The Office of the Fairness Commissioner (OFC) in Ontario has studied the entry-to-practice requirements for regulated professions in other Canadian jurisdictions. This research allows the OFC to understand how the requirements in Ontario compare with those outside the province and informs its mandate of assessing the registration practices of Ontario's regulatory bodies to ensure they are transparent, objective, impartial and fair.

The OFC looked at entry-to-practice requirements for teachers, nurses, engineers, lawyers, and physicians and surgeons in British Columbia, Alberta, Saskatchewan, Manitoba and Quebec. These regulated professions were the five largest by number of members in Ontario in 2008, and the provinces are the five largest in Canada by population, outside of Ontario. This study reports requirements that relate to both internationally trained and domestically trained applicants.

The study examines the following categories of entry-to-practice requirements:

• Requirements for Full Registration or Permanent Certification
• Documentation Required
• Credentials Assessment (Third Party and/or Internal)
• Academic/Program Requirements
• Work or Practice Experience Requirements
• Examinations
• Language Requirements
• Fees Associated with the Licensing Process
• Third Parties Involved in the Licensing Process
• Typical Length of the Licensing Process
• Internal Review/Appeal Process

The categories examined correspond to those studied in the OFC's 2007 Studies of Registration Practices of regulated professions in Ontario. This study focuses only on the requirements for full or permanent registration. The other classes of licence offered by the regulatory bodies are too numerous and vary too greatly among the jurisdictions to be covered here.

The information reported here was gathered primarily from the regulatory bodies' websites and was supplemented by other provincial online resources and by inquiries to the regulatory bodies directly. The information was circulated to each regulatory body for verification of completeness and accuracy. All information, unless otherwise marked, has been validated by the regulatory body in question and is accurate as of January 2010. For the most up-to-date information, check the regulatory bodies' websites.

The study includes a table for each profession, which allows for easy comparison of the entry-to-practice requirements between Ontario and the other five provinces. A summary of findings appears below.

This research provides a comparative context for registration requirements in Ontario and it will inform the OFC's expectations of Ontario regulatory bodies. Such comprehensive information on entry-to-practice requirements for these five professions is not available elsewhere.

This research also provides a snapshot of registration requirements as they stand on the eve of the implementation of the Agreement on Internal Trade (AIT) and provides a good baseline against which to measure the effects of the AIT. The revised agreement was signed in January 2009 by all first ministers and is at different stages of implementation in the various jurisdictions across Canada. According to the agreement, persons who have an unrestricted licence to practise in a given Canadian jurisdiction are eligible for a licence in any other Canadian jurisdiction without undergoing another assessment and without having to meet any additional requirements. This means that, despite any differences in requirements between jurisdictions, licensees are entitled to full labour mobility unless exceptions have been approved.

Regulatory bodies have been holding discussions to determine how best to respond to their obligations under the AIT and have speculated that the AIT may result in the eventual harmonization of requirements across the country. The OFC will continue to monitor developments and to work with regulatory bodies in Ontario to ensure that any changes proposed adhere to the principles of transparency, objectivity, impartiality and fairness and do not result in a greater burden on applicants in the province.

Summary of Findings

Overall, the basic entry-to-practice requirements for British Columbia, Alberta, Saskatchewan, Manitoba and Quebec vary little within each profession. The education, work/practice experience, examinations and language competency required are often substantially similar. The important differences are highlighted below.

The manner in which the requirements for entry to practice are described is often very diverse among regulators in the same profession, making it difficult to understand the differences and similarities in requirements. There is also enormous variation in the clarity and completeness of the information on different regulators' websites. As a result, potential applicants attempting to determine the requirements for entry to practice from province to province may experience great confusion.

The registration processes in Quebec are the most distinct. The length of postsecondary education required is usually shorter than in the other provinces. Three out of the five professions studied require applicants to undertake some sort of training program for orientation to the practice of the profession in Quebec, and where other provinces use national examinations Quebec has developed its own. There is also a standardized French-language examination that all applicants for registration must pass, regardless of the profession. The only exception is for teachers who will be teaching in the English language.

