Introduction

In February 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Psychologists of Ontario (CPO) registers people who apply for a licence to practise in Ontario, to ensure that the registration practices are fair and continue to improve.

Assessment is one of the Fairness Commissioner's mandated roles under the Regulated Health Professions Act, 1991 (RHPA).

Assessment Cycle

To hold regulatory bodies accountable for continuous improvement, the OFC assesses their licensing practices using a two-year assessment cycle.

Assessment cycles alternate between full assessments and targeted assessments:

• Full assessments address all specific and general duties described in the RHPA.
• Targeted assessments focus on the areas where the OFC made recommendations in the previous full assessment.

This approach establishes continuity between the assessment cycles.

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Focus of This Assessment and Report

The February 2014 targeted assessment of the CPO focused on the areas where the OFC made recommendations in the full assessment it completed in September 2011.

The OFC’s detailed report captures the results of the targeted assessment. The assessment summary provides the following key information from the detailed report:

• duties that were assessed
• an overview of assessment outcomes for specific-duty practices
• an overview of comments related to the general duty
• commendable practices
• recommendations

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Availability of Report

The OFC encourages the CPO to provide the detailed report to its staff, council members, the public, and other interested parties.

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Assessment Methods

Assessments are based on the Registration Practices Assessment Guide – For Health Regulatory Colleges. The guide presents registration practices relating to the specific duties and general duty in the RHPA.

A regulatory body’s practices can be measured against the RHPA’s specific duties in a straightforward way. However, the general duty is broad, and the principles it mentions (transparency, objectivity, impartiality and fairness) are not defined in the legislation.

As a result, the specific-duty and general-duty obligations are assessed differently (see the Strategy for Continuous Improvement of Registration Practices).

Specific Duties

The OFC can clearly determine whether a regulatory body demonstrates the specific-duty practices in the assessment guide. Therefore, for each specific-duty practice, the OFC provides one of the following assessment outcomes:

• Demonstrated – all required elements of the practice are present or addressed
• Partially Demonstrated – some but not all required elements are present or addressed
• Not Demonstrated – none of the required elements are present or addressed
• Not Applicable – this practice does not apply to this regulatory body

General Duty

Because there are many ways that a regulatory body can demonstrate that its practices, overall, are meeting the principles of the general duty, the OFC makes assessment comments for the general duty, rather than identifying assessment outcomes. For the same reason, assessment comments are made by principle, rather than by practice.

For information about the OFC’s interpretations of the general-duty principles and the practices that the OFC uses as a guideline for assessment, see the Registration Practices Assessment Guide – For Health Regulatory Colleges.

Commendable Practices and Recommendations

Where applicable, the OFC identifies commendable practices or recommendations for improvement related to the specific duties and general duty.

Sources

Assessment outcomes, comments, and commendable practices and recommendations are based on information provided by the regulatory body. The OFC relies on the accuracy of this information to produce the assessment report. The OFC compiles registration information from sources such as the following:

• Fair Registration Practices Reports, audits, Entry-to-Practice Review Reports, annual meetings
• the regulatory body’s:
  • website
  • policies, procedures, guidelines and related documentation templates for communication with applicants
  • regulations and bylaws
  • internal auditing and reporting mechanisms
  • third-party agreements and related monitoring or reporting documentation
  • qualifications assessments and related documentation
• targeted questions/requests for evidence that the regulatory body demonstrates a practice or principle

For more information  about the assessment cycle, assessment process, and legislative obligations, see the Strategy for Continuous Improvement of Registration Practices.

Assessment Summary

Specific Duties

Specific duties assessed

As a result of the recommendations made in the full assessment completed in September 2011, the CPO has been assessed in the area(s) marked below:

None
Information for Applicants
Internal "Review"
Information on Appeal Rights
Documentation of Qualifications
Assessment of Qualifications
Training
Access to Records

Outcomes

The CPO has partiallydemonstrated the practices in the following specific-duty areas:

• Information for Applicants
• Documentation of Qualifications
• Assessment of Qualifications

For practices that are partially demonstrated or not demonstrated, see the Recommendations section later in this summary.

