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Professions and Trades

Registration Practices Assessment Report 2014- Chiropodists


In February 2014, Ontario’s Office of the Fairness Commissioner (OFC) performed a targeted assessment of the way the College of Chiropodists of Ontario (COCOO) 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.


Focus of This Assessment and Report

The February 2014 targeted assessment of the COCOO focused on the areas where the OFC made recommendations in the full assessment it completed in February 2012.

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


Availability of Report

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

To receive a copy of the detailed report, click here.


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.


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 February 2012, the COCOO has been assessed in the area(s) marked below:

Information for Applicants Checked
Internal "Review"Unchecked
Information on Appeal RightsUnchecked
Documentation of QualificationsChecked
Assessment of QualificationsChecked
Access to RecordsUnchecked


The COCOO has demonstrated all of the practices in the following specific-duty area(s):

  • Documentation of Qualifications

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


General Duty

Assessment Method

The COCOO 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 guideChecked
b.Regulatory body self-assesses based on the practices in the assessment guideUnchecked
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 principlesUnchecked

Principles assessed

As a result of the recommendations made in the full assessment completed in February 2012, the COCOO has been assessed on the principle(s) marked below:

Fairness Unchecked


The OFC found that since the last assessment, the College of Chiropodists of Ontario (COCOO) has taken measures to ensure a transparent registration process. The OFC identified one area where the COCOO needs to take further steps to ensure transparency (see the Recommendations section below).


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

Assessment of Qualifications

  • Streamlining the COCOO’s registration examination. Previously, this examination consisted of three parts:
    • written examination component
    • clinical examination component
    • the Objective Structural Clinical Evaluation (OSCE)
  • In 2012, the COCOO’s council decided to discontinue the clinical examination component and to continue instead with only the written part and the OSCE. This change provides for a more streamlined and valid registration examination process (that is, assessment criteria are more closely linked to the registration requirements and better measure what they intend to measure).


  • Updating the website to expand the COCOO’s information resources for applicants. Changes include the following:
    • making available the Profile of Competencies document
    • identifying variables that may slow down the normal registration process
    • publishing a list of approved postsecondary programs
    • distinctly identifying all requirements that are subject to exemptions
  • These new and improved resources provide clearer and more current information about the registration requirements.
  • In the application package for each applicant, including the COCOO’s current and proposed registration regulation, to ensure that applicants are aware of the upcoming change to the regulation and understand its implications for the registration process.



The COCOO should improve in the following areas:

Information for Applicants

  • Inform applicants about what actions they need to take to meet the language proficiency requirement. (Practice 1.1)
July 2015
  • Develop a formal process for periodically reviewing registration information for accuracy and completeness. (Practice 1.1) †
July 2015

Assessment of Qualifications

  • Develop and introduce a formal process for applicants to appeal the results of the registration examination and/or the way the examination was administered. (Practice 5.7)
July 2015
  • Inform applicants about that process by including relevant information on the COCOO’s website. (Practice 5.8d)
July 2015


  • Develop a more formal approach for recording, reviewing and updating registration policies and procedures for the following:
    • assessing whether an applicant’s conduct meets the COCOO’s registration requirements
    • considering an applicant’s request for special accommodations
  • This approach may involve developing a work plan that includes clearly defined objectives, timelines, and actions to be taken to ensure better recording of the registration procedures.
July 2015

† Recommendations marked with a dagger symbol have been carried forward all or in part from the previous assessment.

July 2015
Blank = Implementation is in progress.
Checked = Recommendation is implemented.
Acceptable alternative = Regulator implements acceptable alternative to this recommendation.

Assessment History

In the previous assessment​, the OFC identified 12 recommendations for this regulatory body.

Eleven of those recommendations have been implemented, and one has been carried forward into this report.

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