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Registration Practices Assessment Report
COLLEGE OF EARLY CHILDHOOD EDUCATORS
2016-2018 Assessment Cycle (Cycle 3)


AVAILABILITY OF REPORT

The Office of the Fairness Commissioner (OFC) provides this report to the regulatory body and posts the full report on its website, www.fairnesscommissioner.ca. In the interests of transparency and accountability, the OFC encourages the regulatory body to provide it to its staff, council members, other interested parties and the public.



Introduction

Assessment is one of the Fairness Commissioner's mandated roles under the Fair Access to Regulated Professions and Compulsory Trades Act, 2006 (FARPACTA) and the Regulated Health Professions Act, 1991 (RHPA) – collectively known as fair access legislation.

Assessment Cycle

One of the primary ways the OFC holds regulators accountable for continuous improvement is through the assessment of registration practices using a three-year assessment cycle.

Assessment cycles alternate between full assessments and targeted assessments:

  • Full assessments address all specific and general duties described in the fair-access legislation.
  • Targeted assessments focus on the areas where the OFC made recommendations in the previous full assessment.

Focus of this Assessment and Report

The 2016-2018 assessment of the College of Early Childhood Educators (the College) is a full assessment.

The OFC’s detailed report captures the results of the full assessment. However, practices related to the provision of information are excluded. For regulators that have previously demonstrated compliance with practices related to the provision of information, these practices have been removed from the report.[1] 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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Assessment Summary


Specific Duties

Specific duties assessed

The regulator has been assessed in all of the specific duties. However, practices related to provision of information were excluded from the assessment and have been removed from the report.

Comments

In this assessment, the OFC found that the College has continued to show a strong commitment towards developing and implementing fair registration practices. In particular, the College has demonstrated all of the practices in the following specific-duty areas:

  • Timely Decisions, Responses and Reasons
  • TInternal Review or Appeal
  • TAssessment of Qualifications
  • Training
  • Access to records

General Duty

Assessment method

The regulator selected the following method for the assessment of the general duty:

a. OFC practice-based assessment (following the practices in the Assessment Guide) Checked
b. Regulator practice-based self-assessment (following the practices in the Assessment Guide) Unchecked
c. Regulator systems-based self-assessment (in which it explains systemically and holistically how it meets the general duty) Unchecked

Principles assessed

The regulator has been assessed on all of the general duty principles: transparency, objectivity, impartiality and fairness.

Comments

The OFC found that since the last assessment, the College has taken further actions to meet its general duty obligations. For example, the College has reviewed and enhanced its policy and process for the individual assessment of educational qualifications, which is an alternative for applicants who do not have the equivalent of an early childhood education program from an Ontario College of Applied Arts and Technology (OCAAT) or a College-approved program to meet registration requirements. Other notable activities include developing and implementing policy documents to consider applicants’ request to provide alternative documentation where required documents are unobtainable, and to expand public outreach through the use of social media.

In this assessment cycle, the College has complied with all requirements for the specific and general duty areas to ensure that their registration practices are transparent, objective, impartial and fair.

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 regulatory body is demonstrating commendable practices in the following areas:

Specific Duty

Timely Decisions, Responses and Reasons

  1. Applying changes to streamline the review process and reduce the time needed by the Registration Appeals Committee (RAC) to review applications and make decisions.

Internal Review or Appeal

  1. Implementing a process that gives an applicant that has been refused certification the option for a reconsideration of the decision by the Registrar.

Training

  1. Providing phone services skills training and compiling an accompanying handbook for staff to ensure consistent and accurate responses to queries from applicants, members and other stakeholders.

Access to Records

  1. Keeping inactive applicant files open for three years to allow applicants to reapply for registration without being required to resubmit information or supporting documentation that is already in the file.

General Duty

Transparency

  1. Developing a Social Media Policy to explain how the College will engage with the public on its social media platforms.
  2. Improving the clarity and accessibility of information on the individual assessment process on the College’s website and in registration materials for applicants.
  3. Implementing a self-assessment tool to provide applicants with increased understanding of the criteria the College uses to assess their educational qualifications against the vocational learning outcomes as part of the individual assessment process.

