Office of the Fairness Commissioner
ISBN 978-1-4606-3230-7 (HTML)
ISBN 978-1-4606-3131-7 (PDF)
I am pleased to present the study, Academic Requirements and Acceptable Alternatives: Challenges and Opportunities for the Regulated Professions in Ontario.
The purpose of the research was twofold: to compile information about the academic requirements that Ontario regulatory bodies demand and to describe the alternatives they are willing to consider when they judge someone's application.
The requirements are sometimes quite rigid and the alternatives hard to get, costly, or unsustainable.
Mostly, of course, this affects people who are internationally educated — the very highly skilled people Ontario so urgently needs. They grapple with a licensing system that undervalues their international qualifications and underrates their overseas experience.
I call on regulatory bodies to be more flexible in their assessments and to boost the alternatives they accept.
Regulators and government officials both have a responsibility to act in the public interest, to find acceptable alternatives to this waste of human resources.
Ad-hoc innovation is not enough. Our collective future depends on long-term vision and a commitment to immigrant success.
I hope this study draws attention to this compelling topic.
Hon. Jean Augustine, PC, CM
November 15, 2013
Internationally educated people often struggle to meet the academic requirements for licensing in a regulated profession in Ontario. This study, Academic Requirements and Acceptable Alternatives: Challenges and Opportunities for the Regulated Professions in Ontario, examines fair-access issues related to those requirements. It focuses principally on 38 professions under the mandate of Ontario's Office of the Fairness Commissioner. The study presents these professions' standard academic requirements, discusses their flexibility in recognizing "acceptable alternatives" to these requirements, and examines fair-access issues for those alternatives.
Canada's immigrants often arrive with high levels of education and may have been licensed to practise a profession. But they often find it challenging to become licensed here.
In some cases, the challenge lies with differences in requirements: applicants who practised their profession with an undergraduate degree in their home country may need a graduate degree to practise here. In other cases, applicants have difficulty showing the equivalence of their education.
National and provincial governments, and many regulatory bodies, have worked to bring increased flexibility to the licensing process for the regulated professions. Their efforts have included improvements to the recognition of international credentials, and innovations in competency-based assessment and training.
Increasingly, regulatory bodies are identifying acceptable alternatives for meeting the academic requirements to become licensed. These include alternative ways for applicants to develop competencies and alternative ways in which these competencies can be demonstrated or assessed.
The professions' academic requirements vary, from college diplomas, to general BAs, to post-graduate academic or professional degrees.
Almost all professions have a mechanism for accepting alternatives to their standard academic requirements.
Five types of acceptable alternatives that are available in various professions include:
Each type of alternative can help improve applicants' access to licensing, and each also presents challenges. For example, time commitments and costs vary widely, and are often extremely significant.
Some alternatives also face sustainability challenges, due to uncertain or project-based funding.
Nationally, there is a significant correlation between the accessibility of acceptable alternatives and reduced disadvantage for internationally educated professionals.
Acceptable alternatives bring new flexibility to the licensing process, but they do not remove all barriers for internationally educated professionals.
Regulators must still ensure that academic requirements are relevant and necessary to the practice of the profession. Acceptable alternatives must be developed with careful attention to accessibility, affordability and sustainability.
Educational institutions and governments are key partners in sustaining acceptable alternatives and maximizing their fair-access contributions. For lasting impact, programming that helps internationally educated professionals to bridge competency gaps must be better integrated into the core work of post-secondary education. And governments must commit ongoing funding and support participants with adequate financial aid.
Today's immigrants in Canada are more highly educated than ever before. However, these immigrants are seeing poor returns on the educational investments they made before coming to Canada. Over the past three decades, the earnings of Canada's immigrants have steadily declined compared to the earnings of their Canadian-born counterparts.1
Response to the decline has focused on finding better ways to recognize international qualifications, especially for people educated in a regulated profession. As a result:
These initiatives have helped to expand the focus of assessment from applicants' paper credentials to their actual competencies, and to introduce new and flexible alternatives for developing and recognizing the required competencies.
Ontario's Office of the Fairness Commissioner (OFC) was created through the passing of fair-access legislation in 2006.2 Since 2007, it has been tracking changes made by many of Ontario's regulated professions. Between 2007 and 2012, 13 Ontario professions introduced changes with regards to acceptable alternatives that applicants can use to meet the requirements for licensing in those professions. These changes included:
However, for the most part, the requirements themselves have not changed. It is a basic principle of self-regulation that the profession itself establishes the registration requirements that are considered necessary to ensure safe and competent practice of the profession.
Therefore, the OFC cannot directly mandate changes to licensing requirements.
However, the OFC can:
This study explores licensing challenges that internationally educated applicants continue to face in meeting academic requirements for licensing in Ontario. In particular, it analyzes the effectiveness of initiatives designed to accommodate differences in educational training received outside of Canada. These "acceptable alternatives" include alternative ways to acquire professional competencies and alternative ways in which these competencies can be demonstrated or assessed.
The study focuses on the following questions:
This focus addresses an important gap in the research literature, where there has been little systematic analysis of acceptable alternatives for meeting academic requirements. The study offers a brief review of the existing research literature on this subject, but focuses mainly on an in-depth analysis of reports and information that regulators have submitted to the OFC.
Many acceptable alternatives are relatively new. Regulators and education-providers have much to learn from each other, regarding the strengths and limitations of different approaches they have taken. At the same time, federal and provincial governments can also learn from these experiences with acceptable alternatives, to better target their funding and to ensure the sustainability of fair-access interventions.
The analysis that follows seeks to contribute to continuous improvement in the designing and implementing of acceptable alternatives for meeting licensing requirements. The analysis will pay particular attention to the alternatives' accessibility, affordability, efficiency and effectiveness.
This study is organized in the following sections:
A significant body of research has documented the challenges that internationally educated people face when they try to get work in Canada.
However, most studies have tended to either:
Further, except for a few profession-specific case studies presented at conferences on prior learning assessment, there has been little systematic exploration of the use of acceptable alternatives to introduce flexibility into the licensing process for regulated professions.
This study addresses that gap.
The study also builds on existing literature that shows the continuing undervaluing of immigrants' education in the Canadian labour market. One study showed that two-thirds of recent immigrants with a university education were working in occupations that usually required no more than a college education or an apprenticeship.3
Such findings illustrate the urgency of developing new strategies to overcome licensing barriers, in order to more effectively mobilize the knowledge and skills of internationally educated professionals.
