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Registration Practices Assessment Report — Summary



In September 2011, Ontario’s Office of the Fairness Commissioner assessed the way the College of Opticians 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 Opticians 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 Opticians of Ontario (COO) 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

  • An excellent flow chart on the COO website explains the registration process for domestic and international applicants. The flow chart information also outlines the requirements that may be satisfied through acceptable alternatives.

Internal "Review"

  • The COO has added an internal appeal mechanism to the registration process. As a result, any applicant has the right to appeal a decision by the registration committee to the new internal registration appeal panel (RAP), within 15 days of receiving the registration committee's decision. Although another layer has been added to the registration process (for the RAP to receive and consider an issue), this is offset by additional transparency and fairness in registration decisions.

Documentation of Qualifications

  • Applicants from non-accredited schools may now submit a copy of their student record if they cannot get an official course outline.

Assessment of Qualifications

  • The COO has implemented the new national Prior Learning Assessment and Recognition (PLAR) process. (This is a process for identifying, assessing and recognizing what a person knows and can do.) This process is now the same across Canada (except for Quebec), regardless of the province the applicant applies in. Applicants who have graduated from an accredited opticianry program recognized by the COO will be accepted for registration, if they meet the general registration requirements.
  • The COO offers regular orientation sessions for newly enrolled students in programs accredited by the Ontario-based National Association of Canadian Optician Regulators (NACOR) and by the Ministry of Health and Long-Term Care. The COO has also started offering exam orientation sessions to the soon-to-be graduates of these programs and to other potential registration exam candidates.
  • Registration committee members attend a detailed orientation session conducted by the COO's legal counsel at the first committee meeting of the year.
  • For the PLAR process, a three-person panel reviews and assesses all the required information submitted by the applicant. The panel consists of members of the profession who are also members of COO's registration committee. A fourth person (a COO council member appointed by the Ontario government) acts as an observer for the panel proceedings, in order to ensure objectivity in the assessment process and to ensure procedural fairness. To help the panel make informed decisions, the acting deputy registrar maintains a file of earlier assessment decisions for panel members to review. A theoretical and practical assessment and an in-person interview are also part of the COO's PLAR process.



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

  • Improve information for applicants by making the following changes on the COO website:
  • Add the following and keep the OFC informed as each addition is completed: the complete application package, including application forms that can be completed online or printed out and delivered to the COO; and an online renewal process. [Required; Good]

January 2012
  • Move the flow chart showing alternative registration pathways into the Registration Practices page. [Good]

January 2012
  • As recommended in the COO Audit Report, create a new website section called "Internationally Educated Candidates" that provides greater information on requirements that may be satisfied through acceptable alternatives. [Good]
    Note: For a copy of the Audit Report, contact the COO.

January 2012
  • Move information about exemptible and non-exemptible registration requirements to the main page of the Becoming an Optician section of the website. [Good]

January 2012
  • Place a short notice in French on the home page, directing francophones to contact the COO by phone, by email, or in writing to get registration information in French. [Good]

January 2012
  • Explore additional ways to support overseas registration processes and make the processes available on the website. [Good]

January 2012
  • Place all information related to qualifications assessment that is in the application package into the Becoming an Optician section of the website. [Required]

January 2012
  • Place information on document retention and accessibility into the Becoming an Optician section. [Good]

January 2012
  • Provide estimated timelines in the Becoming an Optician section for all stages of the registration process within each registration category (registered optician, student optician, and intern optician). [Required]

October 2012
  • Develop an online assessment for PLAR that can be conducted outside of Canada (for example, in a testing centre or university centre in the applicants' home country). [Good]
  • Modernize the interview stage of the registration process through the use of Skype or another similar method for making voice/video calls over the Internet. [Good]
  • Place a copy of the fee schedule that is in the COO bylaws into the Becoming an Optician section of the website. [Good]

January 2012

Assessment of Qualifications

  • Implement recommendations from the COO Audit Report and Entry-to-Practice Review Report to include registration timelines in the COO's registration policy. [Required]
    Note: For a copy of the Audit Report or Entry-to-Practice Review Report, contact the COO.

June 2012


  • The recommendations for Transparency are the same as the recommendations described above in the following categories:
  • Information for Applicants, sub-points 2, 3, 4, 7, and 9
  • Assessment of Qualifications

October 2012


  • Place clearly defined COO registration requirements, assessment criteria, and registration policies on the COO website. [Good]

January 2012
Blank = Implementation is in progress.
= Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.