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Registration Practices Assessment Report
COLLEGE OF NURSES OF ONTARIO
2016–2017 Assessment Cycle (Cycle 3)



AVAILABILITY OF REPORT

This report is provided by the OFC to the regulatory body assessed. The OFC will, upon request, release the report to other parties. The OFC will also post the report on its website. In the interest of transparency and accountability, the OFC encourages regulatory bodies to provide the report to its staff, council members, the public, and other interested parties.



Introduction

Assessment is one of the Fairness Commissioner's mandated roles under the Fair Access to Regulated Professions and Compulsory Trades Act, 2006 (FARPACTA) and the Regulated Health Professions Act, 1991 (RHPA) – collectively known as fair access legislation.

Assessment Cycle

One of the primary ways the OFC holds regulators accountable for continuous improvement is through the assessment of registration practices using a three-year assessment cycle.

Assessment cycles alternate between full assessments and targeted assessments:

  • Full assessments address all specific and general duties described in the fair-access legislation.
  • Targeted assessments focus on the areas where the OFC made recommendations in the previous full assessment.

Focus of this Assessment and Report

The 2016-2017 assessment is a full assessment.

The OFC’s detailed report captures the results of the full assessment. However, practices related to provision of information are excluded for regulators who have previously completed an assessment. For those regulators, these practices have been removed from the transparency section of the report. This includes: all practices from Information for Applicants, practice 3 from Internal Review and Appeals, practice 1 from Information on Appeal Rights, practice 1 from Documentation of Qualifications, practice 1 from Assessment of Qualifications, practice 2 from Access to Records, and practices 4-11 from Transparency of the Registration Practices Assessment Guide. The assessment summary provides the following key information from the detailed report:

  • duties that were assessed
  • an overview of assessment outcomes for specific duty practices
  • an overview of comments related to the general duty
  • commendable practices
  • recommendations

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Assessment Summary


Specific Duties

Specific duties assessed

The regulator has been assessed in all of the areas below. A check mark indicates that the regulator meets the practices within that area of the specific duty. An unchecked box means that the practices within that area are partially demonstrated or not demonstrated. Recommendations are made for partially demonstrated and non-demonstrated areas. These appear later in this report.

Comments

The regulatory body has demonstrated all of the practices in the following specific-duty areas:

  • Information for Applicants
  • Timely Decisions, Responses and Reasons
  • Internal Review or Appeal
  • Information on Appeals
  • Documentation of Qualifications
  • Training
  • Access to Records

General Duty

Assessment method

The regulator selected the following method for the assessment of the general duty:

a. OFC practice-based assessment (following the practices in the Assessment Guide) Checked
b. Regulator practice-based self-assessment (following the practices in the Assessment Guide) Unchecked
c. Regulator systems-based self-assessment (in which it explains systemically and holistically how it meets the general duty) Unchecked

Principles assessed

The regulator has been assessed on all of the general duty principles: transparency, objectivity, impartiality and fairness.

Comments

The OFC found that since the last assessment, the College of Nurses of Ontario (CNO) has taken measures to ensure a transparent, objective, impartial and fair registration process.

Commendable Practices

A commendable practice is a program, activity or strategy that goes beyond the minimum standards set by the OFC assessment guides, considering the regulatory body's resources and profession-specific context. Commendable practices may or may not have potential for transferability to another regulatory body.

The regulatory body is demonstrating commendable practices in the following areas:

General Duty

Transparency

  1. In 2014, the College reviewed all of the application and registration information on the website and rewrote all correspondence for international applicants in clearer language. The College focus-tested the new content with applicants, using their feedback to make further improvements. The College continues to track applicants’ experience.
  2. The College conducts a monthly point of contact survey with applicants, including IENs, regarding their experiences with the registration process. Feedback was also obtained from the College’s 2016 advisory group Nurses Newly Registered. This advisory group is comprised of nurses within their first two years of registration.

Impartiality

  1. College Council participated in a workshop on the Ontario Human Rights Code and their obligations to apply the Code to regulatory decision-making.

Fairness

  1. As of May 2016, the Canadian Practical Nurse Registration Examination (CPNRE) now computer based and more broadly available allowing for more access.

Recommendations

Assessment of Qualifications

That the College work with the National Nursing Assessment Service (NNAS) to clarify for applicants the purpose of collecting practice and employment information.

Assessment History

In the previous assessment, the OFC identified 34 recommendations for the regulator. They have all been implemented.

