Student Suitability to Practice

Purpose of the Policy

Conferral of a degree from Adler Graduate Professional School (AGPS) indicates to the regulatory colleges and the public at large that Adler Graduates are suitable to practise professional psychology in an ethical way, and that they could be deemed eligible to apply for registration with the College of Psychologists of Ontario as Psychologists or Psychological Associates, in accordance with the Regulated Health Professions Act, 1991, S.O. 1991.

Students in the professional psychology programs at AGPS should be aware from the beginning of their program that the School has an ethical obligation to the public to ensure that graduates of our programs are competent, ethical practitioners, and that they will be evaluated on more than just academic performance. 

Because of this commitment, AGPS faculty and administrators strive not to advance graduate students about whom they have demonstrable concerns around issues that may interfere with professional competence to the profession, employers, or the public at large. 

Students must demonstrate they are suitable to:

• Deliver psychological services in a practicum placement under the supervision of a registered member of the CPO according to the policies of AGPS
• Practise professional psychology and psychotherapy in the Province of Ontario after graduation, through registration with The College of Psychologists of Ontario

Any student registered in the program should be advised prior to registering for courses that these standards are in place, and that they will also be evaluated outside of their academic achievement in the program against these standards. 

These standards are based on the following documents:

• Adler Graduate Professional School Code of Conduct
• Canadian Psychological Association. (2017). Canadian Code of Ethics for Psychologists, Fourth Edition 
• College of Psychologists of Ontario. (2027). Standards of Professional Conduct.

Scope

This policy applies to all students registered in the Master of Psychology in Clinical Psychology (MPsy-PSY), and the Doctor of Psychology (PsyD) programs at Adler Graduate Professional School (AGPS), or anyone who would be eligible to apply for registration with the College of Psychologists of Ontario using academic credentials granted by Adler Graduate Professional School. 

Suitability to Practise Statement

A student who is suitable to practise professional psychology should demonstrate the following:

• Respect for the Inherent Dignity and Worth of People
• Pursuit of Social Justice
• Service to Humanity
• Integrity in Professional Practice
• Confidentiality in Professional Practice
• Competence in Professional Practice 
• Adherence to the Standards of Professional Practice for Psychologists in Ontario

Considerations

The application of this policy should be understood in a developmental framework. Where possible the goal of requesting a suitability to practise review should be to determine whether intervention and mitigation would allow a student to successfully complete their program, and what form those interventions could take. 

The student must have received a minimum of one written warning containing both the nature of the concern and information on rectifying the concern, prior to the request for review being made. 

Unless the concern relates to safety of either the student, another member of the community or the public, the Academic Performance Report or Academic Conduct Report processes should be followed first. 

The Dean or Director of the program reserves the right to redirect a concern to either of those processes for an attempt to resolve the issue before proceeding to the STPC after reviewing the request. 

Requests for review, and the actions of the Suitability to Practise Review Committee should have regard for the inherent power difference between students and the faculty and members of the administration. 

Evaluation of Suitability to Practise

Students should be made aware during onboarding, and through the Academic Calendar,  that the program faculty, training staff, and supervisors will evaluate their competence in areas other than, and in addition to, coursework, seminars, scholarship, comprehensive examinations, or related program requirements.  These evaluative areas include, but are not limited to, demonstration of sufficient: 

1. interpersonal and professional competence (e.g., the ways in which students relate to clients, peers, faculty, allied professionals, the public, and individuals from diverse backgrounds or histories); 
2. self-awareness, self-reflection, and self-evaluation (e.g., knowledge of the content and potential impact of one’s own beliefs and values on clients, peers, faculty, allied professionals, the public, and individuals from diverse backgrounds or histories); 
3. openness to processes of supervision (e.g., the ability and willingness to explore issues that either interfere with the appropriate provision of care or impede professional development or functioning); and 
4. resolution of issues or problems that interfere with professional development or functioning in a satisfactory manner (e.g., by responding constructively to feedback from supervisors or program faculty; by the successful completion of remediation plans).
5. Commitment to honesty, integrity, trustworthiness, and attention to professional obligations. 

Application

This policy is applicable to settings and contexts in which evaluation would appropriately occur (e.g., coursework, practica, supervision), rather than settings and contexts that are unrelated to the formal process of education and training (e.g., external social contexts).  However, irrespective of setting or context, when a student-trainee’s conduct clearly and demonstrably impacts the performance, development, or functioning of the student, raises questions of an ethical nature, represents a risk to public safety, or damages the representation of psychology to the profession or public, appropriate representatives of the program may review such conduct within the context of the Suitability to Practise Review Process.

All allegations must be investigated according to the procedures in this policy. 

Grounds for a Review Request

A member of the faculty or administration can request a review of a student’s suitability to practise, and to continue in the program on suspicion of the following concerns. 

