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).

Students must clearly and accurately represent their status in relation to the CiiAT program and their clinical training. When providing services as part of their CiiAT clinical placement or other program requirements, students must identify themselves as a “student art therapist” or “art therapist in training.”

Students must not use a restricted title, imply that they hold professional registration or licensure that they do not hold, or otherwise represent themselves in a manner that could reasonably mislead clients or the public regarding their qualifications, registration status, scope of practice, or level of training.

Where a student independently holds registration, licensure, certification, or another professional designation, they may accurately identify that credential where appropriate; however, this does not alter their status as a student within the CiiAT program or their obligation to clearly identify the capacity in which they are providing services as part of their clinical training.

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 that supports the progressive development of clinical skills, professional judgment, self-regulation, and readiness for practice.
  • Ensure client safety and informed consent are maintained at all times.
  • Align with CRPO and CATA professional practice standards.
  • Maintain appropriate client intake, assessment, and referral practices to ensure that clients are matched with a service provider whose skills, training, and level of competence are appropriate to their needs.
  • Clearly distinguish between the roles of student, supervisor, and practitioner.
  • Maintain appropriate insurance coverage for students and clients.
  • Establish and maintain appropriate procedures for client file management, documentation, access, storage, and retention, as well as for ensuring that clients have appropriate care arrangements in place when a student is unavailable, a placement ends, or a client requires ongoing services, referral, or transfer of care.
  • 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, where CRPO standards apply, it is a requirement you establish a signed written agreement meeting Standard 4.1 and 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 must clearly and accurately represent their status within the CiiAT program. When providing services as part of their clinical training, students must identify themselves as a “student art therapist” or “art therapist in training,” regardless of whether they independently hold another professional registration or designation.
• Students/Learners must identify their student role and use protected professional titles only where legally entitled. Students are not to use any professional titles protected by legislation (e.g., “psychotherapist,” “RP Qualifying”) they are not legally entitled to use.
• RP Qualifyings 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 Qualifying.
• Represent services as being delivered by a registered professional without explicitly identifying the actual provider’s status, whether student or RP Qualifying.
• 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 Qualifyings in a clinical capacity that replaces paid staff or generates revenue for the organization beyond reasonable administrative recovery.

Additional Considerations:

• Students may provide psychotherapy under appropriate supervision where legally permitted and within their competence. Billing must accurately reflect their student and registration status.
• 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 Qualifying is practising autonomously
• Supervisors are not considered the provider of service for student-delivered sessions.
• The use of a supervisor’s registration number in relation to services provided by a student is not permitted without the supervisor’s explicit knowledge, agreement, and case-by-case authorization, including verification of the specific services being billed.
• The student or RP Qualifying’s hours are part of a revenue-generating clinical caseload

These arrangements are prohibited by CiiAT. Misrepresentation may also breach applicable professional standards, or 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.

Placement sites are responsible for ensuring that billing practices are transparent and consistent with regulatory expectations. Where there is uncertainty, CiiAT requires that student-delivered services be offered on a low-fee or no-fee basis to avoid misrepresentation and protect both clients and supervising clinicians.

Informed Consent and Client Transparency

All clients receiving services from students or Registered Psychotherapists (Qualifying) must be informed in writing, before services begin, that:

• The session is facilitated by a student art therapist or Registered Psychotherapist (Qualifying), as applicable, and the individual’s current training, qualification, and registration status must be accurately represented.
• The student or RP (Qualifying) receives clinical supervision from a qualified supervisor. The role of the supervisor, the nature of the supervision arrangement, and any applicable limits to confidentiality associated with supervision must be explained to the client.
• Client wellbeing is supported through shared responsibilities among the service provider, the clinical placement site host, and the clinical supervisor. The student or RP (Qualifying) is responsible for working within their level of competence, recognizing their limitations, and seeking guidance when needed. The placement site host is responsible for appropriate client intake, assessment, and service matching, as well as the management of client records and continuity of care. The clinical supervisor provides ongoing guidance and assessment to support ethical clinical decision-making and ensure that the work undertaken is appropriate to the service provider’s level of skill, training, and competence.
• The placement site host retains ultimate responsibility for the management and oversight of the client file and for ensuring appropriate continuity-of-care arrangements, including when a student or RP (Qualifying) is unavailable, a placement ends, or a referral or transfer of care is required.
• Clients may request clarification about the student’s or RP (Qualifying)’s role, the supervision structure, the individuals involved in their care, and the procedures for managing their records and continuity of care at any time.
• Client consent forms must identify the service provider by name and accurately state their student or RP (Qualifying) status, program or institutional affiliation where applicable, and the name and credentials of the clinical supervisor. The forms must also identify the placement site or responsible service organization and explain relevant arrangements for supervision, access to client records, confidentiality, and continuity of care.
• Clients must be provided with an opportunity to ask questions and make an informed decision about participating in services, including the opportunity to decline or withdraw consent in accordance with applicable policies and professional requirements.

