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Open Letter to the College of Alberta Psychologists

**APRIL 14 UPDATE: 200 SIGNATURES RECEIVED FROM MOST PROVINCES; PREDOMINANTLY ONTARIO & ALBERTA**
We, the undersigned registered Psychologists across Canada, write to the College of Alberta Psychologists (CAP) to express significant concern regarding Alberta’s current registration practices. Alberta’s standards for education, supervised experience, and examination performance are significantly lower than those upheld by most other Canadian jurisdictions and recommended by national and international regulatory bodies and associations. Furthermore, we are concerned about their standards for the Psychologist title. This divergence seriously threatens public protection, undermines professional competence, and risks creating a national floor for standards that is not supported by evidence or consensus. Our position is grounded in empirical evidence, regulatory precedent, and the principle of public protection.
Alberta’s registration standards are significantly lower than those of other Canadian jurisdictions. Provinces representing over 80% of the Canadian population restrict the title "Psychologist" to doctoral level registrants to ensure the designation reflects advanced education and training. In jurisdictions that permit master’s level registration, practitioners are either granted the "Psychologist" title or are distinguished through differentiated designations (e.g. Psychological Associate or Registered Psychologist vs. Registered Doctoral Psychologist). Alberta’s divergence from other Canadian jurisdictions is highlighted by statements from a U.S.-based doctoral program that states that their institution “has made a determination that this curriculum meets the educational content requirements for licensure or certification as a Psychologist in Alberta. This program does not accept applications from prospective learners who reside in all other Canadian provinces and territories” (California Southern University, 2026). This underscores Alberta’s uniquely permissive registration standards and the potential implications for national consistency, especially under the mobility provisions of the Canadian Free Trade Agreement (CFTA). The CFTA allow practitioners from provinces with lower standards to register in other provinces, undermining local requirements. Unlike medicine, which benefits from a high degree of national consistency in training, certification, and regulatory expectations, psychology currently lacks national standards.. As a result, Alberta’s approach effectively sets a de facto minimum for entry-to-practice qualifications across Canada, with significant implications for public protection and professional credibility.
The prevailing professional consensus is clear: doctoral-level training is necessary for entry to independent practice as a psychologist. This is supported by:
• The Association of Canadian Psychology Regulatory Organizations (ACPRO) Position Statement on the Doctoral Standard for Entry to Practice in Psychology (2020), which states: “Licensure under the title ‘Psychologist’ will be for individuals with an applied doctoral degree in Psychology.”
• The Canadian Psychological Association (CPA) Policy Statement (CPA, 2021), which states: “the doctoral degree should be the entry to practice degree for psychologists throughout Canada.”
• The Association of State and Provincial Psychology Boards (ASPPB), which states that “an applicant for licensure as a psychologist must possess a doctoral degree from a psychology training program” (ASPPB, 2024).
• The American Psychological Association (APA, 2023), which also supports the doctoral degree as the standard for licensure as a psychologist. While supporting master’s-level registration, they explicitly state: “Individuals with a master’s degree in psychology should be licensed under a title that differentiates them from psychologists with doctoral training, such as ‘psychological associate’ or ‘licensed psychological practitioner’” (APA, 2023, p. 10).
The Association of Canadian Psychology Regulatory Organizations (ACPRO) position statement further specifies that registration as a psychologist should require a minimum of 600 hours of pre-degree practicum experience (including at least 200 hours of direct, face-to-face client contact) and a minimum of 1,600 hours in a pre-doctoral internship or residency. These requirements are designed to ensure the development of core professional competencies (ACPRO, 2020). In contrast, Alberta’s current requirements for registration as a psychologist at the master’s level do not mandate a pre-doctoral internship or residency, resulting in real-world experience that is significantly lower. At present, the College of Alberta Psychologists does not currently provide clear, publicly verifiable minimum practicum hour requirements on its registration page. In practice, informal reports within student and provisional psychologist communities suggests that applicants may be deemed eligible with a practicum of 400 hours, with limited direct contact exposure (some accounts suggesting as low as 100 hours and no requirement for assessment experience). To be clear that is 18% of the practicum training recommended by ACRPO. Alberta has recently announced that in 2030 they will introduce more defined expectations and explicitly state that a 400-hour practicum will be required, with 100 hours required in psychological assessment and 25 of those assessment hours needing to be direct contact hours (College of Alberta Psychologists, 2026). These ‘increased’ standards remain well below established national benchmarks, and delaying meaningful reform does not fulfill the College’s responsibility to the public or the profession. Furthermore, their noteworthy divergence from the ACPRO standard raises serious concerns about the transparency and rigor of current entry-to-practice requirements.
