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Academic Requirements and Acceptable Alternatives:
Challenges and Opportunities for the Regulated Professions in Ontario

7. Ontario professions: Acceptable alternatives

This section discusses the fair-access implications of recognizing acceptable alternatives for meeting academic requirements. It examines five common types of acceptable alternatives and their availability in the 38 Ontario professions that are included in this study.

A flexible approach to academic requirements

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:

  • alternative ways that an applicant can acquire professional competencies, above and beyond a traditional program of academic study. These alternatives include:
    • additional training or experience that an applicant acquires before applying for licensing
    • extra courses or bridging programs taken to fill gaps in an applicant's knowledge/skill that are identified through the regulator's process for assessing credentials
  • alternative ways that professional competencies are demonstrated or assessed (usually through competency assessments, such as paper-based portfolio processes and written and practical exams)

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.

Contributions and challenges of acceptable alternatives

Acceptable alternatives contribute to fair access by introducing flexibility into the licensing process:

  • Where academic documents are unavailable or are insufficient to demonstrate an applicant's competency, acceptable alternatives allow for alternative forms of assessment.
  • Where gaps exist, acceptable alternatives enable applicants to meet competencies without repeating a full program of academic training.

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.

Five types of acceptable alternatives

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:

  • delivery methods (whether the alternative is delivered by the profession's regulatory body or by another organization)
  • cost for the applicant
  • time requirements
  • processes for appealing the result

Table 2. Acceptable alternatives in Ontario's regulated professions: Availability, delivery mechanisms, and fairness considerations

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

Non-health: 9

Chartered Accountants, Engineering Technicians and Technologists, Engineers, Foresters, Geoscientists, Land Surveyors, Management Accountants, Social Service Workers, Social Workers

Health: 1

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

Variable

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

Non-health: 6

Engineering Technicians and Technologists, Engineers, Foresters, Geoscientists, Lawyers, Veterinarians

Health: 10

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

Variable

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.

Options include:

  • Appeal the result.
  • Retake the exam.
  • Retake a portion of the exam.

Self-paced learning to fill academic gaps

Total: 20 professions

Non-health: 14

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

Health: 6

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.

Variable

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

RAIC: $525/course

Variable

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

Non-health: 3

Engineers, Lawyers, Veterinarians

Health: 10

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.

Advanced standing

Total: 5 Professions2

Non-health: 2

Paralegals, Teachers

Health: 3

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.

Notes:
  • 1 The following professions formally recognize a bridging program as meeting academic requirements for licensing: Dietitians, Engineers, Midwives, Nurses, Optometrists, Pharmacists, Pharmacy Technicians. For the other six professions, bridging programs help applicants build understanding of the Ontario professional environment and prepare to write required exams.
  • 2 It is possible that individuals from other professional backgrounds have also pursued such opportunities directly with educational institutions.

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 assessment of education and experience

Description

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.

Professions

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

Challenges related to this type of alternative include the following:

  • It requires documentation that may be difficult and time-consuming for some applicants to prepare or obtain from overseas.
  • Some applicants' level of language fluency may affect their ability to adequately describe and substantiate competencies.
  • Work samples may be difficult to get or may be subject to confidentiality agreements.
  • Professors and/or work supervisors who could attest to an applicant's knowledge and skills may have moved or died.

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.

Cost

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 of knowledge and/or skills

Description

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:

  • to confirm the results of a credential assessment. Applicants write an exam to confirm whether their education is adequate or they need more training. This type of exam is often called an evaluating exam. It is a prerequisite for writing the licensing exam.
  • to fill gaps identified by a credential assessment. Applicants are assigned exams in specific subject areas in order to fill gaps in education. Typically, regulators suggest study materials to help the applicant prepare for the exam. This approach is used by non-health professions such as engineering and law, where applicants frequently have a choice between taking a course and writing an exam. It is not used by health professions.

Professions

Sixteen Ontario professions use or accept some form of direct assessment as an acceptable alternative for meeting academic requirements (see Table 2).

Delivery

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.

Challenges

  • Exams add significant stress to the licensing process, and may require applicants to spend a significant amount of time studying and preparing.
  • Applicants may not be familiar with the testing format.
  • Many of the exams ask applicants to demonstrate knowledge of subject matter that they covered in their academic studies, but that they have used rarely or not at all during many years of professional practice. Such exams tend to test an applicant's comparability to a recent graduate rather than to an experienced member of the profession.

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:

  • Some professions have considered alternatives such as practice assessments to address the challenges inherent in exams.
  • Others use interviews to assess whether applicants' work experience fills gaps in academic training.

Such approaches can offer insight into practice competencies, but they require:

  • careful development of assessment criteria and common rating tools
  • rigorous training of assessors to minimize the risk of subjectivity

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:

  • Comprehensive exam-preparation materials can help applicants to understand expectations and prepare successfully.
  • Exam-preparation seminars can offer more structured support for helping applicants prepare for exams.