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.
• Assign clients without appropriate intake, assessment, and service-matching procedures. Placement sites must consider each client’s needs, complexity, and risk factors alongside the student’s current skills, training, and demonstrated competence when determining whether a student is an appropriate service provider.
• Discourage or penalize students for identifying concerns about their readiness to work with a particular client, requesting additional supervision or consultation, raising concerns about client safety, or seeking a referral or transfer of care when clinically appropriate.
• Fail to maintain appropriate procedures for client file management, clinical documentation, and continuity of care. Placement sites must ensure that clients have appropriate care arrangements when a student is unavailable, a placement ends, or a client’s needs exceed the services that can safely be provided within the placement arrangement.
• 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.
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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 are responsible for developing self-regulation and professional judgment, monitoring their own capacity, recognizing the limits of their knowledge and skills, and seeking guidance when needed. Placement site hosts are responsible for appropriate client intake, assessment, service matching, workload expectations, and continuity-of-care arrangements. CiiAT clinical supervisors are responsible for ongoing discussions and assessments with students regarding the appropriateness of their clinical work relative to their developing competence, with guidance and intervention where concerns are identified.

These responsibilities are complementary and must work together to safeguard client wellbeing while supporting student learning and professional development. No placement arrangement should rely solely on a student’s ability to recognize their own limitations or on supervision to correct an inappropriate client assignment or unsafe workload after it has occurred.

Such practices may conflict with applicable CATA standards for trainee supervision and safe practice, CRPO requirements concerning competence and professional conduct, and CiiAT’s commitment to ethical, appropriately supervised clinical education.

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 applies Ontario’s statutory definition of the controlled act of psychotherapy. All of the following elements must be present:

• Treatment uses a psychotherapy technique delivered through a therapeutic relationship.
• The individual has a serious disorder of thought, cognition, mood, emotional regulation, perception, or memory.
• That disorder may seriously impair the individual’s judgement, insight, behaviour, communication, or social functioning.

Not all psychotherapy meets this threshold.

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, oversight, and consideration of the student’s level of training, demonstrated competence, and capacity, students may engage in the following activities as part of their clinical placement. All activities must be appropriate to the student’s developing skills and the needs and circumstances of the client. The placement site host and CiiAT clinical supervisor must contribute their respective knowledge and expertise to support appropriate client assignments, guide clinical decision-making, and safeguard client wellbeing:

Facilitation of therapeutic art-based sessions focused on:

• Self-expression, emotional awareness, coping skills, psychoeducation, relational and creative exploration.
  • The focus, goals, and complexity of each session must be appropriate to the student’s competence and the client’s needs. Students must recognize the limits of their training, seek guidance when a client’s needs exceed their current capacity, and refrain from undertaking interventions for which they are not adequately prepared.

Participation in individual or group sessions where:

• Goals are supportive, exploratory, or developmental, rather than diagnostic or treatment-oriented
• The clinical supervisor engages in ongoing discussion and assessment with the student regarding the appropriateness of the clinical work, the student’s developing competence, and any concerns requiring consultation, additional support, modification of the work, or referral.
• Co-facilitation or observation of psychotherapy sessions led by a qualified professional

Conducting intakes, check-ins, or assessments for learning purposes, provided that:

• The placement site host maintains appropriate intake and assessment procedures and is responsible for determining client suitability, appropriate service matching, and arrangements for further assessment or referral.
• Students receive appropriate preparation and guidance before undertaking these activities and understand the limits of their role in gathering information, identifying concerns, and communicating observations.
• Clinical interpretations, decisions about treatment, risk management, and referrals are made or reviewed by the appropriately qualified professional in accordance with the placement site’s procedures and applicable professional requirements. Students must promptly communicate concerns about client safety, changes in client presentation, or needs that may exceed their competence.
• Students do not independently diagnose, undertake interventions beyond their authorized scope or competence, or assume sole responsibility for managing high-risk situations or clients whose needs exceed the support available within the placement arrangement.
• Students are encouraged to recognize and communicate uncertainty, seek consultation, and exercise self-regulation when determining whether they are prepared to undertake a particular activity.

