Conducting Entry-to-Practice Reviews:
Guide for Regulators of Ontario Professions

ISBN 978-1-4435-0659-5 (HTML)
ISBN 978-1-4435-0660-1 (PDF)

MESSAGE FROM THE FAIRNESS COMMISSIONER

This guide was developed to help Ontario regulatory bodies conduct reviews of their registration requirements and practices. Whether you embark upon a voluntary review or undertake a mandatory review at my request under the legislation, I hope you will find the guide to be a clear and helpful tool.

Ontario is a leader in fair access to regulated professions. This is due in part to our groundbreaking legislation. It is also a credit to Ontario regulatory bodies that have worked individually and collectively to come up with practical and innovative solutions.

Entry-to-Practice Reviews are a vital piece of the puzzle. While other processes mandated by the legislation shine a light on registration practices, Entry-to-Practice Reviews are an opportunity to also look at the substance of registration requirements. These reviews will help to ensure that those who practise a profession are qualified and that those who are qualified can be registered. I believe they will also contribute to a culture of thoughtful analysis and meaningful improvement.

I recognize that it would not be practical for a single review to look at all registration requirements in an in-depth way or to examine all registration practices. Even in a mandatory review, my preference will be to engage in dialogue with the regulatory body before I define the scope of the review. I also encourage dialogue during and after the review.

I would like to thank the many regulators who offered advice on this guide and those of you who shared the results of your voluntary reviews. I welcome your continued input.

Sincerely,

Hon. Jean Augustine, PC

Fairness Commissioner

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1.  INTRODUCTION

1.a  Introduction to the guide

Entry-to-Practice Reviews provide an opportunity for regulatory bodies to examine their registration requirements and practices systematically. The main goal is to ensure that the requirements are necessary and relevant and that the practices are transparent, objective, impartial and fair. The purpose of this guide is to help Ontario regulators in conducting Entry-to-Practice Reviews.

The guide includes:

• Discussion of key concepts and terminology (see Section 2.c)
• Step-by-step instructions for conducting an Entry-to-Practice Review (see Section 4)
• Questions to ask in analyzing registration requirements and practices (see Section 5)
• Promising practices based on the experiences of Ontario regulatory bodies (throughout the guide)
• A checklist of topics to include in the final report (see Appendix A)
• Ideas for implementing changes to registration requirements and practices after a review (see Section 6).

This guide builds on and replaces A Starter Kit for Conducting Reviews of Registration Practices, which the Office of the Fairness Commissioner (OFC) issued in December 2008. In developing the guide, the OFC benefited from ideas in the starter kit and from the consultation with regulators that preceded it. The guide was also informed and enriched by approaches regulators have taken in their voluntary reviews, additional feedback from regulators in May 2009, and pertinent reports and literature (see Appendix B).

The guide will be revised and updated from time to time with helpful hints and promising practices as regulators perform reviews and share what they have learned. The Fairness Commissioner welcomes all feedback (see Contact Us).

1.b  Why conduct Entry-to-Practice Reviews?

Entry-to-Practice Reviews are fundamental because, in addition to looking at registration processes, they require regulators to look at the actual substance of their entry-to-practice requirements. These reviews are the only real opportunity to probe:

• Why do we require this particular set of requirements for entry to the profession?
• Are the requirements necessary and relevant for the work to be performed?
• Are the requirements good indicators of the individual's capacity to practise the profession at the entry level?
• Do the requirements have an unintended or different impact on international applicants or other population groups?
• Are there viable alternatives to the requirements or the methods of assessing whether they have been met?

Fair Registration Practices Reports and Audit Reports do not directly address these issues. Therefore, Entry-to-Practice Reviews are vitally important for improving access to professions for qualified applicants while continuing to protect public safety. This is a matter of fairness for all qualified applicants, including people who got their training or experience outside of Ontario.

Reviews can validate and engender confidence in entry-to-practice requirements and practices. Reviews provide a chance to demonstrate that requirements are necessary and relevant and that practices are transparent, objective, impartial, and fair, and to modify or replace those that are not.

Reviews may help regulators to assess compliance with human rights legislation by identifying requirements or practices that may unintentionally discriminate on the basis of an applicant's place of origin, race, gender, or disability.

Reviews can inform and enrich ongoing planning and priority setting. The changes recommended by a review can be an important consideration as a regulator sets priorities, develops a strategic plan, and allocates resources.

Reviews can help regulators to learn from each other. Regulators can benefit from the approach others take in conducting reviews and the findings and solutions they come up with.

1.c  Relationship to other reports

Ontario's legislation on fair access to regulated professions (see Section 2.b) requires three types of reports:

• Fair Registration Practices Reports
• Audit Reports (generated in a compliance audit)
• Entry-to-Practice Review Reports.

It is essential to be clear on the differences among the three reports, and to ensure that they work together in an integrated way.

	REPORTS
	Fair Registration Practices Report	Audit Report	Entry-to-Practice Review Report
Purpose of report	Describe current practices	Assess compliance with the legislation	Assess registration practices and requirements Recommend changes
Who writes the report?	Regulator	External auditor (independent assessment)	Regulator (self-assessment)
Key issues	What are the registration practices? What do the data show about volume of applications, source countries, etc.?	Is the regulatory body doing what the fair access legislation and regulations require? If not, what changes must take place to comply?	Are registration practices transparent, objective, impartial and fair? Are requirements for registration necessary and relevant? Is decision-making timely and efficient? Are fees reasonable? What needs to be changed?
When	Annually (or as specified by OFC)	Every 3 years (or as specified by OFC)	When requested by OFC (or when regulator chooses to conduct a voluntary review)
Statutory reference	Fair Access to Regulated Professions Act, 2006 (FARPA): s.20 Regulated Health Professions Act, 1991 (RHPA) Schedule 2: s.22.7	FARPA: s.21 RHPA: Schedule 2, s.22.8	FARPA: s.19 RHPA: Schedule 2, s.22.6

Each of these reports serves a different purpose, but the work done for one should usually help to make the preparation of the others more manageable. The Fairness Commissioner's analysis of a regulatory body's Audit Reports and Fair Registration Practices Reports can help to identify areas to focus on in a later Entry-to-Practice Review. Similarly, data gathered for an Entry-to-Practice Review will be helpful when doing a Fair Registration Practices Report. In this way, the unique goals of each exercise can be achieved with little duplication of effort. The OFC will work with each regulatory body to achieve this objective.

