BetterHelp

BetterHelp is an application offering therapy and counselling to the public in Canada. Unfortunately, these clinicians are often not licensed in Canada and may not have the correct insurance to practice either. While BetterHelp is the most egregious of these apps, Canadian Counselling is also against the growing body of applications and websites offering globalized mental health services without the ethical standards that protect public health and safety.

Dear Registrar,
I am writing to you today as a concerned member of the college (LCT-C) as well as a member of the public who utilizes mental health services, regarding the rapid proliferation of digital psychotherapy and counselling applications operating within New Brunswick.
As you are aware, the Licensed Counselling Therapy Act mandates the CCTNB to protect the public by ensuring that those providing mental health services meet rigorous standards of competence and ethical care. However, there is a growing trend of international “therapy apps” marketing services to New Brunswick residents while utilizing practitioners who are not licensed by the CCTNB or any other Canadian provincial regulatory body.
In many cases, these platforms bypass traditional jurisdictional boundaries, leaving New Brunswick clients without the protections afforded by the College’s complaints and disciplinary processes. I recently explored the specific risks these platforms pose to public safety—including issues regarding data privacy, the lack of clinical oversight, and the absence of accountability for non-licensed providers—in a detailed analysis here: : https://thoughtsbyshaylynn.substack.com/p/betterhelp-claims-to-offer-ethical
I am also heavily concerned that companies like BetterHelp are using uncompetitive business practices by bidding on Canadian-specific keywords on sites like Google Ads. This means that even if Canadians are advertising their services, they will be outpriced by tech giants with unlimited budgets. This is disastrous for both our counsellors and the public who is trying to find reliable resources in Canada.
Given the College’s mandate to “advance and maintain the standard of counselling therapy in the Province,” I am inquiring as to whether the CCTNB is currently engaged in, or planning, any of the following:
Advocacy for Legislative Reform: Working with the provincial government to close loopholes that allow unregulated platforms to offer “therapy” or “counselling” to New Brunswickers without using LCTs.
Public Awareness Campaigns: Developing resources to educate the public on the importance of verifying that their online therapist is a licensed member of the CCTNB.
Collaboration with National Bodies: Partnering with the Canadian Counselling and Psychotherapy Association (CCPA) or other provincial regulators to address the cross-border challenges posed by these digital entities.
The protection of the public is a shared priority, and I believe the CCTNB’s voice is essential in ensuring that the digital evolution of mental health care does not come at the expense of patient safety or professional standards
I look forward to hearing about the College’s position on this matter and any steps being taken to address these concerns.
Sincerely,
Shaylynn Hayes-Raymond
MA, LCT-C

To the CCPA

Dear CCPA Leadership,
I am writing to you today as a concerned member of the Association (CCC/LCT-C) and as a member of the public who utilizes mental health services. I am deeply concerned by the rapid, unregulated proliferation of international digital psychotherapy applications operating within Canada.
While the CCPA works tirelessly to promote the profession and protect the public, there is a growing trend of international “therapy apps” marketing services to Canadians while utilizing practitioners who are not licensed by any Canadian provincial regulatory body or certified by the CCPA. These platforms frequently bypass jurisdictional boundaries, leaving Canadian clients without the protections afforded by our domestic ethical codes and disciplinary processes.
I recently published a detailed analysis of the risks these platforms pose—including issues regarding data privacy, lack of clinical oversight, and the absence of accountability for non-licensed providers—which can be found here: https://thoughtsbyshaylynn.substack.com/p/betterhelp-claims-to-offer-ethical.
Furthermore, I am gravely concerned by the uncompetitive business practices employed by these entities. Platforms like BetterHelp utilize massive capital to bid on Canadian-specific keywords via Google Ads. This effectively outprices local Canadian counsellors and small private practices, making it nearly impossible for practitioners to compete for visibility in their own communities. This is disastrous for both our Canadian workforce and the public, who are funneled toward international tech giants instead of reliable, regulated local resources.
Given the CCPA’s mission to enhance the counselling profession and the well-being of Canadians, I am inquiring as to whether the Association is currently engaged in, or planning, any of the following:
Federal Advocacy for Platform Regulation: Working with Health Canada or the Competition Bureau to address the “grey market” of digital apps providing mental health services without Canadian-certified providers.
National Awareness Campaigns: Developing resources to educate the public on the importance of choosing a provider who is a member of a Canadian regulatory body or the CCPA.
Addressing Predatory Marketing: Exploring strategies or advocacy to protect the ability of Canadian practitioners to compete fairly in the digital marketplace against international tech conglomerates.
Collaboration with Provincial Colleges: Coordinating a unified national stance against the encroachment of unregulated digital services.
The protection of the public and the sustainability of our profession are shared priorities. I believe the CCPA’s national voice is essential in ensuring that the digital evolution of mental health care does not come at the expense of patient safety or the viability of Canadian practitioners.
I look forward to hearing about the Association’s position and any steps being taken to address these critical concerns.
Sincerely,
Shaylynn Hayes-Raymond, MA, LCT-C