Completing documentation, participating in clinical supervision, and engaging in reflective practice:

Students may complete clinical documentation, case discussions, reflective exercises, treatment-planning activities, and other learning tasks as appropriate to their role and placement requirements. These activities must be completed in accordance with the placement site’s documentation procedures, applicable privacy and confidentiality requirements, and CiiAT policies.

The placement site host retains ultimate responsibility for the management, security, and retention of client files and for ensuring continuity of care. Students must follow established documentation procedures and promptly raise concerns about incomplete records, client safety, or care transitions. CiiAT clinical supervisors must use ongoing supervision discussions and assessments to help students reflect on their clinical work, identify learning needs, recognize limitations, and develop sound professional judgment.

These permitted activities reflect CATA’s emphasis on competence, supervision, and ethical responsibility, as well as applicable CRPO requirements concerning professional competence and appropriate practice by learners. All activities remain subject to the relevant regulatory requirements, professional standards, placement agreements, and CiiAT policies.

Prohibited Student Activities

Students must not engage in activities that exceed their authorized role, level of training, demonstrated competence, or capacity to provide safe and ethical services. The presence of a supervisor does not, on its own, make an otherwise inappropriate activity or client assignment acceptable.

Students must not:

• Practise beyond their scope or competence
  • Independently provide psychotherapy or undertake activities requiring qualifications, registration, authorization, or independent practice authority they have not attained.
  • Undertake clinical interventions, assessments, or other activities for which they lack adequate training, preparation, demonstrated competence, or appropriate supervision.
  • Continue providing a service or intervention when they recognize, or reasonably should recognize, that the client’s needs exceed their current competence or the level of support available.
  • Fail to communicate concerns about client safety, clinical complexity, their own capacity, or the suitability of an intervention to the placement site host and CiiAT clinical supervisor.
• Accept or manage inappropriate client assignments
  • Students must not independently assume responsibility for clients whose needs, presentation, or circumstances exceed their level of competence or the safeguards available within the placement arrangement. This includes situations involving:
    • Acute mental health concerns requiring a level of assessment, intervention, or monitoring beyond the student’s competence.
    • Active suicidality or other significant risk of harm requiring specialized assessment, crisis response, or risk-management capacity beyond the student’s authorized role.
    • Severe trauma, complex psychiatric presentations, or other clinical circumstances requiring expertise or interventions for which the student has not been adequately prepared.
  • The appropriateness of a client assignment must be assessed in advance through the placement site’s intake, assessment, and service-matching procedures, with consideration of the student’s training, demonstrated competence, available supervision, and the client’s needs.
  • Where a client’s needs change or a concern emerges during service delivery, the student must promptly communicate the concern and seek appropriate guidance. The placement site host and CiiAT clinical supervisor must work within their respective responsibilities to determine whether additional support, modification of the service, transfer of care, or referral is required.
  • Direct supervision does not automatically make every high-risk or clinically complex assignment appropriate. Any student involvement in such circumstances must be specifically assessed as suitable for the student’s level of competence and permitted under applicable professional and regulatory requirements, with appropriate qualified oversight and safeguards in place.
• Misrepresent their professional status or qualifications
  • Students must not present themselves in a manner that misrepresents their training, qualifications, registration status, or authority to practise. In particular, they must not:
    • Present themselves as independently qualified or registered psychotherapists, counsellors, or other regulated professionals when they do not hold the relevant qualifications or registration.
    • Describe themselves as Registered Psychotherapists (Qualifying), or use another protected or regulated title or designation, unless they are appropriately registered and legally entitled to use it.
    • Imply that supervision, program enrolment, or participation in a clinical placement grants them professional registration or independent practice authority they have not attained.
• Assume responsibilities beyond their authorized role
  • Students must not independently assume sole responsibility for clinical functions beyond their training, competence, or authorized role, including:
    • Clinical assessment and interpretation beyond their level of competence.
    • Diagnosis where they lack the required qualifications, authorization, or competence.
    • Treatment planning or clinical decision-making beyond their authorized responsibilities.
    • Crisis intervention or risk management beyond their training, competence, and the established procedures and supports available at the placement site.
  • Students may participate in these activities for educational purposes or as part of an appropriately supervised clinical role when permitted by applicable requirements. Such participation must not be represented as independent authority or responsibility that the student does not hold.
• Practise without adequate supervision or safeguards
  • Students must not provide services without the supervision, consultation, and support required by their placement arrangement, applicable professional standards, and CiiAT policies. They must not disregard supervisory guidance, conceal concerns about their clinical work, or continue an activity when they have reason to believe it may compromise client wellbeing.
  • Students are expected to develop self-regulation, professional judgment, and the ability to recognize and communicate the limits of their competence. Seeking assistance, raising concerns, and requesting a reassessment of a client assignment are appropriate professional responsibilities and must not be discouraged.
  • Activities that exceed a student’s authorized role or competence may be inconsistent with applicable CRPO requirements, including relevant provisions of its Code of Ethics and Entry-to-Practice Competencies, and CATA standards relating to scope of practice, competence, supervision, and client safety.

