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Registration Practices Assessment Guide — For Health Regulatory Colleges

General Duty

Legislation: RHPA, Schedule 2, s. 22.2
The College has a duty to provide registration practices that are transparent, objective, impartial and fair.

Does the regulatory body demonstrate the following practices?


TRANSPARENCY
  1. Registration policies and criteria are well-documented. Registration policies and criteria are well-defined and unambiguous. There are no unwritten policies. For example:
    1. Policies and criteria are readily available to registration staff and decision-makers.
    2. Policies and criteria are regularly reviewed and updated.
    3. All registration staff and decision-makers who are responsible for implementing policies and criteria are promptly informed of changes to policy.
  2. The regulatory body provides information about the requirements that may be satisfied through acceptable alternatives.
  3. The regulatory body provides information about all requirements that are subject to exemptions.
  4. If a regulatory body has any requirements for personal attributes such as “good character,” it describes the criteria that are used to assess these requirements.
  5. The regulatory body makes available a fee scale that shows all registration fees that are under the regulatory body’s control.
  6. The regulatory body identifies other costs associated with the registration process, including third-party assessments. This enables the applicant to approximate the total cost of the registration process.
  7. Applicants can see that the documented policies have been followed in their case.
  8. If there is a fee for making records available, the regulatory body gives applicants an estimate of this fee. The amount of the fee does not exceed the amount of reasonable cost recovery.
  9. The regulatory body communicates the following to applicants:
    1. the way that an applicant can ask for records (for example, in person, by email, or by completing and submitting a written form)
    2. the way in which records are available (for example, by photocopy or by access in person)
    3. who may access the records
    4. how long the records are kept
    5. what limitations (if any) exist on the right to access the records
  10. Registration information, including information that applies specifically to internationally trained individuals, is complete, clear, and easy to find. For example:
    1. The information avoids unnecessarily complicated language and minimizes technical language or jargon.
    2. Registration information is current and accurate.
    3. Applicants and individuals intending to apply can access information in multiple formats (such as downloading the information from the regulatory body’s website, having it mailed to them by the regulatory body upon request, or obtaining it orally).
    4. All of the information referred to in this Transparency section is on the regulatory body’s website, for applicants and for people intending to apply.
  11. Regulatory bodies communicate well with applicants about their application. Applicants know how their applications are progressing.
  12. The regulatory body informs applicants about which documents are kept by the regulatory body and which documents are returned to applicants upon written request.
  13. The regulatory body informs applicants about missing or incomplete documentation.
  14. If a language requirement can be met in English or French, the regulatory body provides registration information in English and French.
  15. The regulatory body identifies the steps in the registration process that an applicant can do or start outside of Canada, such as qualifications assessment, language assessment, and examinations.
  16. The regulatory body informs applicants about any qualifications assessment methods it uses.
  17. The regulatory body provides information or a referral to sources of information (for example, a website link) about any resources and supports that are available to applicants during the registration and assessment process. Examples of resources and supports include: examination blueprints, practice tests or examinations, sample assessment questions, programs for orientation to the profession, bridging programs, occupation-specific language-training opportunities, mentorship opportunities, work experience opportunities, and online tools to self-assess language or professional qualifications.
  18. The regulatory body describes the role of any third-party organizations that applicants may come in contact with during the registration process, such as qualifications assessment agencies and organizations that conduct examinations or provide training programs.
  19. The regulatory body gives a website link to, or explains where to find, the documentation required by any third parties who play a role in the body’s registration process.
  20. The regulatory body provides information about the estimated time for each stage of the application process that is under the body’s control. When timelines vary, a range or maximum amount of time is provided. When timelines vary by application type, the different timelines are outlined. Information about variables that may slow down the normal process is included, if these exist.
  21. Decisions and the reasons for them are communicated clearly.

OBJECTIVITY
  1. Subjectivity in decision-making is minimized by the use of specific criteria for assessing qualifications.4 For example: well-crafted marking templates or multiple-choice questions may help make the grading of exams a more objective exercise.
  2. Criteria can be measured by using verifiable data, and decision-makers can determine whether the criteria have been met or not in a straightforward way. For example: “good character” requirements may be measured against concrete criteria such as the lack of a criminal record, or through the completion of a standard template for references.
  3. Different decision-makers reach consistent decisions without requiring a subjective assessment that applies personal views or judgments. For example: there are common tools in place that decision-makers use; decision-makers reference past decisions; and decision-makers have been trained to follow a consistent process and to interpret policies and criteria in the same way.
  4. The regulatory body ensures that training is provided for individuals who assess qualifications, make registration decisions, or review decisions. These individuals receive:
    1. initial training (as soon as they have been assigned their duties)
    2. ongoing training (whenever there is a change in regulations, policies or procedures)

