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Registration Practices Assessment Report — Summary


In February 2012, Ontario’s Office of the Fairness Commissioner assessed the way the College of Medical Radiation Technologists of Ontario   registers people who apply for a licence to practise in Ontario, to ensure that the registration practices are fair and continue to improve.  

This summary of the assessment includes commendable practices that are under way and recommendations for improvement.

The College of Medical Radiation Technologists of Ontario is subject to Ontario's fair access law, which amended the law about health professions, the Regulated Health Professions Act, 1991 (RHPA). The law spells out the college’s obligation to have transparent, objective, impartial and fair registration methods and requirements.

The Office of the Fairness Commissioner

To encourage accountability under the fair access law, the Office of the Fairness Commissioner (OFC) works with professions’ regulatory bodies to improve the way they register people who apply for professional licences. As a result of the OFC’s work, qualified people, no matter where they were originally trained, will have faster, fairer access to their licence to practise here.

In its work with regulators so far, the OFC has found that they have succeeded in streamlining their registration processes, but they need to do more. For example, regulators need to be more transparent and hold their assessment agencies more accountable for fairness.

To encourage, and hold regulators accountable for, continuous improvement, the OFC assesses their licensing practices in a two-year cycle. This cycle includes recommending improvements where needed and monitoring the bodies’ action plans that address the OFC’s concerns. This approach benefits applicants, the professions and the province.

You can read more about the OFC’s strategy for continuous improvement and its guide for assessments elsewhere on this site.

For more information about this particular assessment, contact the OFC.

Note: The words license, register and certify all refer to authorizing a person to practise a profession.


Commendable Practices

The College of Medical Radiation Technologists of Ontario (CMRTO) is demonstrating many commendable practices, in the following areas. (These areas correspond to the sections of the assessment guide, and are derived from the fair access legislation.)

Information for Applicants

  • On its website, the CMRTO has a well-organized process for informing all three streams of applicants (applicants who completed a specialty medical radiation technology program in Ontario, applicants who completed such a program in another province, and applicants who completed such a program in another country) about the steps in the registration process, including any qualifications assessment processes that are required.
  • The CMRTO has dedicated a significant section of its website for all three streams of applicants, providing clear, complete and easy-to-find registration information, including a registration process map for internationally trained applicants.
  • The CMRTO provides a clear rationale for making certain registration requirements exemptible.
  • On the CMRTO's website, a career map for internationally trained medical radiation technologists clearly describes the steps that an applicant can do or start from outside Canada, including qualifications assessment.
  • The website provides information for applicants about the following:
    • costs for language proficiency tests
    • appeals
  • The CMRTO supports HealthForceOntario twice a year when that organization holds information sessions for applicants about the CMRTO's application process.

Documentation of Qualifications

  • The CMRTO has processes in place for the following:
    • determining that required documentation is in fact unobtainable for reasons beyond an applicant's control
    • considering and examining alternatives regarding documentation of qualifications
    • helping applicants get alternative documentation if the required documentation is unobtainable

Assessment of Qualifications

  • The CMRTO developed templates (or “working documents”) to help evaluate registration criteria and ensure transparency in its registration process.
  • In 2009, the CMRTO completed a research project that expanded the range of tests that applicants can use to demonstrate fluency in English. As a result, the accepted tests now include the International English Language Testing Standards (IELTS) test and the Michener English Language Assessment (MELA). The project established the minimum scores that the CMRTO accepts for these tests, and validated the acceptable scores on the Test of English as a Foreign Language (TOEFL). The research results showed that the level of proficiency CMRTO requires reflects the minimum level required to practise the profession.


  • The CMRTO provides training on a regular and ongoing basis for individuals who assess qualifications, make registration decisions, or make internal review and appeal decisions. The CMRTO also provides training in any special considerations for both registration staff and committee members.


  • The CMRTO has two stages of communications with applicants. In the first stage, the CMRTO has an initial contact with the applicant and helps ensure that he or she has submitted all required documents. In the second stage, the CMRTO ensures that the applicant knows how his or her application is progressing.


  • CMRTO decision-makers use working documents to establish all CMRTO registration criteria, based on the components of an educational program completed in Ontario and on the legislated requirements for registration.


  • CMRTO decision-makers review educational programs completed outside of Ontario to determine that they are substantially similar to an Ontario medical radiation technology program in the applicant's specialty.


  • CMRTO decision-makers apply consistency and fairness in ensuring that an applicant's educational program is substantially similar to an Ontario educational program, through ongoing training for registration staff and registration committee members.
  • The criteria that the CMRTO uses in making an assessment about international programs are based on internationally acceptable criteria. The assessment is a necessary and appropriate test of minimal requirements based on a substantial similarity to Ontario programs. Registration requirements do not unjustifiably limit any group, particularly internationally trained applicants.



The OFC recommends improvements in the following areas. (These areas correspond to the sections of the assessment guide, and are derived from the fair access legislation. Recommendations marked "Required" correspond to the practices regulators must demonstrate in order to meet the specific duties in the legislation. Recommendations marked "Good" correspond to the practices the OFC encourages a regulatory body to adopt in order to meet the general duty to provide registration practices that are transparent, objective, impartial and fair.)

Information for Applicants

  • Add the following to the CMRTO website:
February 2012
  • information about timelines related to qualifications assessment for both Ontario graduates and other Canadian graduates [Required]*
February 2012
  • information about documents kept by CMRTO for Ontario and other Canadian applicants [Good]*
February 2012
  • information about how long the registration process takes for Ontario and other Canadian graduates [Required]*
February 2012
  • information about the estimated amount of time for each stage of the application process for internationally trained applicants [Good]*
February 2012

* The CMRTO implemented all recommendations marked with an asterisk before the OFC completed its assessment. The OFC commends the CMRTO for such prompt action.

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