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In December 2013, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Medical Radiation Technologists of Ontario (CMRTO) 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 December 2013 targeted assessment of the CMRTO focused on the areas where the OFC made recommendations in the full assessment it completed in February 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 comments for specific-duty practices
  • an overview of comments related to the general duty
  • commendable practices
  • recommendations


Availability of Report

The OFC encourages the CMRTO 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 February 2012, the CMRTO has been assessed in the area(s) marked below:

None Unchecked
Information for Applicants Checked
Internal "Review" Unchecked
Information on Appeal Rights Unchecked
Documentation of Qualifications Unchecked
Assessment of Qualifications Unchecked
Training Unchecked
Access to Records Unchecked


The CMRTO has demonstrated all of the practices in the following specific-duty area(s):

  • Information for Applicants


General Duty

Assessment Method

The CMRTO 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 February 2012, the CMRTO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Unchecked
Fairness Unchecked


The OFC found that since the last assessment, the College of Medical Radiation Technologists of Ontario (CMRTO) has taken active measures to ensure transparency. Recommendations for further improvement are listed 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 CMRTO is demonstrating commendable practices in the following area(s).

Information for Applicants

  • maintaining a comprehensive, accessible, and user-friendly website. The website’s wording was reviewed by a plain language expert, and the content is regularly reviewed and updated by the CMRTO’s Communications and Publications administrator. The website has distinct subpages pertaining to all aspects of the registration process. For example, it includes separate information for each of the three professional streams, and separate information for graduates of Ontario, other Canadian, and international programs.
  • providing information for applicants that spans the entire application process, including pre-immigration steps
  • providing a consolidated, comprehensive, and current source of information for internationally educated applicants in the “Career Map for Internationally Trained Medical Radiation Technologists,” which was last updated in March 2013


  • providing information on the website for applicants that is comprehensive, clear, and easy to find
  • maintaining well-documented council-approved registration policies. The policies are:
    • readily available to registration staff on the internal intranet and available in hard copy to the registration committee at each meeting
    • directly based on legislated registration requirements 
    • reviewed and updated whenever amendments are made to the registration regulation. The review process includes stakeholder consultation.
  • setting out in the Career Map for Internationally Trained Medical Radiation Technologists all actions that applicants must take to complete the registration process, and providing a rationale for these actions, as well as expected outcomes
  • providing individual, customized support for applicants throughout the entire application process, including the option for in-person meetings, at applicants’ request. The CMRTO works with applicants to ensure that they compile a complete application package before it is referred to the registration committee.



The CMRTO should improve in the following areas.


  • Add information to the CMRTO website to advise applicants that they may request copies of their application documents by submitting a request in writing to the registration department.
  • Add a graphic to the CMRTO website to augment existing material that advises applicants of timelines associated with registration.
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 four recommendations for this regulatory body.

They have all been implemented.