1.d  Mandatory vs. voluntary reviews

Many regulators have embraced the concept of continuous self-assessment and improvement and do reviews of various kinds as part of their regular work plans. Therefore, this guide distinguishes between “mandatory reviews” and “voluntary reviews.”

	Mandatory Review	Voluntary Review
What is it?	A review that the Fairness Commissioner requires a regulator to conduct under section 19 of FARPA or s.22.6 of RHPA Schedule 2.	A review that a regulator chooses to conduct without being required to do so by the Fairness Commissioner.
When is it done?	At a time specified by the Fairness Commissioner.	When a regulator decides to conduct it.
Scope	The Fairness Commissioner determines the scope of the review within the confines of FARPA s.19 and RHPA Schedule 2 s.22.6. The regulator may add to the scope. Note: Mandatory reviews are not expected to cover all registration requirements in depth or to examine all registration practices.	The regulator decides on the scope of the review.
Process	The regulator is expected to follow the steps in Section 4 of this guide, but has latitude in defining the process for its review.	The regulator is encouraged but not required to advise the OFC that the review is planned or underway and to follow the steps in Section 4 of this guide.
Final report	The regulator files a report on the results with the Fairness Commissioner by the due date. The report contains the information specified in the checklist in Appendix A.1 The regulator makes the report it has filed available to the public.2	The regulator is encouraged but not required to file the report with the Fairness Commissioner, use the Appendix A checklist, and make the report available to the public.

Even when conducting mandatory reviews, regulators have latitude. For example, regulators can select from, adapt and add to the sample review questions listed in this guide, provided they honour the scope of review defined by the Fairness Commissioner or go beyond it. Regulators also have latitude about the review process and type of consultation they will undertake.

One of the factors the Commissioner will consider in deciding when to require a mandatory review is whether the regulator has conducted a voluntary review, the scope of that review, and whether the recommended changes are being implemented. Conducting such a review could also reduce the scope of any review the Commissioner requires for that profession.

Here are three examples of Ontario regulatory bodies that conducted voluntary reviews of entry-to-practice requirements. Each had a different methodology and focus but all were valuable exercises.

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2.  FRAMEWORK FOR CONDUCTING REVIEWS

2.a  Vision and guiding principles for reviews

Each Entry-to-Practice Review should be anchored in the following principles:

• Fair access – Registration requirements and practices should help to ensure that qualified people are able to practise their profession in Ontario.
• Making a difference – Entry-to-Practice Reviews acknowledge the positive and lead to a concerted effort to implement change where needed. They embody the letter and the spirit of the legislation on fair access to regulated professions.
• Adding value – Entry-to-Practice Reviews will complement – and not duplicate – other work that Ontario regulatory bodies do, whether for the Fairness Commissioner, for the government, or on their own initiative.
• Participation – Entry-to-Practice Reviews will be participatory, inviting the input and reflecting the views of interested individuals and groups, including members, applicants, staff, and others who can contribute to the achievement of the review's goals.

2.b  Legal framework

Fair Access to Regulated Professions Act, 2006 (FARPA)

For non-health regulators, the requirement to conduct Entry-to-Practice Reviews appears in the Fair Access to Regulated Professions Act, 2006 (FARPA), section 19.

Review of registration practices

19. (1) Every regulated profession shall undertake a review of its registration practices at times specified by the Fairness Commissioner to ensure that the registration practices are transparent, objective, impartial and fair and shall file a report on the results with the Fairness Commissioner by the date specified by the Fairness Commissioner.

Same

(2) The review shall include an analysis of,

(a) the extent to which the requirements for registration are necessary for or relevant to the practice of the profession;
(b) the efficiency and timeliness of decision-making; and
(c) the reasonableness of the fees charged by the regulated profession in respect of registrations.

Regulated Health Professions Act, 1991 (RHPA) Schedule 2

For health professions, the requirement for Entry-to-Practice Reviews appears in the Regulated Health Professions Act, 1991 (RHPA), Schedule 2, section 22.6. The difference is that health colleges must file their reports within 30 days after completing the review instead of by a date specified by the Fairness Commissioner.

Review of practices

22.6 (1)  The College shall undertake reviews of its registration practices at such times as the Fairness Commissioner may specify to ensure that the registration practices are transparent, objective, impartial and fair.

Same

(2)  The review shall include an analysis of,

(a) the extent to which the requirements for registration are necessary for or relevant to the practice of the profession;
(b) the efficiency and timeliness of decision-making; and
(c) the reasonableness of the fees charged by the College in respect of applications.

Reports

(3)  The College shall file a copy of the results of the review with the Fairness Commissioner within 30 days after the completion of the review.

Human rights legislation

“Regulatory bodies are responsible for ensuring that they comply with relevant legislation including human rights legislation. Policies may appear neutral, but a comprehensive review can reveal unintended discriminatory impact or areas for improvement.”

(Ontario Regulators for Access, Regulators' Guide for Priority Access to Professions by International Candidates, 2004)

Requirements or practices that appear neutral can have an unintended impact on groups protected under human rights legislation or the Charter of Rights and Freedoms. For example, a requirement for Canadian experience that applies to all applicants may have a disproportionate impact on applicants trained outside of Canada, many of whom also come from places other than Canada. Requirements and practices with an unintended impact on the basis of gender, disability and other grounds should also be carefully examined.

2.c  Key concepts

This section briefly discusses some key concepts related to Entry-to-Practice Reviews. Nothing discussed in this section should be viewed as formal, restrictive, static, or legal.

Entry-to-Practice Review

An Entry-to-Practice Review is a systematic analysis by a regulator of registration requirements and practices pertaining to its profession.

Registration requirements

Requirements for registration include the qualifications applicants must have, the proof they must provide to show they are met, the fees they must pay, and any other criteria they must meet to be registered. Qualifications typically include academic credentials, language proficiency, workplace or clinical experience, successful completion of registration exams, and good character.

Some requirements appear in the profession's governing statute and regulations. Other requirements are set by the regulator in its bylaws and in its formal and informal policies.

Registration practices

The specific duties listed in FARPA and the RHPA ³ are examples of registration practices. Registration practices include providing information, assessing qualifications, and making registration decisions. They also include training of assessors and decision-makers; providing timely decisions, responses and reasons; holding internal reviews and appeals; and granting applicants access to their records. This is not an exhaustive list since both FARPA and RHPA ⁴ contain a general duty for regulators to provide registration practices that are transparent, objective, impartial and fair. Therefore, for the purpose of this guide, a registration practice is broadly interpreted to mean any practice of a regulatory body that relates to its registration function.