Canada is not alone in facing these challenges for immigrants. A 2009 European study showed that 36% of working-age immigrants born outside of the European Union (EU) were overqualified for their jobs, compared to 28% of those born in the EU and 21% of those who were born in the EU country where they were working. To help address this key policy challenge, the European Commission recently supported a major study on the recognition of migrants' qualifications.4
That study notes several important developments since the year 2000. For example:
EU citizens typically face fewer barriers, while people from countries outside the EU often face limited access to both professional recognition and permanent residence.
Drawing on case studies from Australia and Canada, the EU study recommends initiatives such as:
At the same time, the study stresses the important role that mutual recognition agreements between different jurisdictions can play in easing the recognition of foreign qualifications and enhancing mobility.
Innovations in the assessing and recognizing of qualifications have an important role to play in correcting the undervaluing of immigrants' education. However, other barriers — such as those related to language assessment and learning — must also be addressed.
Recent Australian research has called for improving the assessment of internationally educated health professionals' language skills. It notes that native English speakers often fail to achieve the language benchmarks that internationally educated applicants need to reach to become licensed. The research urges regulators to carefully analyze the language competencies required for professional practice, rather than uncritically adopting benchmarks established by other regulatory bodies.5
Better learning methods are also critical. In Canada, many internationally educated professionals are frustrated by the slow pace and generic nature of intermediate language programs. Despite recent growth in advanced training in occupation-specific language skills, access to these programs is still limited.6
The time lost to meeting language benchmarks — as much as five years — can be significant. Extended time away from practice can contribute to the deterioration of applicants' professional skills and a lack of up-to-date knowledge. This significantly lessens the applicants' chances of becoming licensed.
In Canada, internationally educated professionals face a variety of barriers, at both the individual and system level.7 Language difficulties are a frequent and obvious barrier. But there are other, often-overlooked barriers.
For example, employers prefer applicants who have Canadian experience. This "Canadian experience" barrier is so prevalent that the Ontario Human Rights Commission recently warned employers and regulatory bodies that rejecting applicants on this basis may constitute a human rights violation.
Employers tend to hire immigrants into positions that do not reflect their education and experience. A Toronto research roundtable identified concerns about the emerging trend of "skills hoarding" — where employers benefit from workers' higher-level skills without ever opening doors to jobs and salaries that are appropriate for those skills.8
Research on temporary foreign workers has also pointed to employers' preference for overqualified candidates.
Temporary foreign workers coming through low-skilled pathways face even greater obstacles, as their employment at low-skill jobs makes them ineligible to apply for permanent residence status under the Canadian Experience Class. Because their work visa ties them to a specific employer or sector, many temporary workers have no way forward to employment that is appropriate to their skills.9
Over the last decade, temporary migration — both skilled and low-skilled — has grown rapidly in Canada. This has created new challenges for qualification recognition. It has also driven various changes in the regulation of professions. For example:
However, there remain serious contradictions between the "just-in-time" orientation of temporary migration programs and the complexities of the licensing process for regulated professions.
To improve economic outcomes for immigrants, government policy-makers have repeatedly adjusted the way Canada selects skilled immigrants. The Immigration and Refugee Protection Act (2002) introduced a human-capital model that awarded points based on language, education and work experience, while later changes brought back a priority-occupations list.
However, changing selection criteria alone has been largely ineffective in helping to appropriately integrate immigrants into the economy.
Census data shows that immigrants earn significantly lower amounts than their Canadian-born counterparts. In 2006, the average annual income of university-educated immigrants in their prime working years was just over half that of their Canadian-born counterparts.10 Another study of pre- and post-migration employment showed that 48% of immigrants were employed in occupations requiring university training before they came to Canada. Only 23% were employed in such occupations four years after landing.11
Improving the process for selecting immigrants is not enough:
Researchers who have focused on the regulated professions have recommended that regulators and governments target their help at the early years after immigrants arrive in Canada. The reasoning is that if immigrants are to succeed in entering their intended profession, that success is most likely to happen during these early years — or not at all. Long delays in getting licensed can lead immigrants to a downward economic spiral.14 Prolonged unemployment or underemployment leads to deterioration of their professional skills and loss of confidence, which reduce their chances of getting appropriate work.15
Research indicates that interventions should aim to improve understanding of other jurisdictions' educational systems and increase the scope of mutual recognition agreements, while also building capacity to pinpoint and address applicants' competency gaps.
Currently, the region where immigrants were originally educated has a significant impact on their licensing and employment outcomes, as does their education after they arrived in Canada. Immigrants have better outcomes if they studied in countries with education systems and language of instruction that are similar to Canada's. So do immigrants who complete post-migration education in Canada.16
Observers note that regulatory bodies need funding and support from government to correct the generally poorer outcomes for immigrants. They have questioned the prospects for future progress on the recognition of foreign qualifications, given that much government funding has been project-based rather than ongoing.17
Researchers argue that several positive initiatives that need support include those designed to:
This study of academic requirements and acceptable alternatives was carried out from December 2012 to August 2013. Its goal was to identify fairness issues related to academic requirements for licensing and acceptable alternatives for meeting those requirements, in 38 Ontario professions, by reviewing information sources readily available to the Office of the Fairness Commissioner (OFC).
The OFC oversees 40 regulatory bodies for Ontario professions and trades. Some regulatory bodies oversee more than one profession. This study:
As background to this study, a brief literature review analyzed major research findings related to the undervaluing of immigrants' education.
No primary research was undertaken.
Rather, data collection included:
To enrich the analysis, 10 reviewers were asked to comment on a draft version of this document. These reviewers have a broad range of expertise in research, the education of professionals, the regulation of professions, bridge training, and the integration of individuals and groups into the labour market.
In recent years, there has been a strong public policy focus in Canada on improving processes for recognizing and assessing foreign credentials, both for reasons of fairness and to maximize immigrants' contributions to the Canadian economy.
Some progress has been made.
For example, the Pan-Canadian Framework for the Assessment and Recognition of Foreign Qualifications has helped to raise awareness and increase financial support for assessment and recognition initiatives by regulatory stakeholders (for example, provincial regulatory bodies and national organizations that deliver assessments and exams). At the same time, the framework has enhanced national coordination and harmonization of professional standards. This, together with labour-mobility legislation, helps professionals who are already registered in one Canadian jurisdiction to practise in another.
However, it is difficult to assess the framework's success in meeting its primary goal: to help immigrant professionals "use to the fullest their skills and experience within the Canadian labour market."18 The federal government's latest progress report notes that Canada has not yet developed a strategy for measuring the framework's impact.19
Despite the Pan-Canadian Framework, internationally educated people seeking licensing in a regulated profession continue to face significant challenges.
