Proposed Psychotherapy Reserved Practice Requirements and Process

DRAFT – For Consultation Only – Information Subject to Change

February 20, 2026

Introduction

The Standards for Psychotherapy will come into effect later this year. The new Standards bring changes to the practice of psychotherapy by occupational therapists in Nova Scotia:

1. Requirements for yearly professional development and ongoing consultation and/or clinical supervision when practicing psychotherapy
2. New rules for Use of Title when practicing psychotherapy
3. Changes to expectations for Delegation and Assignment of Psychotherapy
4. The designation of Psychotherapy as Reserved Practice, and the creation of a new authorization process for Reserved Practice

Reserved Practice

“Reserved Practice” means an activity, procedure, or service that involves enough risk to clients that the NSOTR Board requires registrants to have additional education, training, or other requirements beyond the entry-to-practice level and approval from NSOTR before they can engage in it.

The designation of psychotherapy as Reserved Practice means an Occupational Therapist requires additional authorization from the Regulator before they can practice psychotherapy (including using any psychotherapeutic approach).

The Standards and Reserved Practice authorization process will be implemented in two phases:

Phase 1 – Application Period: this period will begin several months prior to the implementation date of the Standards. During this time, the Standards will not be in effect, but registrants can apply for authorization to engage in psychotherapy reserved practice through their Online Portal. This will allow registrants to obtain authorization before implementation.

Please note:if you apply and are approved for authorization to engage in psychotherapy reserved practice before the implementation date, you must immediately follow all requirements as outlined in the Standards, even though the Standards will not yet apply to all registrants.

Phase 2 – Implementation: after the implementation date, an occupational therapist will need to be authorized by the Regulator to engage in psychotherapy or use any psychotherapeutic approaches in their practice.

This Consultation

The purpose of this document is to explain the practical effects of these changes for occupational therapists. Until March 6, 2026, registrants and stakeholders may provide feedback on the proposed changes and requirements. In particular, we are seeking feedback on:

1. how the changes may affect your practice
2. any difficulties you perceive in applying the new requirements/standard to your practice
3. whether the requirements are clearly explained and any points of confusion

Please note that the information shared in this survey is for consultation only and is subject to change. All responses are anonymous and confidential. Thank you in advance for your contribution to this process.

What is Psychotherapy?

Psychotherapy involves developing a therapeutic relationship with a client where specific psychotherapeutic approaches are applied to collaboratively assess and address a client’s thoughts, emotions, and/or behaviours.

The Standards for Psychotherapy apply to occupational therapists who use psychotherapeutic approaches, including psychotherapy. The Standards do not apply when occupational therapists are using approaches that are not psychotherapeutic, such as health teaching, supportive listening, and coaching.

Psychotherapeutic Approaches

NSOTR recognizes that psychotherapy is not a single, defined clinical act, but instead comprises many separate evidence-based psychotherapeutic approaches, clinical protocols, and therapeutic techniques.The use of any psychotherapeutic approach, protocol, or technique is considered the practice of psychotherapy, and requires specific, formal training in that approach in order to practice safely.

Authorization from NSOTR to engage in psychotherapy reserved practice is not authorization to engage in all psychotherapeutic approaches. When authorizing a registrant to engage in psychotherapy reserved practice, NSOTR will also specify which listed psychotherapeutic approach or approaches they are authorized to use in their practice. A preliminary list is below:

Listed Psychotherapeutic Approaches

• Acceptance and Commitment Therapy (ACT)
• Behavioural Family Therapy (BFT)
• Brief Psychodynamic Therapy (BPT)
• Cognitive Behavioural Therapy (CBT)
• Cognitive Processing Therapy (CPT)
• Dialectic Behavioural Therapy (DBT)
• Exposure and Response Prevention (ERP)
• Eye Movement Desensitization and Reprocessing (EMDR)
• General/Good Psychiatric Management (GPM)
• Intensive Short-Term Dynamic Psychotherapy (ISTDP)
• Interpersonal Therapy (IPT)
• Prolonged Exposure Therapy (PE)
• Short-Term Dynamic Psychotherapy (STDP)
• Solution Focused Therapy (SFBT)
• Somatic Experiencing (SE)

A registrant can only practice a listed psychotherapeutic approach if they are authorized to do so by NSOTR. To obtain authorization, you must provide evidence that you have completed acceptable training in that approach. You can add a listed approach to your authorization at any time by providing NSOTR with proof you meet the training requirement, without having to pay a fee.