Fairness

  1. Offering the individual assessment process as an alternative to applicants that do not have equivalent educational qualifications or a College-approved program to meet registration requirements.
  2. Providing applicants with more options to meet the language proficiency requirement for registration through revisions to the Policy regarding Language Fluency.
  3. Developing and implementing the Policy regarding Unavailable Documents to guide decision-makers in considering applicants` requests to provide alternative documentation, where required documentation cannot be obtained for reasons beyond their control.

Assessment History

In the previous assessment, the OFC did not identify any recommendations for the regulator.

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Detailed Report[2]


Specific Duty

2. Specific Duty — Timely Decisions, Responses and Reasons

FARPACTA, s. 8 and s. 9 (1)

1. If a regulator rejects an application, it gives written reasons to the applicant. [Fairness, Transparency]

Assessment Outcome

Demonstrated

2. The regulator makes registration decisions, and gives written decisions and reasons to applicants, without undue delay*. [Fairness]

Assessment Outcome

Demonstrated

OFC Comments

The OFC finds in its information for applicants that the College’s typical processing time for a complete application is 4 to 6 weeks. Processing time for applications that require an Individual Assessment (IA) are 4 to 12 weeks.

The College informed the OFC that the Registration Department is undertaking a workflow redesign with the intent to streamline the steps taken to process applications and to reduce overall timelines for registration decisions. The OFC supports the College’s efforts to review its registration processes and to implement measures to achieve greater efficiencies in its timelines. In its efforts, it would be useful for the College to include a dedicated review of the IA process to ensure that registration timelines are reasonable and to determine if there are measures that can be taken to further reduce these timelines.

Suggestions for continuous improvement

Conduct a review of the individual assessment process to ensure that registration decisions are made and decisions and reasons are communicated to applicants in a reasonable time. Where possible, take further measures to reduce the timelines for the individual assessment process.

3. The regulator responds to applicants’ inquiries or requests without undue delay*. [Fairness]

Assessment Outcome

Demonstrated

4. The regulator provides internal reviews of decisions, or appeals from decisions, without undue delay*. [Fairness]

Assessment Outcome

Demonstrated

5. The regulator makes decisions about internal reviews and appeals, and gives written decisions and reasons to applicants, without undue delay*. [Fairness]

Assessment Outcome

Demonstrated

Commendable practice

Applying changes to streamline the review process and reduce the time needed by the RAC to review applications and make decisions. For instance, independent legal counsel attends deliberations to promptly address any questions or concerns posed by the RAC and committee members have received training on decision and reasons letter writing to improve their communications to applicants. These changes have helped the RAC to review and make decisions on more files at each meeting.

3. Specific Duty — Internal Review or Appeal

FARPACTA, s. 7, s. 9(2-3, 5)

1. The regulator provides applicants with an internal review of, or appeal from, registration decisions. [Fairness]

Assessment Outcome

Demonstrated

OFC Comments

The College provides applicants that have received a proposal to refuse (PTR) certification with two options, either to submit new documentation not included in their original application and request reconsideration by the Registrar or to request a review of the decision by the RAC.

The College states in its information for applicants that a request for review by the RAC may be accompanied by written submissions. However, when assessing this practice, the OFC was not able to confirm that an applicant’s request for a review by the RAC would proceed if they did not submit additional information or supporting documentation. It might be useful for the College to clarify in its information for applicants that the review process will move forward even if an applicant chooses not to make additional submissions to support their application.

Suggestions for continuous improvement

Clearly state in information for applicants that it is optional for an applicant to submit new information or documents when requesting a review and that the review process will proceed whether or not submissions are made.

Commendable Practice

Implementing a process that gives an applicant that has been refused certification the option for a reconsideration of the decision by the Registrar. As part of this process, the applicant can submit supporting documentation that was not included in their original application to the College. A request for reconsideration provides an applicant with the opportunity to give the Registrar a more complete and strengthened version of their application without a need to request a review by the RAC.