Necessary and relevant

Entry-to-Practice Reviews must include an analysis of registration requirements to ensure that they are necessary and relevant to the practice of the profession.

Necessary means essential, needed, or vitally important. A registration requirement is necessary when, without it, a regulatory body could not be satisfied that an applicant can practise the profession competently and safely at an entry level. Special requirements for internationally trained applicants are necessary when they are clearly justifiable.

Relevant means logically connected to the issue at hand. A registration requirement is relevant when it helps to make a well-founded assessment or registration decision or to verify an important fact. For example, a required qualification is relevant when there is a logical connection between the qualification and a person's competence to practise the profession at an entry level.

Transparent, objective, impartial and fair

Entry-to-Practice Reviews also examine registration practices to ensure that they are transparent, objective, impartial and fair.

Transparent

In a literal sense, transparent means “see-through” or “clear.” Transparent registration practices include well-documented policies and criteria and good communication with applicants about their application.

Indicators of transparent policies and criteria: The policies and criteria are easy to find; they are described in a forthright, direct way; their meaning is readily apparent; they are well-defined and unambiguous; and nothing is hidden in “unwritten” policies.

Indicators of transparent communication: Applicants know how their applications are progressing; decisions and the reasons for them are communicated clearly; applicants can see that the stated policies have been followed in their case.

Opposites of transparent: unclear, vague, ambiguous, subtle, hidden, hard to find.

Objective

Criteria are objective when they can be measured on the basis of verifiable data without requiring a subjective assessment that applies personal views or judgments. Well-crafted marking templates or multiple-choice questions can help to make the grading of exams a more objective exercise. A decision about whether a “good character” requirement has been met would be highly subjective if left open-ended. It would be more objective if fully or partially measured against concrete criteria such as the lack of a criminal record, or the completion of standard reference templates by practising professionals who have supervised the applicant.

Decision-makers need to be objective in the sense that they must apply clear, understandable criteria. They lose their objectivity when their personal viewpoints have too great an influence on their decisions. This is closely linked to the requirement for impartiality discussed below.

Indicators of objective criteria and decision-making: Determining whether the criteria have been met is straightforward; different decision-makers reach consistent decisions.

Opposites of objective: subjective, introspective.

Impartial

Impartiality is tied to objectivity in that it requires making decisions about individual applicants based on objective criteria and without bias, prejudice, or favouritism. Impartial assessments are made free from preconceived notions about any party or class of parties. To be impartial, decision-makers must have no vested interest in the outcome and must come to each case without a preconceived view about the merits of the application. They must maintain an open mind as they review the evidence to determine if the applicant meets the criteria.

Indicators of impartiality: Decision-makers are well trained in applying criteria; they do not give undue preference to applicants from certain jurisdictions or undervalue those from others.

Opposites of impartial: biased, one-sided.

Fair

Fairness is broad and difficult to define. It includes the concepts of transparency, objectivity and impartiality.

Procedural fairness is an important consideration in analyzing registration practices. The main question of procedural fairness is: “How fair is the process by which qualifications are assessed and registration decisions are made?”

Indicators of procedural fairness: Decisions adhere to published criteria, standards and policies. Applicants receive due process in relation to their application. A variety of interested parties have confidence in the criteria, process, and results.

Substantive fairness is an important consideration in analyzing registration requirements. It is closely tied to “necessary and relevant” (discussed above) in the sense that the requirements must be clearly justified and logically connected to the matter at hand. One indicator of substantive fairness would be that special requirements for internationally trained applicants are clearly justified. For example, it may be unfair to require all internationally trained applicants to complete a lengthy program before taking a registration exam.

In some cases, fairness means treating everyone the same. In other cases it means treating people differently based on their circumstances (reasonable accommodation) to achieve an equal result. For example, insisting that all applicants provide original documents treats everyone the same but may not be fair where records are not obtainable, and alternative methods exist to prove the credential or competency.

Opposites of fair: unjust, discriminatory, inequitable.

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3.  ROLE OF THE FAIRNESS COMMISSIONER

3.a  When will the Commissioner require a review?

Entry-to-Practice Reviews should not be done only when a problem has been identified. They are systemic reviews that consider, for example, whether registration requirements and practices that appear to be neutral may be having an unnecessary or unfair impact on some or all groups of applicants.

3.b  Determining the scope of a mandatory review

Discussing the scope

Before specifying the scope of a mandatory review, the Fairness Commissioner or OFC staff will discuss the matter with the regulatory body, ideally to agree on the scope that makes sense and the timing for the review. Ultimately, however, the Commissioner is responsible for determining the scope of each mandatory review. Regulators conducting voluntary reviews should also consider the priority areas on which their reviews should focus.

The goal is for reviews to achieve the greatest impact and to be manageable. Even when the legislation requires a topic to be included in mandatory reviews (i.e., necessity and relevance of requirements, reasonableness of fees, and efficiency of decision-making), the Commissioner will specify which topics should be analyzed in an in-depth way and those that may be analyzed in a summary way. The Commissioner cannot exempt these topics entirely, because the legislation requires that they be included.

In deciding on the scope, the Commissioner considers work the regulator has done to review and improve registration requirements and practices. The Commissioner also considers potential problem areas indicated by the OFC's analysis of Fair Registration Practices Reports and Audit Reports.

Registration requirements

An analysis of registration requirements is a component of all mandatory reviews. This is because section 19(2) of FARPA and 22.6(2) of RHPA Schedule 2 require these reviews to include an analysis of “(a) the extent to which the requirements for registration are necessary for or relevant to the practice of the profession.”

Sections 19(2) and 22.6(2) also state that reviews must include an analysis of registration fees, which are one kind of registration requirement. Specifically the analysis must include “(c) the reasonableness of the fees charged by the regulated profession in respect of registrations.”

The items listed below are all examples of registration requirements. It is unlikely that a single review would be expected to address them all.

