Skip to Content


In February 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Occupational Therapists of Ontario (COTO) 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 February 2014 targeted assessment of the COTO focused on the areas where the OFC made recommendations in the full assessment it completed in April 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


Availability of Report

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

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


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

  • Assessment of Qualifications


General Duty

Assessment Method

The COTO 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 April 2012, the COTO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Checked


The OFC found that since the last assessment, the COTO has taken measures to ensure transparent, impartial and fair registration practices. However, it should make some minor changes to further improve the fairness of its practices. 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 COTO is demonstrating commendable practices in the following area(s).

Assessment of Qualifications

  • systematically reviewing occupational therapy degrees obtained outside of Canada using the Academic Review Tool. This comprehensive and standardized process helps ensure that programs are reviewed consistently and objectively. The substance of international degrees is measured against the Essential Competencies of Practice for Occupational Therapists in Canada.


  • formulating and presenting COTO registration policies in a systematic and consistent way. Each policy includes detailed information that makes clear which COTO policies underlie each aspect of the registration process. Articulating the principles and legislative/regulatory provisions on which the policies are founded makes it easy to understand the rationale for the policies. This gives the COTO a defensible basis for its registration practices.


  • in the registration committee orientation material, specifically mentioning fiduciary duty in relation to conflict of interest. This sends a strong message to decision-makers that they must not let competing interests influence the decision-making process. Professional regulatory bodies have a fiduciary duty to protect the public interest by ensuring that only qualified and competent individuals are licensed to practise. The fiduciary duty therefore requires that registration decisions are made in an impartial and unbiased way.


  • choosing to undergo a legal audit of the registration committee’s processes, to provide an external, objective view of the legal aspects of the registration committee’s function. Following the audit, the COTO implemented the recommendations.



The COTO should improve in the following areas:


  • Indicate in its registration information that applicants can complete all steps in the registration process while they are outside of Canada, with the exception of writing the National Occupational Therapy Certification Examination.
June 2014
  • Modify its Accessibility Customer Service Policy, in order to indicate clearly that applicants may ask any COTO staff member for any type of accommodation (as part of the registration process or any other dealings with the COTO).
June 2014
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 the COTO.

They have all been implemented.