2. The regulator implements rules and procedures that prevent anyone who acted as a decision-maker in a registration decision from acting as a decision-maker in an internal review or appeal of that same registration decision. [Impartiality]

Assessment Outcome

Demonstrated

4. The regulator provides information on its website about any limits or conditions on an internal review or appeal*. [Transparency]

Assessment Outcome

Demonstrated

6. Specific Duty — Assessment of Qualifications

FARPACTA, s. 10 (2)

2. The regulator communicates the results of qualifications assessment to each applicant in writing. [Transparency]

Assessment Outcome

Demonstrated

3. The regulator gives its assessors access to assessment criteria, policies and procedures. [Transparency]

Assessment Outcome

Demonstrated

4. The regulator shows that its tests and exams measure what they intend to measure*. [Objectivity]

Assessment Outcome

Not Applicable

OFC Comments

This practice does not apply to the College as they do not conduct examinations.

5. The regulator states its assessment criteria in ways that enable assessors to interpret them consistently. [Objectivity]

Assessment Outcome

Demonstrated

6. The regulator ensures that the information about educational programs that is used to develop or update assessment criteria is kept current and accurate. [Objectivity]

Assessment Outcome

Demonstrated

7. The regulator links its assessment methods to the requirements/standards for entry to the profession or trade. [Objectivity]

Assessment Outcome

Demonstrated

8. The regulator requires that assessors consistently apply qualifications assessment criteria, policies and procedures to all applicants. [Objectivity]

Assessment Outcome

Demonstrated

9. The regulator uses only qualified assessors to conduct the assessments. [Objectivity]

Assessment Outcome

Demonstrated

10. The regulator monitors the consistency and accuracy of decisions, and takes corrective actions as necessary, to safeguard the objectivity of its assessment decisions. [Objectivity]

Assessment Outcome

Demonstrated

11. The regulator prohibits discrimination and informs assessors about the need to avoid bias in the assessment. [Impartiality]

Assessment Outcome

Demonstrated

12. The regulator implements procedures to safeguard the impartiality of its assessment methods and procedures. [Impartiality]

Assessment Outcome

Demonstrated

13. The regulator gives applicants an opportunity to appeal the results of a qualifications assessment or to have the results reviewed. [Fairness]

Assessment Outcome

Demonstrated

14. The regulator assesses qualifications, communicates results to applicants, and provides written reasons for unsuccessful applicants, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

15. Regulators that rely on third-party assessments establish policies and procedures to hold third-party assessors accountable for ensuring that assessments are transparent, objective, impartial and fair. [Transparency, Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

OFC Comments

The College uses assessment results from designated third-party language testing agencies to verify whether an applicant, who did not complete their post-secondary education in English or French, meets the language fluency requirement for registration. The College has taken measures to ensure that these third-party assessors’ assessment practices are transparent, objective, impartial and fair. For example, the College has:

  • Researched and consulted with various third-party agencies, other regulators and post-secondary institutes before finalizing decisions to work with specific third-parties;
  • Monitored issues and concerns raised by the College’s counterparts in several networks with other regulators in relation to third-party practices; and
  • Reviewed the content of third-party assessors’ websites to include relevant information on the College’s website and in its registration materials for applicants.

To further the College’s efforts in this area, it may be worthwhile for the College to consider added measures to monitor and evaluate these third-parties’ assessment practices. For example, the College could develop an agreement with each third-party assessor that establishes service standards and procedures for monitoring and holding the third-party assessor into account. The College could also work in collaboration with these third-party assessors to identify and address any potential issues from applicants in relation to their assessments.

Suggestions for continuous improvement

Identify and implement added measures to verify that third-party language assessment agency practices are transparent, objective, impartial and fair. Measures might include:

  • Developing procedures to evaluate and monitor third-parties’ assessment practices;
  • Identifying and taking actions to address issues raised by applicants; and
  • Documenting service standards and agreements with third-party agencies.