In some cases, these challenges may be related to differences in the academic requirements for licensing in different jurisdictions for the same profession. For example, a person might have practised as a psychologist with a master's degree in his or her home country, but require a doctoral degree to be licensed in Ontario.
In other cases, the greater challenge for applicants may lie in demonstrating that their academic background is "equivalent" or "substantially equivalent" to the academic requirement in Ontario.
Some individuals also experience difficulties getting the transcripts and course descriptions they need to prove their academic achievements.
Regulating a profession involves defining acceptable qualifications and establishing a distinction between people who are qualified to practise the profession and those who are not.
On the one hand, this distinction protects the public from unqualified practitioners.
At the same time, it grants power, social status and higher income to the members of a closed group. This can lead to protectionism, where escalating academic requirements and restrictive licensing practices exclude new members unnecessarily.
Professionalization can therefore both serve and undermine the public interest. Sociologists have explored the relationship between professions and income inequality, and have documented patterns of exclusion on gender and racial lines.20 At the same time, sociologists have recognized the positive role that specialized knowledge and an altruistic professional ethos can play in the self-regulation of professions.21
Regulators are pulled in different directions by their public-protection mandate and by the interests of their members. Progress on recognizing international credentials needs to be grounded in:
At the same time, self-regulation must be balanced by oversight and accountability. Vigilance is required to ensure fair access to the professions, and to enrich their membership with the contributions of diverse applicants.
In Ontario, as in other provinces, regulatory bodies are subject to intense public scrutiny and take seriously their mandate to protect the public interest. Given the variation in educational programs in different jurisdictions, regulators seek a high level of assurance that applicants have the knowledge and skills that are necessary to practise competently and safely.
In many cases, regulators do not understand the applicant's academic program well enough to have this level of assurance. Even in cases where a paper-based assessment of applicants' credentials suggests that the applicants have an academic background similar to the profession's requirements, non-traditional applicants22 may have to undergo additional assessments or exams before regulators can recognize the "equivalency" of their academic qualifications.
Gaps in regulators' understanding of international credentials can thus drive the development of alternative assessments and even bridge training, to address perceived gaps in academic training. While such alternatives are preferable to not recognizing the credentials at all, they frequently add to the complexity, length and cost of the licensing process.
To decrease the burden on applicants, the development of acceptable alternatives for meeting licensing requirements must be matched by improvements to credential-recognition processes and the expansion of mutual recognition agreements that allow for automatic full or partial recognition of credentials.23 Currently, mutual recognition agreements are largely limited to English-speaking Commonwealth countries.
Regulators may also need to reflect on their experience with competency-based assessments, and to integrate this learning into their processes. For example, where applicants with a particular educational background are consistently successful on an assessment, it may be unnecessary to assess later applicants with that same background.
This can help streamline the recognition of qualifications and standardize requirements for those later applicants. For example, Professional Engineers Ontario's academic requirements committee has reduced the number of technical exams assigned to a particular group of applicants based on past performance on these tests by applicants with the same educational background.
By building on experience and improving qualification-recognition programs over time, regulators can offer targeted alternatives to applicants with true gaps in academic training, rather than bridge gaps in assessors' abilities to recognize international credentials. For this to happen, regulators may need more resources to conduct research, improve assessor training, and enhance objectivity.
Offering targeted alternatives is all the more important because of the different impact of existing academic requirements and qualification-recognition processes on different groups of applicants.
Some applicants benefit from the regulatory body's advance screening of their academic program, through either an accreditation or mutual recognition process. For these applicants, the licensing process is relatively streamlined. For example:
On the other hand, applicants from non-accredited programs and non-recognized jurisdictions must individually prove the equivalency of their education. Often this involves some form of competency assessment or bridge training to confirm that they have the required knowledge and skills to practise the profession in Ontario. Applicants not only bear the burden of proving their competency, but may also face significant challenges related to the time and cost associated with these extra assessments and training.
The challenges associated with meeting academic requirements may also vary depending on the length of the educational program required for licensing. Where required programs are relatively short (such as a college diploma), it may be easier for non-traditional applicants to repeat all or part of their studies through a regular academic program. Where programs are longer (such as a university degree), there may be a greater need for alternative pathways for demonstrating competencies and/or filling gaps in academic training.
Ontario's fair-access legislation includes the Fair Access to the Regulated Professions and Compulsory Trades Act (FARPACTA) and corresponding provisions in the Regulated Health Professions Act (RHPA). This legislation recognizes the authority of self-regulating professions to specify licensing requirements and acceptable alternatives.
But it also introduces a new level of accountability:
The Office of the Fairness Commissioner (OFC) follows up on issues identified in entry-to-practice reviews that the regulators submit, and monitors the transparency of acceptable alternatives. However, it does not exert direct influence over licensing requirements.
The fair-access legislation does establish two key principles that are critical to improving fair access to the professions:
Following these two principles, the OFC encourages regulators to identify "acceptable alternatives" for meeting licensing requirements.
Most professions require some form of post-secondary education for licensing.
Indeed, the development of a separate field of academic knowledge is central to the process of establishing a profession. A profession presents itself as the knowledge authority in a particular field and defines acceptable qualifications for professional practice. The primary marker of qualification is usually a post-secondary education.
Among Ontario professions, academic requirements vary, but most professions require a university degree. As shown in Table 1:
Some professions also require a program of professional education or training, such as a post-graduate residency at a medical school or a professional program offered by one of the accounting regulators. Professional education and training requirements are distinct from educational requirements, and present unique challenges beyond the scope of this study. Acceptable alternatives to professional education requirements are often quite limited, as these requirements are very specifically linked to intensive practical training or work experience in Canada.
Compared to small professions, large professions and those requiring university degrees are more likely to have national or bi-national accreditation bodies. These professions tend to have a longer history and a stronger resource base.
Accreditation and approval processes specify what kind of academic program meets the standard for licensing.
Canadian programs are usually held accountable to this specific standard, although an increasing number of Canadian private career colleges offer non-accredited programs.
Non-accredited and international programs can be assessed in relation to an accredited or approved program, to determine whether an applicant meets the academic requirement or requires further training.