When the regulatory bodies for the professions surveyed were asked to provide an indication of the typical length of the registration process for their applicants, the responses varied considerably. Some declined to provide a specific response, stating that the process depends entirely on the individual applicant. In many instances, the length of time is longer for international graduates than for graduates from Canada or the United States. Regulators cite the time required for credentials assessment and for receiving the required documentation as the main factors that prolong the process for the internationally trained. It is also difficult to compare the lengths of the registration processes for the various regulatory bodies of a given profession because they use different starting points. Some start the count only after all the documentation has been received, credentials assessment is complete, and the applicant has finished any remedial education or training that was necessary to meet the requirements. Others calculate the length from the initiation of an application, and still others, as in the case of engineers in Quebec, from the initiation of the program of required professional experience.

Compared with the other provinces surveyed, Ontario has more or less onerous requirements, depending on the profession.

For teaching, Ontario has some of the least stringent requirements for teacher education for permanent certification.

For registered nursing, Ontario's requirements are no more onerous than those of other provinces. Before the implementation of the Agreement on Internal Trade, the College of Nurses of Ontario was requiring applicants who graduated after 2005 without a four-year baccalaureate degree to complete additional education before they could be issued a full licence. This is no longer the case.

Applicants to the professional engineering designation in Ontario do not have to meet any more burdensome requirements than in the other provinces surveyed. In fact, Ontario is the only province that does not have a language requirement. Like Alberta and British Columbia, however, Ontario demands Canadian citizenship or permanent residency for full registration.

For lawyers, Ontario stands out by offering the possibility of exemption for internationally trained applicants from the entire articling term if they have sufficient professional experience. This exemption was introduced in 2008. Unlike many of the other provinces, however, it does not offer exemption from the bar admission course.

Applicants to the profession of physician or surgeon in Ontario have to meet similar requirements to those of the other provinces studied.

Information is accurate as of January 2010. Check the regulatory bodies' websites for the most up-to-date information.

Teachers

All the provincial regulatory bodies surveyed require the completion of a postsecondary degree and a teacher education program that includes student teaching experience. There are some interesting differences, however.

The amount of required teacher-specific education varies: Ontario requires only one year of teacher education; British Columbia, Alberta and Saskatchewan require 1.6 years; and Manitoba requires two. Quebec requires three years for those intending to teach preschool and at the elementary level, but only one for those intending to teach at the secondary level. British Columbia, Manitoba and Saskatchewan will issue a provisional licence to applicants who have only one year of teacher education, allowing them to work while they complete the additional education.

In Alberta, all applicants must first apply for a provisional certificate. They can obtain a permanent certificate only after they have taught in the province for two years. Quebec, Saskatchewan and Ontario require only applicants educated outside the province to teach within the province for a period of time before upgrading from a provisional, conditional or interim certificate to a permanent certificate. In Quebec, that period is four or five months; in Ontario and Saskatchewan, it is one year. At the time of publication of this study, however, Ontario was working to remove that requirement for both Canadian-trained and internationally trained applicants, and Saskatchewan was planning to remove it for Canadian-trained applicants.

Beyond basic teacher education, both British Columbia and Quebec require applicants to demonstrate familiarity with the education system in the province. In British Columbia, internationally educated applicants may have to complete a Professional Qualification Program, which can greatly extend the length of time it takes to start working in the field. It is mandatory in Quebec for all applicants educated outside the province to complete an additional brief program.

Currently, Manitoba and Saskatchewan are the only provinces that do not require applicants to demonstrate language competency. At the time of the publication of this study, however, the regulatory body for teachers in Saskatchewan was working on developing a language requirement.

Alberta, Manitoba and Quebec require Canadian citizenship or permanent residency for full certification; the other three provinces do not.

Nurses

The basic requirements for registered nurses are the same in all six provinces surveyed: applicants must have graduated from a recognized nursing program, must pass a professional examination and must demonstrate language competency, and the ability to practise, either by having graduated in the past four or five years or by having practised a given number of hours during that time. This ability to practise is referred to variously as competency, currency of practice, safe practice or fitness to practise. In Quebec, the number of required hours is 500; it is 1,125 everywhere else. All the provinces also require registration in good standing where the applicant previously practised.