7. Specific Duty — Training

FARPACTA, s. 11

1. The regulator provides training for staff and volunteers who assess qualifications or make registration, internal review or appeal decisions. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

OFC Comments

The College provides staff that assesses qualifications and makes registration and internal review decisions with ongoing training on topics specific to their roles and functions. Training has included fair registration principles and practices, decisions and reasons writing, conflict of interest and bias, and assessing refugee qualifications, to name a few of the areas covered. The College has also provided its staff with training on phone services skills and accompanying handbook to ensure that responses to requests from applicants, members and the public are courteous, consistent and accurate.

The College has informed the OFC that they are undergoing a workflow redesign of their Registration Department. Registration staff is closely involved in redeveloping administrative procedures and resources, including those related to the processing of applications. In the final stage of the Registration Department’s reorganization, the College intends to implement a training plan that will prepare all staff for the resultant changes. In addition to the training plan, it would be useful for the College to develop support materials and resources for future reference by required staff as needed.

Suggestions for continuous improvement

Develop and provide support materials and resources obtained through training to required staff involved in the assessment of qualifications and registration decisions.

Commendable practice

Providing phone services skills training and compiling an accompanying handbook for staff to ensure consistent and accurate responses to queries from applicants, members and other stakeholders.

2. The regulator addresses topics of objectivity and impartiality in the training it provides to assessors and decision-makers. [Objectivity, Impartiality]

Assessment Outcome

Demonstrated

3. The regulator identifies when new and incumbent staff and volunteers require training and provides the training accordingly. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

8. Specific Duty — Access to Records

FARPACTA, s. 12

1. The regulator provides each applicant with access to his or her application records. [Fairness]

Assessment Outcome

Demonstrated

Commendable practice

Keeping inactive applicant files open for three years to allow applicants to reapply for registration without being required to resubmit information or supporting documentation that is already in the file.

3. If there is a fee for making records available, the regulator review the fee to ensure that it does not exceed the amount of reasonable cost recovery. [Fairness]

Assessment Outcome

Not Applicable

OFC Comments

The College does not have a fee for making records available to applicants. However, the OFC notes that this information is not included in the College’s information for applicants.

Suggestions for continuous improvement

Indicate that there is no fee for an applicant that requests access to their records in information for applicants.

General Duty

FARPACTA, Part II, s.6

Transparency

  • Maintaining openness
  • Providing access to, monitoring, and updating registration information
  • Communicating clearly with applicants about their status
Assessment Outcome

The College takes various measures to achieve transparent registration practices. To take these efforts even further, the OFC identified five suggestions for continuous improvement. Three commendable practices have also been identified.

Openness

The College implements various steps to enable interested stakeholders to understand how the registration process operates and how registration decisions are made. The College’s actions include:

  • Providing information on up and coming council meetings and elections, and meeting highlights that include key updates and council approvals;
  • Publishing information about the structure of accountability for registration and appeals functions, including references to the number of appointed public members in each committee;
  • Providing detailed information and documentation on its website about registration requirements and processes, including application forms and guides, frequently asked questions, and paths to registration flowcharts;
  • Collaborating with Global Experience Ontario (GEO) to develop resources for internationally trained migrants to Ontario in the early childhood education field;
  • Conducting a bi-annual entry-to-practice survey to elicit feedback from recent graduates on their experiences in applying for membership, finding employment, transitioning in their careers, and their levels of professional satisfaction;
  • Eliciting feedback from external stakeholders, through activities such as focus groups, to inform the development and review of registration policies, procedures and requirements;
  • Implementing a communications strategy that will increase and diversify their interactions with interested stakeholders;
  • Distributing a bi-annual magazine that provide updates on the College and the early childhood education sector;
  • Developing a Social Media Policy that guides the College’s interactions with the public through a variety of social media platforms, including YouTube and Twitter; and
  • Modifying the website to improve compatibility with tablets and smartphones.

It is evident that the College has numerous structures and processes already in place to promote transparency. However, to create even further clarity, the College could consider providing interested stakeholders with access to the council meeting packages by posting these materials on their website under Council Meeting Highlights.

