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Introduction

In July 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Respiratory Therapists of Ontario (CRTO) 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 CRTO focused on the areas where the OFC made recommendations in the full assessment it completed in August 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

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Availability of Report

The OFC encourages the CRTO 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 August 2012, the CRTO 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 Unchecked
Assessment of Qualifications Checked
Training Unchecked
Access to Records Unchecked

Outcomes

The CRTO has demonstrated or partially demonstratedall of the practices in the following specific-duty area(s):

  • Assessment of Qualifications

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General Duty

Assessment Method

The CRTO 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 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 Checked

Principles assessed

As a result of the recommendations made in the full assessment completed in August 2012, the CRTO has been assessed on the principle(s) marked below:

None Unchecked
Transparency Checked
Objectivity Unchecked
Impartiality Checked
Fairness Unchecked

Comments

The OFC found that since the last assessment, the CRTO has demonstrated all of the practices in the following general-duty areas:

  • Transparency
  • Impartiality

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

Assessment of Qualifications

  • using clear language and providing a rationale for registration requirements in registration policies. The Determining Good Character Policy is particularly helpful in articulating the rationale for the policy and how it is used in the determination of eligibility for registration. The policy is supported by well-defined criteria and provides a description of possible outcomes of a good-character assessment. The policy also allows this requirement to be exempted, where appropriate. The policy also provides for possible outcomes that may result from a good-character assessment. 
  • reviewing the entire assessment process for internationally educated applicants. Later in 2014, the CRTO will implement new mechanisms for a competency-based assessment that aligns with the National Competency Profile developed by the national Alliance of Respiratory Therapy Regulatory Bodies. To promote consistent and reliable decision-making, the CRTO used various techniques to make the new mechanisms valid and fair. For example, the CRTO worked with an assessment company with extensive psychometric training to conduct and validate a needs assessment related to entry-to-practice requirements. The CRTO consulted with stakeholders to analyze entry-to-practice requirements and worked with content experts and a psychometrician to develop an assessment blueprint.
    One of the new assessment mechanisms for internationally educated applicants is an interview. Although interviews may be vulnerable to subjective and inconsistent decision-making, the CRTO has taken steps to mitigate this. Notably, the interview will follow the Behaviour Description Interview (BDI) approach, which is well-established as a valid and reliable means of predicting future performance based on past performance. The CRTO developed the interview format with a psychometrician to ensure validity and consistency in decision-making. BDI methodology has been enhanced by the development of behavioural scoring anchors based on the National Competency Profile companion documents, as well as content experts nominated by the CRTO.
    The interview will use two or more questions to assess each competency to obtain multiple samples of behaviour and will be administered by a panel. This will encourage procedural fairness (e.g., increased rating reliability and decreased potential for bias). Every interview will be scored immediately after its administration.
    Interviewer training is underway. It addresses substantive and procedural issues related to rating accuracy. Before the first actual interviews are administered, the CRTO will conduct additional training on the scoring process.
    The interview is one of three components of the CRTO’s assessment of internationally educated applicants (in addition to educational review and clinical skills assessment). Interview findings will not exclude applicants from other steps in the assessment process.

Transparency

  • surveying members about their communications needs before developing a new communications plan and launching a new website for the CRTO.

Impartiality

  • providing extensive training for council, committee and staff members on impartial and unbiased decision-making, with a strong emphasis on conflict of interest. For example:
    • New council, committee and staff members receive orientation and training on governance, code of conduct, conflict of interest, committee roles and scope of responsibility, relevant legislation and CRTO policies.
    • The Annual Education Day exposes council, committee and staff members to topics such as anti-discrimination, cultural competence, values in ethical decision-making, quality and community.
    • The Chairs Dinner allows council and committee chairs, vice chairs and staff to review and discuss good governance and decision-making.
    • The Annual Committee Orientation provides formal orientation and ongoing training to committee members.
    • Annual training for registration committee and registration staff provides ongoing education on: how to assess qualifications and make registration and review decisions; dealing with special considerations; human rights; anti-discrimination; and legislation and policies.
    • The Ontario Regulators for Access Consortium Learning Day provides additional exposure to topics such as recognizing diversity in cultural perspectives and managing situations where there is potential for misunderstanding and conflict.
    • Additional guidance, oversight and peer training on emerging issues are provided to registration decision-makers by senior staff, legal counsel and consultants.
  • updating its Professional Practice Guideline on Conflict of Interest in support of its general regulation under the Respiratory Therapy Act. The updated guideline will outline what may constitute conflict of interest and offer guidance on how to prevent and deal with it.

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Recommendations

There are no recommendations for this assessment period.

In the spirit of continuous improvement, the OFC expects that the CRTO will maintain its standards and continue its efforts toward more transparent, objective, impartial and fair registration practices.

Assessment History

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

They have all been implemented.

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