Introduction

In September 2011, Ontario’s Office of the Fairness Commissioner assessed the way the College of Psychologists of Ontario registers people who apply for a licence to practise in Ontario, to ensure that the registration practices are fair and continue to improve.  

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

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

The Office of the Fairness Commissioner

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

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

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

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

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

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

Commendable Practices

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

Information for Applicants

• Upcoming examination dates and the registration committee's meeting dates are posted clearly on the Prospective Members page of the CPO's website.
• All timelines and fees for the registration process are clearly described in separate sections of the Registration Guidelines in the Prospective Members section of the website.
• The criteria for meeting the good-character requirement are fully and clearly laid out in the Registration Guidelines and application forms.
• The Registration Guidelines have a separate section devoted to each requirement for registration in the profession, with comprehensive information.
• The application forms contain a page on examination accommodation that ensures that applicants are informed about the accommodation offered for people with special needs, so that they make the appropriate request where needed.
• The CPO is completing a web-based registration module that will improve communication with applicants. For example, the module will allow them to log in and view which of their documents have been received by the CPO and which documents are outstanding.

Documentation of Qualifications

• The CPO accepts certified copies of university transcripts, if the university cannot send transcripts directly to the CPO.

Assessment of Qualifications

• The CPO holds an annual meeting with World Education Services (WES) and Comparative Education Service (CES) to review the Third-Party Organizations section of the Fair Registration Practices (FRP) Report and to ensure that WES and CES are following the practices listed there. (These third-party organizations are qualifications assessment agencies.)
• The CPO's staff members and registration committee members train extensively in writing reasons to support registration decisions, in order to ensure that applicants receive a full explanation of how they did or did not meet registration criteria.

Fairness

• Via its Entry-to-Practice Review, the CPO has adopted a series of initiatives to ensure that registration decisions are made quickly, and also to ensure that the decisions and supporting reasons are communicated quickly. These initiatives include the following:
  • completing the construction of a web-based registration module
  • modifying the existing database to support tracking measures
  • keeping an ongoing record of registration-staff meetings and database reports of response times
  • charting and graphing weekly numbers of new applications
  • accumulating year-over-year data to identify peak periods for the receipt of applications
• The CPO has removed the registration requirement for three reference letters. This requirement was causing delays, and the CPO determined that the references were not necessary, because the requirement for supervised practice provides more current evaluations of applicants' character/competence.
• The CPO accepts transcript copies that have been certified by WES, so that applicants only need to get one set of documents.

Recommendations

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

Information for Applicants	Status
Make the following changes to the registration information on the CPO website:
Clarify how applicants may meet the language requirement. [Required]
Explain that language fluency is subject to limited exemption for applicants who are hearing impaired, and note that all other requirements are non-exemptible. [Good]
Consider offering registration information in French. [Good]
Clarify which steps in the registration process can be done outside of Canada. [Good]
Describe the criteria for passing the oral examination. [Required]
Provide more specific information about the objective criteria that are used for evaluating knowledge requirements for an applicant's intended practice area. (This evaluation is done in order to determine whether retraining is required.) [Required]
Clarify that if applicants are dissatisfied with their initial scoring on the jurisprudence and ethics examination, they can request a hand scoring. [Required]
Inform applicants that they may contact the CPO if they need accommodation (for special needs) for the oral examination. [Required]
Add a statement to clarify that original documents are not returned, but that applicants may request copies of any documents. [Good]
Add a note in the fee scale clarifying that internationally trained applicants must pay a fee for credential evaluation by World Education Services (WES) or Comparative Education Service (CES) and are responsible for any costs related to the translation of required documents. [Good]
Consider reviewing registration information on the website to ensure that the information is in plain language and that the steps in the registration process are clear. [Good]
Documentation of Qualifications
Provide information on the website about how applicants can contact the CPO to learn what alternate documentation may be acceptable, if they cannot get the required documentation for reasons beyond their control. [Required]
Assessment of Qualifications
Clarify the criteria for assessing language fluency in the Registration Guidelines on the website. [Required]
Provide more specific information about the objective criteria that are used for evaluating knowledge requirements for an intended practice area. (This evaluation is done in order to determine whether retraining is required.) [Required]
Once core competencies (the knowledge, skills and training that are needed to practise the profession) have been identified, review all assessment methods to ensure they are objective, valid and reliable. [Required]
Take more active measures to ensure that the Association of State and Provincial Psychology Boards (ASPPB) conducts the Examination for Professional Practice in Psychology in a way that is transparent, objective, impartial and fair. For example, the CPO could review with the ASPPB the Third-Party Organizations section in the Fair Registration Practices (FRP) Report, as it already does with WES and CES. (These third-party organizations are qualifications assessment agencies.) [Required]
Training
Consider including anti-discrimination material in the training provided to staff members and registration committee members who are involved in the registration process. [Good]
Access to Records
In the Registration Guidelines, include information on how long records are kept and what, if any, limitations exist. [Good]
Transparency
In the Registration Guidelines, clarify the criteria for meeting the language requirement and for passing the oral examination. [Good]
Fairness
Consider developing a general policy regarding reasonable accommodation (for special needs) in the registration process. [Good]
Continue to identify core competencies (the knowledge, skills and training that are needed to practise the profession), in order to ensure that the CPO's registration requirements - and the corresponding criteria that are used to assess applicants - are based on these competencies, as opposed to being based on the completion of a North American degree. [Good]
Allow applicants to add to their degree, so that their education is equivalent to a degree that is acceptable to the CPO. [Good]
Consider exempting from the supervised-practice requirement all applicants who have been registered in good standing in a jurisdiction that has a written reciprocity agreement with the CPO or that has requirements substantially equivalent to those of the CPO. [Good]
Have the registration committee continue to review its processes periodically in order to identify any opportunities to streamline the process for applicants to:
get approval for a retraining program reading list
get an answer to a question raised by the committee
[Good]

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