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Registration Practices Assessment Report — Overview
COLLEGE OF AUDIOLOGISTS AND SPEECH-LANGUAGE PATHOLOGISTS OF ONTARIO (CASLPO)

Introduction

In August 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Audiologists and Speech-Language Pathologists of Ontario (CASLPO) registers people who apply for a licence to practise in Ontario, to ensure that the registration practices are fair and continue to improve.

Assessment is one of the Fairness Commissioner's mandated roles under the Regulated Health Professions Act, 1991 (RHPA).

Assessment Cycle

To hold regulatory bodies accountable for continuous improvement, the OFC assesses their licensing practices using a two-year assessment cycle.

Assessment cycles alternate between full assessments and targeted assessments:

  • Full assessments address all specific and general duties described in the RHPA.
  • Targeted assessments focus on the areas where the OFC made recommendations in the previous full assessment.

This approach establishes continuity between the assessment cycles.

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Focus of This Assessment and Report

The August 2014 targeted assessment of CASLPO focused on the areas where the OFC made recommendations in the full assessment it completed in June 2012.

The OFC’s detailed report captures the results of the targeted assessment. The assessment summary provides the following key information from the detailed report:

  • duties that were assessed
  • an overview of assessment outcomes for specific-duty practices
  • an overview of comments related to the general duty
  • commendable practices
  • recommendations

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Availability of Report

The OFC encourages CASLPO to provide the detailed report to its staff, council members, the public, and other interested parties.

To receive a copy of the detailed report, click here.

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Assessment Methods

Assessments are based on the Registration Practices Assessment Guide – For Health Regulatory Colleges. The guide presents registration practices relating to the specific duties and general duty in the RHPA.

A regulatory body’s practices can be measured against the RHPA’s specific duties in a straightforward way. However, the general duty is broad, and the principles it mentions (transparency, objectivity, impartiality and fairness) are not defined in the legislation.

As a result, the specific-duty and general-duty obligations are assessed differently (see the Strategy for Continuous Improvement of Registration Practices).

Specific Duties

The OFC can clearly determine whether a regulatory body demonstrates the specific-duty practices in the assessment guide. Therefore, for each specific-duty practice, the OFC provides one of the following assessment outcomes:

  • Demonstrated – all required elements of the practice are present or addressed
  • Partially Demonstrated – some but not all required elements are present or addressed
  • Not Demonstrated – none of the required elements are present or addressed
  • Not Applicable – this practice does not apply to this regulatory body

General Duty

Because there are many ways that a regulatory body can demonstrate that its practices, overall, are meeting the principles of the general duty, the OFC makes assessment comments for the general duty, rather than identifying assessment outcomes. For the same reason, assessment comments are made by principle, rather than by practice.

For information about the OFC’s interpretations of the general-duty principles and the practices that the OFC uses as a guideline for assessment, see the Registration Practices Assessment Guide – For Health Regulatory Colleges.

Commendable Practices and Recommendations

Where applicable, the OFC identifies commendable practices or recommendations for improvement related to the specific duties and general duty.

Sources

Assessment outcomes, comments, and commendable practices and recommendations are based on information provided by the regulatory body. The OFC relies on the accuracy of this information to produce the assessment report. The OFC compiles registration information from sources such as the following:

  • Fair Registration Practices Reports, audits, Entry-to-Practice Review Reports, annual meetings
  • the regulatory body’s:
    • website
    • policies, procedures, guidelines and related documentation templates for communication with applicants
    • regulations and bylaws
    • internal auditing and reporting mechanisms
    • third-party agreements and related monitoring or reporting documentation
    • qualifications assessments and related documentation
  • targeted questions/requests for evidence that the regulatory body demonstrates a practice or principle

For more information  about the assessment cycle, assessment process, and legislative obligations, see the Strategy for Continuous Improvement of Registration Practices.

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Assessment Summary

Specific Duties

Specific duties assessed

As a result of the recommendations made in the full assessment completed in June 2012, CASLPO has been assessed in the area(s) marked below:

None Unchecked
Information for Applicants Checked
Timely Decisions, Responses and Reasons Unchecked
Internal Review or Appeal Unchecked
Information on Appeal Rights Unchecked
Documentation of Qualifications Unchecked
Assessment of Qualifications Checked
Training Unchecked
Access to Records Unchecked

Outcomes

CASLPO has demonstrated all of the practices in the following specific-duty area(s):

  • Information for Applicants
  • Assessment of Qualifications

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General Duty

Assessment Method

CASLPO selected the method marked below for the assessing of its adherence to the general-duty principles, and informed the OFC:

a. OFC assesses based on the practices listed in the assessment guide Unchecked
b. Regulatory body self-assesses based on the practices in the assessment guide Checked
c. Regulatory body self-assesses using a system-based approach, in which it explains what it does to ensure that its practices are adhering to the general-duty principles Unchecked

Principles assessed

As a result of the recommendations made in the full assessment completed in June 2012, CASLPO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Unchecked

Comments

Since the last assessment, CASLPO has taken some measures to ensure transparent and impartial registration practices, including having documented registration policies that are developed in consultation with the registration committee, executive committee and council. Also, the registration committee is developing a policies and procedures manual that is expected to be complete later in 2014.

There are, however, a number of ways in which CASLPO can improve its practices (see the Recommendations section below).

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Commendable Practices

A commendable practice is a program, activity or strategy that goes beyond the minimum standards set by the OFC assessment guides, considering the regulatory body’s resources and profession-specific context. Commendable practices may or may not have potential for transferability to another regulatory body.

CASLPO is demonstrating commendable practices in the following area(s).

Information for Applicants

  • providing comprehensive, easy-to-understand information for applicants in concisely organized application guides. There are different guides for Canadian and international graduates describing the respective requirements.

Assessment of Qualifications

  • providing CASLPO staff with opportunities to undergo continuing professional development in order to understand education systems across the world and to keep abreast of current trends in the profession.

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Recommendations

CASLPO should improve in the following areas:

Transparency

Status
  • Determine whether its registration policies and criteria are written in a way that makes it easy for decision-makers to interpret and apply them. This could be done through a survey or another means of gathering feedback.

    If CASLPO identifies concerns with the ease of understanding and interpretation of registration policies and criteria, it should make necessary modifications to improve these tools. This could include, for example, making plain-language refinements.
 
  • Consider providing training in plain-language writing for individuals who are involved in writing registration materials, policies, guidelines, decisions and other communication with applicants. 
   Checked
May 2015 
  • Determine whether its written communication to applicants – particularly decision letters and reasons for decisions – is clear to applicants. This could be done through a survey or another means of gathering feedback.

    If CASLPO identifies concerns with the clarity of its written communication to applicants, it should make necessary modifications to improve its written communication. This could entail training for decision-makers specifically that addresses how to write decisions.
 
  • Communicate to applicants:
    • which records are returned to applicants on request
    • how they can ask for records
      (for example, in person, by email, or by completing and submitting a written form)
    • the way in which records are available
      (for example, by photocopy or by access in person)
    • who may access the records 
    • how long records are kept
   Checked
May 2015 

Impartiality

 
  • Formalize a process or policy to identify specific training needs related to impartiality and ways to address those needs.
 
  • Conduct a risk assessment or review process to identify possible ways in which bias may enter into qualification assessment and/or registration decisions and to develop strategies to address identified risks.
 
Blank = Implementation is in progress.
Checked = Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.

Assessment History

In the previous assessment, the OFC identified eight recommendations for the regulatory body.

They have all been implemented.

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