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Detailed Report[1]


Specific Duty

1. Specific Duty — Information for Applicants

Exempt as Previously Assessed

2. Specific Duty — Timely Decisions, Responses and Reasons

RHPA, Schedule 2, s.20 (1)

*Only applies to regulatory bodies governed by FARPACTA

1. If a regulator rejects an application, it gives written reasons to the applicant. [Fairness, Transparency]

Assessment Outcome

Demonstrated

2. The regulator makes registration decisions, and gives written decisions and reasons to applicants, without undue delay*. [Fairness]

Assessment Outcome

Not Applicable

3. The regulator responds to applicants’ inquiries or requests without undue delay*. [Fairness]

Assessment Outcome

Not Applicable

4. The regulator provides internal reviews of decisions, or appeals from decisions, without undue delay*. [Fairness]

Assessment Outcome

Not Applicable

5. The regulator makes decisions about internal reviews and appeals, and gives written decisions and reasons to applicants, without undue delay*. [Fairness]

Assessment Outcome

Not Applicable

3. Specific Duty — Internal Review or Appeal

RHPA, Schedule 2, s. 15, s. 17, s. 19, s. 22.3

*Only applies to regulatory bodies governed by FARPACTA

1. The regulator provides applicants with an internal review of, or appeal from, registration decisions. [Fairness]

Assessment Outcome

Demonstrated

2. The regulator implements rules and procedures that prevent anyone who acted as a decision-maker in a registration decision from acting as a decision-maker in an internal review or appeal of that same registration decision. [Impartiality]

Assessment Outcome

Demonstrated

3. The regulator provides information on its website that informs applicants about opportunities for an internal review or appeal. [Transparency]

Exempt as Previously Assessed

4. The regulator provides information on its website about any limits or conditions on an internal review or appeal*. [Transparency]

Exempt as Previously Assessed

4. Specific Duty — Information on Appeal Rights

Exempt as Previously Assessed

5. Specific Duty — Documentation of Qualifications

Exempt as Previously Assessed

6. Specific Duty — Assessment of Qualifications

RHPA, Schedule 2, s. 22.4(2)

*Only applies to regulatory bodies that develop and administer their own exams.

1. On its website, the regulator informs applicants about the process, criteria, and policies for the assessment of qualifications. [Transparency]

Exempt as Previously Assessed

2. The regulator communicates the results of qualifications assessment to each applicant in writing. [Transparency]

Assessment Outcome

Demonstrated

3. The regulator gives its assessors access to assessment criteria, policies and procedures. [Transparency]

Assessment Outcome

Demonstrated

4. The regulator shows that its tests and exams measure what they intend to measure*. [Objectivity]

Assessment Outcome

Not Applicable

5. The regulator states its assessment criteria in ways that enable assessors to interpret them consistently. [Objectivity]

Assessment Outcome

Demonstrated

6. The regulator ensures that the information about educational programs that is used to develop or update assessment criteria is kept current and accurate. [Objectivity]

Assessment Outcome

Demonstrated

7. The regulator links its assessment methods to the requirements/standards for entry to the profession or trade. [Objectivity]

Assessment Outcome

Demonstrated

8. The regulator requires that assessors consistently apply qualifications assessment criteria, policies and procedures to all applicants. [Objectivity]

Assessment Outcome

Demonstrated

9. The regulator uses only qualified assessors to conduct the assessments. [Objectivity]

Assessment Outcome

Demonstrated

10. The regulator monitors the consistency and accuracy of decisions, and takes corrective actions as necessary, to safeguard the objectivity of its assessment decisions. [Objectivity]

Assessment Outcome

Demonstrated

11. The regulator prohibits discrimination and informs assessors about the need to avoid bias in the assessment. [Impartiality]

Assessment Outcome

Demonstrated

12. The regulator implements procedures to safeguard the impartiality of its assessment methods and procedures. [Impartiality]

Assessment Outcome

Demonstrated

13. The regulator gives applicants an opportunity to appeal the results of a qualifications assessment or to have the results reviewed. [Fairness]

Assessment Outcome

Demonstrated

14. The regulator assesses qualifications, communicates results to applicants, and provides written reasons for unsuccessful applicants, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

15. Regulators that rely on third-party assessments establish policies and procedures to hold third-party assessors accountable for ensuring that assessments are transparent, objective, impartial and fair. [Transparency, Objectivity, Impartiality, Fairness]

Assessment Outcome

Partially Demonstrated

Recommendations

That the College work with the National Nursing Assessment Service to clarify for applicants the purpose of collecting practice and employment information.