• Qualifications for competence to practice
  • Education credentials
  • Language proficiency
  • Workplace or clinical experience
  • Successful completion of registration exams
  • Good character
  • Any special requirements for internationally trained applicants
• Other requirements for entering practice
  • Legal status
  • Professional liability insurance
• Submitting proof that qualifications and other requirements are met
  • Documentation required and alternatives acceptable to the regulator ⁵
• Payment of fees
  • A particular fee related to registration
  • Fees charged by qualifications assessment agencies
  • Fees and waivers of fees for access to records. ⁶

Registration practices

An Entry-to-Practice Review analyzes registration practices to ensure they are transparent, objective, impartial and fair. The items listed below are examples of registration practices drawn from the legislation.

• Providing information about:
  • Registration practices ⁷
  • The amount of time the registration process usually takes ⁸
  • Objective requirements for registration and where alternative means of satisfying them may be acceptable to the regulator ⁹
  • The fee scale related to registration ¹⁰

• Assessing qualifications, whether by the regulator or a qualifications assessment agency ¹¹
  • Implementing measures to ensure that regulators and qualifications assessment agencies make assessments in a transparent, objective, impartial and fair manner ¹²
• Making registration decisions
• Managing internal reviews or appeals
  • Providing the opportunity for applicants to make submissions in the internal review or appeal ¹³
  • Using different decision-makers than the ones who made the original decision ¹⁴
  • Informing applicants of any right they have to request further review of or appeal from the decision ¹⁵
• Granting applicants access to records ¹⁶
• Training assessors and decision-makers ¹⁷

• Making decisions in an efficient and timely way ¹⁸
  • Making registration decisions within a reasonable time ¹⁹
  • Giving applicants written responses and reasons for decisions within a reasonable time ²⁰
  • Providing an internal review or appeal within a reasonable time. ²¹

3.c  Possible scenarios for the scope of mandatory reviews

The following are hypothetical scenarios showing how the scope of Entry-to-Practice Reviews can differ. Note: In-depth analysis of a topic means that significant time and attention will be spent on it. Summary analysis means that the topic is included but not examined in detail. A summary analysis is a brief look at an issue as opposed to a comprehensive examination.

Scenario #1: Previous voluntary review

Three years ago, a mid-sized regulatory body conducted a voluntary review of its work-experience requirement. The review was extensive and participatory, and included an analysis of the justification for the requirement and its impact on both Canadian and internationally trained applicants. The review's recommendations have been implemented.

The Fairness Commissioner's research suggests that the registration-related fees for this regulatory body appear to be low. Any issues raised by the Commissioner as a result of the regulator's Fair Registration Practices Report have been dealt with. The regulator's Audit Report indicated compliance with the legislative requirements but suggested a few improvements about timely communication with applicants. The audit suggestions have been implemented. Most assessment decisions for this profession are made by a national body with which the regulator has a memorandum of understanding.

In this scenario, the Commissioner could specify the following scope for a mandatory review:

	In-depth analysis	Summary analysis
Registration requirements	necessity and relevance of qualifications for registration (apart from workplace experience) requirements for proving how the qualifications are met (apart from workplace experience)	necessity and relevance of the work-experience requirement reasonableness of fees
Registration practices		efficiency and timeliness of decision-making

Scenario #2: First review, bridging program

A large regulator has not yet conducted a review of its entry-to-practice requirements. The regulator's Audit Report indicates compliance with the legislative requirements. Data from the Fair Registration Practices Reports indicate a high success rate for internationally trained applicants. However, applicants and advocacy groups have expressed concern about a new mandatory bridging program for internationally trained applicants and the associated fee.

In this scenario, the Commissioner could specify the following scope for a mandatory review:

	In-depth analysis	Summary analysis
Registration requirements	necessity and relevance of qualifications for registration, with an emphasis on the mandatory bridging program requirements for proving how the qualifications are met reasonableness of fees for the mandatory bridging program	reasonableness of all other registration fees
Registration practices		efficiency and timeliness of decision-making

Scenario #3: First review, timeliness

A small regulator has not yet conducted a review of its entry-to-practice requirements. This profession has a low proportion of internationally trained applicants. No particular issues have emerged from the Fair Registration Practices Reports or Audit Reports. However, applicants have complained about the length of time to find out the results of internal appeals.

In this scenario, the Commissioner could specify the following scope for a mandatory review:

	In-depth analysis	Summary analysis
Registration requirements	necessity and relevance of qualifications for registration and of requirements for proving they are met	reasonableness of registration fees
Registration practices	efficiency and timeliness of internal appeal decisions	efficiency and timeliness of other decisions

Scenario #4: First review, assessment

A mid-sized regulator has not yet conducted a review of its entry-to-practice requirements. After reviewing the Fair Registration Practices and Audit reports, the Fairness Commissioner remains unclear about criteria used to assess the qualifications of internationally trained applicants and the accountability arrangements between the regulator and a qualifications assessment agency.

In this scenario, the Commissioner could specify the following scope for a mandatory review:

	In-depth analysis	Summary analysis
Registration requirements	necessity and relevance of qualifications for registration and of requirements for proving they are met	reasonableness of fees
Registration practices	assessment of qualifications for internationally trained applicants accountability arrangements to ensure transparent, objective, impartial and fair assessments by the qualifications assessment agency	efficiency and timeliness of decision-making

3.d  Time for conducting a review

Under the legislation, mandatory reviews must be conducted at times specified by the Fairness Commissioner. The time needed to conduct a review depends on the scope of the review and the nature of the consultation process. A review of a single fee or practice, for example, would be less extensive than an in-depth review of all qualifications for registration. Therefore, in discussing the scope of the review, the OFC and regulator will consider the length of time necessary to complete the review. This will help the Commissioner to determine the period within which the regulator must complete the review.

3.e  Support to regulators

The Fairness Commissioner provides the following types of support to Ontario regulators for Entry-to-Practice Reviews.

Working collaboratively

The Fairness Commissioner is committed to a respectful, collaborative relationship with regulatory bodies, recognizing their distinct roles. Before requiring a mandatory Entry-to-Practice Review, the Commissioner or OFC staff meet with the regulator to discuss timing, focus and scope. During the review, regulators are encouraged to keep in touch with their contacts at the OFC to discuss how the review is progressing and to raise any questions about the process.

Sharing information, trends and analysis

As OFC staff analyze information provided by Ontario regulators and other sources, they share helpful hints and trends. Among other benefits, this will reduce the information regulators have to gather on their own in their reviews. For example, it would be more efficient for the OFC to provide cross-country information on common topics where possible rather than requiring each regulator to collect it during the course of its review. Promising practices that Ontario regulators identify are an important source of information for the OFC to share more broadly.