An applicant must have completed...
|ACCREDITATION OR APPROVAL
The academic program must be...
|Architects||A degree in architecture from a post-secondary institution||Accredited by the Canadian Architectural Certification Board|
|Chartered Accountants||A four-year undergraduate degree / prescribed course credit requirements||Accredited by the Institute of Chartered Accountants of Ontario|
|Early Childhood Educators||A diploma from a program in early childhood education||Approved by the College of Early Childhood Educators|
|Engineering Technicians and Technologists||A two-year engineering technician/applied science diploma program or a three-year engineering technologist/applied science diploma program||Accredited by the Canadian Technology Accreditation Board|
|Engineers||A bachelor's degree in an engineering program||Accredited by the Canadian Engineering Accreditation Board|
|Foresters||A four-year science-based degree||Approved by the Ontario Professional Foresters Association|
|General Accountants||A four-year undergraduate degree / prescribed course credit requirements||Accredited by Certified General Accounts of Ontario|
|Geoscientists||A four-year bachelor of science degree in an area of geoscience||Approved by the Association of Professional Geoscientists of Ontario on the basis of meeting the course requirements set out in the document entitled "Minimum Knowledge (Academic) Requirements"|
|Land Surveyors||A program at the baccalaureate level in professional surveying||Approved by the Association of Ontario Land Surveyors|
|Lawyers||A bachelor of laws2 or juris doctor degree||Accredited by the Law Society of Upper Canada|
|Management Accountants||A four-year university baccalaureate-level or graduate degree / prescribed course credit requirements||Accredited by Certified Management Accountants of Ontario|
|Paralegals||A legal services program||Accredited by the Law Society of Upper Canada|
|Social Service Workers||A diploma in social service work||At a college of applied arts and technology in Ontario|
|Social Workers||A degree in social work||Accredited by the Canadian Association for Social Work Education|
|Teachers||An acceptable post-secondary degree||A program of professional education accredited or approved by the Ontario College of Teachers|
|Veterinarians||A basic degree in veterinary medicine||Accredited by the American Veterinary Medical Association Council on Education|
|Audiologists and Speech-Language Pathologists||A professional master's degree in audiology or speech-language pathology or both||Accredited by the Council for Accreditation of Canadian University Programs in Audiology and Speech-Language Pathology|
|Chiropodists||A post-secondary program whose curriculum includes courses in health sciences, chiropodial sciences, humanities and clinical education3||Approved by the College of Chiropodists of Ontario|
|Chiropractors||The requirements for graduation from a chiropractic education program||Accredited by the Canadian Federation of Chiropractic Regulatory and Educational Accrediting Boards|
|Dental Hygienists||A program in dental hygiene equivalent to a full-time program of two years||Accredited by the Commission on Dental Accreditation of Canada|
|Dental Surgeons||A degree in dentistry as evidence of successful completion of a course in dental studies of at least four years duration at a university-based dental school||Accredited by the Commission on Dental Accreditation of Canada|
|Dental Technologists||An approved program in dental technology||At a college of applied arts and technology in Ontario|
|Denturists||A diploma in denture therapy or denturism||Approved by the College of Denturists of Ontario|
|Dietitians||A university program in foods and nutrition||Accredited by Dietitians of Canada|
|Massage Therapists||A diploma in massage therapy||At a private vocational school or college of applied arts and technology in Ontario|
|Medical Laboratory Technologists||An approved course of study in medical laboratory technology||Accredited by Canadian Medical Association — Conjoint Accreditation Services|
|Medical Radiation Technologists||A program in medical radiation technology||Approved by the College of Medical Radiation Technologists of Ontario|
|Midwives||A baccalaureate degree in health sciences (midwifery)||Obtained in Ontario|
|Nurses||Nurse Practitioner: Master's degree in nursing / Nurse practitioner program||Approved by the College of Nurses of Ontario|
|Registered Nurse: A baccalaureate degree in nursing||Accredited by the Canadian Association of Schools of Nursing|
|Registered Practical Nurse: A program in practical nursing||Approved by the College of Nurses of Ontario|
|Occupational Therapists||A bachelor of science degree or master of science degree in occupational therapy||Obtained in Ontario|
|Opticians||An opticianry program||Accredited by the National Association of Canadian Optician Regulators|
|Optometrists||An optometry degree||Accredited by the Accreditation Council on Optometric Education|
|Pharmacists||A minimum of a baccalaureate degree in pharmacy4||Accredited by the Canadian Council for Accreditation of Pharmacy Programs|
|Pharmacy Technicians||A pharmacy technician program||Accredited by the Canadian Council for Accreditation of Pharmacy Programs|
|Physicians and Surgeons||A degree in medicine||Accredited by the Committee on Accreditation of Canadian Medical Schools|
|Physiotherapists||A degree in physiotherapy / physical therapy||Approved by the College of Physiotherapists of Ontario|
|Psychologists||Psychologist: a doctoral degree from a program of study with content primarily psychological in nature
Psychological Associate: a master's degree
|Approved by the College of Psychologists of Ontario on the basis of meeting guidelines published by the college|
|Respiratory Therapists||A program in respiratory therapy||Accredited by the Council on Accreditation for Respiratory Therapy Education|
|Column 2||Column 3|
|College program is required||No profession-specific approval is needed|
|Undergraduate degree is required||Must be approved by the regulatory body|
|Graduate/professional degree is required||Must be accredited by an external accreditation body|
Ontario's regulated professions operate within the constraints imposed by their statutes, regulations and bylaws. Professions can propose changes to any of these official documents, but the amendment process can be long and cumbersome. Changes to statutes and regulations must be approved by the Ontario government. Changes to bylaws must be approved by the profession's membership.
These approval processes help ensure that changes are carefully considered. However, they can also limit the regulators' flexibility in responding to new challenges, such as the increasing number of internationally educated applicants.
Typically, professions describe their academic requirements in registration regulations.
Some consider that taking a flexible approach to academic requirements is incompatible with their registration regulations.
However, many professions have relied on flexible interpretations of terms like "equivalent academic qualifications" to introduce acceptable alternatives for assessing or developing professional competencies. Others prefer to go through the amendment process and embed new approaches within their registration regulations.
The regulations or other official documents typically state that an applicant must have:
Some professions' regulations include a third clause that:
The variations in this third clause reflect a growing recognition among regulators that professional competencies can be developed in a variety of ways, and not only through formal academic study.
The bar for recognizing alternative academic credentials is high:
The wording of most registration regulations continues to emphasize credentials, rather than competencies. This can translate into a focus on program format and hours, rather than content and skills development. The regulations for pharmacists and pharmacy technicians are unique in specifying their acceptance of a program approved by their council as "one whose graduates should possess knowledge, skill and judgment at least equal to those of current graduates of an [accredited] program."32
Despite the continued emphasis on academic programs and credentials, registration regulations frequently allow for acceptable alternatives for meeting academic requirements. These acceptable alternatives involve recognition of competencies developed through complementary training and/or work experience.
