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Introduction

In December 2013, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the Institute of Chartered Accountants of Ontario (ICAO) 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 Fair Access to Regulated Professions and Compulsory Trades Act (FARPACTA).

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 FARPACTA.
  • 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 December 2013 targeted assessment of the ICAO focused on the areas where the OFC made recommendations in the full assessment it completed in September 2011.

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 the ICAO 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 Regulated Professions and Trades. The guide presents registration practices relating to the specific duties and general duty in FARPACTA.

A regulatory body’s practices can be measured against FARPACTA’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 Regulated Professions and Trades.

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 September 2011, the ICAO 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 Checked
Assessment of Qualifications Checked
Training Unchecked
Access to Records Unchecked

Outcomes

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

  • Information for Applicants
  • Documentation of Qualifications
  • Assessment of Qualifications

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General Duty

Assessment Method

The ICAO 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 September 2011, the ICAO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Unchecked
Fairness Checked

Comments

The OFC found that since the last assessment, the Institute of Chartered Accountants of Ontario (ICAO) has taken measures to ensure a transparent and fair registration process. The OFC identified three areas where the ICAO needs to make its registration practices fairer and more transparent (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 or trade-specific context. Commendable practices may or may not have potential for transferability to another regulatory body.

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

Information for Applicants

  • implementing information technology controls that alert the appropriate ICAO staff member about ICAO website content that is more than six months old. Alerts prompt the staff member to review, update and republish the content. This approach ensures that the registration information on the ICAO’s website remains current, relevant and accurate.

Assessment of Qualifications

  • implementing internal tools and models for evaluating key metrics of the process for assessing applicants. These internal tools and models help to ensure the quality of the assessment decisions.
  • developing seven examples of factors that contribute to delays in assessments. Each of the examples describes a situation that involves a delay and explains the causes of the delay.
  • creating resources to help applicants estimate whether their degree courses meet the ICAO academic requirements. These resources include:
    • generic course descriptions that include an overview of the required content, the objective of the course, and the learning outcomes linked to the profession’s competency framework
    • procedures for assessing degrees and credits. Grade point average (GPA) templates are included. These help applicants predict their GPAs on the required credit hours of course work that they have completed.
    • grade-conversion tables, which help applicants convert letter grades into numbers when grades have been reported in letter format

Transparency

  • publishing examples that clarify the assessment process for applicants who want to be exempted from a requirement. Each example describes the background and circumstances of an applicant who asks for an exemption, and offers an explanation of the rationale for the ICAO’s decision. This resource helps clarify eligibility for exemptions.

Fairness

  • creating a new position – Associate Director, Regulatory Compliance – whose role includes:
    • reviewing all regulatory matters falling under the authority of the registrar, including matters relating to registration with the ICAO
    • reporting to the registrar each month on regulatory findings and opportunities for improvement. The registrar then meets with members of the ICAO’s management group to address regulatory issues that impact the ICAO as a whole.
  • This approach contributes to continuous improvement of the ICAO’s registration practices.

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Recommendations

The ICAO should improve in the following areas.

Transparency

Status

In the registration materials for applicants:

 
  • Find a way to identify costs associated with the registration process, including costs that are not under the ICAO’s control: that is, augment existing information about fees with brief examples of fees imposed by external parties.
Acceptable alternative,
March 2015
  • Organize information about access to records in a more structured way, so it is easier to find and access. Include information about:
Acceptable alternative,
March 2015
  • the way in which records are available
 
  • who may access the records
 
  • how long the records are kept
 
  • what limitations exist on the right to access records
 

Fairness

 
  • Investigate whether any irregularities may have taken place during the June 2013 School of Accountancy (SOA) exam, and inform the OFC about those findings as follows:
Checked
March 2015
  • Describe the steps taken to conduct the investigation.
 
  • If the ICAO identifies any irregularities during the exam, identify actions to address the irregularities, and describe how the ICAO will implement those actions.
 
  • If the ICAO does not detect any irregularities, confirm the findings.
 
  • The investigation must review procedures related to the following:
Checked
March 2015
  • administration of the exam
 
  • marking of the exam papers
 
  • providing any appeal opportunities resulting from the exam
 
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 10 recommendations for this regulatory body.

They have all been implemented.

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