7. Specific Duty — Training

RHPA, Schedule 2, s. 22.4(3)

1. The regulator provides training for staff and volunteers who assess qualifications or make registration, internal review or appeal decisions. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

2. The regulator addresses topics of objectivity and impartiality in the training it provides to assessors and decision-makers. [Objectivity, Impartiality]

Assessment Outcome

Demonstrated

3. The regulator identifies when new and incumbent staff and volunteers require training and provides the training accordingly. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

8. Specific Duty — Access to Records

RHPA, Schedule 2, s. 16

1. The regulator provides each applicant with access to his or her application records. [Fairness]

Assessment Outcome

Demonstrated

2. If there is a fee for making records available, the regulator gives applicants an estimate of this fee. [Transparency]

Exempt as Previously Assessed

3. If there is a fee for making records available, the regulator review the fee to ensure that it does not exceed the amount of reasonable cost recovery. [Fairness]

Assessment Outcome

Not Applicable

General Duty

RHPA, Schedule 2, S.22.2

Transparency

  • Maintaining openness
  • Providing access to, monitoring, and updating registration information
  • Communicating clearly with applicants about their status
Assessment Outcome

OFC Comments:

The OFC made a number of recommendations for the College in the second assessment cycle to improve the way that information is presented and managed on the College website. All of these changes have been implemented. This assessment found that the College meets all of the practices under the Transparency section, and demonstrates a commendable practice in integrating applicant input into registration information.

Openness

  • The CNO registration policies explain registration criteria and evidence required to meet the criteria, and decision-making authority.
  • Policies and decision-making criteria are readily available to staff and decision-makers. Staff members assist decision-makers in interpreting and applying policies.
  • Policies and criteria are reviewed and updated in response to changes in the regulatory environment. Input is sought from decision-makers and other stakeholders.
  • The CNO makes its registration policies available on its website and in its application guides (which are also available on the website). This includes information about requirements that may be satisfied through acceptable alternatives and requirements that may be exempted.

Access

  • The CNO advises applicants of the progress of their application through written status updates. It also has a Customer Service Centre that applicants can call.

Clarity

  • Information provided about registration requirements and the assessment process is clear. Information about the Internationally Educated Nurses Competency Assessment Program (IENCAP) is provided in a dedicated section of the website. The page describes the conditions under which applicants are referred to the program, the process of applying and undertaking the exam, and the methodology by which applicants are evaluated.
  • The College reviewed all of the application and registration information on the website and rewrote all correspondence templates for international applicants in clearer language. The College focus-tested the new content with applicants, using their feedback to make further improvements. The College continues to track applicants’ experience.

Commendable Practices

In 2014, the College reviewed all of the application and registration information on the website and rewrote all correspondence templates for international applicants in clearer language. The College focus-tested the new content with applicants, using their feedback to make further improvements. The College continues to track applicants’ experience.

Objectivity

  • Designing criteria and procedures that are reliable and valid
  • Monitoring and following up threats to validity and reliability
Assessment Outcome

OFC Comments:

The College practices were assessed against standards of objectivity in 2012, and found to meet the OFC standards. As a result, these practices were not assessed in the second cycle in 2014.

Since the second assessment cycle, a national assessment service (NNAS) has been implemented that conducts an initial screen of program comparability for all internationally educated applicants. In addition, the National Council Licensure Examination for Registered Nurses (NCLEX-RN) has been established as the RN registration exam, replacing the Canadian Registered Nurses Exam (CRNE) in Canada. Language testing and jurisprudence testing continues to be assessed through instruments administered and developed by third party agencies.

The College continues to conduct its own assessments in cases where alternative evidence of language proficiency is provided, and where additional education and / or experience is provided to demonstrate program equivalence.

In this third assessment cycle, the College continues to meet the OFC’s criteria for assessment design, provision of decision making instruments, application of evidence, and quality assurance.

The College does not design or administer examinations.

Reliability

  • expresses its registration criteria in measurable units. Where criteria are complex it establishes specific conditions for meeting the criteria (e.g., professional suitability)
  • has a process for reviewing criteria for clarity
  • provides decision-makers with the tools and information they need to do their job, such as training in assessment and standardized templates for assessment.

Validity

To achieve validity in the registration decisions, the College:

  • has a process for assessing the extent to which registration decisions are accurate
  • when corrective actions are necessary, the College grounds them in analysis and research.

Impartiality

  • Identifying bias, monitoring, and taking corrective action
  • Implementing strategies
Assessment Outcome

OFC Comments:

The College’s practices were assessed against standards of impartiality in the first assessment cycle in 2012, and found to meet the OFC standards. As a result, these practices were not assessed in the second cycle in 2014.

In this assessment, the College continues to meet the OFC’s criteria for impartial assessment and registration practices, through the following mechanisms and strategies.

Identification of Bias

The College bylaws identify bias as it relates to individual relationships that may influence a committee members decisions.

Strategies

The bylaws identify specific actions that a committee member should take if they identify a potential source of bias.

Commendable Practice

The College bylaws identify and define bias as it relates to impartial decision making and identifying recourse for committee members where the potential of biased decision making exists. The issue is made clear by distinguishing in it from the broader concept of conflict of interest.

Fairness

  • Ensuring substantive fairness
  • Ensuring procedural fairness
  • Ensuring relational fairness
Assessment Outcome

The College shows evidence of fairness in its registration practices, drawn from policies, annual reports, and FRP reports.

Substantive Fairness

In 2014, the OFC made recommendations that the College demonstrate a rationale for the development of the IENCAP Objective Structured Clinical Exam (OSCE ) and identify a plan to evaluate the exam. The College has acted on both of these recommendations. The website now includes a detailed section on exam methodology and administration. The College has completed an evaluation of the OSCE and implemented changes to the exam as a result.

Procedural Fairness

In 2014, the College commented on the lengthy registration process for some applicants. The College has indicated its intention to reduce the median time for domestic graduates’ registration times, while committing to help applicants to understand and manage the process, thereby reducing the overall time to licensure. The number of internationally educated applicants has declined from a peak of over 5,000 in 2012 to just over 1,000 in 2015. The CNO attributes the cause of this decline to the launch of the NNAS in 2014. While other factors may be at play, the NNAS process appears to have impacted the ability of international applicants to access the registration process.

Since May 2016, the Canadian Practical Nurse Registration Examination (CPNRE) is now computer based and more broadly available allowing for more access.

Relational Fairness

The College has a process for taking applicants’ circumstances into consideration

  • has a process for providing accommodations to applicants
  • considers and provides accommodations where an applicant indicates that he or she cannot get the required documents.
  • Council participated in a workshop on the Ontario Human Rights Code and the College’s obligation to apply the Code to regulatory decision-making. Seven of eleven Registration Committee members sit on Council.

Commendable Practice

Since May 2016, the Canadian Practical Nurse Registration Examination (CPNRE) is now computer based and more broadly available allowing for more access.

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Background


Assessment Methods

Assessments are based on the Registration Practices Assessment Guide: For Regulated Professions and Health Regulatory Colleges. The guide presents registration practices relating to the specific duties and general duty in the RHPA.

A regulatory body's practices can be measured against the FARPACTA’s specific duties in a straightforward way. However, the general duty is broad, and the principles it mentions (transparency, objectivity, impartiality and fairness) are not defined in the legislation.

As a result, the specific-duty and general-duty obligations are assessed differently (see the Strategy for Continuous Improvement of Registration Practices).

Specific Duties

The OFC can clearly determine whether a regulatory body demonstrates the specific-duty practices in the assessment guide. Therefore, for each specific-duty practice, the OFC provides one of the following assessment outcomes:

  • Demonstrated – all required elements of the practice are present or addressed
  • Partially Demonstrated – some but not all required elements are present or addressed
  • Not Demonstrated – none of the required elements are present or addressed
  • Not Applicable – this practice does not apply to the CNO’s registration practices

General Duty

Because there are many ways that a regulatory body can demonstrate that its practices, overall, are meeting the principles of the general duty, the OFC makes assessment comments for the general duty, rather than identifying assessment outcomes. For the same reason, assessment comments are made by principle, rather than by practice.

For information about the OFC's interpretations of the general-duty principles and the practices that the OFC uses as a guideline for assessment, see the OFC's website.

Commendable Practices and Recommendations

Where applicable, the OFC identifies commendable practices or recommendations for improvement related to the specific duties and general duty.

Sources

Assessment outcomes, comments, and commendable practices and recommendations are based on information provided by the regulatory body. The OFC relies on the accuracy of this information to produce the assessment report. The OFC compiles registration information from sources such as the following:

  • Fair Registration Practices Reports, audits, Entry-to-Practice Review Reports, annual meetings
  • the regulatory body's:
    • website
    • policies, procedures, guidelines and related documentation templates for communication with applicants
    • regulations and bylaws
    • internal auditing and reporting mechanisms
    • third-party agreements and related monitoring or reporting documentation
    • qualifications assessments and related documentation
  • targeted questions/requests for evidence that the regulatory body demonstrates a practice or principle

For more information about the assessment cycle, assessment process, and legislative obligations, see the Strategy for Continuous Improvement of Registration Practices.

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References

  1. ^ Please note: Suggestions for continuous improvement appear only in the detailed report. Suggestions for improvement are not intended to be recommendations for action to demonstrate a practice, but are made solely to provide suggestions for areas that a regulatory body may consider improving in the future.

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