As noted earlier, some regulators take a flexible approach to interpreting clauses about "equivalent" or "substantially equivalent qualifications." Others embed clauses that describe the specific approach to recognizing competencies developed outside a formal academic program.
A full 20 professions use language that allows for a more holistic assessment of knowledge and skills:
Professions requiring graduate-level education are the least flexible about recognizing competencies developed outside of formal academic education.
An academic program is still the normal route to developing professional competencies. Registration regulations may allow applicants to demonstrate a combination of education and experience that is considered equivalent to the academic requirement, but they rarely allow for exemptions from the requirement to have completed an academic program.
Accounting bodies are more flexible than most professions, since they require both an undergraduate academic education and a program of professional training offered by the regulator. Applicants can complete required academic credits either during or after their undergraduate degree, and develop core competencies through their professional program. As a result:
Only two health regulators — for physiotherapy and respiratory therapy — offer exemptions. These exemptions are offered only in extremely limited circumstances, where the applicant was previously licensed or registered in either the same or a different province.
The flexible wording of many registration regulations (see section 6) reflects a growing recognition by regulators that applicants can develop professional competencies in various ways, and not only through an academic program. Many professions have put this principle into practice, by recognizing a range of "acceptable alternatives" for meeting academic requirements.
Ontario's fair-access legislation encourages this flexible approach to academic requirements. FARPACTA states that regulated professions must provide information about "objective requirements for registration by the regulated profession together with a statement of which requirements may be satisfied through alternatives that are acceptable to the regulated profession."37
Regulators interpret this clause in a variety of ways. For example, in their Fair Registration Practices Reports, some regulators describe alternative pathways for meeting academic requirements, while others define the requirement itself as including several options, and therefore list no alternatives.
For the purpose of this study, acceptable alternatives include:
Acceptable alternatives go significantly beyond the acceptance of alternative documentation of academic credentials. All but two38 of the professions included in this study recognize some kind of acceptable alternative for meeting academic requirements.
As stated in section 6, twenty professions take a holistic approach to assessing academic qualifications, and consider competencies developed outside of formal education. Others complete a more traditional credential assessment, but offer applicants various ways to address identified gaps in their competencies.
Acceptable alternatives contribute to fair access by introducing flexibility into the licensing process:
However, acceptable alternatives can also present challenges to fair access. Applicants may not have the time or the financial resources to take advantage of acceptable alternatives for meeting academic requirements.
Regulators, for their part, struggle with issues of sustainability. In many cases, alternative assessments and training programs designed to fill gaps are delivered by external qualifications-assessment agencies and education providers, and are highly dependent on time-limited funding from the federal or provincial government.
In this study, the Office of the Fairness Commissioner (OFC) does not prescribe a preferred approach to acceptable alternatives. Rather, the aim is to describe current practices, and to highlight relevant fairness issues.
In this study, acceptable alternatives have been classified into five broad types or categories:
Table 2 identifies the professions offering these types of acceptable alternatives, and presents highlights about:
|Acceptable Alternative||Professions where this alternative is available||Delivery||Cost to applicant||Time implications||Access to appeal of the result|
Paper-based assessment of education and experience
Total: 10 professions
Chartered Accountants, Engineering Technicians and Technologists, Engineers, Foresters, Geoscientists, Land Surveyors, Management Accountants, Social Service Workers, Social Workers
Medical Laboratory Technologists
7 professions' regulatory bodies directly deliver paper-based assessments:
Chartered Accountants, Engineers, Geoscientists, Land Surveyors, Management Accountants, Social Service Workers, Social Workers
3 professions use tools developed nationally:
Engineering Technicians and Technologists, Foresters, Medical Laboratory Technologists
Low end: Included in licensing application fee
High end: $678
Several professions inform applicants that the assessment process is complex and lengthy.
Most structured example: Assessments take place twice yearly with results available after 6–8 weeks.
Appeal of registration decision is available in all cases. No fee.
Structured portfolio assessment process offers options for full and partial reassessment. Involves a fee.
Direct assessment of knowledge and/or skills
Total: 16 Professions
Engineering Technicians and Technologists, Engineers, Foresters, Geoscientists, Lawyers, Veterinarians
Audiologists & Speech-Language Pathologists, Dental Hygienists, Dental Surgeons, Dental Technologists, Massage Therapists, Nurses, Opticians, Pharmacists, Pharmacy Technicians, Physicians
9 professions' regulatory bodies directly deliver an assessment or exam:
Audiologists & Speech-Language Pathologists, Dental Hygienists, Dental Technologists, Engineering Technicians and Technologists, Engineers, Foresters, Geoscientists, Massage Therapists, Opticians.
6 professions accept assessments or exams delivered by a national body:
Dental Surgeons, Lawyers, Pharmacists, Pharmacy Technicians, Physicians, Veterinarians
The nursing profession offers an Objective Structured Clinical Examination delivered through a provincial third party: the Centre for the Evaluation of Health Professionals Educated Abroad.
Low end: $75 per written exam
High end: $7,200 for a clinical exam
Low end: Exams offered 4 times per year.
High end: Exams offered once yearly.
One exam has a waiting period of 24 months.
Recourse is typically specific to the exam or assessment process and may involve a fee.
Self-paced learning to fill academic gaps
Total: 20 professions
Architects, Chartered Accountants, Early Childhood Educators, Engineering Technicians and Technologists, Engineers, Foresters, General Accountants, Geoscientists, Land Surveyors, Lawyers, Management Accountants, Social Service Workers, Social Workers, Teachers
Audiologists & Speech-Language Pathologists, Dietitians, Massage Therapists, Medical Laboratory Technologists, Nurses, Opticians
13 professions direct applicants to take courses at a post-secondary institution:
Architects, Chartered Accountants, Early Childhood Educators, Engineering Technicians and Technologists, Engineers, General Accountants, Geoscientists, Lawyers, Management Accountants, Nurses, Social Service Workers, Social Workers, Teachers.
Accounting courses may be taken at a university or through a regulatory body
For 7 professions, an individualized plan for filling gaps is negotiated by the applicant and regulator:
Audiologists & Speech-Language Pathologists, Dietitians, Foresters, Land Surveyors, Massage Therapists, Medical Laboratory Technologists, Opticians.
The Association of Ontario Land Surveyors offers its own bridging courses.
Architecture Canada offers the Royal Architectural Institute of Canada (RAIC) curriculum, an alternative to university-based courses.
Depends on discipline, institution and the number of courses required.
Courses offered by a regulator or national professional organization are generally cheaper.
Association of Ontario Land Surveyors: $282/course
Depends on learning needs and number of courses required.