The following are examples of informational supports that could be provided over time as the OFC builds its capacity in this area:

• Annual immigration data per occupation from Citizenship and Immigration Canada to show the number of entrants per occupation
• Summaries of promising developments in Ontario and elsewhere in relation to registration requirements and practices
• Innovative approaches to conducting reviews of registration requirements and practices.

Providing guidance

The Fairness Commissioner has produced this guide to help regulators conduct Entry-to-Practice Reviews. The guide will be enhanced as more experience is gained about what works well in the process. Policy staff from the Office of the Fairness Commissioner will be available to discuss issues and answer questions with individual regulatory bodies before, during and after the review.

Advocating changes

When an Entry-to-Practice Review recommends changes to legislation or regulations that will increase fair access to a regulated profession, the Fairness Commissioner can support the regulatory body by advocating agreed-upon changes to government. For example, the Commissioner could promote omnibus changes to regulations or legislation when several regulatory bodies state the need for regulatory or legislative change as a result of their reviews.

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4.  THE REVIEW PROCESS

Process Overview

Entry-to-Practice Reviews consist of four key steps. The time to complete a review will vary, depending on the scope of the review and the chosen methodology.

Step 1: Create and approve the project plan

This first step is to create and approve a project plan. In a mandatory review, the project plan should contain each of the elements listed below along with any others the regulator wishes to add.

	The Project Plan
Objectives	What is the review intended to accomplish? How will the findings be used?
Scope	What topics will the review cover in depth and what will be covered in a summary way?
Review questions	What are the specific questions the review will be designed to answer?
Data collection plan	What information will be collected, and why? From what sources? Whose input will be sought and why? How will it be obtained? Will an outside facilitator or researcher be retained?
Project governance	Who is accountable for the review? Will there be an oversight or advisory committee?
Project management	What are the key tasks, products, milestones, timelines and resources? Who are the team members, and what are their individual roles?

Step 2: Collect and analyze data

What information should be collected?

Much of an Entry-to-Practice Review will be spent collecting and analyzing data. Work already done for an earlier Fair Registration Practices Report or Audit Report should make some of the data collection much easier. The following types of data will be helpful.

TYPE OF DATA	PURPOSE
Governing statute, regulations, bylaws, standards, guidelines, policies and procedures	To identify registration requirements that must be analyzed for necessity and relevance To identify registration practices that must be analyzed for transparency, objectivity, impartiality and fairness
Qualitative data (through interviews, focus groups, surveys, or questionnaires)	To learn about positive and negative experiences and ideas for improvement
Statistics, appeals, applicant complaints	To identify trends or problems in general or for certain classes of applicants; flag issues to probe
Contextual information about the environment in which you operate (“environmental scan”)	To understand trends and emerging issues

It could also be helpful to get the following types of data, depending on the scope of the review.

TYPE OF DATA	PURPOSE
Information on other professions or jurisdictions	To compare with and learn from comparable organizations (supplementing any research that may be provided by the Fairness Commissioner)

Whose input should be gathered?

One of the guiding principles for Entry-to-Practice Reviews is that they be participatory. In a mandatory review, input should be gathered from:

• Registrar, Registration Committee and staff
• Members and current applicants
• Applicants who were unsuccessful or withdrew
• Qualifications assessment agencies (including affiliated national bodies).

Be sure to include a variety of members and applicants, including internationally trained ones, in order to get a range of perspectives on registration requirements and practices.

Depending on the nature and scope of the review, regulators are also encouraged to ask for input from one or more of the following:

• Professional associations
• Similar regulatory bodies in other jurisdictions
• Other Ontario regulatory bodies in related professions
• Organizations that support internationally trained applicants
• Educational institutions that offer programs needed for the profession
• Programs that help internationally trained applicants to upgrade their qualifications
• Employers that offer workplace or clinical experience required for registration
• Ministries and other government bodies.

How should the data be analyzed?

The purpose of analyzing the data is to determine which requirements and practices work well and which ones will be the subject of recommendations for change. Analysis is often the most difficult part of the review process. The extent of analysis depends on which topics the Commissioner specifies for in-depth or summary analysis and which topics the regulator adds.

For topics identified for in-depth review, the final report should include a thoughtful response to each review question based on what the data, consultations and analysis show. For topics identified for summary analysis, a brief paragraph in the report will suffice.

When should you seek outside help?

In most cases, it should be possible to complete the review without third-party help. When the collection and analysis of data will be extensive, and the regulatory body has the resources, it may wish to hire an external consultant to help in specific parts of the review. Under the regulatory body's direction, a consultant could prepare the project plan for approval, design surveys or consultation questions, conduct focus groups or facilitate meetings, and draft or edit the final report. In addition, regulators who have conducted reviews can be a source of ideas and tips on how to conduct a review, with or without the help of an external consultant.

Step 3: Make recommendations and an implementation plan

Determine recommendations

A key part of an Entry-to-Practice Review is recommending which registration requirements or practices need to be modified and the nature of the changes. In some cases, the modified requirement or practice may be more or less stringent than the one that currently exists. In other cases it will simply reflect a different approach. In all cases, the change should be clearly justified based on an assessment of the considerations set out for Entry-to-Practice Reviews in the legislation. Regulators conducting reviews must ensure that any new or revised requirement or practice does not create unnecessary barriers for applicants.

Develop an implementation plan

It is also essential to develop an implementation plan to include in the final report. The implementation plan should set out measurable goals for each recommended change, timelines for achieving the goals, the resource allocation, and responsibility within the organization for meeting the goals and evaluating progress.

Implementation of some changes may require action by the government or legislature. In that case, the regulatory body should take all steps possible to advocate for the change, with help from the Fairness Commissioner.

Step 4: Write, approve and file the report

The final step in an Entry-to-Practice Review is to write, approve and file the report.

Write the report

Reports for mandatory reviews should contain the components listed below and cover the topics listed in the checklist in Appendix A.²²

Approve the report

FARPA requires that the report include a statement by a person in authority certifying that all the information required has been provided and is accurate. ²³ Ideally, the report should be approved by the regulator's Registration Committee and board/council to ensure there is support for the recommendations and a commitment to implement the changes.

File the report

Reports from mandatory reviews must be filed with the Fairness Commissioner. For regulators governed by the RHPA, ²⁴ the filing deadline is 30 days from completion of the review. Regulatory bodies governed by FARPA must file by the date specified by the Commissioner. ²⁵ In exceptional circumstances, the Commissioner may extend a date for a regulatory body governed by FARPA. The Commissioner encourages regulators conducting voluntary reviews to also file their reports with the OFC.