IMPARTIALITY
  1. The regulatory body takes measures to ensure that all staff members who deal with applications have training in the following:
    1. anti-discrimination (for example: staff have been trained on the Ontario Human Rights Code; staff have been trained on internal policies related to anti-discrimination)
    2. cultural diversity (for example: staff are trained in cultural differences and how to identify the potential for biases)
    3. the objectives of Schedule 2 to the Health Professions Procedural Code of the RHPA)
  2. The regulatory body takes measures to ensure that qualifications assessments5 are made free from bias and preconceived notions about any individual or group of individuals. For example: the regulatory body has established a code of conduct for qualifications assessors; policies and controlled processes are in place to ensure that different assessors would come to the same decision; and the regulatory body can demonstrate identified risks of biases and has measures in place to mitigate the risk.
  3. The regulatory body takes measures to ensure that registration decisions are made free from bias and preconceived notions about any individual or group of individuals. For example: the regulatory body has established a code of conduct for decision-makers; policies and controlled processes are in place to ensure that different decision-makers would come to the same decision; and the regulatory body can demonstrate identified risks of biases and has measures in place to mitigate the risk.
  4. The regulatory body takes measures to ensure that decision-makers come to each case without a preconceived view about the merits of the application. They maintain an open mind as they review the evidence to determine whether the applicant meets the criteria. For example: decision-makers have different levels of access than non-decision-makers to applicant information, to ensure that they are not influenced by information that is not relevant to the decision; multiple decision-makers are involved in reviewing an application; decision-makers use controlled processes; and those same processes are used for all applicants.
  5. The regulatory body takes measures to ensure that decision-makers do not undervalue applicants from certain jurisdictions or give undue preference to those from other jurisdictions, by ensuring that the decision-makers are well trained in applying assessment criteria. For example: training exists for decision-makers on how to apply criteria; there is a training plan for decision-makers; processes are in place to measure the effectiveness of training; and processes are in place to identify the performance and quality of decision-makers.
  6. The regulatory body takes measures to ensure that assessors, decision-makers and any other staff members who deal with registration applications are free from real or perceived conflicts of interest.6 For example: the regulatory body has a conflict-of-interest policy and/or formalized processes for both decision-makers and staff. The regulatory body has an ongoing process in place to review conflict-of-interest risk and has measures in place to mitigate this risk.


FAIRNESS

Substantive fairness

  1. The regulatory body is able to explain its registration requirements, including how new requirements emerged.
  2. The regulatory body is able to explain why all requirements are necessary and relevant to the practice of the profession.
  3. Requirements do not unjustifiably exclude or limit certain groups, such as internationally trained applicants.
  4. When language proficiency is a requirement, the level of proficiency required reflects the level required to practise the profession.
  5. The regulatory body can either:
    1. clearly justify the Canadian or Ontario experience it claims is necessary for applicants to become familiar with the specifics of practice in Ontario
         or
    2. explain how international experience alone is insufficient to meet the objectives of the regulatory body’s workplace or clinical experience requirement.
  6. Registration fees are reasonable. The regulatory body can show how fees under its control are set and can provide the rationale for the amounts. Fees are not unjustifiably higher than the cost of providing the service.


Procedural fairness

  1. Registration decisions adhere to published criteria, standards and policies.
  2. The registration process is streamlined and unnecessary steps are eliminated.
  3. Applicants can have their qualifications assessed while outside Canada.
  4. The regulatory body does the following within a reasonable time: makes registration decisions; gives the decisions (in writing) to applicants; and gives reasons where applicable.
  5. The regulatory body responds to applicants’ inquiries or requests within a reasonable time.
  6. The regulatory body provides “reviews” from decisions within a reasonable time.
  7. The regulatory body does the following within a reasonable time: makes decisions about internal reviews and appeals; gives the decisions (in writing) to applicants; and gives reasons, where applicable.
  8. When requested, access to records is granted as soon as possible, within a maximum of 30 days.


Relational fairness

  1. Applicants are treated in a way that takes their circumstances into consideration (reasonable accommodation) to achieve an equitable result. This may include, for example: accommodation of special needs, providing and accepting communication in multiple formats, providing mechanisms to allow flexibility in demonstrating competencies or ways to meet the requirements, and providing flexibility and/or offering multiple dates for applicants participating in assessments.
  2. If an applicant indicates that he or she cannot get the required documentation for reasons beyond his or her control, the regulatory body has a process:
    1. to determine whether the documentation is in fact unobtainable
    2. to consider and examine alternatives
    3. if possible, to help the applicant get alternative documentation if the required documentation is unobtainable

4 This practice refers to qualifications assessments conducted by the regulatory body itself. Qualifications assessment includes assessment of the following: academic credential/educational programs, work experience, language, examinations, prior learning assessment, and (in some cases) currency of qualifications.

5 This practice refers to qualifications assessments conducted by the regulatory body itself. Qualifications assessment includes assessment of the following: academic credential/educational programs, work experience, language, examinations, prior learning assessment, and (in some cases) currency of qualifications.

6 A conflict of interest includes, for example, any situation or circumstance in which the person’s other commitments, relationships or financial interests:

  • could improperly influence the person’s objective, unbiased and impartial exercise of his or her independent judgment, or could be perceived as doing so; or
  • could compromise, impair or be incompatible with the person’s effective performance of his or her contractual obligations, or could be perceived as doing so.