Post-secondary institutions typically allow for an appeal of course grades.
RAIC course marks can be appealed.
Bridging programs to support applicants in meeting academic requirements1
Total: 13 Professions
Engineers, Lawyers, Veterinarians
Dietitians, Medical Laboratory Technologists, Medical Radiation Technologists, Midwives, Nurses, Occupational Therapists, Optometrists, Pharmacists, Pharmacy Technicians, Physiotherapists
For all 13 professions, bridging programs are offered by a post-secondary educational institution.
Low end: Under $5,000, and all direct costs can be covered by the Ontario Bridging Participant Assistance Program
High end: $40,000
Low end: 3–4 months (college)
High end: 9–12 months (university)
Post-secondary institutions typically allow for an appeal of course grades.
Total: 5 Professions2
Chiropractors, Dental Surgeons, Massage Therapists
All 5 professions direct applicants to advanced standing or transfer credit options at post-secondary educational institutions.
Low end: Under $4,500
High end: $150,000
Low end: Under 1 year
High end: 2 years
Post-secondary institutions typically allow for an appeal of course grades.
It is important to note that many professions recognize more than one category of alternative. In such cases, alternatives are sometimes used in combination. For example, two or more assessments may be used together to generate a more complete picture of an applicant's knowledge and skills. Or an assessment may uncover gaps that the applicant can address through self-paced or structured learning.
Sometimes, applicants may have a choice of alternatives, particularly when it comes to filling gaps. For example, they might be able to choose between taking a course and writing an exam. Or they might have the option of self-study or a bridging program to prepare for required exams.
Paper-based assessments require an applicant to describe learning or work experience that demonstrates competencies required for the profession. This may be as simple as submitting academic credentials and a resumé or work-experience record that are assessed together in a holistic way. In other cases, it may involve putting together a portfolio submission that provides a more detailed description of how each competency has been met. In a portfolio submission, the applicant must typically provide expert witnesses and/or documentary evidence to support each of the competencies that the applicant claims to have. In this way, regulators receive a high level of assurance and applicants have the opportunity to submit evidence they believe to be useful.
Ten Ontario professions use a paper-based assessment of education and experience to determine whether applicants have met the academic requirement for licensing (see Table 2).
Seven of the 10 professions' regulatory bodies administer their own assessment process. The remaining three use nationally developed tools and processes.
Non-health professions use paper-based assessment more often than health professions. Health professions tend to rely more heavily on exams and clinical assessments.
Challenges related to this type of alternative include the following:
Portfolio submissions are particularly challenging to prepare. Regulators report that many applicants are reluctant to present a portfolio submission. These applicants tend to prefer more familiar options, such as taking a course or writing an exam, to demonstrate competencies that were not covered by their academic training. Other regulatory bodies report difficulty getting the level of detail they need to make a confident assessment.
Providing clear and comprehensive instructions to applicants can help them understand what documents to provide and how to provide them. Several professions warn applicants that the assessment process is long and complex.
The cost of paper-based assessments tends to be lower than the cost of other kinds of acceptable alternatives for meeting academic requirements. Many professions include this service in the application fee payable to the regulatory body.
One profession, which uses a national assessment process, charges a fee of $678 (the highest fee for this service among the professions studied).
At least one other has considered introducing a fee, to cover the costs of individualized support for preparing submissions.
Direct assessment requires an applicant to pass one or more tests, of a written or practical nature. Depending on the profession, the test may be called an "assessment" or — more frequently — an "examination." Non-health professions tend to use written exams. Some professions, particularly health and veterinary professions, require a combination of written and clinical exams. Clinical exams may involve working on a human patient or live animal, or they may involve interacting with a trained actor.
Direct assessments allow regulators to evaluate the current knowledge and/or skills of applicants, for two main purposes:
Sixteen Ontario professions use or accept some form of direct assessment as an acceptable alternative for meeting academic requirements (see Table 2).
Nine professions' regulatory bodies deliver the direct assessment or exam themselves, while six professions rely on exams offered by a national body. Nursing uses a provincial third party, the Centre for the Evaluation of Health Professionals Educated Abroad, to administer its new objective structured clinical exam.
Regulators are keenly conscious of their public-protection mandate. They continue to struggle with developing assessments that are appropriate to mid-career professionals and that provide adequate assurance of competency. For example:
Such approaches can offer insight into practice competencies, but they require:
Where exams are used, they should be thoughtfully designed to focus on knowledge and skills that are directly relevant and necessary to safe and competent professional practice.
Regulators can also use a variety of strategies to help applicants be successful:
Bridging programs can also help applicants prepare for exams that are required of all internationally educated applicants, or can provide a more structured alternative to self-study for exams that are individually assigned to address specific gaps in education.
The cost of exams can be high, and sometimes prohibitively so.
Written exams offered by the regulatory body itself tend to be the least expensive, starting at $75 for an exam in a specific subject area.
Clinical exams are the most expensive, with costs reaching as high as $7,200. This is particularly problematic when success rates are low, and many applicants have to repeat all or part of an exam.
Self-paced learning pathways allow applicants to address specific gaps in academic training without repeating training that they already have. Typically, these gaps are:
Rather than undertaking a full program of study, applicants typically enrol in individual courses to address gaps at their own pace. Some professions allow for individualized learning plans. This approach increases flexibility through openness to non-traditional and workplace learning.
Twenty professions recognize some form of self-paced learning to fill gaps in academic training (see Table 2).
Of the 20 professions that use self-paced learning:
The Association of Ontario Land Surveyors offers its own courses in high-priority topics such as survey law. These topics address Ontario-specific gaps that are common to most internationally educated applicants.
Architecture Canada, a national body, offers self-paced learning opportunities through the Royal Architectural Institute of Canada (RAIC) Syllabus Program.
Unless the regulator has specifically arranged access for applicants, they may have difficulty registering for individual courses.39
In some cases, the applicant may only really need specific sections of one or more courses. However, the only way to access that content is to take the entire course. This means that the applicant may still need to repeat training that he or she already has. It can also extend the time involved in meeting academic requirements for licensing, especially if the required courses are not offered every semester.
Regulators can and should consider negotiating access to courses on behalf of applicants. The College of Respiratory Therapists of Ontario successfully negotiated with providers of academic programs to reserve spaces for applicants who were referred to the college's "supported integration" pathway.40
Professions may also improve access by working provincially or nationally to develop targeted training to address gaps that are common to many non-traditional applicants. The professions can then offer this training in a way that allows for self-paced learning.