Normally, the Commissioner will specify that a report from a regulator governed by FARPA must be filed within 30 days after the time specified for completing the review. This will provide consistency in the timing for health and non-health professions.

Make the report public

Non-health regulators must make the filed report available to the public. ²⁶ Although there is no similar requirement for health professions, it is a good practice to make the reports publicly available in the spirit of transparency. The simplest way to make the report available to the public is by posting it on the regulator's website.

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5.  SAMPLE REVIEW QUESTIONS

One of the most important tasks in an Entry-to-Practice Review is defining the questions for review. This section provides a list of sample questions on a variety of topics. The purpose of the list is to stimulate ideas about potential questions rather than to prescribe any questions that must be included. Actual questions will depend on the focus of the review, the chosen methodology, and the specifics of the profession.

5.a  Registration requirements: necessary and relevant

Qualifications: general

Registration is meant to ensure that persons who enter a profession are qualified to do so safely and competently. The qualifications an individual must have are set out in governing statutes, regulations, policies and bylaws. Typically they include academic credentials, workplace or clinical experience, language proficiency, successful completion of exams, and good character. Having the required qualifications is an indicator that the applicant has the necessary knowledge, skills and abilities to practise the profession.

Possible review questions:

• How does the qualification relate to competent and safe practice at the entry level of the profession to ensure public safety? How well does it predict competence?
• How did the qualification emerge? Why is it there? Have there been any changes in the practice of the profession or the environment in which it is practised? Is it still relevant in the current context? Have legal requirements been taken into account?
• Does the qualification have an unintended impact on any group? Does it unfairly exclude or limit certain groups such as internationally trained applicants?
• What changes could be made to the qualifications to better predict competence or to reduce negative impact?

Qualifications: specific

The following are possible additional review questions pertaining to specific qualifications:

Academic credentials requirement

• How directly does the academic credential relate to competent practice?

Language proficiency requirement

• How does the required degree of language proficiency relate to the realities of professional practice?
• Is the required degree of language proficiency clearly defined?

Workplace or clinical experience requirement

• Are the length of time, conditions, location and nature of the required experience necessary and relevant to ensure competent practice?
• To what extent is international experience sufficient to meet the objectives of a workplace or clinical experience requirement? To what extent is Canadian or Ontario experience necessary for applicants to become familiar with the specifics of practice in Ontario?
• Are there barriers that may unfairly restrict access to workplace or clinical positions (e.g., not enough spaces, lack of supervisors, etc.)?

Registration exams requirement

• How well do registration exams administered by the regulator or a qualifications assessment agency test the knowledge and skills required to competently and safely practise the profession at an entry level?

Special requirements for internationally trained applicants

• What is the rationale for any requirements that apply only to internationally trained applicants?
• Are courses or bridging programs available to fill gaps?
• If a bridging or other program is a mandatory requirement for internationally trained applicants, is it necessary in all cases? Are there ways for internationally trained applicants to get full or partial exemptions?

Other requirements for entry-to-practice

The governing statute or regulation may include other requirements that do not deal with competence.

Legal status requirement

• Is a requirement for citizenship or permanent residency status necessary? Would legal permission to work in Canada (e.g., as a temporary foreign worker or provincial nominee not yet provided permanent residence by the federal government) be sufficient?

Proving that qualifications and other requirements are met

Applicants must prove that they meet the prescribed qualifications and other registration requirements. Often this is done by submitting documentation from academic institutions, examiners, workplace or clinical supervisors, immigration authorities, etc.

Possible review questions include:

• To what extent is the required documentation a clear indicator that a qualification or other requirement is met?
• What is the greatest challenge that internationally trained applicants face in proving they meet the qualifications? Are there alternative methods of proof that would be effective?

Reasonableness of fees

Fees are charged by both regulators and qualifications assessment agencies. Fees vary in number and amount based on factors such as the size of the regulatory body, types of licences or certificates, and number of required exams. Considering the reasonableness of fees is a required component of mandatory reviews.

Possible review questions include:

• How were the fees originally set? What was the rationale for the amounts? Is there an objective basis for the amounts?
• Do the fees discourage potentially qualified applicants or create hardship for those who do apply? In what circumstances can fees be waived or paid in instalments?
• Are the fees higher than the cost of providing the service?
• Are the fees higher than those charged for comparable services by other regulators?
• Are there measures to ensure that fees charged by qualifications assessors are reasonable?

5.b Registration practices: transparent, objective, impartial and fair

Providing information

The way regulators and qualifications assessment agencies provide information is a vital component of the transparency requirement of the fair access legislation. It is also a matter of fairness. If qualified applicants – including internationally trained applicants – do not know what is required of them and how the process works, they will have difficultly succeeding.

Possible review questions include:

General information

• How clear and complete is information about registration requirements, practices and timelines? How easy is it to find the information?
• How clear and complete is information on requirements or practices that apply specifically to internationally trained applicants? How easy is it to find this information?
• How easy is it for applicants and potential applicants to know the total amount of registration-related fees, including those charged by qualifications assessment agencies?

Communication with individual applicants

• What formal policies and procedures are in place for communicating decisions, responses and reasons to applicants?
• How easily can applicants find out how their application is progressing and the estimated time for each stage of the process?
• Are applicants notified of gaps before a decision is made so that they have a chance to upgrade their qualifications or provide further documentation?
• Are negative decisions substantiated by clear reasons?

Website information

• Does the website provide a step-by-step path through the registration process, self-assessment tools and fact sheets?
• Do users find navigation of the website to locate registration information to be user-friendly and intuitive? Can users get directly to registration information without more than two layers or links?
• How well does the website comply with accessibility standards under the Accessibility for Ontarians with Disabilities Act, 2005 or the World Wide Web Consortium?

Assessing qualifications: general

An applicant's success depends largely on assessments made by the regulator, a qualifications assessment agency, or both about whether the applicant meets the required qualifications.

Possible review questions include:

Assessment: transparency

• How transparent are the criteria for assessing qualifications?
• Are there unwritten rules or policies that applicants should be aware of?

Assessment: objectivity

• Are assessors and decision-makers well-trained in applying the criteria?
• Are the criteria for assessing qualifications sufficient for making objective decisions? Or are there gaps in the criteria that could result in unduly subjective decision-making?
• How does the regulator or qualifications assessment agency work to ensure that different assessors and decision-makers reach consistent decisions?