The OFC also noted in the latest entry-to-practice survey report that the College targeted only those registered graduates from an approved Ontario post-secondary early childhood education program. It might be helpful for the College to widen their outreach for the survey to include feedback from respondents who applied for registration from non-accredited educational programs.

Access

The College ensures that applicants have access to relevant information at the time and in the way they need to take the appropriate steps in the registration process. For example, the College’s website includes information on third-party agencies that an applicant may come into contact with in the registration process, and steps in the process that an applicant can complete before their arrival in Canada. The College has also implemented a self-assessment component for the Individual Assessment (IA) process. The self-assessment form provides applicants with the chance to gain a clearer understanding of the criteria the College uses to assess their educational qualifications against the vocational learning outcomes for registration.

Clarity

The College takes measures to communicate with applicants throughout the registration process and to ensure that the information provided is complete, accurate and easy to understand. For instance, the College:

  • Made recent revisions to registration materials and communications with applicants to enhance clarity and readability and to highlight pertinent information;
  • Put a system into place that helps registration staff promptly notify applicants about the status of their applications throughout the registration process; and
  • Sends reminders to applicants about missing documentation until the application is complete.

While the College has implemented measures to ensure that information for applicants is clear and easily available, the OFC has identified one area where the College might make efforts to further increase transparency. The College provides fees information related to the registration and appeals processes in their registration materials for applicants. However, this information does not make reference to the related costs that an applicant who undergoes the IA process will need to consider, including costs associated with credential assessments, language testing and translations of documents. For further transparency, the OFC suggests that the College include a dedicated webpage for a fees schedule to outline the full range of costs to applicants in the registration process.

The College informed the OFC that they have taken measures to reduce the time that inactive files remain open from two years to six months. Applicants that are unresponsive to the College’s requests to provide required information and documentation according to established processes and timelines will receive a proposal to refuse (PTR) certification. The OFC has not identified any exclusions or barriers to applicants due to this amendment in process; however, it will be important to monitor this change to ensure that there are no unintended consequences to applicants.

Suggestions for Continuous Improvement

Provide council meeting packages, including meeting agendas and resource materials, available to interested stakeholders on their website.

Widen the outreach for the entry-to-practice survey to elicit feedback from diverse groups of applicants and members.

Establish a community advisory group to provide ongoing public input into discussions about key registration policies and practices. Include a range of community member voices and perspectives, including Francophone, Indigenous and internationally trained individuals.

Develop an online fees schedule that outlines the costs to applicants in the registration process, including other related costs that an applicant may incur in completing the process. Provide references to this schedule in information for applicants and registration materials.

Develop and implement guidelines or other similar documents for staff and decision-makers that include a process for informing applicants of potential delays in the registration process and estimated decision dates, when delays are unavoidable.

Commendable Practices

Developing a Social Media Policy to explain how the College will engage with the public on its social media platforms.

Improving the clarity and accessibility of information on the individual assessment process on the College’s website and in registration materials for applicants. This included:

  • Compiling all content on the individual assessment process on one webpage for easier navigation
  • Aligning frequently asked questions with registration materials
  • Enhancing the individual assessment guide for applicants with more information on the process and required documentation
  • Designing a flowchart that helps applicants determine if they will need to undergo the individual assessment process to register with the College.

Implementing a self-assessment tool to provide applicants with increased understanding of the criteria the College uses to assess their educational qualifications against the vocational learning outcomes as part of the individual assessment process.

Objectivity

  • Designing criteria and procedures that are reliable and valid
  • Monitoring and following up threats to validity and reliability
Assessment Outcome

The College takes various steps to achieve objectivity in its registration process as follows:

Reliability

To attain reliability in registration decisions, the College:

  • Provides decision-makers with access to a range of policy documents that guide them in interpreting documented evidence from applicants against registration requirements and criteria;
  • Documents the steps and procedures that all decision-makers need to take to reach consistent and reliable assessment and registration decisions;
  • Using an application entry system and checklists to record applicants’ completed and missing requirements; and
  • Provides the necessary training to ensure that decision-makers have a shared understanding of their roles and responsibilities, the requirements of each stage of the registration process and their purpose.