The cost of self-paced learning varies among providers. Targeted courses offered directly by a regulator or national professional organization can be cheaper for applicants than a semester-long course at a post-secondary educational institution. However, such courses can be expensive to develop and maintain, especially for small professions that do not have strong national organizations.
Bridging programs, like self-paced learning pathways, help internationally educated people to fill specific gaps in knowledge and skills. However, bridging programs offer a complete package of courses and other learning opportunities specially designed to meet the needs of internationally educated professionals. In this regard, they are distinct from both self-paced learning and advanced-standing opportunities in regular programs of professional education.
Participant feedback affirms the value of Ontario's bridging programs in helping applicants prepare for exams.41 While evaluation research is limited, some programs have documented improved success rates for bridging participants.42
Bridging programs provide a supportive community to participants during the often stressful journey to becoming licensed and employed in their profession. The most successful bridging programs also include a mentoring or internship component that helps participants develop a professional network.
This analysis focuses on bridging programs that help participants become licensed in their field of expertise in a new jurisdiction. It excludes bridging programs that are solely focused on employment.
For 13 professions, applicants can enrol in a bridging program that helps them meet academic and/or exam requirements for licensing (see Table 2).
Formal recognition of bridging programs varies:
Bridge training is funded by the provincial government and delivered by a variety of third-party providers. All of the bridging programs considered in this study are delivered by a post-secondary educational institution.
The province may identify priority professions based on analysis of service gaps in Ontario and the numbers of new immigrants with a particular professional background, but the provision of bridging programs has relied heavily on sectoral champions. These champions pioneer projects and develop partnerships. This has resulted in significant variation in the availability and the quality of bridging programs among professions.
The most successful bridging programs are those where there is a strong collaborative relationship between the provider and the regulator. The regulator must be confident in the quality of the training in order to affirm that a bridging program meets academic requirements for licensing. For maximum benefit, the regulator must also be open to feedback from bridging providers about licensing requirements or processes that create unnecessary barriers for internationally educated applicants.
Access to bridging programs can be a challenge, especially for immigrants who live in smaller centres where there are few such specialized services. Even in large cities such as Toronto, access can be difficult for applicants to highly competitive bridging programs where the number of available spots is lower than the demand.
Access is of particular concern in the case of those bridging programs that are a mandatory component of the licensing process for internationally educated professionals:
Costs can also limit access to bridging programs. University-based bridging programs in nursing, optometry, pharmacy and veterinary medicine all cost over $10,000. Most bridging participants cannot access the Ontario Student Assistance Program (OSAP).
The Ontario Bridging Participant Assistance Program provides aid for the direct costs of bridging programs delivered by publically funded post-secondary institutions, but this aid does not even begin to address living costs. Most programs recognized as meeting academic requirements for licensing are nine months to one year long. It can be difficult to forgo an income and make ends meet for that period of time, especially for applicants with family obligations.
Given the access challenges discussed above, the OFC has discouraged regulators from making these programs mandatory for internationally educated applicants. Some bridging programs are exploring flexible options such as:
Each of these approaches introduces new challenges. For example, with uncertain funding, many providers are concerned about programs' sustainability, especially for professions where numbers are small:
The OFC continues to urge the provincial government to maintain funding for bridge training and to improve financial aid for participants.
In some cases, the gap between an applicant's education and the regulator's requirement may be too great to close by way of self-paced learning or a bridging program. And in certain professions, self-paced learning or a bridging program may not be available or appropriate. For example, paralegals must graduate from an accredited Ontario program to qualify for licensing.
In these situations, applicants may have to enrol in a regular academic program that is accredited or approved by the Ontario regulator.
However, they may be able to apply for partial recognition of their past education. The educational institution may grant recognition for specific courses or transfer credits, or it may grant advanced standing and allow applicants to enter the program in mid-stream.
Advanced standing allows a person to fill gaps in academic training without having to repeat a full program. Because participants complete the final stages of training within an accredited program, there is a high level of assurance for regulators.
Advanced standing is an option for at least five Ontario professions: chiropractors, dental surgeons, massage therapists, paralegals and teachers.45 Regulatory bodies for these professions are aware of advanced-standing opportunities and can direct applicants to relevant information. Generally, access to advanced standing is determined by the educational program and may be formalized to a greater or lesser degree. For example:
Like bridging programs, advanced-standing pathways present challenges related to access and affordability:
Regulatory bodies can advocate for formal advanced-standing spots for internationally educated candidates. As in the case of dentistry, they can also introduce more alternatives to alleviate access concerns.
Appeal processes are generally available for each category of acceptable alternative (see Table 2).
In the case of assessments and exams, applicants usually have recourse to a formal appeal of the exam result, retaking the exam, or retaking a portion of the exam.
Increasing the flexibility of the licensing process does have an impact. Among regulated professions, there is a significant correlation between the accessibility of acceptable alternatives and reduced disadvantage for internationally educated professionals.This section explores that correlation, and the costs of inflexibility.
To date, the most significant statistical study of profession-specific differences in employment "match rates" for immigrants and Canadian-educated people is Zietsma's 2010 analysis of 2006 census data.46 The analysis looked at how well people's field of study matched their occupation in Canada, for 15 fields of study that usually lead to a regulated occupation.
In Canada, overall:
Match rates for immigrants were above the national average in Saskatchewan and Alberta, which had strong labour markets in 2006. Ontario figures mirrored national averages.
Variation among professions was considerable. For example:
There is a correlation between more flexible licensing approaches that offer acceptable alternatives for meeting academic requirements and reduced disparity in employment outcomes between internationally educated professionals and their Canadian-born counterparts.
The smallest gaps in match rates between Canadian-educated and internationally educated people were for engineers, nurses, occupational therapists, and chiropractors (see Table 3):
These gaps are much lower than the average: For the total study population of all 15 regulated professions combined, the comparable figure was 38 percentage points.
(in percentage points)
|Total||Employed in profession of training||Total||Employed in profession of training|
|Total study population||937,050||62%||284,080||24%||38|
The engineering and nursing professions, with large numbers of internationally educated applicants, were among the early innovators in alternative assessment and bridge training. A 2007 national inventory of bridging programs lists 15 bridging programs for internationally educated engineers and 11 for internationally educated nurses — more than for any other profession.48
Ontario has led and sustained innovation in both these professions. In Ontario today, both nursing and engineering offer four categories of acceptable alternatives:
Occupational therapy, while a smaller profession, has also been an innovator:
In Ontario today, the Occupational Therapy Examination and Practice Preparation Project (OTepp) is among the most condensed and inexpensive of all bridging programs for the regulated professions. OTepp offers both a complete program and a modular option for applicants who need only selected courses. The full program of five courses has a modest cost of $1,000 and lasts seven months.
