Advocacy: CHCPBC Bylaw Feedback & HPOA

The Ministry of Health has announced that the Health Professions Act (HPA) will be repealed on April 1, 2026 and replaced by the Health Professions and Occupations Act (HPOA). On that date, the HPOA will be in force as the governing legislation for regulation of health professions in BC.

The BC government posted updates to the regulations for health professions to align them with the HPOA. The regulations outline the name of the college that regulates each health profession, reserved titles, scope of practice statements, activities restricted to the health profession, and limits or conditions on practice.
 

• Health and Care Professionals Regulation (specific to professions regulated by CHCPBC)
• Regulated Health Practitioners Regulation (includes restricted activities)
• Health Professions and Occupations Regulation

While the updated regulations are now publicly available, they will not be in effect until April 1, 2026, when the HPOA comes into force.

Bylaw Review & Feedback: CHCPBC
 

CHCPBC is seeking feedback on their draft bylaws under the HPOA.  We encourage psychologists across the province to review the College's website and provide feedback as bylaws are released.

BCPA created an HPOA Task Force in the Spring of 2025 and has been providing bylaw feedback, as well as engaging directly with the College to advocate for bylaw amendments.

Advocacy: HPOA

BCPA has been analyzing the HPOA, collecting member feedback, and collaborating with our HPOA Task Force to identify sections of the HPOA of greatest concern to Psychologists. We have retained legal counsel to provide insight into possible steps moving forward, and are working with a Government Relations firm to strengthen our advocacy efforts with the BC Government.

Snapshot of Concerns Identified (analysis is ongoing):

• Extraordinary Investigative Powers & Privacy Violations. Concern: Sections 506–511, 512, 75, 97–105, 178, 257–259, and Schedule 23 grant warrantless search, seizure, and investigative powers without due process protections.
   
• Lack of Right of Appeal. Concern: Section 512 removes the statutory right of appeal, leaving only Judicial Review.
   
• Broad and Vague Definition of Misconduct. Concern: Section 11 expands “misconduct” to include “conduct unbecoming” and “unfitness to practise.”
   
• Random and Intrusive Quality Assurance Audits. Concern: Sections 97–105 and related bylaws allow random audits, on-site reviews, and peer evaluations that may access confidential records.
   
• Compelled Third-Party Evidence. Concern: Section 257 allows investigators to order “any person” to provide relevant information or documents.
   
• Criminal-Scale Penalties. Concern: Sections 514–518 establish fines up to $200,000 and imprisonment up to two years for broadly defined offences.
   
• Vague Offence Language (“Misleading the Public”). Concern: Section 514(a) includes “misleading the public” without clear parameters.
   
• Governance and Representation Framework. Concern: The HPOA replaces self-regulation with government appointment and control, removing electoral accountability, profession-specific input, and regulatory independence, fundamentally altering how psychologists and other health professionals are represented and governed.
   
• Impact on Public Trust and Access to Care. Concern: The cumulative effect of these provisions undermines confidentiality and safety.
   
• Conflict with DRIPA and “In Plain Sight” Commitments. Concern: The legislation risks violating principles of Indigenous self-determination and culturally safe practice.
   

The Board of BCPA is approaching this situation with strength, clarity, and unity. We are deeply aware of the challenges before us and have gone to great lengths to be well-informed. We are responding with a strategic, informed, and collaborative approach. Our goal is to ensure that the voice of our profession remains respected, credible, and effective in conversations with the College and the Government.

Regulation of New Health Professions

The new regulations will also add new health professions to BC’s health regulatory framework. On November 29, 2027, psychotherapists will be regulated by CHCPBC. This is in line with the Ministry’s recommendations published in August 2020 to modernize the BC health regulatory framework. The College will work collaboratively to integrate psychotherapists into our regulatory framework and advance public safety in more areas of BC’s healthcare system.

For more information about the updated regulations and regulation of psychotherapists, see the BC Government’s Health Professions and Occupations Act webpage.

For questions regarding BCPA's advocacy work, please contact Laura Darch at laura.darch@psychologists.bc.ca.