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Introduction

In September 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Chiropractors of Ontario (CCO) 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 September 2014 targeted assessment of the CCO 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 CCO 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 September 2011, the CCO 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

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

  • Information for Applicants
  • Assessment of Qualifications

For practices that are partially demonstrated or not demonstrated, see the Recommendations section later in this summary.

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General Duty

Assessment Method

The CCO 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 Checked
b. Regulatory body self-assesses based on the practices in the assessment guide Unchecked
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 CCO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Checked

Comments

The OFC found that since the previous assessment, the CCO has demonstrated some of the general-duty practices in the areas of transparency, impartiality and fairness. Improvements could be made in all of these assessment areas (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.

The OFC has not identified any commendable practices in this assessment cycle.

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Recommendations

The CCO should improve in the following area(s):

Information for Applicants

Status
  • On the CCO website, provide an approximation of the time that is required to complete the entire registration process from its start to when the applicant is licensed – not merely the time needed to complete the application for registration process. This should include information about the time required for exams at the Canadian Chiropractic Examining Board (CCEB). (Practice 1.3)
Checked
February 2015

Assessment of Qualifications

 
  • For the Legislation and Ethics Examination, provide a list of the content required to prove the knowledge requirement on the CCO website. The list should include the topics covered and the different pieces of legislation an applicant is required to know. (Practice 5.1)
Checked
April 2015
  • On the CCO website, indicate how the CCO assesses an applicant’s knowledge of the content required on the Legislation and Ethics Examination, and describe the process by which a decision is made about whether an individual has passed that exam. (Practice 5.2)
Checked
February 2015
  • On the CCO website, distinguish the competencies in Core Competencies for CCO Members from the core competencies identified in the CCEB exam content guide as requirements for entry into the profession. (Practice 5.2)
Checked
February 2015
  • On the CCO website, make the timelines clear for:
 
  • assessing qualifications
Checked
February 2015
  • communicating results to applicants
Checked
April 2015
  • providing reasons, in writing, for unsuccessful applications
Checked
February 2015
  • making other registration decisions related to applications as a whole
Checked
February 2015
  • registration committee decisions (Practice 5.9)
Checked
February 2015
  • Develop tools for monitoring timelines, to ensure adherence to them. Include a process for informing applicants about potential delays and estimated decision dates when delays become unavoidable. (Practice 5.9)
Checked
June 2015 
  • Take reasonable measures to ensure that the CCEB, Council on Chiropractic Education Canada, Councils on Chiropractic Education International, and accredited chiropractic educational institutions such as the Canadian Memorial Chiropractic College, provide transparent, objective, impartial and fair assessment practices. (Practice 5.10)
Checked
February 2015

Transparency

 
  • The CCO could improve its communication to applicants, particularly on its website. For example:
 
  • Dedicate a page to fees. Include all fees for the entire registration process, not just the application for registration process.
Checked
February 2015
  • Place all relevant policies together so applicants can see all policies related to registration.
Checked
February 2015
  • Provide a rationale for all requirements, and illustrate why they are relevant to the practice of the profession, particularly the requirement for good character.
Checked
June 2015   
  • Communicate that applicants can have access to their registration records, and explain how that access is provided, including any limitations.
Checked
February 2015

Impartiality

 
  • Continue to train new council and registration staff members on anti-discrimination, cultural diversity, bias-free assessments and decision-making, and the fair-access legislation.
Checked
February 2015

Fairness

 
  • Justify the CCO’s registration requirements by explaining the relationship between these requirements and the competencies and standards that the CCO has identified as essential for entry to the profession. †
Checked
June 2015 
† Recommendations marked with a dagger symbol have been carried forward all or in part from the previous assessment.
 
Blank = Implementation is in progress.
= Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.

Assessment History

In the previous assessment, the OFC identified 11recommendations for this regulatory body.

Ten of those recommendations have been implemented and one has been carried forward into this report.

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