Newly Released Records Regarding CPBAO’s Proposed Changes

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The following is an editorial written by a group of concerned individuals. It is posted here in its entirety to provide an easily accessible and anonymous platform for their comments regarding the manner in which changes to the profession are being made. 

Dear psychologists of Ontario,

New records obtained through recent freedom-of-information (FOI) requests raise questions about the CPBAO’s leadership, the influence of the Office of the Fairness Commissioner (OFC), and the evidence underlying proposed changes to psychology regulation. The proposed regulatory amendments remain before the Ministry of Health awaiting a decision. These records obtained through FOI matter because they provide information that psychologists, the public, stakeholders, and government should consider before a decision is made.

Two batches of records received via FOI are contained on this webpage: (1) correspondence and related records received from the OFC; and (2) correspondence received from the Centre for Addiction and Mental Health (CAMH).

First, records from the OFC raise several significant questions and concerns:

1. The OFC appears to have been a significant driver of the proposed changes to psychology registration.

The CPBAO’s independent Board effectiveness review found that Registration Modernization was driven “to a large degree” by the OFC and that several Board members viewed the decision before them as inevitable. These findings make the evidentiary basis for the OFC’s recommendations particularly important. The OFC’s 2024 risk-rating report included on this page provides a starting point for understanding the changes it was seeking and the evidence it relied upon.

2. The CPBAO’s Registrar challenged the OFC’s evidence himself.

In April 2024, Dr. Tony DeBono, then Registrar & Executive Director of the College of Psychologists of Ontario, now the CPBAO, raised significant concerns with the OFC about its analysis and recommendations related to the College’s risk rating. His emails and the OFC’s meeting notes, reproduced below, are particularly notable because many of the arguments he advanced closely resemble concerns later raised by psychologists and institutional stakeholders. The FOI documents reveal that the Registrar argued:

• Increasing the supply of psychologists would not, by itself, necessarily improve access to psychological services. The Registrar pointed to Ontario’s existing workforce of regulated professionals providing psychotherapy and mental-health services. He argued that access problems therefore cannot be understood simply as a shortage of psychologists, pointing instead to factors including the movement of psychologists from public to private practice and differences in compensation;

• The OFC’s reliance on the Canadian Occupational Projection System (COPS) was insufficient to explain Ontario’s workforce challenges. The Registrar argued that projections were not a substitute for a comprehensive economic analysis, including consideration of differences between private and public sector employment and compensation;

• Many existing Master’s programs in Ontario did not prepare graduates adequately for independent psychology practice. He reported that Ontario training directors overwhelmingly indicated that their programs did not train students to the competencies required for independent practice at the Master’s level;

• Psychology training varied considerably across jurisdictions. The Registrar argued that different training pathways should not be assumed equivalent simply because they lead to use of the same “psychologist” title;

• Supervised practice was an important safeguard for competency and public protection. In responding to the OFC’s criticism of the 1,500-hour Ontario supervised-practice requirement for internationally trained applicants, the Registrar defended it as necessary preparation for independent practice, particularly given variability in applicants’ prior training.

Importantly, these concerns were also reflected in the College’s own Closure of Master’s Level Registration Report, presented at its March 21, 2024 Council meeting and approved for submission to the Ministry of Health. Building on years of consideration by the College, the 14-page report drew on interviews with 15 Ontario training directors and the College’s registration, appeals, complaints, and workforce data. It supported closing Master’s-level registration and explicitly linked doctoral preparation to competency and public protection. It identified substantial variability in Master’s-level preparation for independent practice and questioned the evidence that closing this registration route would reduce the workforce in public settings such as education and corrections.

3. The records reveal a striking change in position.

By 2025, the CPBAO was advancing proposed regulatory changes that departed substantially from the position set out in its March 2024 report and defended by the Registrar in his subsequent correspondence with the OFC. Sixteen months after that correspondence, CAMH raised overlapping concerns about training, competency, and public protection. The Registrar’s response to CAMH was markedly different from the position he had advanced in 2024. What new evidence or analysis explains this shift? The records released do not provide an answer.

