Introduction

In November 2011, Ontario’s Office of the Fairness Commissioner assessed the way the College of Massage Therapists 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. In February 2012, the office revised its assessment.

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

The College of Massage Therapists 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 Massage Therapists of Ontario (CMTO) 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

• The CMTO provides the Initial Registration Application Guide, which lists all the documents that an applicant must submit and the CMTO's rationale for requiring them.
• The CMTO advises applicants to contact the CMTO if they cannot obtain documentation, such as transcripts. The CMTO offers a statutory declaration as an acceptable alternative.
• The CMTO website provides a significant amount of registration information in French, and it has an area for applicants educated outside of Ontario.

Documentation of Qualifications

• The CMTO informs applicants about the Credential and Prior Learning Assessment (CPLA) process and the documentation required for it through the CPLA package and handbook. (The CPLA process is for internationally trained applicants and applicants from non-accredited programs outside of Ontario.)
• In its Initial Registration Guide, the CMTO clearly describes the documentation required for registration, its format, and the way it must be sent to the CMTO. The Initial Registration Application Document Checklist provides a quick reference to the necessary documentation.

Assessment of Qualifications

• To minimize subjectivity, the CMTO:
  • uses a standardized test for assessing applicants' language fluency, and tells applicants the required scores
  • requires all applicants to successfully complete the written and clinical certification examinations
  • requires all applicants to make declarations about all of the following: conviction of a criminal offence, finding of professional misconduct, current proceeding of professional misconduct, and unsuccessful application for registration as a massage therapist
  • requires a CPLA for all applicants who have completed a non-approved massage therapy program outside of Ontario.
• The CMTO ensures that its examinations are both valid and reliable through consistent and comprehensive reviews.

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
The OFC recommends that the CMTO make the following changes to its website:
Provide plain-language information about all the requirements that are subject to exemptions and the process for making an appeal to the registration committee. [Good]	March 2012
Inform applicants about the opportunity to review the results of the CPLA. [Required]	February 2012
Consider clarifying which documents are kept and which are returned upon request. (For example, upon request, the CMTO returns an original report of a criminal record screening.) [Good]	March 2012
Provide information for applicants about timelines and variables that may slow down the application process. [Good]	March 2012
Transparency
Currently, registration information is well documented, but it is not always easy to find. The CMTO is updating its website to help correct this. The OFC recommends that the CMTO group its registration information more appropriately - for example, in a dedicated registration area of the website. [Good]	May 2012
Fairness
Given that the CMTO is concerned that some of its fees are not cost-recoverable, the OFC recommends that the CMTO conduct a comprehensive analysis of its direct and indirect costs to enable it to make evidence-based decisions about its fees. (Due to limited resources, the CMTO could not conduct an extensive analysis of its direct and indirect costs in 2010.) [Good]
Although the CMTO has few internationally trained applicants, it has a process (the CPLA) for addressing their applications. However, the CMTO is reviewing the CPLA process, and is considering eliminating it, because of its high cost. The CMTO has requested input from the OFC in this area. The OFC recommends that the CMTO analyze its costs, explore alternative options for assessing the competency of applicants trained outside of Ontario (to ensure that CMTO's assessment requirements do not exclude these applicants), and document the outcomes. [Good]

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