Supervisory and Site Responsibilities

The safe and ethical delivery of services within a student placement requires coordinated action by the student, the placement site host, and the CiiAT clinical supervisor. Each party must fulfil its respective responsibilities to support student development and safeguard client wellbeing. These responsibilities are complementary and do not eliminate or transfer any independent professional, organizational, or regulatory obligations.

Placement Sites must ensure that:

• Student roles and limits are clearly defined and understood.
• Client intake, assessment, and service matching are appropriate.
• Client consent is informed and transparent.
• Caseloads, clinical hours, client complexity, and assigned activities reflect the student’s training, demonstrated competence, and capacity to engage in supervision, reflection, documentation, and other required learning activities.
• Client records and continuity of care are maintained.
• Concerns are identified and addressed promptly.
• Students must be able to communicate uncertainty, identify limitations, request additional guidance, and report concerns about client safety or the appropriateness of an assignment without being pressured to continue work beyond their competence.

CiiAT Clinical Supervisors must:

• Engage in regular discussions with students about their client work, clinical decision-making, professional boundaries, developing competence, and capacity to undertake assigned activities safely and ethically.
• Evaluate whether their interventions, client assignments, and clinical responsibilities are appropriate to their level of training and demonstrated competence.
• Where concerns arise about a student’s competence, capacity, clinical judgment, or the suitability of a client’s needs for the placement arrangement, supervisors must provide appropriate guidance and take action within their role to address the concern. This may include recommending additional support, modifying the student’s activities, consulting with the placement site and CiiAT, or recommending referral or transfer of care.
• Ensure students understand when and how to seek assistance, particularly where there are concerns about risk, crisis situations, clinical complexity, or needs beyond the student’s competence.
• Communicate with the placement site host and relevant CiiAT personnel to address concerns affecting client safety or the suitability of the placement, consistent with confidentiality requirements and applicable professional obligations.

CiiAT reserves the right to review, require modifications to, suspend, or terminate a placement where there are concerns that student activities, client assignments, workload expectations, or site practices are inconsistent with CiiAT policies, applicable professional standards, regulatory requirements, or client safety obligations.

Where concerns are identified, CiiAT may work with the student, placement site host, and clinical supervisor to determine appropriate corrective action. Depending on the circumstances, this may include reassessing client assignments, restricting particular activities, requiring additional supervision or safeguards, arranging a referral or transfer of care through the placement site, or discontinuing the placement.

Any action affecting a client’s services must account for the placement site’s responsibility for client records and continuity of care. Placement changes or termination must not result in clients being left without appropriate care arrangements.

The purpose of these oversight measures is to maintain an ethical learning environment, support the student’s development, and safeguard client wellbeing through the coordinated fulfilment of each party’s responsibilities.

