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In August 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Opticians of Ontario (COO) 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 August 2014 targeted assessment of the COO focused on the areas where the OFC made recommendations in the full assessment it completed in September 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 COO 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 September 2011, the COO has been assessed in the area(s) marked below:

None Unchecked
Information for Applicants Checked
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 COO has demonstrated all of the practices in the following specific-duty area(s):

  • Information for Applicants

For practices that are partially demonstrated or not demonstrated, see the Recommendations section later in this summary.


General Duty

Assessment Method

The COO 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 September 2011, the COO 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 COO has taken measures to ensure transparency and fairness in the registration process. Two further improvements should be made in the areas of transparency and fairness (see the Recommendations section later in this summary).


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

Assessment of Qualifications

  • participating in a full-scale review and validation of the national entry-to-practice competencies and the Prior Learning Assessment and Recognition (PLAR) process, in order to do the following:
    • prioritize the competencies and map them to the Computerized Gap Analysis (CGA) and interview
    • validate and determine the reliability of the multiple-choice questions in the CGA
    • develop interview questions
    • develop a standard scoring approach for each interview question and create an objective cut score to guide performance evaluation
    • develop an interviewer training manual
  • These activities will help to improve the objectivity of the PLAR process and the consistency of assessments.


  • launching the new COO website, which:
    • provides more complete registration information
    • improves the accessibility of registration information
    • enables applicants to understand the registration process from start to finish
    • helps applicants to understand what is expected at each step in the process
  • informing applicants on the website that if they cannot provide formal documentation about previous education or practice history, the COO will accept a written explanation and a statutory declaration instead. This helps to ensure that applicants have access to all relevant information about acceptable alternatives and are not deterred from applying if they do not have formal documentation.


  • informing applicants, both on the website and in individual communication, about the upcoming dates for the interview component of the PLAR process. This is important because there are only four interview dates per year. Applicants can now plan accordingly and be strategic about when to schedule the CGA component of the PLAR process, which must be completed before the interview.



The COO should improve in the following area(s):

Assessment of Qualifications

  • On the PLAR process application form, remove the requirement that applicants with non-accredited education must provide three professional references, since this requirement is not linked to any of the COO’s registration requirements. (Practice 5.2)
April 2015


December 2015
  • In the COO’s registration materials, describe:
  • the criteria for the evaluation of “yes” responses for the Declaration of Conduct
  • the process the registrar and the registration committee use to make their decisions


  • Continue to explore options for providing applicants with resources that help them understand the format and expectations of the interview component of the PLAR process
Blank = Implementation is in progress.
= Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.

Assessment History

In the previous assessment, the OFC identified 16 recommendations for the regulatory body.

Thirteen of those recommendations have been implemented. The remaining three have since been deemed not feasible by the COO and the OFC.