To the NB Government

Hon. Dr. John Dornan Minister of Health Government of New Brunswick HSBC Place, P. O. Box 5100 Fredericton, NB E3B 5G8 Via Email: John.Dornan@gnb.ca
RE: Urgent need for regulation of digital psychotherapy platforms in New Brunswick

Dear Minister Dornan,
I am writing to you today as a Licensed Counselling Therapist Candidate (LCT-C) and a concerned citizen to bring to your attention a significant and growing gap in New Brunswick’s healthcare oversight: the unregulated operation of international digital psychotherapy platforms within our province.
While the Licensed Counselling Therapy Act was designed to ensure that mental health services are provided by qualified, ethical, and accountable professionals, the rise of “therapy apps” like BetterHelp has created a “grey market.” These platforms actively market to New Brunswick residents but frequently utilize practitioners who are not licensed by the College of Counselling Therapists of New Brunswick (CCTNB) or any other Canadian regulatory body.
As a result, New Brunswickers seeking mental health support are being paired with providers who:
Lack Jurisdictional Accountability: They fall outside the disciplinary reach of the CCTNB, leaving clients with no recourse in cases of malpractice or ethical breaches.
Operate Under Opaque Privacy Standards: Many platforms utilize data-sharing practices that do not align with the stringent requirements of New Brunswick’s Personal Health Information Privacy and Access Act (PHIPAA).
Engage in Predatory Marketing: These billion-dollar tech giants use aggressive bidding on Google Ads to outprice local, regulated New Brunswick clinics, making it difficult for citizens to find legitimate, domestic care.
I have detailed these risks—including the specific ways these platforms bypass our provincial safety nets—in a recent analysis found here: https://thoughtsbyshaylynn.substack.com/p/betterhelp-claims-to-offer-ethical.
Furthermore, a growing number of practitioners and citizens have joined a call for action to ensure that any platform offering “psychotherapy” or “counselling” in our province is required by law to utilize Canadian-regulated professionals. You can view this initiative here: https://www.change.org/p/force-betterhelp-to-hire-canadian-therapists-or-cease-operations-in-canada.
I am respectfully requesting that the Department of Health:
Review the Licensed Counselling Therapy Act to close loopholes that allow “virtual” services to be provided by individuals not licensed in New Brunswick.
Coordinate with the CCTNB to launch a public awareness campaign regarding the dangers of using unregulated mental health apps.
Advocate for Fair Digital Competition to protect New Brunswick’s mental health workforce from uncompetitive practices by international tech conglomerates.
Protecting the mental health of New Brunswickers requires that we maintain the same standards for digital care as we do for in-person care. I would welcome the opportunity to discuss this issue with you or your staff in more detail.
Sincerely,
Shaylynn Hayes-Raymond, MA, LCT-C

To the Federal Government

Dear Minister Holland,
I am writing to you as a Licensed Counselling Therapist Candidate (LCT-C) in New Brunswick and a member of the Canadian Counselling and Psychotherapy Association (CCPA). I am deeply concerned about the lack of federal oversight regarding international digital psychotherapy platforms, such as BetterHelp, which are currently operating within Canada without adhering to provincial regulatory standards.
While health care delivery is a provincial mandate, the digital nature of these platforms creates a cross-border regulatory vacuum. Currently, these multi-billion-dollar entities market “therapy” to Canadians while frequently utilizing practitioners who are not licensed or regulated by any Canadian provincial body. This bypasses our national standards for clinical safety, ethical accountability, and patient protection.
In a detailed analysis of these risks, I have highlighted how these platforms threaten the integrity of the Canadian mental health landscape: https://thoughtsbyshaylynn.substack.com/p/betterhelp-claims-to-offer-ethical.
Furthermore, I wish to bring to your attention two critical areas of federal concern:
Predatory Marketing & Uncompetitive Practices: These platforms use massive capital to outbid Canadian practitioners on search engine keywords. This effectively “prices out” domestic, regulated providers, making it nearly impossible for Canadians to find local, accountable care.
Data Privacy and PIPEDA Compliance: There are significant concerns regarding how these international entities handle sensitive Canadian health data, which often fails to meet the stringent requirements of federal privacy legislation.
Over [Current Number of Signatures] Canadians have already signed a petition urging the government to require these platforms to hire regulated Canadian therapists or cease operations in our country: https://www.change.org/p/force-betterhelp-to-hire-canadian-therapists-or-cease-operations-in-canada.
I am respectfully requesting that Health Canada:
Establish a National Framework for digital mental health services that mandates the use of provincially regulated Canadian professionals.
Collaborate with the Competition Bureau to investigate the uncompetitive advertising practices that disadvantage Canadian healthcare small businesses.
Strengthen Digital Health Standards to ensure that any app offering “controlled acts” like psychotherapy is subject to the same oversight as a physical clinic in Canada.
As we strive to improve mental health access for all Canadians, we must ensure that “accessibility” does not become a pretext for the erosion of professional standards and public safety.
I look forward to your response and would welcome the opportunity to discuss how the federal government can protect the Canadian mental health workforce and the public.
Sincerely,
Shaylynn Hayes-Raymond, MA, LCT-C