Please note: some listed approaches encompass multiple related protocols, modalities, or techniques. For example, NSOTR considers “Exposure Therapy” to be a modality of Cognitive Behavioural Therapy (CBT). Therefore, once approved to engage in CBT, a registrant does not need to get a separate authorization to use Exposure Therapy.

However, regardless of NSOTR’s authorization, registrants are always expected and required to ensure they practice psychotherapy within their personal scope. In the above example, a registrant is still professionally responsible to complete specific training in Exposure Therapy before using that modality with clients.

Other (Unlisted) Approaches

NSOTR recognizes it is not possible or practical to provide a comprehensive list of all psychotherapeutic approaches used in clinical practice. Authorized registrants may also use additional, unlisted psychotherapeutic approaches in their practice. However, they must still:

1. complete appropriate training in the approach
2. be authorized by NSOTR to practice at least one listed approach
3. declare which non-designated approaches they use when they apply for authorization and at annual renewal.

An example of an unlisted approach is Comprehensive Behavioural Intervention for Tics (CBIT). CBIT is an established modality, but is not listed at this time due to the specific nature of the clinical protocol and small client base. NSOTR may change which approaches are listed over time as circumstances change.

Training Requirement

Occupational therapists must obtain and maintain competence in each psychotherapeutic technique they intend to use. For this reason, authorization to practice psychotherapy has a basic training requirement.

To be eligible for authorization, you must complete at least fourteen (14) hours of practical, theoretical, and instructor-led training in each listed psychotherapeutic approach which you use in your practice. At least seven (7) of the fourteen (14) hours must be from one course.

To be acceptable, a training course must be:

• “Instructor-led”: not self-taught, designed and presented by a regulated health professional with psychotherapy in their regulatory scope of practice and who is trained in the psychotherapeutic method being taught.
• “Theoretical”: based on psychotherapeutic theories and includes theoretical content.
• “Practical”: includes instruction on the practical application of a psychotherapeutic approach in clinical care and treatment of clients.

When you apply for authorization, you will need to give NSOTR information about your training courses and provide proof of completion. For clarity, you do not need to submit every training course in psychotherapy you have ever taken – only enough to meet the requirements of this policy.

Example

Sheila uses three listed psychotherapeutic approaches in her role as a clinical therapist with NSH: Cognitive-Behavioural Therapy (CBT), Acceptance and Commitment Therapy (ACT), and Dialectical Behavioural Therapy (DBT). She provides NSOTR proof that she completed the following courses:

CBT: Sheila completed 50 hours of training in CBT through NSH’s PCTEL Program. Sheila meets the training requirement for CBT.
DBT: Sheila completed an 8-hour “Intro to DBT” course and two 4-hour advanced seminars on DBT through the CAOT. Sheila meets the training requirement for DBT.
ACT: Sheila completed a 4-hour “Intro to ACT” seminar. Sheila does not meet the training requirement for ACT. She must complete an additional 10 hours of training, including a course on ACT that is at least 7 hours long.

In this example, Sheila would be eligible for authorization to practice psychotherapy, using the listed psychotherapeutic approaches of CBT and DBT. Sheila will be eligible for authorization to use ACT after completing additional training.

Clinical Psychotherapy Supervision

Once authorized to practice psychotherapy by NSOTR, you must complete a period of Clinical Psychotherapy Supervision.

Alternatively, you can provide NSOTR with proof that you previously completed a period of supervision that meets the below requirements by having your former/current supervisor sign NSOTR’s Supervision Attestation Form.

Clinical Psychotherapy Supervision involves:

• a formal, intentional arrangement where an experienced and qualified provider of psychotherapy assists the authorized registrant in their professional growth
• a structured process to support foundational competence and support in the practical application of theory to practice
• regular meetings and supervision activities
• clear record-keeping of all supervision activities

Clinical Psychotherapy Supervision is different from:

• General (or “managerial”) supervision: an employee can receive clinical psychotherapy supervision from a manager or team leader in their workplace, but this is not required. A clinical supervisor does not necessarily have the same oversight responsibilities as a manager.
• Consultation peers, colleagues, or other professionals: consultation is less structured than clinical psychotherapy supervision.
• Supervision of students and/or new graduates: clinical psychotherapy supervisors are not responsible for supervising the entirety of the supervisee’s practice (as with new graduates), or fully responsible for their practice (as with students).