Chiropractors, with the lowest gap in match rates, are a unique case, as the profession has a very small base outside North America, Europe and Australasia. In those regions, the Councils on Chiropractic Education International has worked to establish agreement on international educational standards and ensure their adoption by accredited chiropractic colleges.
As this analysis suggests, employment disparities are comparatively low for professions that recognize a variety of acceptable alternatives, and where these alternatives are relatively accessible in terms of cost and time. Disparity is also low where foreign-credential-recognition is high.
In contrast, disparities are greater for professions where acceptable alternatives have historically been more limited and more expensive. In Zietsma's study, the gap between employment match rates for internationally educated and Canadian-born professionals rises above 50 percentage points for veterinary medicine, optometry and law (see Table 4).
(in percentage points)
|Total||Employed in profession of training||Total||Employed in profession of training|
|Total study population||937,050||62%||284,080||24%||38|
In Canada, various causes have contributed to these higher gaps:
It is always difficult to prove causal relationships within complex social processes, where many factors influence outcomes. Immigrant employment outcomes are significantly influenced not only by access to licensing but also by employer preferences and the strength of the labour market.
Nevertheless, this analysis shows a significant positive correlation between recognition of acceptable alternatives for meeting academic requirements and stronger licensing/employment outcomes for internationally educated applicants. It may be that professions that have invested in acceptable alternatives have also developed stronger systems for recognizing international credentials.
In its 2011–12 assessments of regulated professions' licensing practices, the Office of the Fairness Commissioner made 16 recommendations related to acceptable alternatives, encouraging regulators to move towards more flexible pathways to licensing.
Internationally educated applicants face a number of challenges when trying to meet academic requirements for licensing in Ontario.
In some cases, these challenges may relate to the fact that applicants require more education to become licensed in Ontario than they did in their country of training. In others, the greater challenge lies in demonstrating the required "equivalency" or "substantial equivalency" in academic background.
Ontario's fair-access legislation has established the principle that all requirements for licensing must be relevant and necessary to the practice of the profession. And Canadian labour-mobility legislation has obliged professions to work towards a national consensus on requirements, contributing to healthy national debate about the relevance and necessity of requirements that have historically varied across provinces and territories.
Such debate and exploration are also needed at the international level. For example:
Globally, full harmonization of standards remains a distant goal. Considerable variation exists among jurisdictions both in the resourcing of educational systems and the technological contexts of professional practice.
As a result, Canada will continue to receive skilled immigrants who need bridging support in order to practise safely and effectively in a new professional environment.
At the same time, differences in knowledge and skills must be assessed — not assumed. Competency-based assessment has an important role to play in distinguishing between those applicants who already have the required knowledge and skill — however developed — and those with competency gaps. A focus on competency also supports the design of learning opportunities that allow applicants to bridge gaps in the most streamlined way possible.
Fair-access legislation has established the principle that competencies are more important than credentials, and that applicants should be made aware of any "acceptable alternatives" for meeting licensing requirements. The evidence suggests that acceptable alternatives can make the licensing process more flexible and contribute to improved employment outcomes for internationally educated professionals. However, care must be taken to ensure that such alternatives remain accessible, timely and effective in helping applicants to become licensed.
Post-secondary institutions are heavily involved in the delivery of self-paced learning, bridging programs, and advanced-standing programs.
To ensure the sustainability of these options and improve their accessibility:
These changes would foster more consistent coverage and quality across the full range of regulated professions. To date, the development of opportunities to close educational gaps has been led by people in a variety of organizational contexts who were passionate about integrating internationally educated individuals within a specific profession. A more systematic approach would help to ensure that high-quality opportunities are available in all professions.
Further, post-secondary institutions also need to make academic programs more flexible:
Yet bridging and other alternatives are not a cure-all. They must not be used to compensate for gaps in the ability of assessors to recognize the real competencies of applicants.
Continued investment is needed in initiatives that help regulators and national bodies ensure that foreign qualifications can be recognized in an efficient and timely way. Such initiatives could focus on credential assessment, competency assessment, or both.
Only these investments and initiatives can minimize the deterioration of professional competency caused by prolonged periods away from practice — a deterioration that all too often makes a temporary career interruption into a permanent one.
Both federal and provincial governments have an important role to play in providing resources for foreign-qualification-recognition and for bridging programs. Significant financial investments have already been made, but observers have questioned whether momentum can be maintained, given the project-based approach to funding.51
Federally, the Foreign Credential Recognition Program (FCRP) is the main source of funding for assessment tools and processes. The federal government's latest progress report on foreign-credential-recognition states that the FCRP funded initiatives worth $120 million up to the end of 2011.52 Funding tends to cover the cost of developing a new approach to assessment, but not the ongoing expenses for delivering that new approach.
Provincially, the Ministry of Citizenship and Immigration has tended to take the lead role in funding bridge training. From 2003 to 2011, the Ontario government invested $240 million in bridging projects. In 2012, Ontario bridging investment was projected at $57 million, co-funded by the provincial and federal governments.53
However, Ontario's Premier has stated concern about the sustainability of bridging programs, in light of proposed changes to federal funding for skills training. Federal funding to the province under the current labour-market agreement may fall significantly in April 2014, with the implementation of the Canada Job Grant, a new grant program to be funded equally by Ottawa, the provinces and the private sector.54
Project-based funding often results in a downloading of costs to applicants, for assessments, exams and bridging programs. The benefits of acceptable alternatives cannot be achieved if the alternatives are too expensive. Internationally educated applicants often face significant financial barriers, and have limited access to financial aid. Regulatory stakeholders and education providers can and should make affordability an important consideration in the design of acceptable alternatives, but government also needs to play a role in enhancing access to financial aid.
Canada cannot afford not to invest in finding solutions to the undervaluing of immigrant education. A 2011 Royal Bank of Canada report estimates a total loss of $30.7 billion in potential immigrant earnings, equivalent to 2.1% of GDP in 2006.55
Behind these numbers lies an uncounted human cost: men and women frustrated by shattered dreams, children growing up in poverty, communities searching for professional services informed by their own language and cultural experience.
Both government and regulatory stakeholders have a responsibility to act in the public interest, to find acceptable alternatives to this waste of human resources. They must continue to collaborate to improve and sustain assessment processes and learning opportunities that allow internationally educated individuals to make their full contributions — to their profession and to the public.
The Office of the Fairness Commissioner makes the following recommendations to regulatory bodies, educational institutions, and government. The recommendations will help all stakeholders to: