Promising Audit Practices
Audits have several purposes. They:
- are an important step in ensuring that regulatory bodies comply with the fair access laws
- provide a high level of assurance that a regulatory body’s registration practices are transparent, objective, impartial and fair
- help identify unnecessary barriers
- help identify promising practices to share
- improve access to the professions through their findings and the implementation of their recommendations
The following promising practices, gleaned from the first round of audits, apply to two aspects of an audit:
- the procedures auditors use to determine if a regulatory body’s practices are transparent, objective and fair
- the recommendations auditors make to regulatory bodies about how to improve their registration policies, practices and procedures
Information for Applicants
Evaluation question C1a:
Does it [the regulated profession or health regulatory college] provide information about its registration practices to persons applying or intending to apply for registration?
Promising practices:
- The auditor completed a “mock” application online to check the clarity and transparency of the information the college provides to applicants. [Ontario College of Teachers audit]
- The auditor also compared the English and French versions of the college’s application information and forms to ensure that they provide consistent information to all applicants. [Ontario College of Teachers audit]
Timely Decisions, Responses and Reasons
Evaluation question C2a:
Does it make registration decisions within a reasonable time?
Promising practices:
- The auditor reviewed a sample of the college’s records for Ontario, out-of-province and international applications to assess the timeliness of the college’s registration decisions.
- The auditor noted that the college processes applications in a timely fashion, but that it does not acknowledge receipt of applications. The auditor recommended that the college issue a letter of acknowledgement for each application received, and include a registration number that the applicant can use to access his or her records. If this procedure is considered impractical, the college could include, in the registration information it publishes, a statement that in certain instances applicants may not receive an acknowledgement letter. Such a statement would enhance transparency. [Ontario College of Teachers audit]
Internal Review or Appeal
Evaluation question C3c:
Possible additional question: Does it provide timely appeal decisions?
Promising practices:
- The auditor checked the timeliness of the college’s denial and appeal evaluation process against the 120-day time frame communicated in the college’s published registration information, using a sample of 10 appeals. The auditor found three instances where the appeals process took longer than the posted time line, but noted that the delays appeared reasonable, given the college’s constant communication with each applicant and the extensions granted by the college’s registration committee to allow for receipt or translation of documents from international sources. [Ontario College of Teachers audit]
Information on Appeal Rights
Evaluation question C4a:
Does it inform applicants of any rights they may have to request a further review of, or appeal from, a registration decision?
Promising practices:
- The auditor reviewed the records for all applications referred to the college’s registration committee during the period under audit, checking for copies of notices and other documentation about applicants’ rights related to reviews and appeals. The purpose of this review was to see if the college had disclosed the statutory grounds for referrals to the committee and the right of applicants involved to make written submissions to the committee. [Royal College of Dental Surgeons of Ontario audit]
Documentation of Qualifications
Evaluation question C5a:
Does it make available to the public its requirements for the documentation of qualifications that must accompany an application?
Promising practices:
- The auditor noted that the college’s requirements for applicants who were educated in New York State were different from those for applicants educated elsewhere. The auditor recommended that the different requirements be communicated to applicants as part of the college’s registration guide. [Ontario College of Teachers audit]
Assessment of Qualifications
Evaluation question C6a:
Does it make its own assessment of qualifications in a way that is transparent, objective, impartial and fair?
Promising practices:
- The auditor determined that the college had no formal process to ensure that the records staff, who authenticate documents, and the evaluation staff, who assess credentials, were objective. The auditor recommended that the college implement such a process, requiring records and evaluation staff to declare conflicts so that, for example, they are not involved in reviewing files of applicants they know. [Ontario College of Teachers audit]
Access to Records
Evaluation question C8a:
Does it give applicants access to records related to their application?
Promising practices:
- The auditor reviewed a sample of applications to the college to verify that all documentation related to their application is available electronically to applicants, and that all registration staff have access to the same information so that they can provide applicants with factual information about the status of their applications. [Ontario College of Teachers audit]