Ethical and Compliant Placement Models

Purpose

This policy outlines the ethical, legal, and professional requirements for clinical placement sites partnering with the Canadian International Institute of Art Therapy (CiiAT). It establishes clear parameters for acceptable and unacceptable placement models in accordance with the standards of the College of Registered Psychotherapists of Ontario (CRPO) and the Canadian Art Therapy Association (CATA).
The purpose of this policy is to protect clients, uphold student learning outcomes, and ensure that all placements meet professional, ethical, and legal expectations regarding ethical client care, adequate student supervision, client billing transparency, and overall safety.

Guiding Principles

CiiAT placement partnerships must:

• Provide students with a safe, ethical, and structured learning environment.
• Ensure client safety and informed consent are maintained at all times.
• Align with CRPO and CATA professional practice standards.
• Clearly distinguish between the roles of student, supervisor, and practitioner.
• Maintain appropriate insurance coverage for students and clients.
• Avoid any billing or employment arrangement that misrepresents services delivered by students.

Supervision Requirements

Qualifications of Supervisors
The site supervisor (site manager) is an onsite resource for the student/learner for operational and practical matters of their clinical placement. This role is filled by the host organization, may have a varied professional background depending on the placement site, and will be the primary onsite resource during the clinical placement.

The clinical supervisor is responsible for clinical and therapeutic oversight of the student/learner’s direct client contact. This individual should have specific qualifications to enable them to provide clinical supervision. All of the clinical supervision hours needed to graduate are provided by CiiAT. A student may choose to seek out clinical supervision outside of CiiAT, and should refer to the policy Private Supervision Hours Outside of CiiAT.

Clinical supervisors must be in good standing with their regulatory college or professional association. In Ontario, supervisors must meet CRPO standards and be qualified to provide clinical supervision to students.

Clinical Supervision Structure
CiiAT provides sufficient supervision hours for students to graduate. If a student’s clinical placement site is able to provide clinical supervision and the student would like to engage in extra clinical supervision hours through their site, it is the responsibility of the student and supervisor to appropriately track and record the supervision hours obtained. More information about this process can be found in the Private Supervision Hours Outside of CiiAT policy.

If a student chooses to pursue outside clinical supervision, it is important that the student pursues a written clinical supervision agreement outlining:

• Frequency and duration of supervision
• Method (individual, group, or combination)
• Learning objectives and scope of practice
• Evaluation process
• Roles, responsibilities, and accountability of both student and supervisor

Billing and Representation

Acceptable Billing Models

Placement sites may:

• Offer no-fee or low-fee services to clients when sessions are conducted by individuals in training, whether classified as:
  • Art Therapy Students/Learners (not yet registered with a regulatory college), or
  • Registered Psychotherapists (Qualifying) who are completing direct client contact hours as part of CiiAT’s Art Psychotherapy Diploma program.
• Issue receipts that clearly identify:
  • The status of the service provider:
    • “Art Therapy Student under Supervision” for individuals who are not RP(Q)s
    • “Registered Psychotherapist (Qualifying) under Supervision” for those registered with the CRPO
    • The name and credentials of the supervising professional responsible for oversight.

Additional Considerations:
Students/Learners may not use any professional titles protected by legislation (e.g., “psychotherapist,” “counsellor,” “RP(Q)”), and must be represented strictly as students.
RP(Q)s must use their correct CRPO-protected title (“Registered Psychotherapist (Qualifying)”) and adhere to CRPO standards regarding advertising, billing, and informed consent.

Unacceptable Billing Models

CiiAT does not permit placements that:

• Bill clients under the registration number of a Registered Psychotherapist, psychologist, or clinic owner for services delivered by a student/learner or RP(Q).
• Represent services as being delivered by a registered professional without explicitly identifying the actual provider’s status, whether student or RP(Q).
• Charge clients additional fees under the premise of “supervision costs” when supervision is already being provided through CiiAT or by designated faculty supervisors.
• Employ students or RP(Q)s in a clinical capacity that replaces paid staff or generates revenue for the organization beyond reasonable administrative recovery.

Additional Considerations:

• Students/Learners cannot legally provide psychotherapy or be represented as psychotherapists; therefore, any billing must reflect their training status, and sites must ensure that all services fall within a permitted scope under supervision.
• RP(Q)s may provide psychotherapy within the limits of their competence only under clinical supervision, but they still cannot be billed as “Registered Psychotherapists” or have their services represented as being delivered independently.

