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Introduction

In March 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Early Childhood Educators (CECE) 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 March 2014 targeted assessment of the CECE focused on the areas where the OFC made recommendations in the full assessment it completed in January 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 the CECE 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 January 2012, the CECE 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 Checked
Documentation of Qualifications Checked
Assessment of Qualifications Unchecked
Training Unchecked
Access to Records Unchecked

Outcomes

The CECE has demonstrated all of the practices in the following specific-duty areas:

  • Information on Appeal Rights
  • Documentation of Qualifications

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General Duty

Assessment Method

The CECE 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 January 2012, the CECE 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 CECE has demonstrated all general-duty practices related to transparency and impartiality.

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

Information on Appeal Rights

  • developing a document that describes each step of the registration process, including directions for applicants who are not satisfied with the registration decisions of the registration appeals committee. This document, published on the CECE’s website, explains the following:
    • all of the actions that applicants need to take to become registered
    • the outcomes of the registration process
    • the applicant’s right to a further review through Ontario Divisional Court
  • The layout of the material enables quick and easy access to essential registration information, including aspects of the appeals process. Applicants who require more specific details about appeals opportunities are referred to the Registration Appeals Frequently Asked Questions (FAQs) section on the CECE’s website.
  • ensuring that a CECE staff member in the editorial role performs a cold reading of registration appeals committee decisions and provides feedback on their clarity and consistency, while not commenting on the decisions themselves. This process is meant to ensure that information provided to applicants about registration decisions is user-friendly.

Documentation of Qualifications

  • taking a systematic approach to reviewing the CECE’s registration materials for applicants, to ensure that the registration information remains current and accurate. This approach includes the following:
    • regularly surveying the CECE’s applicants to get feedback about their experiences during the registration process. The CECE analyzes the survey results and uses the findings to help improve the registration materials, including those related to documentation of qualifications.
    • reviewing application forms and guides at least once a year. When the CECE has completed the review, it updates these materials and records the date of the review on them.

Transparency

  • taking several measures to make it easy to see how the registration process operates – for example:
    • adding a new resource to the CECE website to guide applicants through the registration process: the Becoming an RECE in Ontario pamphlet 
    • developing specific application forms for different categories of applicants
    • providing a timeline chart and additional information concerning appeals, to further inform applicants about the registration appeals process

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Recommendations

The OFC has not identified any immediate opportunities for improvement for the practices assessed for this assessment period. The OFC expects that the CECE will continue maintaining its standards in the future.

In the spirit of continuous improvement, the OFC encourages the CECE to continue its efforts towards more transparent, objective, impartial and fair registration processes.

Assessment History

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

They have all been implemented.

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