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Introduction

In April 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Dental Hygienists of Ontario (CDHO) 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 April 2014 targeted assessment of the CDHO focused on the areas where the OFC made recommendations in the full assessment it completed in October 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 CDHO 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 October 2011, the CDHO has been assessed in the area(s) marked below:

None Unchecked
Information for Applicants Unchecked
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 CDHO has demonstrated most of the practices in the following specific-duty area(s):

  • 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 CDHO 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 October 2011, the CDHO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Unchecked

Comments

The OFC found that since the last assessment, the CDHO has taken some additional measures to ensure a transparent and impartial registration process. The OFC identified one area where the CDHO needs to take further steps to ensure transparency (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 CDHO is demonstrating commendable practices in the following area(s).

Assessment of Qualifications

  • monitoring consistency in the application of criteria for the CDHO’s Clinical Competency Evaluation by:
    • ensuring that clinical evaluators meet specific criteria set by the CDHO
    • requiring all evaluators to participate in training sessions and internal reliability exercises conducted by the CDHO
    • requiring evaluators to use a clinical performance evaluation form to assess the clinical competency evaluation
    • auditing the consistency of evaluators, including keeping statistics on their pass/fail rates
    • having two people mark every evaluation. The CDHO pairs evaluators based on their pass/fail statistics and changes pairings frequently.
    • using a third evaluator to assess three random candidates. This evaluator’s results are not part of the candidate’s record but are used by the CDHO as an internal audit of evaluators’ performance. CDHO staff members compare the third evaluator’s assessments to those of the other two evaluators assigned to the candidate. The CDHO changes the third evaluator for each clinical competency evaluation.

Transparency

  • maintaining very open governance, by including on the CDHO website the materials that are reviewed and decided upon in public council meetings. The website includes not only descriptive meeting updates and decision documents but also all of the meeting materials that council members need. This allows applicants and members of the public to see the CDHO’s approach to documenting, reviewing, updating and approving policies that govern the CDHO and affect registration.

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Recommendations

The CDHO should improve in the following areas.

Assessment of Qualifications

Status
  • On the CDHO website, make information available about the written competency evaluation. This information should include a description of:
Checked
September 2014
  • the criteria used for the evaluation
 
  • how the criteria are linked to the standards for entry into the profession
 
  • cost
 
  • appeal process (Practice 5.8a–d)
 
  • In the registration materials on the website, describe procedures relating to the accommodation of special considerations for all qualifications assessments administered by the CDHO (e.g., course of study/equivalency process, clinical and written competency evaluations). (Practice 5.8e)
Checked
September 2014

Transparency

 
  • Identify all possible costs that an applicant may incur while completing the registration process. (Or, clearly describe where the applicant can learn these costs.) The costs include those associated with translation, notarizing, statutory declarations, and requests for education and other supporting documentation. If there are ways that an applicant can mitigate these costs through acceptable alternatives (e.g., through the CDHO’s accepting documentation provided to the National Dental Hygiene Certification Board and/or allowing registration staff to verify true copies from original documents, to help reduce the cost of notarial services), describe these ways in the registration information on the website.
Checked
September 2014
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 nine recommendations for this regulatory body.

They have all been implemented.

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