Critical Considerations for Members in Private Practice Regarding In-Person Practice

The Ontario College of Social Workers and Social Service Workers (the College) is issuing the following considerations for members who work in private practice and are looking for guidance in planning when and how to return to providing in-person services.

As the Province moves forward with stage 1 of its Framework for Reopening, the College has already provided a number of important considerations for all members regarding their return to practice, in both a May 8, 2020 eBulletin and a May 15, 2020 eBulletin.

The College is providing this guidance for members who work in private practice because, under the Closure Regulation, as of May 19, 2020, professionals or organizations that provide in-person counselling services are listed as an essential business. This means that such professionals and organizations may open their business provided that the person responsible for a place of business that is open must operate the business in compliance with the advice, recommendations and instructions of public health officials, including any advice, recommendations or instructions on physical distancing, cleaning or disinfecting.

As noted in our May 29, 2020 eBulletin, on May 26, 2020 Ontario’s Chief Medical Officer of Health replaced the original Directive issued on March 19, 2020 with Directive #2 for Health Care Providers under the Health Protection and Promotion Act. The new Directive allows health care providers to gradually return to in-person practice, provided that they comply with the requirements set out in the COVID-19 Operational Requirements: Health Sector Restart. While it is important to note that this communication from the Ministry of Health does not directly apply to College members, we believe that it is relevant.

In these unprecedented times, the College has decided that it is important to comment on some specific practices that members who are in private practice (that is, members who are not employed by an organization) should use when they resume in-person practice; we are providing the following recommendations in an effort to protect the health and well-being of our members and the Ontario public. We remain committed to providing practice support to our members as part of our ongoing mandate of public protection.

General considerations

Members in private practice must use their professional judgment to determine whether it is appropriate for them to resume in-person services at this time. Members should consider the safety and infection control measures that must be in place to ensure their own safety and that of the clients and communities they serve.

While resuming in-person services may be permitted, it is not required. Members are advised to use their professional judgment and to continue – wherever reasonably possible – to provide services by electronic means.

Members must consider a number of factors as they decide how and when they will return to in-person practice. We encourage them to use the ETHICS-A: Ethical Decision-Making Tool to assist them in applying their professional judgment to this important decision. Members should also consider the following principles, described in the Ministry of Health’s Directive #2:

Proportionality: Decision to restart services should be proportionate to the real or anticipated capacities to provide those services.
Minimizing Harm to Patients: Decisions should strive to limit harm to patients wherever possible.
Equity: Equity requires that all persons with the same clinical needs should be treated in the same way unless relevant differences exist.
Reciprocity: Certain clients and client populations will be particularly burdened as a result of our health system’s limited capacity to restart services. Consequently, there is a reciprocal obligation to ensure that those individuals who are the most vulnerable receive appropriate care.

Safety protocols

Members in private practice should carefully consider how to implement the following safety protocols before returning to in-person practice:

Screening/self-screening

Conduct regular self-screening.
Conduct screening of clients and any individual accompanying a client by asking if they have been experiencing symptoms of illness consistent with COVID-19 prior to booking appointments.
Conduct screening of clients and any individual accompanying a client for symptoms of COVID-19 at the office/physical practice location.
Place signage within the workplace reminding clients about the signs and symptoms of COVID-19, what to do if they feel unwell and how to protect themselves (e.g., hand hygiene, etc.).
Inform clients that the limits of confidentiality may include the requirement to disclose client names, appointment dates, time of entry and departure to Public Health to aid in contact tracing should a member become aware that a client has a confirmed infection.

Physical distancing and Personal Protective Equipment

Maintain physical distance of at least 2 metres between all persons, including clients.
Schedule appointments in a staggered manner to limit, whenever possible, overlap with clients in waiting area(s).
Ensure appropriate spacing between seating in waiting area(s).
Consider alternative options to having clients in the waiting area(s). This could include, for example, asking them to wait in their vehicles or outside prior to their appointment.
Consider limiting the number of individuals accompanying the client to the office/physical practice location to only those who are essential.
Ensure appropriate spacing in client meeting rooms/office.
Establish contactless methods of payment to ensure physical distancing is kept during the payment process.
Consider whether and when to use personal protective equipment (PPE) themselves.
Ensure they are competent with respect to safely putting on, using, removing and disposing of PPE. Members can learn more about proper PPE procedures from the Public Services Health and Safety Association’s COVID-19 Resource Centre.
Consider whether and when to request that clients wear PPE.
Consider whether and when it would be appropriate to provide PPE in waiting area(s).
Establish alternative protocols in the event that a client cannot tolerate wearing PPE, or if there is no PPE available (e.g., cancelling an in-person appointment, providing services by electronic means etc.).
Clearly communicate with all clients regarding policies and protocols around the use of PPE.

Environmental cleaning and disinfection of work space

Using the links to resources set out further below, develop and maintain cleaning best practices to be undertaken prior to the provision of in-person services and upon clients’ departure from the office/physical practice location.
Provide hand sanitizer both in waiting area(s) as well as client meeting room/office space.
Eliminate or reduce the number of items provided in waiting area(s) and the office/physical practice location (e.g. magazines, pamphlets, toys, etc.).
Communicate to clients regarding best practices that are being followed with respect to cleaning and disinfection; this should include signage in the waiting area(s) as well as other forms of communication (email, etc.).

Government and public health authorities resources

We continue to advise all members to seek additional information and guidance from government and public health authorities. A number of relevant COVID-19 resources can be found below:

Thank you for your continued commitment to the well-being of the clients and communities that you serve. We will continue to provide considerations and updates to members as circumstances change.

Keep well.

Lise Betteridge, MSW, RSW
Registrar and CEO