Why is there a Supervision Requirement?

Most regulated health professions that practice psychotherapy require a minimum period of Clinical Psychotherapy Supervision to develop foundational competence and support safe and effective services.

This Clinical Psychotherapy Supervision requirement is based on the requirements of other Nova Scotia health professional regulators but applied to an occupational therapy context.

Supervision Requirement

The supervision requirement is fifty (50) hours of formal, regular, and practical supervision in psychotherapy over the course of at least one (1) year of psychotherapy practice.

• “Formal”: there was a signed, structured agreement between the supervisor and supervised registrant to establish expectations.
• “Regular”: supervision activities occur regularly throughout the period of supervision, allowing the supervised registrant time to integrate feedback into their practice.
• “Practical”: supervision activities must concern the direct clinical application of psychotherapeutic approaches and techniques, relevant to the registrant’s practice, such as through client-specific consultation, case review, or direct observation of clinical practice.

Eligible supervision activities must be direct, real-time communication between the supervisor and supervised registrant(s), either in-person or via secure videoconference. Group supervision activities are allowed, but at least twenty (20) supervision hours must be one-on-one communication between the supervisor and supervised registrant or direct observation of clinical practice. Groups must be small enough to allow all supervised registrants to meaningfully participate and discuss their own clinical practice in each meeting.

Timeline

You must complete the supervision requirement within two (2) years of the date you are authorized to engage in psychotherapy. Any periods where you are not authorized are not counted towards this deadline.

A registrant can request an extension to the deadline due to special circumstances, up to a maximum extension of two (2) years, after which time you may be required to complete the training requirement again.

You must still receive regular supervision until you have completed at least one (1) year of supervised psychotherapy practice, even if you complete 50 hours of supervision activities early.

If you do not provide proof to the Regulator that you have met the supervision requirement within two (2) years from the date of authorization, your authorization to engage in reserved practice will be immediately cancelled and your employer will be notified. You may also need to complete additional documents, requirements, or training in order to be eligible for re-authorization.

What Happens If I Stop Practicing Psychotherapy or Lose My Supervisor?

If you have not met the supervision requirement, you cannot practice psychotherapy without an active clinical psychotherapy supervision agreement.

In addition, until you complete the supervision requirement, you must have a clinical psychotherapy supervisor and be actively practicing psychotherapy in order to maintain your authorization. If NSOTR finds that you do not have an approved supervisor, we may immediately cancel your authorization.

During this supervision period, if you no longer have a supervisor or you stop practicing psychotherapy (due to unemployment, leave, etc.), you must notify NSOTR. Your authorization will be automatically paused.

When you locate a new supervisor and/or want to begin practicing psychotherapy again, you can apply to renew your authorization. At that time, NSOTR will accept any supervised practice and supervision hours which you completed in the previous 3 years towards your supervision requirement.

Example: Aida completes six months of supervised practice and 20 hours of supervision activities and then changes jobs and stops practicing psychotherapy (meaning she loses her authorization). When she renews her authorization to practice psychotherapy a year later, she must complete another 30 hours over at least six months of supervision.

Requirements to Act as a Supervisor

A Clinical Psychotherapy Supervisor must be a regulated health professional who:

1. Is licensed and in good standing with a health professional regulator in any province or territory of Canada;
2. Has a professional scope of practice that includes psychotherapy;
3. Has practiced psychotherapy for at least 2 years prior to the start of supervision;
4. Is not related to the supervisee;
5. Is permitted by their professional regulator to supervise the practice of psychotherapy by an occupational therapist, and;
6. Has competence in the specific psychotherapeutic approach(es) being utilized by the occupational therapist.

The following regulated health professionals may be qualified to act as a supervisor for psychotherapy reserved practice:

1. Counselling Therapist or equivalent regulated profession authorized to practice psychotherapy;
2. Psychologist;
3. Physician or Psychiatrist;
4. Occupational Therapist;
5. Social Worker;
6. Registered nurse;
7. Nurse practitioner;
8. Registered psychiatric nurse.