Sites must avoid any arrangement that implies:

• The student or RP(Q) is practising autonomously
• The supervising professional is the one providing the service directly
• The student or RP(Q)’s hours are part of a revenue-generating clinical caseload

Such arrangements violate the CRPO Standards on Clinical Supervision (Standard 4.1) and Fees (Standard 6.1), as well as CATA’s Standards of Practice (Sections E and G), by misrepresenting service providers, blurring professional accountability, and compromising transparency in client consent and billing.

Informed Consent and Client Transparency

All clients seen by students/RP(Q)s must be informed in writing that:

• The session is facilitated by a student art therapist under supervision.
• The student receives clinical supervision from a qualified supervisor.
• The supervising professional holds ultimate responsibility for client welfare.
• Clients may request clarification on the supervision structure at any time.
• Client consent forms must include the student’s name, program affiliation, and the supervising professional’s name and credentials.

Appropriate Workload for Students in Clinical Placement

CiiAT is committed to ensuring that all clinical placements provide a safe, ethical, and educationally appropriate learning environment. In alignment with the Canadian Art Therapy Association (CATA) Standards of Practice and the CRPO Code of Ethics and Entry-to-Practice Competencies, students must maintain a workload that supports competent, ethical, and reflective clinical practice while protecting client wellbeing and student learning.

Maximum Allowable Hours

To safeguard student development and client safety, CiiAT establishes the following workload limits:

• Students may complete no more than 12 hours of direct client contact hours (DCCH) per week, and no more than 50 hours per month, that may be submitted toward direct client contact hours (DCCH).
• These limits ensure that clinical responsibilities remain proportionate to the student’s level of training and capacity for supervised practice.

Ethical and Professional Rationale

These workload boundaries reflect core principles found in:

• CATA Standards of Practice, particularly:
  • Section D: Competence — requiring practitioners in training to practise within their current abilities, training, and level of supervision.
  • Section E: Professional Responsibility — emphasizing safe, ethical, and client-centred service delivery.
  • Section G: Supervision — mandating adequate supervision and appropriate caseloads for trainees.
• CRPO Code of Ethics and Entry-to-Practice Competencies, specifically:
  • Client Welfare and Safety — ensuring students do not take on more clients than they can ethically support.
  • Competency Development and Self-Awareness — requiring regulated trainees to recognize limits, seek guidance, and avoid overextension.
  • Professional Conduct — maintaining clear boundaries and ensuring workload does not compromise judgment or therapeutic effectiveness.
  • Exceeding these limits increases risks to clinical quality, student wellbeing, and client safety, which would contravene the expectations of both CATA and CRPO regarding ethical practice and competent service delivery.

Unacceptable Workload Expectations

Placement sites must not:

• Require or encourage students to exceed 12 hours/week or 50 hours/month of clinical activity.
• Assign students caseloads resembling those of independent or fully qualified clinicians.
• Use student clinicians to compensate for staffing shortages or meet revenue or service-volume demands.
• Create expectations that undermine reflective practice, supervision engagement, or ethical decision-making capacities.

Such practices conflict with CATA’s standards for trainee supervision and safe practice, and with CRPO expectations that psychotherapists-in-training avoid practising beyond competence or capacity.

Responsibilities of Students, Sites, and CiiAT

Students must communicate workload limits to placement supervisors and monitor their own capacity in accordance with CATA and CRPO expectations for self-regulation and recognition of limits.
Placement Sites must ensure caseloads, schedules, and duties fall within CiiAT’s established limits and uphold the ethical standards of CATA and CRPO.

CiiAT reserves the right to review, adjust, or discontinue a placement if workload exceeds what is educationally and ethically appropriate.

Insurance and Workplace Safety Coverage

All placement sites must hold:

• Professional liability insurance that covers all staff, clients, and students participating in services at the site, where applicable, such as in a private practice.
• General liability insurance for the physical premises where services occur (including remote or hybrid contexts, where applicable).

If the site does not hold appropriate insurance coverage that extends to students, the placement may not be approved or may be discontinued until coverage is obtained.

Placement sites are responsible for ensuring that all local, provincial, and federal workplace safety regulations are met.

Responsibility of the Educational Institution (CiiAT)

• Institutional Liability Insurance: Covers claims related to the structure and administration of our program, ensuring that students are safeguarded if a claim involves the institution’s responsibilities.
• Supervisor’s Professional Liability Insurance: Covers claims involving guidance or advice provided to students during clinical supervision.
• Workers’ compensation or equivalent workplace insurance that extends coverage to students engaged in clinical placement activities.