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General Duty

Assessment Method

The CPO selected the method marked below for the assessing of its adherence to the general-duty principles, and informed the OFC:

a.	OFC assesses based on the practices listed in the assessment guide
b.	Regulatory body self-assesses based on the practices in the assessment guide
c.	Regulatory body self-assesses using a system-based approach, in which it explains what it does to ensure that its practices are adhering to the general-duty principles

Principles assessed

As a result of the recommendations made in the full assessment completed in September 2011, the CPO has been assessed on the principle(s) marked below:

None
Transparency
Objectivity
Impartiality
Fairness

Comments

Since the last assessment, the College of Psychologists of Ontario (CPO) has taken measures to ensure transparent, impartial and fair registration practices. However, there are still a number of areas where the CPO should implement further measures for improvement. See the Recommendations section below for details.

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Commendable Practices

A commendable practice is a program, activity or strategy that goes beyond the minimum standards set by the OFC assessment guides, considering the regulatory body’s resources and profession-specific context. Commendable practices may or may not have potential for transferability to another regulatory body.

The CPO is demonstrating commendable practices in the following area(s).

Documentation of Qualifications

• clarifying in the Registration Guidelinesthe options for submitting academic transcripts that are from institutions outside of Canada or the USA and/or that are written in languages other than English or French
• clarifying in the Registration Guidelines that the requirement for fluency in English or French is documented by passing each required examination within a standard time period

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Recommendations

The CPO should improve in the following areas:

Information for Applicants	Status
Review registration information on the website to ensure that it is in plain language, and that steps in the registration process are clear.†	February 2016
Documentation of Qualifications
Provide more detail about the form in which documentation of qualifications for each registration requirement must be submitted.	September 2014
Assessment of Qualifications
Develop criteria for the evaluation of “good character.”	May 2015
Provide more specific information about the objective criteria that are used for evaluating knowledge requirements for an intended practice area. Criteria should be directly linked to the core competencies required to practice the profession.†
Once the college has identified core competencies and developed objective criteria for assessing them, review all assessment methods to ensure they are objective, valid and reliable.†
Once the college has identified core competencies and developed objective criteria for assessing them, inform applicants about these criteria.†
Provide evidence that it reviews its assessment methods for objectivity, validity and reliability.	May 2015
Transparency
Once the college develops criteria for evaluating “good character,” clearly communicate this to applicants.	May 2015
Include information in the Registration Guidelines about how long applicant records are kept by the college, and what, if any, limitations exist on returning records to applicants.†	September 2014
Impartiality
Evaluate the rigour of the training it provides to decision-makers in identifying conflict of interest and bias to determine whether it is effective. This applies to training related to both assessment of qualifications and ultimate registration decisions.	December 2014
Implement measures to guard against decision-makers over- or under-valuing certain groups of applicants. This is particularly important when assessing applicants educated in international jurisdictions.
Fairness
Continue to identify core competencies in order to ensure that registration requirements and the corresponding assessment criteria are based on those competencies as opposed to being based on the completion of a North American degree.†	May 2015
Allow applicants to augment/upgrade their education so that it is equivalent to a degree that is acceptable to the college.†	April 2015
Review the necessity and relevance of its Ontario-based supervised practice requirement: Identify the competencies underlying the requirement for supervised practice in Ontario. Explore acceptable alternatives for applicants to demonstrate or develop these competencies. Implement alternatives or clearly justify why Ontario-based supervised practice is necessary and relevant to the practice of the profession.
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 college or that has requirements substantially equivalent/similar to those of the college.†	March 2014
† Recommendations marked with a dagger symbol have been carried forward all or in part from the previous assessment.

Assessment History

In the previous assessment, the OFC identified 24 recommendations for this regulatory body.

Sixteen of those recommendations have been implemented. Eight are carried forward in this report.