Assessment: impartiality

• Are assessors and decision-makers well trained and neutral?

Assessment: fairness

• Are all applicants assessed on the basis of their individual competence as opposed to general assumptions about where they have studied or practised?
• Can the assessment process begin while an applicant approved for immigration to Canada is still overseas?

Assessments by qualifications assessment agencies

• How effective are measures to ensure that the agencies make assessments in a transparent, objective, impartial and fair way?
• Does the regulator have a clearly articulated agreement with the agencies to hold them accountable for their practices?

Assessing qualifications: specific

Assessing academic credentials

• How do assessors of academic credentials keep up-to-date on educational equivalencies in other jurisdictions?
• How are assessors trained to determine equivalencies?
• What alternatives exist if the required documentation is unobtainable for reasons beyond the applicant's control?

Assessing language proficiency

• Is there a rational basis for when French or English language proficiency will be assumed and when it must be assessed?
• How well do language tests assess occupation-specific language?
• Before taking a language proficiency test, are there ways for applicants to self-assess and, if necessary, upgrade their relevant language skills?
• How are assessors of language proficiency trained to conduct impartial assessments (e.g., to avoid being unduly influenced by accent)?
• Is the language level of the test superior to the level required to practise?

Assessing performance on exams

• Are applicants advised about the exam format, scoring method, and right (if any) to appeal the result?
• What safeguards exist to reduce subjectivity in scoring?
• What safeguards exist to prevent bias based on the applicant's country of origin, race, ethnicity, name or other identifying features?
• In what ways could the exam format create an obstacle for internationally educated applicants? Are practice tests available? Can applicants retake the exam?

Assessing workplace or clinical experience

• How does the regulator determine whether the workplace or clinical experience requirement has been met?
• Is there a role for the regulator in facilitating access to workplace and clinical experience opportunities?

Assessing good character

• Are applicants aware of how the assessment is made (e.g., what documents are reviewed and who is consulted)?
• To what extent are the methods for assessing good character objective and concrete?
• Are decision-makers trained not to be unduly subjective in assessing good character?
• Do good-character assessments work to the advantage or disadvantage of any group of applicants?

Making registration decisions

• How transparent are the criteria for making registration decisions?
• How are decision-makers trained to make objective registration decisions based on the documentation submitted and assessments conducted by the regulator or a qualifications assessment agency?

Internal reviews or appeals

• In what way may applicants make submissions in an internal review or appeal? How are they advised of this opportunity?
• What safeguards are in place to ensure that decision-makers on internal reviews and appeals are different from those involved in the original decision?
• How and when are applicants advised of the right to request a further review or appeal?

Granting access to records

• Does the regulator's policy on access to records clearly indicate how an applicant may access records related to the application and any limitations on such access?
• Are there measures in place to ensure that applicants can access their files with qualifications assessment agencies?

Efficient and timely decision-making

Considering the efficiency and timeliness of decision-making is a required component of mandatory reviews.

Efficient and timely decision-making: objectivity

• How consistently does the regulator or qualifications assessment agency follow its published timelines for decision-making?
• What monitoring does the regulator or qualifications assessment agency do to ensure procedures are followed and time standards are met?

Efficient and timely decision-making: fairness

• How quickly are assessment decisions, registration decisions, and internal review and appeal decisions completed and communicated? What are the reasons for delays?
• Are the timelines significantly longer or shorter than those of comparable regulators (e.g., where volume of applications and size of the organization are similar)?
• What parts of the process could be streamlined? Could certain timelines be reduced?

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6.  AFTER THE REVIEW

6.a  Implementing the results

The Entry-to-Practice Review is complete once the report – including recommendations and an implementation plan – is filed with the Fairness Commissioner. It is up to the regulator to make a concerted effort to implement the changes and monitor success. Demonstrating progress will be a factor in the Commissioner's decision regarding future reviews.

The progress regulators make in implementing recommended changes will also be an indicator of FARPA's effectiveness. The Fairness Commissioner will comment on this progress in the annual report to the minister. ²⁷

6.b Keeping policies up-to-date

In most cases, regulators will not need to conduct another mandatory review for some time, provided that the review covered the identified issues and the Commissioner knows that progress on implementing the changes is proceeding well. However, there are important steps regulators can take to ensure that policies remain up-to-date and that new barriers do not emerge.

Whenever a regulator plans to introduce a new or amended registration requirement, it is a good idea to consider the extent to which the requirement is necessary and relevant (and the reasonableness of fees). Similarly, before introducing a new registration practice, it will be helpful to consider whether the practice is transparent, objective, impartial and fair. If possible, pretest new requirements or practices using focus groups or other methods.

In addition, regulators may wish to consider revising requirements and practices when changes occur (e.g., when applications from certain parts of the world increase) or particular issues are flagged (e.g., via complaints). In developing new initiatives, consider the needs of internationally trained individuals from the outset.

6.c  Feedback

There is no requirement for the Fairness Commissioner to approve the final report. However, in the spirit of ongoing dialogue and learning, a feedback discussion would be helpful to discuss:

• How well did the Entry-to-Practice Review fulfill its objectives?
• How can promising practices and lessons learned from this review be shared with others?
• How is implementation of any proposed changes proceeding?

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APPENDICES

Appendix A.  Report checklist for the Entry-to-Practice Review

This checklist sets out points that should be covered in the final report of a mandatory review. Regulators conducting voluntary reviews are encouraged to use the checklist as well. For more information on writing, approving and filing reports, see Section 4.

1. Executive summary
   • Briefly summarize the review process, key findings, recommendations, and implementation strategies.
2. Objectives and scope
   • State whether this was a mandatory or voluntary review and describe how it builds on previous reviews.
   • State the objectives established for the review.
   • Describe the scope of the review: what was examined in depth; what was looked at in a summary way.
   • List the review questions pertaining to this review.
3. Methodology
   • Describe the governance structure for the review.
   • List the types and sources of data obtained.
   • State the number and categories of participants who gave input.
   • State the time period during which the review was conducted.
   • Describe the process that was used.
4. Analysis and findings
   • Describe conclusions that can be drawn from the quantitative and qualitative data that you gathered.
   • Respond to each question specified for the review (whether by the Fairness Commissioner or the regulatory body).
   • Describe your findings about the extent to which the registration requirements under review are relevant and necessary (including reasonableness of fees).
   • Describe your findings about the extent to which the registration practices under review are transparent, objective, impartial and fair (including the efficiency and timeliness of decision-making).
5. Recommendations
   • Make recommendations about which registration requirements and practices need to be modified and the nature of the proposed change.
6. Implementation plan
   • Set out measurable goals and timelines for each recommended change.
   • Identify implementation challenges and strategies you will use to address them.
   • Identify who in the organization is responsible for meeting the goals and evaluating progress.
   • Describe the commitment of the organization to allocate resources and implement the changes.
7. Statement of approval
   • Include a signed statement by a person in authority to certify that the report contains the required information and that the information is accurate.