Timeline of Documents

OFC Documents

April 12, 2024: The OFC’s notes of a meeting between College representatives, including the Registrar, and representatives of the OFC record the Registrar questioning a central premise underlying the OFC’s analysis: whether increasing the supply of psychologists would improve access to psychological services in Ontario. The notes record him questioning whether increased supply would resolve Ontario’s labour-market shortage and stating that he had no evidence that saturating the market with psychologists would improve access to care for vulnerable people.

April 27, 2024: In an email to the OFC, the Registrar raised concerns about what he described as the OFC’s “preconceived negative biases” regarding psychology regulation. He said the OFC’s conclusions appeared to be based on opinion rather than evidence and failed to cite relevant data that the College had made publicly available.

April 29, 2024: The Registrar escalated his concerns. He told the Fairness Commissioner that the College Council was well informed about a year of data concerning the “risks of the Master’s class,” none of which he said the OFC had cited. He requested that any further discussion be “data-driven and not ideological in nature.”

April 30, 2024: In a detailed response to the OFC, the Registrar:

• Expressed “significant concerns” about the OFC’s assessment and apparent bias writing: “I am both disappointed and concerned with the OFC’s assessment in terms of its partiality, low level of fairness, and reliance on opinion”;
• Strongly refuted the OFC’s criticism of the College’s doctoral requirement and approach to remediation;
• Reported that Ontario programs did not prepare Master’s-level graduates for the competencies required for safe independent practice;
• Challenged the OFC’s reliance on Alberta as a comparison, writing: “Alberta is the outlier, but there is no mention of every other province. A data point was selected to confirm a particular narrative at the exclusion of other data not consistent with the bias”;
• Defended Ontario supervised practice for internationally trained applicants as a “much-needed mentorship and preparatory period to ensure safe practice”; and
• Warned that the “current state and the pressured future state” would not advance quality and safety for the Ontario public.

Throughout April 2024, the Registrar challenged the OFC’s evidence while defending doctoral preparation and supervised practice on competency and public-protection grounds.

Sixteen months later, CAMH raised overlapping concerns.

CAMH Documents

August 11, 2025: The incoming and outgoing Chiefs of Psychology at CAMH, together with CAMH’s Chief Medical Officer, signed a letter expressing strong opposition to the proposed registration changes. They warned that removing the doctoral requirement, shortening supervised practice, weakening accreditation standards, and eliminating defined scopes of practice could compromise quality, safety, and public protection. The letter was sent to the CPBAO on August 12. These concerns resembled those the Registrar had raised with the OFC in April 2024.

August 13–14, 2025: The Registrar responded by describing CAMH’s message as insufficiently “nuanced and data driven,” raised the possibility that the letter could be subject to Ministry of Health review, and sought clarification about whether the letter represented CAMH as an institution. On August 14, after CAMH’s Chief Medical Officer confirmed that the signatories had written in their CAMH leadership roles and that the letter was “on behalf of CAMH,” the Registrar said he would inform the appropriate government officials of CAMH’s stance.

August 17, 2025: The Registrar escalated the matter to CAMH’s President and CEO. He characterized CAMH’s position as a “biased opinion” and an “uncaring perspective,” asked that his “deep disappointment” be shared with the Chair of CAMH’s Board, and suggested that the letter could cause harm to Master’s-level staff. The CEO acknowledged receipt on August 20.

January 6, 2026: Following the CPBAO’s public consultation, the Registrar again challenged CAMH’s position. The contrast is notable. Concerns about training, competency, and public protection that the Registrar had raised with the OFC were later raised by CAMH but met with a markedly different response. The records released to date do not explain what changed.

Why These Records Matter

The significance of these records extends beyond the Registrar’s disagreement with the OFC. The concerns he raised in 2024 about evidence, access, training, competency, and public protection closely resemble concerns later raised during the CPBAO’s consultation period, which ran from October 10 to December 9, 2025.

1. How evidence was selected and presented. In April 2024, the Registrar criticized what he described as the OFC’s “appearance of bias in specifically not citing quantitative and qualitative data that were collected and made available to both the public and the OFC prior to the release of your report” (April 30 email). He also questioned the OFC’s reliance on Alberta as a comparator, arguing that its analysis did not adequately consider evidence that pointed in a different direction.