From the public’s perspective, the title “Psychologist” is widely understood to imply doctoral-level education, completion of a supervised internship/residency, and demonstrated competency in diagnosis and assessment. When these expectations are not met or are met inconsistently, it undermines public trust and the credibility of the profession.
Evidence from Canadian jurisdictions demonstrates the risks of lowering entry standards. Québec transitioned from master’s- to doctoral-level entry in 2006 following concerns that master’s-level graduates were insufficiently prepared for independent practice (Ordre des psychologues du Québec, 2026). This experience provides a direct precedent, showing that lowering standards does not improve access in a way that maintains public protection or professional competence. More recently, in 2024, the Nova Scotia Board of Examiners in Psychology submitted a proposal to the provincial Ministry of Health recommending a shift to doctoral-level entry. This proposal was rejected by the provincial government; among the stated reasons for this rejection were concerns regarding maintaining public access to psychological services and ensuring interprovincial mobility under the Canadian Free Trade Agreement (CFTA). Thus systemic pressures have complicated the implementation of higher entry requirements elsewhere in Canada. However, this proposal shows that concerns about the appropriate educational standard for safe practice are a topic of ongoing consideration across multiple Canadian jurisdictions. Similarly, Ontario also previously sought to raise its entry standard by eliminating the Masters pathway but subsequently reversed this decision, citing similar concerns regarding workforce mobility.
Recent data reinforce these concerns. According to the Ontario Psychological Association (OPA) Member Toolkit “25% of discipline referrals to the CPBAO from 2023 through spring 2025 appeared to involve Alberta-trained, master’s-level entrants, though they likely represent only 2–3% of registrants, which is an 8–12x overrepresentation. 50% of all referrals in this sample involved non-standard or externally trained entrants” (p = 0.02, OPA Member Toolkit, 2025). Given the sample size was small this information should be interpreted cautiously, although we feel the finding raises potential and meaningful public protection concerns. Québec reportedly found a 28-fold higher discipline rate for master’s-level candidates prior to closing that pathway.
National examination data further highlight the risks. Between January 2020 and December 2024, first-time EPPP candidates from APA- or CPA-accredited doctoral programs (N = 17,748) achieved a 75% pass rate on their first attempt, compared to 45% among candidates from non-accredited or otherwise unaccredited doctoral programs (N = 2,274; ASPPB, 2025; Weiss, 2025). Alberta’s EPPP pass rates are consistently poor: quarterly data reported in The CAP Monitor between 2020 and 2024 show pass rates ranging from 41% to 68% across 19 reporting periods (N = 2,806 test-takers; weighted mean = 52%) (Weiss, 2025). In contrast, Ontario’s CPA-accredited programs in the same period reported a weighted mean first-time pass rate of 97% (n = 355) (Weiss, 2025). The ASPPB recommended pass rate is 70%, which is the threshold used in all Canadian jurisdictions employing the EPPP (ASPPB, 2025). While these comparisons are not perfectly equivalent, they illustrate the impact of training model differences.
These data, combined with the proliferation of online programs of widely variable quality, highlight the risks of relying on regulatory approval in the absence of external accreditation. Students completing some online degrees report minimal weekly hours (sometimes as few as ten per week), and one such program actually advertises their online MACP can be obtained while working full-time. This further calls into question the rigor of some pathways currently eligible for registration in Alberta.