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Appendix B.  Other resources

Legislation

All Internet addresses below were last accessed on June 30, 2009

Fair Access to Regulated Professions Act, 2006 (FARPA). Available at:
www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_06f31_e.htm

Regulated Health Professions Act, 1991 (RHPA) Schedule 2, sections 22.1 to 22.14. Available at:
www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_91r18_e.htm

OFC publications

2007–2008 Annual Report. Available at: www.fairnesscommissioner.ca/en/downloads/PDF/ofc_annual_report_2007-2008_english_online.pdf

A Starter Kit for Conducting Reviews of Registration Practices. December 2008. Available at: fairnesscommissioner.ca/en/downloads/PDF/starter_kit_for_conducting_reviews_of_registration_practices_english_print_and_pdf_dec_12_08.pdf

Framework for Audits of Registration Practices: Guidance for Ontario's Regulatory Bodies. August 2008. Available at: www.fairnesscommissioner.ca/en/downloads/PDF/framework_for_audits_of_registration_practices_guidance_for_ontario%27s_regulatory_bodies_pdf_english.pdf

Guidelines for Fair Registration Practices Reports. June 2008. Available at: www.fairnesscommissioner.ca/en/downloads/PDF/guidelines_for_fair_registration_practices_reports_pdf_english.pdf

Ontario's Regulated Professions: Report on the 2007 Study of Registration Practices. June 2008. Available at: fairnesscommissioner.ca/en/downloads/PDF/ontario%27s_regulated_professions_report_on_the_2007_study_of_registration_practices_english_pdf.pdf

Study of Qualifications Assessment Agencies. March 2009. Available at: www.fairnesscommissioner.ca/en/downloads/PDF/study_of_qualifications_assessment_agencies_print_pdf_english.pdf

Voluntary reviews

College of Physiotherapists of Ontario Registration Practices – Self-Audit: report.

Licensing & Accreditation Task Force of the Law Society of Upper Canada. Report to Convocation, September 25, 2008. Available at: www.lsuc.on.ca/media/convsep08_licensing.pdf

Ontario College of Teachers. Fair Registration Practices Review – Final Report. Toronto, March 2008. Available at: www.oct.ca/publications/PDF/fair_registration_practices_e.pdf

Canadian context

Reitz, Jeffrey G. Immigrant Skill Utilization in the Canadian Labour Market: Implications of Human Capital Research. 2001. Available at: www.utoronto.ca/ethnicstudies/Reitz_Skill.pdf

Frameworks for conducting reviews

Alboim, Naomi, and The Maytree Foundation. Fulfilling the Promise: Integrating Immigrant Skills into the Canadian Economy. Caledon Institute of Social Policy, 2002. Available at:
www.caledoninst.org/Publications/PDF/553820134%2Epdf

Chinn, Roberta, and Norman Hertz. Job Analysis: A Guide for Regulatory Boards. 2000. Available at:
www.clearhq.org/hertz.htm

Cornish, Mary, Elizabeth Mclntyre, & Amanda Pask. “Strategies for Challenging Discriminatory Barriers to Foreign Credential Recognition,” in Update (Cavalluzzo, Hayes, Shilton, McIntyre & Cornish) (January 2000). Paper originally presented to the National Conference, “Shaping the Future: Qualification Recognition in the 21st Century,” Toronto, October 12-15, 1999. Available at: www.cavalluzzo.com/publications/newsletters/access_website.PDF

Human Resources and Skills Development Canada, Ministry of Labour. Guidelines for the Employment Equity Act and Regulations – Guideline 6: Employment Systems Review. 2003. Available at: www.hrsdc.gc.ca/eng/lp/lo/lswe/we/legislation/guidelines/gdln6.shtml

Ontario Regulators for Access. Regulators' Guide for Promoting Access to Professions by International Candidates. 2004. Available at: www.regulators4access.ca/html/regguide.htm

Thomson, George M. Report to the Ontario Minister of Citizenship and Immigration: Review of Appeal Processes from Registration Decisions in Ontario's Regulated Professions. Queen's Printer for Ontario, 2005. Available at: http://www.ontarioimmigration.ca/documents/ThomsonReportNov2005.pdf

Fairness

Gruber, Gerald P. “The Meiorin Case: Implications for I/O psychologists,” in The Canadian Industrial & Organizational Psychologist, Vol. 20, No. 2 (January 2004), pp. 10–14. Available at: www.psychology.uwo.ca/csiop/jan2004.pdf

Manitoba Ombudsman. Understanding Fairness: A Handbook on Fairness for Manitoba Municipal Leaders. n.d. Available at: www.ombudsman.mb.ca/pdf/Understanding%20Fairness%20Web%20Report.pdf

Pillutla, Madan M., and J. Keith Murnighan. “Fairness in Bargaining,” in Social Justice Research, Vol. 16, No. 3 (September 2003), pp. 241–262. Available at: www.springerlink.com/content/v714701403mxr511/

Assessment

Gonczi, Andrew. “Competency Based Assessment in the Professions in Australia,” in Assessment in Education: Principles, Policy & Practice, Vol. 1, Issue 1 (1994), pp. 27–44. Available at: www.informaworld.com/smpp/ftinterface?content=a739133146&rt=0&format=pdf

Public Service Commission of Canada. “Section 1: Generic Standards for Selection and Assessment,” in Standards for Selection and Assessment. n.d. Available at: www.collectionscanada.gc.ca/webarchives/20071122013222/http://www.psc-cfp.gc.ca/plcy-pltq/staf-dot/stand_selec/generic_e.htm

Walker, James. “International Approaches to Credential Assessment,” in Canadian Issues, Spring 2007, pp. 21–25.

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Appendix C.  End notes