Similar concerns were later raised about how evidence was presented when the CPBAO considered the proposed changes. At its pivotal December 12, 2025 meeting, relatively little of the extensive public and professional consultation feedback was discussed, and the little specific feedback that was discussed in the meeting was generally supportive of the changes despite being the minority opinion during the consultation period. Of 21 institutional letters received, 17 opposed the changes and four supported them. One of the supportive letters, from the Northwest Territories, was specifically highlighted by the Registrar and referenced again in his January 6, 2026 correspondence with CAMH.

2. Access and public-sector workforce. In April 2024, the Registrar also challenged the OFC’s analysis of whether increasing supply would resolve Ontario’s access problem. Although the OFC’s report acknowledged differing views about workforce distribution and private practice, the Registrar argued that it had not adequately addressed the underlying economic evidence. He emphasized public/private compensation differences, writing:

“The College should not be blamed for a public market that is not competitive in relation to the private sector. Not a single mention in the report. The OFC’s opinion appears not to have shifted despite evidence that does not support their conclusions” (April 30 email).

This distinction remains central. Increasing the number of individuals eligible for registration is not the same as demonstrating that those individuals will enter or remain in publicly funded settings experiencing access problems.

Questions that Remain Unanswered

The documentary record shows the Registrar’s position in April 2024 and highlights the apparent change in position by August 2025. What it does not show is how the CPBAO got from one to the other. Several important questions remain unanswered:

1. What new evidence shifted the CPBAO away from the position its Registrar articulated in 2024 and what led it to make such significant regulatory changes just a year later in 2025?

2. Why was the CPBAO leadership not transparent with the public and the profession in 2025 about their own reservations about the proposed regulatory changes?

3. Considering the Registrar’s concerns raised in April 2024 and considering his role as Registrar requires maintaining positive relationships with key stakeholders in the province, why did the Registrar believe it productive to criticize the feedback received from experts at CAMH (and possibly other organizations) in the manner that he did?

4. What evidence supported the OFC’s push for changes to psychology registration, particularly regarding online degrees and the supervised practice period, and how were competency and public protection considered in their analyses?

A Call to Action

The proposed regulatory changes remain before the Ministry of Health. If these records raise concerns for you, please consider contacting your local MPP and ask that the Ministry reject the proposed amendments until the evidence and unresolved public-protection questions have been independently reviewed. In particular, you may wish to request:

1. A pause in consideration of the amendments pending further review;
2. An independent review of the evidence and decision-making underlying the CPBAO’s proposed changes, including the role and recommendations of the OFC ;
3. Public release of any additional evidence, analysis, or data considered by the CPBAO between 2024 and 2025 that may explain its significant change in position; and
4. Greater transparency regarding the evidence, analysis, and decision-making that led the CPBAO from its 2024 position to the substantially different regulatory approach advanced in 2025 . 

Find your local MPP here.

Personalize your message with your clinical, supervisory, educational, or institutional experience. Keep correspondence professional, evidence-focused, and centered on the public interest. Do not include identifiable patient information.

This is a call for accountability. Consequential changes to psychology regulation should be supported by transparent evidence, independent and accountable decision-making, and a clear demonstration that access, competency, and public protection have all been adequately considered. The OFC’s recommendations should likewise be evidence-based, proportionate, and appropriately grounded in its fair-registration mandate.

Attached are:

• Dr. DeBono’s April 27, April 29, and April 30, 2024 emails;
• The April 12, 2024 OFC meeting notes as supporting context;
• CAMH’s signed August 11, 2025 letter;
• Email correspondence between the Registrar and CAMH leadership from August 12, 2025 to January 6, 2026;
• The CPBAO’s 2026 independent third-party assessment of Board effectiveness;
• The College’s Closure of Master’s Level Registration Report; and
• The OFC’s April 26, 2024 risk-rating report.

If you or your organization received emails from the Registrar in 2025 or 2026 similar in content or tone to those sent to CAMH leadership, please contact Matt Marshall at mmarshall@mlmj.ca to arrange for their submission for review.

The publication of this editorial is on behalf of, and with the express permission of those who wrote it, and no commentary contained herein should be attributed to Matthew Marshall, Ex Parte Law Professional Corporation, or Marshall Lutz Martin & Jarrett LLP. The preceding content is comment, not statements of fact, based upon true facts, on matters of public interest, which are published without malice.