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Introduction

In June 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Dietitians of Ontario (CDO) 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 June 2014 targeted assessment of the CDO focused on the areas where the OFC made recommendations in the full assessment it completed in December 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 CDO 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 December 2011, the CDO 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 CDO has demonstrated or partially demonstratedall of the practices in the following specific-duty area(s):

  • Assessment of Qualifications

For practices that are only partially demonstrated, see the Recommendations section later in this summary.

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General Duty

Assessment Method

The CDO 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 December 2011, the CDO 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 CDO has taken several measures to ensure transparent and fair registration practices. The OFC identified two areas where CDO needs to take further steps (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 CDO is demonstrating commendable practices in the following area(s).

Assessment of Qualifications

  • adopting a new approach for assessment, to allow for more flexibility in assessing prior learning and considering work experience toward achievement of the academic and practical training requirements. This new approach includes:
    • recognizing university credits awarded by other educational institutions as a result of their prior learning assessment
    • considering an applicant’s working experience teaching a university-level course as an acceptable alternative to completion of a course
  • streamlining the registration process for applicants who are members in good standing of the Dietitians Association of Australia (DAA). The mutual recognition agreement with the DAA came into effect on July 1, 2012. Under the agreement, qualified applicants are eligible for temporary registration and are eligible to write the Canadian Dietetic Registration Examination in order to obtain a general/full certificate of registration. Previously, those applicants were required to meet the academic and practical training requirement. The CDO’s website, letters, resources and other communications were updated to reflect this new agreement.
  • improving the monitoring of registration timelines by implementing the following measures:
    • changes to the registration database to better track the registration timelines
    • a new policy to ensure review of the actual performance of registration staff against the timelines stated in the policy
    • These measures enable the CDO to be more effective in adhering to its own policies and procedures.

Transparency

  • continuing to enhance the CDO’s website with clear, concise and easy-to-understand information. The number of application checklists has been reduced from 17 to 1, yet information remains relevant and user-friendly.

Fairness

  • notifying applicants of their exam results via email, which has shortened the process by up to 13 business days. This initiative demonstrates the CDO’s responsiveness to applicant feedback and its willingness to eliminate unnecessary steps.

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Recommendations

The CDO should improve in the following areas.

Assessment of Qualifications

Status
  • Establish and follow definite timelines for reviewing and clarifying the criteria used in assessing an applicant’s portfolio for evidence that he or she has current dietetic knowledge and competence (Practice 5.1).When the review and clarification are completed, post details about the criteria on the website (Practice 5.8a). †
Checked
  • Continue to work on establishing a direct link between all assessment criteria and the Integrated Competencies for Dietetic Education and Practice (Practice 5.2). The CDO reports that final approval and implementation of this linking are to be completed by June 2014.  
Checked

Transparency

 
  • Describe the role of the agencies that provide acceptable English and French language assessments, and provide website links to those organizations.
Checked

Fairness

 
  • Continue work to incorporate professional communications into the new assessment tools that will be developed as part of a new assessment schema for internationally educated applicants, and inform the OFC of progress with respect to its development and implementation.
 

† Recommendations marked with a dagger symbol have been carried forward all or in part from the previous assessment.

 
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 six recommendations for this regulatory body.

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

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