An occupational therapist who is licensed with NSOTR must also meet the following requirements to be a supervisor:

Supervision completed before the implementation date of the Standards:

1. hold a practicing licence on the practicing register;
2. have at least 3 years of full-time practice experience in occupational therapy prior to the start of supervision.

After the implementation date of the Standards:

1. hold a practicing licence on the practicing register;
2. have at least 3 years of full-time practice experience in occupational therapy;
3. be authorized to engage in psychotherapy reserved practice;
4. have completed the supervision requirement;
5. not be subject to an ongoing regulatory process that, in the opinion of the Registrar, may affect their suitability to serve as a supervisor for psychotherapy reserved practice.

Psychotherapy Currency and Continuing Competence Requirements

A registrant with an authorization to practice psychotherapy must maintain currency in the psychotherapeutic approaches they use in their practice by:

• actively practicing psychotherapy; and
• completing professional development and continuing education activities related to the practice of psychotherapy annually.

At renewal, all registrants with an authorization to practice psychotherapy must declare the following:

• whether they have practiced psychotherapy within the past year;
• the psychotherapeutic approaches (designated and non-designated) they are using in their practice;
• whether they wish to maintain their reserved practice authorization;
• that they have reviewed the Standard for Psychotherapy and are aware of the requirement to engage in professional development annually.

To maintain your authorization, you must have practiced psychotherapy within the past three years while being licensed with a Canadian health professional regulator.

Non-Compliance

If NSOTR finds that an authorized registrant is not engaging in professional development and continuing education activities related to the practice of psychotherapy on an annual basis, we may require that registrant to complete specific activities in a set amount of time to maintain their authorization. Failure to maintain currency or complete appropriate professional development may result in the cancellation of an authorization to practice psychotherapy.

Delegation and Assignment of Psychotherapeutic Components

Based on feedback from consultation on the draft Standards for Psychotherapy, NSOTR is proposes the following rules for delegation and assignment of psychotherapeutic components:

1. An occupational therapist cannot delegate psychotherapy.
2. An occupational therapist may assign non-psychotherapeutic elements of an intervention related to a psychotherapeutic approach (e.g. going for a walk with a client to support a CBT goal) to support personnel as per the Standards for the Assignment of Service Components to Support Personnel. The occupational therapist retains responsibility for the components completed under this assignment.
3. An occupational therapist should never assign a psychotherapeutic intervention to support personnel.

Proposed Definitions:

Assignment: The process by which an occupational therapist designates a support personnel to carry out a specific activity related to the occupational therapy service. This activity is within the typical employment scope of the support personnel. The assigning occupational therapist still remains accountable for the provision of occupational therapy services to the client, including those tasks assigned to support personnel. The occupational therapist is responsible for ensuring that the support personnel has the appropriate skills and knowledge to perform the assigned activity safely and effectively, and must assign tasks in keeping with the requirements outlined in the NSOTR Guideline for Assigning Tasks to Support Personnel.

Delegation: The process by which an occupational therapist provides/receives authority to perform an activity to/from another regulated health professional. A delegated activity is one that outside of the typical scope of practice for the regulated health professional receiving the delegation, but must be within the legislative and regulatory scope of practice for the regulated health professional delegating the activity. The regulated health professional receiving the delegation must have the appropriate skills and knowledge to perform the delegated activity safely and effectively.

Use of Title

To ensure accountability to the profession and clarity for clients and other professionals, occupational therapists who practice psychotherapy must clearly identify that they are occupational therapists in the title that they use, both verbally and in writing.

Occupational therapists in Nova Scotia cannot use the title “psychotherapist” when describing themselves or their practice. Occupational therapists wishing to indicate that they providing psychotherapy can denote this by using one of the following titles:

First name Last name, Occupational Therapist, practicing psychotherapy
First name Last name, OT Reg. (N.S.), practicing psychotherapy

Occupational therapists who practice psychotherapy in a position with a job title other than “Occupational Therapist” (such as “Clinical Therapist”, etc.), must list that they are an occupational therapist first. For example:

First Name Last Name, OT Reg. (N.S.), Job Title
First Name Last Name, Occupational Therapist, Job Title

The reason for this requirement is that while psychotherapy is reserved practice for NSOTR registrants, psychotherapy falls into the scope of occupational therapy. An occupational therapist who practices psychotherapy is practicing occupational therapy. Therefore, you must clearly use occupational therapist title when offering psychotherapy services.