1. False, distorted or misleading information submitted as part of an application for admission to AGPS, or an application for approval of a Practicum Placement in any program at AGPS
2. behaviour contrary to
   1. The ADLER Code of Conduct, or 
   2. The Code of Ethics of the Canadian Psychological Association (Canadian Psychological Association, 2017), or
   3. The College of Psychologists of Ontario Standards of Professional Conduct (2017)
3. Harassment or any threat, intimidation or attempt to harm another person;
4. Serious or repeated unethical behaviour in a professional or academic context
5. An inability to effectively exercise judgement or function in a professional or academic context;  
6. Evidence of persistent and/or serious inability to form or maintain professional relationships;  
7. evidence of discriminatory behaviour, or a persistent lack or inability to reflect about behaviour or lack of effort to change behaviour identified as discriminatory;  
8. persistent abuse or misuse of substances that interferes with the ability to function within a professional or academic context;  
9. criminal behaviour (a charge and/or conviction for crimes such as physical assault, sexual assault, drug trafficking, for which a pardon has not been received) which would interfere with the ability to function within a professional context;
10. Serious, significant or persistent conduct prohibited by any policy of a placement setting which cannot be resolved through negotiation;
11. Any allegation from one or more clients or supervisors in a practicum setting, fellow students,  faculty members, members of the public, or members of the administration alleging conduct which demonstrates a breach of professional suitability in terms of professionalism or ethics
12. Faculty or external supervisors allege that the student has show evidence of inappropriate incompetency
    1. As defined by the Regulated Health Professions Act, 1991, a person is incompetent if they display a lack of knowledge, skill or judgement of a nature or to an extent that demonstrates that they are unfit to continue to practise

Suitability to Practice Review Committee (STPC) Procedures

The Suitability to Practice Review process is an internal process of Adler Graduate Professional School. It is not a legal proceeding and no party can be represented in the process by legal counsel. Interviewees may be accompanied by a support person. This person cannot participate in the proceedings and cannot be a legal representative of the individual being interviewed.

Adler Graduate Professional School is a private degree-granting educational institution in the Province of Ontario. Decisions to confer degrees on a given student rest solely with the academic faculty of AGPS, and is at their discretion.

Primary Responsibilities

The primary responsibility for the Suitability to Practice Review Process rests with the Director of the Program in which the student is registered.

A member of the faculty cannot be disqualified from sitting on a STPC because of previous or possible future contact with the student. The STPC process is considered evaluation as part of the program in which the student is registered, and all program faculty are authorised by AGPS to evaluate students.

Suitability to Practise Review Committee (STPC)

Committee Chair

The Committee Chair is appointed by the Director of the Program in which the student is registered. They should, when possible, be an Adler Faculty Member. They must have experience teaching psychology in an academic program. They must be a member in good standing of the College of Psychologists of Ontario, and not currently teaching or supervising the student.

The Committee Chair will:

• Consult with the Program Director on the appointment of the two Committee Members
• Be the main point of contact for the student during the process
• Inform the student of the concerns being reviewed
• Advise the students what documentation and evidence they can submit to the committee
• Invite the student to an interview
• Lead the STPC process
• Deliver the report and recommendations to the Program Director

Committee Members

Two Committee Members will be appointed by the Program Director in consultation with the Committee Chair. The Committee Members will be members in good standing of the College of Psychologists of Ontario, and when possible be Adler Faculty Members.  They should not be currently teaching or supervising the student. 

Interim Sanctions

The Dean or Director of the program, in consultation with faculty and administrators may decide to remove a student from program components such as classes or practicum placements for the duration of an investigation, if there is cause to believe there is a risk of harm to either the student, other members of the school community, or members of the public. 

Suitability to Practice Review Request Process

Any Adler Faculty Member, or member of the administration, can make a Suitability to Practice Review Request to the Program Director of the program in which the student is registered, based on any of the grounds listed in this policy.

If a faculty member, or member of the administration requests a review of a student’s Suitability to Practice, they must follow the procedures in this policy.

