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Introduction

In May 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Optometrists 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.

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Focus of This Assessment and Report

The May 2014 targeted assessment of the COO focused on the areas where the OFC made recommendations in the full assessment it completed in December 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

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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.

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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.

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 of Registration Practices.

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Assessment Summary

Specific Duties

Specific duties assessed

As a result of the recommendations made in the full assessment completed in December 2011, the COO 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 Checked
Assessment of Qualifications Checked
Training Checked
Access to Records Unchecked

Outcomes

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

  • Training

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

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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 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 December 2011, the COO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Checked

Comments

The OFC found that since the last assessment, the COO has taken some measures to promote transparency, impartiality and fairness. Recommendations for further improvement are listed below.

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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).

Documentation of Qualifications

  • working with applicants to identify acceptable alternative evidence of course content – such as testimonials from instructors – in cases where applicants cannot get the required course descriptions for reasons beyond their control

Training

  • promptly implementing training recommendations made in the last assessment report

Transparency

  • communicating well with applicants about their application. For example, the COO:
    • takes the time to explain policies and criteria to applicants one-on-one
    • maintains a checklist of required documents for each applicant’s file and contacts applicants regularly to inform them of any outstanding documents

Fairness

  • working to remove the requirement that all internationally educated applicants must complete bridging, by initiating the development of an evaluating exam. Candidates who are successful on the evaluating exam would proceed directly to the licensing exam. This will help to address access challenges related to limited spaces in the bridging program. 
  • recently consulting a specialist about increasing the number of acceptable tests for the demonstration of language proficiency
  • ensuring that, at every registration committee meeting, there is a standing agenda item to review registration policies, with the goal of addressing inefficiencies and streamlining processes
  • providing reviews about decisions as quickly as possible. Additional registration committee meetings may be convened so that applicants do not have to wait for the next scheduled meeting.
  • funding the entire development of the evaluating exam without passing costs onto applicants

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Recommendations

The COO should improve in the following areas.

Documentation of Qualifications

Status
  • Update the table of required documents in “Submitting Documents Required for Registration” and “Acceptable Variations in Documents Required for Registration,” or create similar tables to explain documentation requirements for the pre-registration application process. (Practice 4.1)
Checked
July 2014
  • Provide information about how to contact the COO to explore what alternative documentation may be acceptable, if applicants cannot get the required documentation for reasons beyond their control. (Practice 4.1)
Checked
July 2014

Assessment of Qualifications

 
  • In the appropriate section of the website, describe how work experience is taken into account during the credential assessment process. (Practice 5.1)
Checked
July 2014
  • Provide a detailed description of the content of an acceptable degree in optometry, so that applicants can see what their credentials will be assessed against. (Practice 5.1)
Checked
July 2014
  • Continue to provide input into policy development for the national credential assessment process, to ensure that qualifications assessment criteria are applied consistently to all applicants. Suggest the development of a more explicit policy for factoring work experience into the determination of academic equivalency. (Practice 5.3)
Checked
August 2014
  • Ensure that a bylaw is approved to create a separate panel of the registration committee that will consider appeals of credential assessments independently of the original decision-makers. (Practice 5.7)
Checked
May 2014
  • Provide more detailed information on the website about how to access the appeal option within the pre-registration process. (Practice 5.8) *
Checked
May 2014

Transparency

 
  • Clearly state the following on the website:
 
  • The COO will accept a combination of undergraduate study and work experience to meet the pre-registration requirement.
Checked
July 2014
  • At present, successful completion of a bridging program is mandatory for all applicants who did not complete an accredited program in Canada or the U.S. *
Checked
May 2014
  • Add the following information to the website:
 
  • the type of World Education Services assessment that applicants need to obtain (that is, a course-by-course evaluation)
Checked
July 2014
  • the steps in the assessment process that may be undertaken from outside of Canada
Checked
July 2014
  • timelines for each stage of the application process that is under the COO’s control
Checked
July 2014
  • Develop and post a formal access-to-records policy that documents the following:
 
  • the way that an applicant can ask for records
Checked
July 2014
  • the way in which records are available
Checked
July 2014
  • who may access the records
Checked
July 2014
  • how long the records are kept
Checked
July 2014
  • what limitations (if any) exist on the right to access the records
Checked
July 2014
  • Continue revising the website, to make information easier to find and understand.
Checked
August 2014

Impartiality

 
  • Continue to develop a review process for identifying ways in which conflict of interest may impact registration decisions. Develop strategies to mitigate any potential risks identified.
Checked
September 2014

Fairness

 
  • Explain the rationale for the pre-registration requirement for completion of a three-year undergraduate degree or completion of three years of optometric work experience, so that applicants can understand why the requirement is necessary and how it is linked to the standards of practice.
Checked
September 2014
  • Continue to develop an evaluating exam that will enable internationally trained applicants to bypass the bridging program when they demonstrate the required competencies for practice.
Checked
June 2015
  • Explore the potential differential impact of any of the COO’s requirements on groups of applicants by discussing the issue with other regulatory bodies at a future Registration Exchange Group meeting.
 
  • Re-evaluate the required format of each document that applicants must submit, with the goal of increasing flexibility and reducing expense to applicants without compromising standards.
Checked
October 2014
  • Consult with other regulators about their documentation requirements for course descriptions and syllabuses, to explore options for increasing flexibility without compromising standards.
Checked
July 2014

* The COO implemented all recommendations marked with an asterisk before the OFC completed its 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 13 recommendations for the regulatory body.

They have all been implemented.

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