Considerations for Ethical Virtual Clinical Placement

Virtual clinical placement may be incorporated into a student’s clinical placement experience only where the placement model supports appropriate client care, student learning, privacy, security, and legal and ethical practice. Virtual placement, outside of CiiAT’s Virtual Art Therapy Clinic, is intended to supplement an in-person clinical placement and must not constitute the entirety of a student’s clinical placement experience at one particular site.

For a virtual component of a clinical placement to be approved, the following requirements must be met:

• Portion of an In-Person Placement

• • • Virtual clinical placement activities must comprise only a portion of the student’s clinical placement at a particular site. The placement must maintain an appropriate in-person component that provides opportunities for onsite learning, professional interaction, and access to the placement environment.

• Appropriate Location for Student Practice

• • • Students must be able to facilitate virtual clinical sessions from a location other than their private home residence. The location must be appropriate for professional clinical practice and must provide sufficient privacy, security, confidentiality, and environmental conditions to support ethical client care.
    • The placement site must provide the student with a private and appropriate workspace from which virtual clinical services can be facilitated. The space must allow for confidential conversations and clinical work without unauthorized individuals being able to hear, observe, or otherwise access client information.

• Onsite Support

• • • The placement site must provide access to an individual onsite who can serve as an immediate operational and practical resource for the student during virtual placement activities. This requirement is in addition to the clinical supervision provided through CiiAT or an appropriately qualified clinical supervisor.

• Compliant Telehealth Platform

• • • The placement site must provide and require the use of a secure, privacy-compliant telehealth platform for all virtual clinical services. Examples may include Jane App, Owl Practice, or another platform that meets applicable privacy, security, recordkeeping, and professional practice requirements. Students must not use personal video-conferencing accounts or other platforms that have not been approved and supplied by the placement site.

• Documentation and Record Retention

• • • All clinical documentation, client records, consent forms, communications, session notes, and other records associated with virtual clinical services must be stored, secured, and retained by the placement site in a manner that complies with all applicable legal, regulatory, privacy, and ethical requirements. 
    • Students must not store client records or personal health information on personal devices, personal cloud storage, personal email accounts, or other personal accounts, and that all clinical records must be documented, stored, secured, and retained through the placement site’s approved systems and procedures.

• Group Facilitation

• • • Virtual group facilitation requires a co-facilitator approved by the clinical placement site. The student must be made aware of the roles and responsibilities of each facilitator ahead of time to ensure success. 

• Cyber Insurance

• • • The placement site must maintain appropriate cyber liability/cyber insurance coverage that applies to the storage, transmission, and management of client information and virtual clinical services. CiiAT reserves the right to request proof of current cyber insurance coverage from the placement site before approving or continuing a virtual clinical placement.

• Client Consent

• • • The placement site is responsible for ensuring that appropriate and informed client consent is obtained before a student provides services virtually. Consent must appropriately address the student’s role, supervision arrangements, the use of virtual services, privacy and confidentiality considerations, and any relevant limitations or risks associated with virtual care. Client consent must be documented and retained by the placement site.

• Privacy and Confidentiality

• • • Students must conduct virtual sessions in a manner that protects client privacy and confidentiality. The placement site must establish appropriate procedures for the use of computers, cameras, microphones, headphones, internet connections, electronic records, and other technology used in virtual service delivery.

• Emergency and Risk Management Procedures

• • • The placement site must have procedures in place for responding to client safety concerns, emergencies, technological disruptions, and other risks that may arise during virtual sessions. Students must know how to access onsite support and follow the placement site’s established procedures.

• Jurisdiction and Location of Care

• • The placement site must establish procedures to identify and document the client’s location at the time of each virtual session and ensure that virtual services are provided in accordance with applicable legal, regulatory, professional, privacy, and ethical requirements.

CiiAT reserves the right to request additional information or documentation regarding the placement site’s telehealth platform, privacy and security practices, cyber insurance, consent procedures, documentation practices, physical workspace, and emergency procedures before approving a virtual placement component.

CiiAT may decline, suspend, modify, or terminate a virtual clinical placement component if the placement site cannot demonstrate that the virtual arrangement provides an appropriate level of client protection, student support, privacy, security, supervision, and professional accountability.

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