Validity

The College also take several steps to ensure that registration decisions are valid. For instance the regulator:

  • Conducts peer-reviews of applications and groups meetings to discuss complex files;
  • Cross-checks assessment and registration decisions throughout the decision-making process;
  • Requires that the Office of the Registrar review all applications that have been assessed by assessors before final decisions are made about applicants’ eligibility for registration.

Impartiality

  • Identifying bias, monitoring, and taking corrective action
  • Implementing strategies
Assessment Outcome

The College implements measures to achieve impartiality in its registration decisions.

Identification of Bias

The College has taken steps to help its decision-makers identify sources of potential bias in the registration process. For example, the College has:

  • Implemented a conflict of interest policy and formal procedures that require staff, committee and council members to declare any potential conflicts of interest;
  • Provided staff and committee members with ongoing training and resource materials on various topics, including managing cultural differences, fair registration practices and procedures, and conflict of interest. Training materials additionally outline the steps staff and committee members need to take to manage situations of bias; and
  • Provided the RAC with additional training on bias and human rights issues.

The College also has guidelines in place for staff and committee members that prohibit discrimination and outline expectations and procedures for identifying, addressing and mitigating bias in its registration practices.

Strategies

The College uses the following strategies to both avoid and mitigate situations of bias in its decision-making:

  • Using documented evidence, including third-party documentation where appropriate, as a basis for assessments and registration decisions;
  • Conducting registration staff group discussions, peer-reviews and blind reviews to come to assessment and registration decisions; and
  • Considering internal and external factors that may influence policy changes and potential impacts that the changes might have on those affected by it.

Suggestions for continuous improvement

Provide staff and committee members with the opportunity to view and discuss the OFC learning module, Fair-Access Law in Scenarios, and apply strategies learned to registration and reviews practices.

Fairness

  • Ensuring substantive fairness
  • Ensuring procedural fairness
  • Ensuring relational fairness
Assessment Outcome

The College takes a number of measures to promote fairness in its registration practices.

Substantive Fairness

The College takes the following actions to promote substantive fairness:

  • Offers the Individual Assessment (IA) process as an alternative for applicants that do not have either an educational qualifications equivalent to an early childhood education program from an Ontario College of Applied Arts and Technology (OCAAT) or a College-approved program to meet registration requirements;
  • Assesses whether an applicant meets the minimum educational requirements for registration as part of the first phase of the IA process;
  • Clearly maps the each registration requirement to the specific competencies or set of competencies that it addresses in its information for applicants and registration materials;
  • Reviews and updates relevant policy documents that relate to registration, such as language proficiency and professional conduct policies, to better align criteria and provide alternatives to applicants to meet the requirements; and
  • Periodically reviews registration requirements to ensure that they remain relevant and necessary to the practice of early childhood education in Ontario.

The College recently introduced fees for applicants to request reconsiderations and reviews of registration decisions. While the College has provided a rationale for these fees, the OFC suggests that further analysis be conducted going forward to ensure that these fees do not deter applicants from accessing their right to reviews of registration decisions. With fairness in mind, the College could consider refunding the fee for a request to reconsideration or a review if the registration decision is overturned.

The College informed the OFC that in 2017, the Ministry of Advanced Education and Skills Development (MAESD) began a review of the standards for OCAAT diploma programs in early childhood education. As part of MAESD’s first round of stakeholder consultations, the College submitted a report with eight recommendations for the new program standards being developed. Any changes made by MAESD to the program standards will result in associated changes to the College’s registration requirements and regulations. If changes are implemented, the OFC understands that the College will undergo a review of its policies and procedures for the education requirement to identify and address any consequential impacts to applicants. If from this review it is determined that changes are necessary and relevant, it would be important that the College implements them in a way that is transparent, objective, impartial and fair. The OFC will continue to monitor these developments and would be prepared to consult with the College on these matters as needed.