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.

Cost

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

Description

Self-paced learning pathways allow applicants to address specific gaps in academic training without repeating training that they already have. Typically, these gaps are:

  • identified through the assessment of an applicant's academic credentials
  • defined in terms of the courses or competencies that the applicant is missing

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.

Professions

Twenty professions recognize some form of self-paced learning to fill gaps in academic training (see Table 2).

Delivery

Of the 20 professions that use self-paced learning:

  • 13 direct applicants who have gaps to take courses through academic programs.
  • 7 negotiate an individualized plan with the applicant, which may include course work and other forms of 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.

Challenges

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.

Cost

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

Description

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.

Professions

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:

  • In 7 professions, applicants can meet academic requirements for licensing by successfully completing a bridging program that is recognized by the regulatory body.43 (For Dietitians, the bridging program allows most participants to meet the academic requirements, but some applicants may have to take extra courses outside of the bridging curriculum.)
  • For the 6 other professions, the bridging program helps applicants understand the Ontario work environment and prepare for required exams.44 The exams may themselves constitute an acceptable alternative for meeting academic requirements, or they may be licensing exams required of all applicants.

Delivery and funding

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.

Challenges: Limited space and competitive application processes

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:

  • Program caps can force eligible applicants onto waiting lists, imposing a delay of a year or more in the licensing process.
  • Programs that have adopted a competitive application process may exclude applicants who meet minimum eligibility requirements but do not rank well against their peers.

Challenges: Program and living costs

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.

Overcoming challenges

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:

  • providing online and distance learning options
  • integrating bridging participants into certain courses within regular professional programs, to help make the programs sustainable and ease student access to OSAP
  • developing modular approaches where participants take specific courses to fill specific knowledge gaps rather than a one-size-fits-all program

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 massage therapy bridging program has not run since 2011. This leaves applicants educated outside Ontario with no option but to apply for advanced standing in an approved program in Ontario. [Correction: This paragraph contains corrected information about the massage therapy program.]
  • The College of Respiratory Therapists of Ontario recently suspended its alternative pathways to licensing. The "bridging pathway" did not have enough eligible applicants, and the "supported integration" pathway did not have enough spaces to meet demand. The college is currently reviewing the pathways model in an effort to ensure successful and sustainable alternatives.

The OFC continues to urge the provincial government to maintain funding for bridge training and to improve financial aid for participants.

Advanced standing

Description

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.

Professions

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:

  • For dentistry, the process is highly formalized and universities reserve advanced placement spots for internationally educated dentists.
  • For the paralegal profession, individual applicants with prior legal training must take the initiative to apply for transfer credits.

Challenges

Like bridging programs, advanced-standing pathways present challenges related to access and affordability:

  • There are often limited spaces available to internationally educated applicants.
  • The process can be long and costly. Dental surgeons choosing this route must study for two years, at a cost of up to $150,000. To provide a quicker and less costly alternative, the profession has introduced an alternative option involving three assessments administered by the National Dental Examining Board.

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

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.


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Notes and references

  • 37. Fair Access to Regulated Professions and Compulsory Trades Act, 2006 (FARPACTA) s. 7.
  • 38. Chiropodists and Denturists.
  • 39. For example, internationally educated nurses have expressed challenges in finding courses that correspond to gaps identified through the Objective Structured Clinical Examination.
  • 40. This pathway has since been suspended because of capacity limitations. The college continues to explore strategies to ensure successful and sustainable alternatives.
  • 41. The OFC has heard direct feedback from bridging participants during site visits.
  • 42. Based on program reports submitted to the Ministry of Citizenship and Immigration.
  • 43. Dietitians, Engineers, Midwives, Nurses, Optometrists, Pharmacists, Pharmacy Technicians.
  • 44. Lawyers, Medical Laboratory Technologists, Medical Radiation Technologists, Occupational Therapists, Physiotherapists, Veterinarians.
  • 45. It is possible that individuals from other professional backgrounds have also pursued such opportunities directly with educational institutions. However, some academic programs will not accept applicants who already have a degree in the same discipline.

Academic Requirements and Acceptable Alternatives:
Challenges and Opportunities for the Regulated Professions in Ontario

Exemplary Practices

The OFC gathers regulatory bodies' exemplary licensing practices so that they may learn from one another. Exemplary practices about academic requirements and acceptable alternatives are listed below.

  1. Accepting and supporting diverse applicants

    This practice acknowledges a diversity of midwifery...

  2. Clarifying documentation requirements and acceptable alternatives

    This practice will be of interest to regulators seeking...

  3. Communicating acceptable alternatives for applicants with non-accredited education

    This practice offers a visual map of pathways to registration...

  4. Communicating acceptable alternatives for meeting certification requirements

    This practice allows applicants to better understand...