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In June 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Massage Therapists of Ontario (CMTO) 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.


Focus of This Assessment and Report

The June 2014 targeted assessment of the CMTO focused on the areas where the OFC made recommendations in the full assessment it completed in November 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


Availability of Report

The OFC encourages the CMTO 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.


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.


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.


Assessment Summary

Specific Duties

Specific duties assessed

As a result of the recommendations made in the full assessment completed in November 2011, the CMTO 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


The CMTO has demonstrated some 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.


General Duty

Assessment Method

The CMTO 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 November 2011, the CMTO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Unchecked
Fairness Checked


The OFC found that since the last assessment, the CMTO has taken some measures to ensure a transparent and fair registration process. However, the OFC identified areas where the CMTO needs to make its registration practices fairer and more transparent (see the Recommendations section below).


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 the areas reviewed, for this assessment period.



The CMTO should improve in the following areas.

Assessment of Qualifications

  • Provide evidence to the OFC to indicate that certain decision-making criteria for the language assessment and Credential and Prior Learning Assessment (CPLA) are clear to applicants, staff and decision-makers involved in the processes. In particular, provide evidence that:
  • The criteria for determining who is required to provide evidence of a language assessment are recorded in a way that is complete, clear, and available to applicants, staff and decision-makers.

July 2015
  • The criteria for determining results, decisions and directions for each of the CPLA components (education assessment, Diagnostic Health Studies Written Examination (Diagnostic MCQ), Objectively Structured Clinical Examination (OSCE), and Comprehensive Clinical Evaluation (CCE)) are recorded in a way that is complete, clear, and available to applicants, staff and decision-makers. (Practice 5.1)
  • Provide evidence to the OFC of a clearly explained connection to the competencies for certain assessments, including:
  • language assessment

April 2016
  • CPLA components (education assessment, Diagnostic MCQ, OSCE, and CCE)

April 2016
  • Given that the CMTO is transitioning from a provincial to an inter-jurisdictional competency model, it must demonstrate a connection between each of the assessment methods and specific competencies. (Practice 5.2)

April 2016
  • Provide clear guidelines for interpreting and applying criteria, and provide sufficient training, for the following:
  • assessing the need for an applicant to provide evidence of a language assessment

July 2015
  • compiling supporting documents and assessing results in order to make a decision during the CPLA process (Practice 5.3)

July 2015
  • Completely review all the qualifications assessment tools the CMTO uses for language assessment, CPLA and exams, to ensure that the tools, criteria, procedures and training for assessors and decision-makers continue to be valid and reliable. (Practice 5.6)
  • Give all applicants the same opportunity to appeal the qualifications assessments that the CMTO administers. (Practice 5.7)

July 2015
  • Clearly articulate on the CMTO website:
  • the criteria for determining who is required to provide evidence of a language assessment, and when this determination is made

July 2015
  • the criteria for determining results, decisions and directions for the CPLA (e.g., content areas, weightings and pass scores for the Diagnostic MCQ, OSCE, and CCE components; and the criteria required for assessing education equivalency, such as breadth and depth of content areas, and clinical hours)
  • how the assessment criteria for language proficiency and the CPLA are linked to the competencies required for practising the profession (Practice 5.8)

April 2016
  • Monitor timelines for communicating with applicants about qualifications assessments. (Practice 5.9)

July 2015 


  • List accurate fees in all of the registration documentation.

July 2015
  • Give francophone applicants access to registration materials in French, by providing one of the following on the CMTO website:
  • a statement in French instructing applicants how to contact the CMTO for information in French

July 2015
  • translated registration materials

July 2015
  • Identify the steps in the registration process that can be completed outside of Canada.

July 2015


Substantive Fairness  
  • Complete a comprehensive review (including mapping) of, and provide justification for, the necessity and relevance of all of the CMTO’s registration requirements and their relevance to the Inter-Jurisdictional Practice Competencies and Performance Indicators for Massage Therapists at Entry-to-Practice, to ensure that all of the requirements continue to be necessary and relevant to demonstrating these competencies. †
    Note: This recommendation combines two recommendations that have been carried forward from the OFC’s November 2011 full assessment.

July 2016
Procedural Fairness  
  • Remove all elements of subjectivity from the identifying of who is required to undergo an assessment of language proficiency.

July 2015
  • Give applicants an opportunity to appeal all components of the qualifications assessment.

July 2015
  • Inform applicants that their rights to ask questions, disagree with a process, dispute results and request an appeal are not threatened or limited by the information explaining the CMTO’s expectations about applicant conduct during the registration process.

July 2015
  • Provide clear guidance to staff members and the registration committee about the interpretation of the conduct requirement. This guidance should include objective criteria on which to base their opinion of an applicant’s suitability to practise with decency, honesty, integrity and a professional attitude.

July 2015
  • Document all internal processing timelines, in particular the timelines for registration committee decisions. Without set timelines, the CMTO cannot adequately monitor its adherence to timelines.

July 2015

† 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 seven recommendations for the regulatory body.

Five of those recommendations have been implemented and two have been carried forward into this report as one combined recommendation.