Procedural Fairness

The College takes steps to support procedural fairness in its registration practices, including:

  • Highlighting steps that an applicant can take to start the registration process from outside of Canada;
  • Redesigning the workflow and streamlining steps to process applications for registration, including those steps involved in the IA process;
  • Cross-checking assessment results at various points in the process and finalizing registration decisions through the Office of the Registrar; and
  • Promotes diversity and representation in its committees and among committee chairs.

As part of the IA process, the College assesses an applicant’s work experience in the early childhood education field for the practicum component of the education requirement. To meet the requirement, an applicant’s work experience must be validated by someone who has supervised their practice. Validators are provided with a form that they need to complete by the College. Previously, letters of reference were provided to meet this requirement. While a guide for validators is available on the College’s website, applicants are not provided access to the validation of work experience form. To ensure that this practice does not unjustifiably exclude or limit applicants from jurisdictions where English and French are not the working languages, it might be useful for the College to provide applicants with access to this form on their website. This will allow applicants the opportunity to provide clarity and support to validators as needed to demonstrate this requirement.

The College also requires that applicants for the IA process submit detailed course descriptions for each course that they have completed as part of their education. Previously, short course descriptions were accepted; however, the College stated that these descriptions provided limited information for the assessment. While the OFC recognizes the importance of a comprehensive assessment to the IA process, it is suggested that the College consider the potential impacts that changes to registration requirements and procedures have on applicants. Impacts to applicants as a result of changes could include are additional costs and increased application processing times.

As previously noted in this report, the OFC recognizes that as part of the workflow redesign of the Registration Department, the College will be looking for ways to lessen the overall timelines for applicants undergoing the IA process. The OFC supports these efforts and encourages the College to continue to monitor their processes and implement strategies that will further reduce these timelines.

Relational Fairness

The College takes the following actions to ensure relational fairness for its applicants:

  • Considers applicants’ requests to provide alternative documentation, where required documentation cannot be obtained for reasons beyond their control, as per the Policy regarding Unavailable Documents; and
  • Provides accessible customer service to persons with disabilities and training to staff on AODA, the customer service standard, the Regulation and the Human Rights Code, as per the Accessibility Standards Policy.

Suggestions for continuous improvement

Refund the fee for the reconsideration and reviews process to the applicant if the registration decision is overturned.

Include the Validation of Work Experience Form for the individual assessment process in information for applicants for further transparency.

Take measure to examine and monitor the impact of changes to registration requirements and procedures of the IA process to identify whether they have the effect of excluding or limiting certain groups of applicants.

Commendable Practice

Offering the individual assessment process as an alternative to applicants that do not have equivalent educational qualifications or a College-approved program to meet registration requirements. The first phase of the process tells an applicant whether they meet the minimum educational qualifications required to register with the College. Applicants who have not met the minimum requirements are therefore not required to go through with the remainder of the process.

Providing applicants with more options to meet the language proficiency requirement for registration through revisions to the Policy regarding Language Fluency.

Developing and implementing the Policy regarding Unavailable Documents to guide decision-makers in considering applicants’ requests to provide alternative documentation, where required documentation cannot be obtained for reasons beyond their control.

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Background


Assessment Methods

Assessments are based on the Registration Practices Assessment Guide: For Regulated Professions and Health Regulatory Colleges. The guide presents registration practices relating to the specific duties and general duty in the fair access legislation.

A regulatory body’s practices can be measured against the fair access legislation’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 the Order’s registration practices

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 OFC's website.

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.

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References

  1. ^ These includes: all practices from Information for Applicants, practice 3 from Internal Review and Appeals, practice 1 from Information on Appeal Rights, practice 1 from Documentation of Qualifications, practice 1 from Assessment of Qualifications, practice 2 from Access to Records, and practices 4-11 from Transparency of the Registration Practices Assessment Guide.
  2. ^ Please note: Suggestions for continuous improvement appear only in the detailed report. Suggestions for improvement are not intended to be recommendations for action to demonstrate a practice, but are made solely to provide suggestions for areas that a regulatory body may consider improving in the future.

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