British Columbia and Alberta have an additional requirement for internationally trained nurses: they must first apply for a provisional licence and complete 250 or 225 hours of practice in the province before they are eligible for full registration. In Quebec, there is an additional requirement, but it applies to all applicants who completed their nursing education outside the province, not only to internationally trained nurses: they must complete a Professional Integration Program that may last from a few weeks to a few months, depending on the applicant's profile.

Engineers

The requirements for engineers are almost entirely uniform from province to province. A bachelor's degree in engineering is required everywhere, as is pass standing on a professional examination. Outside of Quebec, this is the Professional Practice Examination (PPE). Quebec has its own exam, which mirrors the PPE. Demonstration of language competency is a requirement everywhere except Ontario.

All provinces surveyed except Quebec require four years of engineering experience; Quebec requires only three. For all six, however, one of those years of experience must be completed in Canada, to allow the applicant to demonstrate a good knowledge of local engineering laws, practices, standards, customs, codes, conditions and climates. This Canadian experience requirement is one of the most frequently cited obstacles to licensing for the internationally trained. British Columbia, Saskatchewan, Quebec and Ontario may accept experience obtained outside Canada if it allowed the applicant to gain the required knowledge of the Canadian situation. Such knowledge could be gained, for example, by working for a company that uses Canadian standards.

Four provinces, but not Saskatchewan and Quebec, will issue a provisional licence to internationally trained applicants who have met all the requirements aside from Canadian experience.

Given that the requirements are so similar across the provinces, it is surprising that Ontario, British Columbia and Alberta require Canadian citizenship or permanent residency for licensing when Saskatchewan, Manitoba and Quebec do not. Where citizenship or residency is required, the licensing process can be delayed while applicants wait for their immigration paperwork to be processed.

Good character is a requirement for professional engineers in five jurisdictions, but not in Quebec.

Lawyers

For lawyers, the requirements in the six provinces surveyed are essentially the same: a law degree, completion of a bar admission course and a professional internship known as the articling term. Good character is a requirement everywhere, as well. None of the regulatory bodies requires a formal assessment of language competency.

While the rest of Canada follows the common-law system, Quebec follows the civil-law system, and therefore applicants to the bar in that province must have a civil-law degree.

The length of the articling term varies from six months in Quebec to between nine and 12 months elsewhere. Internationally trained applicants to the bars of Ontario, Alberta and Quebec can be exempted from this requirement, however, if they have sufficient professional experience. British Columbia and Manitoba offer reductions for up to half of the articling term if applicants demonstrate equivalent experience.

While the subject matter is consistent across provinces, the length and format of the bar admission course vary, depending chiefly on whether the course must be undertaken concurrently with the articling term or not. The course runs for four weeks in Quebec and 10 in British Columbia, while elsewhere it runs the length of the articling term. In Ontario, British Columbia and Quebec, applicants must pass formal examinations; in the other provinces, the evaluations are staggered and embedded in the bar admission course. All the provinces except Ontario and Saskatchewan offer exemptions for portions of the bar admission course.

Physicians & Surgeons

For physicians and surgeons, the requirements are quite standard in the six provinces. They include a medical degree from an accredited medical school, the Licentiate of the Medical Council of Canada (LMCC) and the completion of a set period of postgraduate training, also referred to as a residency. This is a period of two years for those applying to family practice and four to five years for those applying to a specialty practice, depending on the specialty. This latter period differs only in Quebec, where five to six years is required.

For family practice, certification by the College of Family Physicians of Canada (CFPC) is required in Ontario, British Columbia and Alberta. Obtaining certification entails passing an examination after completing the two-year residency. In Saskatchewan and Manitoba, passing the exam for CFPC certification is not required. Quebec has its own examination that applicants must pass.

For specialty practice, certification by the Royal College of Physicians and Surgeons of Canada (RCPSC) is required everywhere except Manitoba and Quebec. RCSPC certification also entails passing an examination after completing the four- or five-year residency. Manitoba requires only the residency and Quebec has its own examination.

Ontario and British Columbia require Canadian citizenship or permanent residency for full registration. Saskatchewan and Manitoba require applicants to undergo a successful interview with the provincial college.