Verification

CiiAT reserves the right to request and verify copies of insurance certificates and WSIB/WorkSafe documentation prior to and during the placement period.
Sites must notify CiiAT immediately of any lapse or change in coverage.

Compensation and Financial Ethics

• Students are not to be charged for placement opportunities or supervision costs provided by the site.
• Placement sites may not profit from student clinical hours.
• Any financial arrangements between students and placement sites (e.g., reimbursement for materials, honoraria) must be transparent and approved by CiiAT in advance.

Appropriate Student Activities in Clinical Placement

Clinical placement is intended to support learning and competency development, not independent clinical practice.

Distinction Between Psychotherapy and Therapeutic Support

CRPO identifies psychotherapy as a controlled act when it involves:

• Treating a serious disorder of thought, cognition, mood, emotional regulation, perception, or behaviour
• Using a structured therapeutic relationship to bring about significant change
• Addressing clinically significant distress or impairment through psychotherapeutic techniques
• Students in placement must not independently perform the controlled act of psychotherapy. All activities must occur under supervision and within clearly defined learning parameters.

Permitted Student Activities (Under Supervision)

With appropriate supervision and oversight, students may engage in the following activities:

• Facilitation of therapeutic art-based sessions focused on:
  • Self-expression
  • Emotional awareness
  • Coping skills
  • Psychoeducation
  • Relational and creative exploration
  • Participation in individual or group sessions where:
    • Goals are supportive, exploratory, or developmental, rather than diagnostic or treatment-oriented
    • The supervising clinician retains clinical responsibility for assessment, treatment planning, and risk management
    • Co-facilitation or observation of psychotherapy sessions led by a qualified professional
  • Conducting intakes, check-ins, or assessments for learning purposes, provided that:
    • Final clinical decisions rest with the supervisor
    • Students do not independently diagnose, treat serious mental health disorders, or manage high-risk clients
    • Documentation, reflective practice, and case discussion as part of supervision

These activities align with CATA’s emphasis on competence, supervision, and ethical responsibility, and with CRPO’s expectation that learners practise within clearly defined limits.

Prohibited Student Activities

Students must not:

• Independently provide psychotherapy as defined under the controlled act
• Treat clients presenting with:
  • Acute mental illness
  • Active suicidality
  • Severe trauma or complex psychiatric conditions unless directly overseen and managed by a qualified professional
  • Present themselves as:
    • Psychotherapists
    • Counsellors
    • Registered or qualifying registrants of a regulatory college
  • Assume sole responsibility for:
    • Clinical assessment
    • Diagnosis
    • Treatment planning
    • Crisis intervention or risk management
    • Practise without adequate supervision or beyond their level of training and competence

Engaging in such activities would contravene CRPO’s Code of Ethics, Entry-to-Practice Competencies, and CATA’s Standards of Practice related to scope, competence, and client safety.

Supervisory and Site Responsibilities

Placement Sites must ensure that:

• Student roles are clearly defined
• Client consent explicitly acknowledges student involvement
• A qualified supervisor retains ultimate clinical responsibility

Clinical Supervisors must:

• Monitor student activities to ensure alignment with ethical and legal standards
• Intervene when clinical complexity exceeds what is appropriate for a student

CiiAT reserves the right to review, modify, or terminate placements where student activities exceed appropriate scope or violate regulatory expectations.

Institutional Oversight and Compliance

CiiAT reserves the right to:

• Review all placement agreements and supervision structures before approval.
• Decline or discontinue placements that do not comply with CiiAT, CRPO, or CATA standards.
• Require corrective action from the placement site if billing, supervision, or insurance practices are found to be non-compliant.

Failure to comply may result in the immediate termination of the placement agreement.

References
CRPO “Understanding the Controlled Act of Psychotherapy” https://crpo.ca/apply-to-crpo/controlled-act-of-psychotherapy/
CRPO Standards of Practice
Standard 4.1 – Providing Clinical Supervision
Standard 6.1 – Fees
CRPO Practice Standards – Client-Therapist Relationship https://crpo.ca/practice-standards
CATA Standards of Practice
Sections E and G – Supervision, Roles, and Public Representation https://www.canadianarttherapy.org/standards-of-practice