowering Ontario’s own entry requirements.

Driver

Equity, diversity, and access concerns

Pressure Being Applied

The Office of the Fairness Commissioner flagged CPBAO as “medium to high risk” for registration fairness: long processes, low success for internationally educated applicants, and underrepresentation of racialized PhD registrants.

How It’s Used to Justify Change

These concerns are being used to argue for loosening education and supervision requirements, suggesting current barriers exclude capable candidates from marginalized backgrounds.

Driver

Workforce shortage & access gaps

Pressure Being Applied

Ontario lacks enough psychologists to meet public demand, especially in rural or low-income areas.

How It’s Used to Justify Change

Lowering entry barriers is framed as a way to “increase access” by producing more psychologists quickly — critics warn this prioritizes quantity over quality, risking public protection.

Driver

Pressure Being Applied

How It’s Used to Justify Change

Labor mobility & “as-of-right” legislation

Psychology may be added to the list of professions eligible for interprovincial mobility.

Psychologists licensed elsewhere in Canada — sometimes under lower standards — could practice in Ontario with fewer hurdles. CPBAO is using this to justify lowering Ontario’s own entry requirements.

Equity, diversity, and access concerns

The Office of the Fairness Commissioner flagged CPBAO as “medium to high risk” for registration fairness: long processes, low success for internationally educated applicants, and underrepresentation of racialized PhD registrants.

These concerns are being used to argue for loosening education and supervision requirements, suggesting current barriers exclude capable candidates from marginalized backgrounds.

Workforce shortage & access gaps

Ontario lacks enough psychologists to meet public demand, especially in rural or low-income areas.

Lowering entry barriers is framed as a way to “increase access” by producing more psychologists quickly — critics warn this prioritizes quantity over quality, risking public protection.

What OPA & CPA Are Saying

The Ontario Psychological Association (OPA) and Canadian Psychological Association (CPA) have issued a joint letter opposing the most extreme proposals:

  • They acknowledge pressures of mobility, equity, and workforce shortages — but radically lowering entry standards is not the solution.
  • Removing doctoral requirements and cutting supervision would erode public protection and trust.
  • They recommend moderate reforms:
    • Streamline registration processes
    • Harmonize standards across provinces
    • Allow interim registrations
    • Maintain high training and supervision standards while addressing barriers thoughtfully

What CPBAO Has Publicly Acknowledged

  • Psychology is being considered for the “as-of-right” exemption list, which would facilitate intra-provincial mobility under federal-provincial trade agreements (CFTA).
  • The CFTA already allows psychologists licensed in one province to apply in another, sometimes under different standards.
  • CPBAO is pursuing “registration modernization”, redefining practice areas and aligning with accrediting bodies.
  • CPBAO emphasizes equity, diversity, and inclusion in supervision and training, including cultural humility, bias awareness, and systemic power dynamics.

My Take: DEI & Access Are Real — But the Path Is Dangerous

There are legitimate pressures here:

  • Barriers exist for racialized, international, or marginalized applicants.
  • There is a genuine need for more psychologists in underserved communities.

The danger is the chosen route: eroding core protections — doctoral requirements, supervision, exams, specialty oversight — instead of reforming the barriers themselves. It’s essentially saying:

“We can’t fix access? Let’s just lower expectations.”

This is a high-risk tradeoff that could harm public safety, professional standards, and trust.

A safer, smarter approach (endorsed by OPA/CPA):

  • Remove process bottlenecks: simplify paperwork, improve credential recognition
  • Support internationally trained applicants: bridge programs, mentoring, assessment pathways
  • Review training requirements with evidence: clarify essential components
  • Invest in the workforce: more training seats, public psychology jobs, and supervision support

“Access” Is the Excuse — Deregulation Is the Reality

The government’s justification is “increasing access”, but this isn’t really about access — it’s about cost-cutting and control.

Lowering standards will not produce more qualified psychologists. It will flood the system with undertrained providers, eliminating supervised, low-fee clinics that serve thousands of Ontarians.

True solutions would be obvious:

Fund graduate programs to train more psychologists

Fund hospital and school-based positions to retain qualified clinicians

Fund public mental health programs that already exist

You don’t fix a water shortage by watering it down.

Competence Protects Clients

Every hour of my training — over 6,000 hours of supervised therapy, assessment, and consultation — taught me humility, precision, and the limits of my knowledge. These weren’t barriers — they were safeguards.

Without them:

  • Trauma gets misdiagnosed as “stress”
  • Bipolar disorder gets treated as depression
  • A child with autism is misunderstood as defiant

In hospitals, courtrooms, and crisis settings, these aren’t small errors — they destroy lives. When training standards fall, people don’t just get less care — they get the wrong care.

The Dunning–Kruger Effect: The Blind Spot That Can Harm

People with low competence often overestimate their abilities, because they don’t have the depth to recognize their mistakes. When clinicians are rushed through training, this bias becomes deadly.

Exams and prolonged supervision exist not to gatekeep, but to protect the public from confident incompetence.

Imagine If We Lowered the Bar in Medicine

Would you:

  • Trust a surgeon who skipped residency?
  • Board a plane with a pilot trained on YouTube?
  • Let an engineer design your child’s school after one semester of drafting class?

Then why would we accept half-trained clinicians treating people’s minds, the most complex and delicate organ we have?

Mental health deserves more protection, not less.

What You Can Do

We will soon have 60 days (consultation period has not yet started) before these proposals could become law. Once standards are lowered, there’s no going back.

Here’s how to act:

Do:

  1. Write to the College at regchanges@cpbao.ca and respectfully express your opposition to lowering professional standards.
  2. Follow @PsychologyOntarioAdvocacy for updates and to learn more 
  3. Talk about it — with colleagues, friends, clients. Awareness is the antidote to apathy
  4.  SOON we will ask the public to contact MPPs— however the public consultation hasn’t opened, and they can’t act on this issue until it does. We will have a letter template to follow.
  5. Avoid hostile or political commentary — maintaining professional and factual communication is critical right now.

    This is a marathon, not a sprint. The OPA and advocacy groups are working closely together, and coordinated, evidence-based communication will make the biggest impact.

A Final Word

The mind is not a place for shortcuts.

When we lower standards in the name of “access,” we dilute care, trade safety for speed, and ethics for efficiency. The most vulnerable will pay the price.

Once public trust is fractured, it takes generations to rebuild. Let’s not gamble with mental health.

Let’s choose integrity over expedience, depth over shortcuts, and care over convenience.

We do this work not for the title — we do it for the people who place their lives in our hands. That trust is sacred, and it must be safeguarded.

 

— Dr. Bev Walpole, C.Psych
Health & Clinical Psychologist | Founder, Haven Wellness by Design