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Registration Practices Assessment Report — Overview
ONTARIO COLLEGE OF PHARMACISTS (OCP):
Pharmacists and Pharmacy Technicians

Introduction

In July 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the Ontario College of Pharmacists (OCP) 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 July 2014 targeted assessment of the OCP focused on the areas where the OFC made recommendations to the OCP in September 2011 in separate, full assessments for Pharmacists and Pharmacy Technicians.

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 OCP 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 assessments completed in September 2011, the OCP 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 Checked
Training Unchecked
Access to Records Unchecked

Outcomes

The OCP has demonstrated most of the practices in the following specific-duty area(s).

  • Information for Applicants
  • Assessment of Qualifications

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 OCP 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 assessments completed in September 2011, the OCP has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Unchecked
Fairness Checked

Comments

Transparency: The OCP is transparent about the registration process, timelines and requirements. The OCP website is an effective tool for clear and accurate communication of registration information. The OCP communicates often with applicants throughout the registration process and provides guidance for completing supporting documents and exams. Applicants can see that how decisions are made and policies are applied; nothing is hidden. Reasons are provided in writing and steps applicants can take to correct deficiencies are identified. Applicants have access to an appeal mechanism and to their own records, if necessary. The OCP meets the principles of openness, access, and clarity.

Fairness: The OCP continues to work cooperatively and willingly with the OFC toward fairness in registration. The principles of fair registration practices were at the core of many of the changes made to the OCP regulation in 2010. The OCP has a continuous quality-improvement process and formally evaluates its registration programs and tools to ensure that they are relevant and necessary and that objectives are being met. The OCP intends to revise its Structured Practical Training (SPT) Program so that applicants with international experience similar in scope to Canadian practice can demonstrate their competence for entry to practice more quickly. The revised program will be implemented in 2015.

Suggestions for further improving transparency and fairness are described in the Recommendations section later in this summary.

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

Information for Applicants

  • laying out registration information clearly on the new OCP website. In particular, the pathways to registration are well laid out for each type of applicant, with links to requirements and helpful forms.
  • positioning the link to O.Reg. 202/94 on the OCP website’s main “Registration” page
  • providing helpful guidance for completing the Declaration of Good Character form, via the Guidance for Completion of the Declaration Questions information sheet that immediately precedes the form. The information sheet clearly states what to report to the OCP, and allows applicants to consider the relevance of good character as it relates to their suitability to practise the profession. It also allows applicants to self-assess their ability to practise the profession safely, ethically, and effectively.
  • stating clearly that applicants in all registrant classes require professional liability insurance, and providing the rationale for this policy. Hypothetical questions and answers help clarify the requirement and the types of insurance available to candidates. Further, the OCP explains the amount of insurance required and the steps applicants can take if they cannot obtain coverage.
  • providing the “Supporting Documentation for Registration” page for each type of applicant. This page lists many documents that an applicant must provide in order to be registered. The OCP also informs applicants how to contact the OCP when they cannot obtain documents.
  • providing timelines for each type of applicant on the OCP website, in an easy-to-follow chart. It explains processing timelines; expiry dates to ensure currency of knowledge, skills, and judgement at the time of final application; and the time required to complete the entire registration process, including requirements at the Pharmacy Examining Board of Canada (PEBC).

Assessment of Qualifications

  • posting on the OCP website the minimum acceptable scores for all language assessments (such as the Test of English as a Foreign Language (TOEFL), Michigan English Language Assessment Battery(MELAB), and International English Language Testing System (IELTS)). The OCP also considers alternative evidence of language proficiency in English or French, and explains how an applicant might approach the registration committee with this non-objective evidence. The policy on non-objective evidence is clear and the higher burden of proof for non-objective evidence is clearly stated.
  • providing an abundance of resources with respect to the jurisprudence exam, including:
    • an e-learning module, slides, and sample questions to guide applicants
    • an exam blueprint, which includes the content required to prove knowledge of all legislation affecting the profession of pharmacy
    • an exam protocol, which describes the exam format, material required, the length of the exam, and general rules when taking the exam. It also includes the hand-scoring process the OCP uses when an applicant appeals his or her exam score. 
  • sending out broad communication to all candidates when exam results are posted. The OCP communicates directly with unsuccessful applicants to tell them their exam result and how to self-assess weaknesses in order to better prepare for another attempt at the exam. It also tells eligible applicants that they can immediately register for another exam sitting.

Transparency

  • enabling applicants to log on to an online registration portal to find information that helps them understand the requirements for registration and how they apply to the applicants’ specific situations. When a policy applies to an applicant, he or she is advised by email.
  • giving stakeholders many ways to give feedback to the OCP on the registration process, including by email or by phone. With the launch of its new website, the OCP introduced a new, more formalized consultation process for gaining stakeholders’ input on policy and guideline development. Using the “News” section of the “Applicant” homepage, the OCP can inform applicants of any consultation that is ongoing.

Fairness

  • developing the ability to respond to multiple types of accommodation requests, including special accommodations, requests for part-time completion of the Structured Practical Training (SPT) Program, and accommodations at the PEBC. Development of the online course for the International Pharmacy Graduate (IPG) Program and the National Bridging Program for Pharmacy Technicians was based on the desire to accommodate applicants who want to complete registration part-time and to provide greater accessibility for applicants in various locations.
  • evaluating core registration requirements (such as SPT) in depth, and over time. In this way, ongoing determination of the relevance and necessity of all the requirements will be part of the cyclical continuous quality improvement (CQI) process.
  • reviewing OCP programs (such as the IPG Program and the SPT Program) to increase flexibility in the way programs are applied to individuals and to reduce the programs’ differential impact on international applicants.

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Recommendations

The OCP should improve in the following areas:

Information for Applicants

Status
  • Include a sentence on the OCP website stating that registration information is available in French upon request. (Practice 1.1)
Checked
July 2014

Assessment of Qualifications

 
  • On the OCP website, inform applicants about how the criteria that qualifications assessments are based on are linked to the requirements/standards for entering the profession. That is, describe each topic for the jurisprudence exam and explain how those topics and knowledge of Ontario law relate to the competencies for pharmacy practice. (Practice 5.8b)
Checked
July 2014
  • Include information on the OCP website about applicants’ opportunity to appeal the results of a qualifications assessment to the registration committee. (Practice 5.8d)
Checked
July 2014

Transparency

 
  • Indicate on the OCP website when a policy serves as an alternative mechanism to meet a registration requirement.
Checked
July 2014
  • In the Privacy Code, include more inclusive language regarding pharmacy technician applicants.
Checked
July 2014
  • Closely review the OCP website to ensure that all exemptible requirements are identified.
Checked
July 2014

Fairness

 
  • Provide a clear rationale for all non-exemptible requirements for registration on the OCP website.
Checked
July 2014
  • Allow applicants more than a mere administrative appeal of an exam result.
Checked
July 2014

NOTE: The OCP implemented all recommendations before the OFC completed its assessment. As a result, no action plan for implementing recommendations is required

 
Blank = Implementation is in progress.
Checked = Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.

Assessment History

In the previous, separate assessments of the OCP for Pharmacists and Pharmacy Technicians, the OFC identified eight recommendations.

They were all implemented.

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