The public has a right to accurate information about the qualifications of those providing psychological services. Title differentiation is a critical safeguard, ensuring that the “Psychologist” designation reflects a consistent and rigorous standard. Failing to uphold this distinction exposes clients to potential harm from inadequately prepared practitioners and erodes the credibility of the profession.
We recognize the importance of improving access to care; however, access must not come at the expense of competence, transparency, and public protection. We therefore call on the College of Alberta Psychologists to: 1. Align its registration standards with those of ACPRO, CPA, ASPPB, APA, and the majority of Canadian jurisdictions by requiring a high level of education to practice psychology, as well as doctoral-level training for the Psychologist title. 2. Implement clear title differentiation for master’s-level practitioners, as recommended by the APA and as practiced in other provinces, and as has been the case for decades. 3. Enhance transparency within its public register by including information on registrants’ educational backgrounds, including degree type and granting institution to support informed decision-making by the public. 4. Ensure that reforms are transparent, evidence-based, and prioritize public protection over short-term access. 5. Engage in meaningful consultation with stakeholders across Canada, including professional associations, academic institutions, and regulatory bodies.
Alberta’s current trajectory risks establishing a national floor for standards that was never democratically chosen and is not supported by evidence. We urge the College to recommit to standards that reflect the complexity and responsibility of psychological practice, protect the public, and safeguard the profession’s integrity.
We urge CAP to act now to restore public trust and ensure that the psychologist title in Alberta, and by extension across Canada, continues to represent the highest standards of professional training and competence. High and consistent entry-to-practice standards are a matter of public protection. These safeguards ensure that individuals entrusted with psychological care possess the necessary training, competence, and accountability to serve the public safely and effectively.
*PLEASE SIGN & SUBMIT AFTER REFERENCES*
References: • Association of Canadian Psychology Regulatory Organizations. (2020). Position statement on the doctoral degree as the national standard for entry to the practice of psychology in Canada. https://acpro-aocrp.ca/wp-content/uploads/2020/03/ACPRO-Position-Statement-National-Standard-November-2014.pdf • Association of State and Provincial Psychology Boards. (2024). Model act for licensure and registration of psychologists. https://asppb.net/wp-content/uploads/2024/10/model_act_for_licensure_and_.pdf • California Southern University. (2026). Doctor of Psychology (PsyD) program: Admission and registration information. Retrieved April 7, 2026 from https://www.calsouthern.edu/online-degree-programs/behavioral-sciences/doctor-psychology-psyd/ • Canadian Psychological Association. (2021). Breaking down barriers: Position statement on the doctoral standard for entry to practice in psychology. https://cpa.ca/docs/File/Position/Breaking%20Down%20Barriers%20Position%20Statement%20EN.pdf • College of Alberta Psychologists (2026). Criteria for Evaluating Academic Credentials. https://www.cap.ab.ca/Portals/0/adam/Text%20with%20Cards/YSgPjTTXLEeNlFn580XQ6A/ButtonLink/Criteria%20for%20Evaluating%20Academic%20Credentials%202030.pdf • Nova Scotia Board of Examiners in Psychology. Assessment Submission for Entry-to-Practice Credential Change. Retrieved from https://www.ns-rp.ca/downloads/ETP_Application_FINALSept122024.pdf • Ontario Psychological Association. (2025). OPA Member Toolkit for CPBAO Consultation Feedback. https://www.psych.on.ca/getmedia/9ca4b563-f2bb-495e-9dfa-8e66a2730710/11-19-2025-OPA-Member-Toolkit-for-CPBAO-Consultation-Feedback.pdf • Ordre des psychologues du Québec. (2026). What is a psychologist? In Ordre des psychologues du Québec. Retrieved from https://www.ordrepsy.qc.ca/web/english/what-is-a-psychologist • Weiss, J. A. (2025, November 2). Analysis of CPBAO consultation data and regulatory trends in Canadian psychology [Policy report]. York University. https://www.yorku.ca/health/lab/ddmh/wp-content/uploads/sites/407/2025/11/CPBAO-Analysis-Final-Nov-2-2025.pdf

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