Review Request Steps

1. The individual requesting the review must ensure that the student has received at least one written warning related to the concern for which the review request is being made, to their adler.ca email address
2. Inform the student in writing that a Suitability to Practise Review is being requested, including the reason for the request
3. Make a written request to the Program Director for the program in which the student is registered. The request must include at a minimum:
   1. The name of the student
   2. The context in which the concern arose
   3. Steps which have been taken, including confirmation that the student has been given at least one written warning about the concern
   4. The details of the concern, including any relevant dates, times
   5. Any documentation of the concern
   6. The hoped for outcome of the review process
4. Within five business days of receiving the request the Program Director will
   1. Forward a copy of the request and any additional documentation to the Registrar for storage
   2. Ensure that the student has received a previous warning related to the concern
   3. Appoint a STPC Chair and in consultation with the Chair appoint two additional Committee Members who meet the criteria in this policy
   4. Inform the student in writing to the students adler.ca email address that a request has been made, who has made the Review Request, and the substance of the Review Request
   5. Provide the student with information about the process and next steps
   6. Provide the student with the name of the STPC Chair (after the appointment has been made)
5. Within five business days of the appointment of the full STPC, the STPC Chair will
   1. Contact the student in writing to inform them of the composition of the committee
   2. inform the student in writing of the date, time and location of the interview, with at least ten business days’ notice of the interview;
   3. inform the student of their right to respond to the allegation in writing, and provide any documentation or information they feel is relevant to the STPC Chair;.
   4. Provide an overview of the process;
   5. Call a meeting of the STPC to review the request and materials submitted by the individual making the request, and any school or academic records they feel are relevant
6. Within five business days of being contacted by the Committee Chair, the student must:
   1. Confirm interview date and time with the Committee Chair
      1. The student must make themselves available for an interview with the Committee at a time set by the Committee Chair
      2. If the student chooses not to attend the interview, the review can continue 
   2. Submit to the Committee Chair any materials or documentation they feel would be relevant to the STP Review
7. The STPC may also arrange for interviews with any other individuals they believe would have information or insight relevant to the STP Review.
   1. Interview requests must be made within ten business days of the appointment of the STPC 
   2. All interviews must take place within twenty business days of the appointment of the STPC
8. All  interviews, document reviews, deliberations and consultations must take place within twenty business days of the appointment of the STPC
9. Within fifteen days after the interview with the student, the Committee Chair will deliver a report to the Program Director containing at a minimum:
   1. A summary of the process followed by the STPC, including a list of individuals interviewed,  interview dates, documentation and information reviewed, and dates of STPC meetings
   2. The recommendations of the STPC with regards to the Suitability to Practice of the student, including recommended outcomes of the STP Review Process. The potential outcomes can include but are not limited to:
      1. Academic Sanctions
         1. No sanctions – There may be minor or uncomplicated conditions set for the student, or a monitoring plan in place, but student can continue in the program without major interruption or intervention
         2. Probation – The performance and conduct of the student are monitored for a given period of time, primarily by the Program Director, to ensure compliance with School policy, and the Code of Conduct and the Standards of Professional Practice
         3. Suspension – The student will be removed from all academic and other activities related to the School and Program for a given period of time. There may be stipulations or conditions which the student must meet before they can be reinstated in the program. No school services will be available to the student other than transcript requests
      2. Withdrawal from the program – If the STPC finds that there are no circumstances under which the student could meet the requirements to graduate, or meet the ethical and professional standards of the school required for graduation, they may recommend the student be withdrawn from the program, with or without conditions
10. The Program Director will review the recommendations and discuss with the senior leadership and CEO, and decide to either accept or reject the recommendations. A decision to reject the findings must be approved by the CEO and be accompanied by an alternate plan
    1. Within five business days, the Program Director will inform the student and the individual who requested the review:
       1. by e-mail at an adler.ca email account 
       2. of the decision on the matter and cite the reasons given.

Request to Appointment	Appointment to Student contact	Student Interview			Other Interviews	Report Submitted
5 days	5 days	10-20 Days from appointment			10–20 Days from appointment	15 days after last interview

Committee Procedures

Interviews with the student or other relevant individuals can take place either through School-owned telecommunications platforms or in-person at the School, at the discretion of the STPC Chair.

If the interview takes place through a telecommunication platform, the student must be provided with a link to the meeting a minimum of five business days prior to the interview. 

Students may be accompanied at an interview by one individual. This individual may not function as legal representation for the student and may not participate in the interview. The student must give the Chair the name of any individual who will be accompanying them to the interview a minimum of five business days before the interview. 

The interview is held in closed sessions and the only people allowed to attend are the members of the Review Committee, the student and the individual accompanying them.

Recording of Interviews

An official recording of any interviews or proceedings can be made by the STPC Chair, using technology provided by AGPS and will be made available to the student for appeals or other processes by request. No other recordings can be made of interviews or STPC proceedings.

Appeals Process

A student who disagrees with the findings or recommendations of the STPC may appeal to the Program Director on the basis that the STPC decided in error. They must do so in writing, to the adler.ca email address of the Program Director, within five business days of receiving a notification of outcomes and recommendations from the Program Director.

The Program Director, in consultation with the senior leadership of the academic and administrative departments, or School legal counsel, will determine if there is merit to the appeal, and either grant or reject the appeal request.

If the appeal is granted, the Program Director will appoint an Appeal Reviewer, who meets the requirements for the STPC Chair, who was not involved in the original STPC. This reviewer will have access to all materials and may choose to interview any relevant individuals. The same stipulations apply to interviews and processes as the original STPC process, but the reviewer is not obligated to repeat all interviews.

The Appeal Reviewer  will deliver a recommendation to the Program Director within 20 business days of their appointment. 

If the Program Director accepts the recommendations of the external reviewer, the decision is final and cannot be further appealed. 

Documentation

Records from the STPC process will be stored by the Registrar.

The School may disclose the student record or portions of it to persons or agencies where required by applicable access-to-information and protection-of-privacy laws, by other applicable legislation, or by a court college, summons or subpoena directing the School to release information. The School may also release information to the Ministry of Training, Colleges and Universities or to other government bodies for accreditation purposes, for enrollment audits or in accordance with the requirements of duly constituted professional regulatory and licensing bodies.