Introduction

Assessment is one of the Fairness Commissioner's mandated roles under the Fair Access to Regulated Professions and Compulsory Trades Act, 2006 (FARPACTA) and the Regulated Health Professions Act, 1991 (RHPA) – collectively known as fair access legislation.

Assessment Cycle

One of the primary ways the OFC holds regulators accountable for continuous improvement is through the assessment of registration practices using a three-year assessment cycle.

Assessment cycles alternate between full assessments and targeted assessments:

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

Focus of this Assessment and Report

The 2016-2018 assessment of the Chartered Professional Accountants of Ontario (CPA Ontario) is a full assessment.

The OFC’s detailed report captures the results of the full assessment. However, practices related to provision of information are excluded for regulators who have previously been assessed. For those regulators, these practices have been removed from the report.^[1] 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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Assessment Summary

Specific Duties

Specific duties assessed

The regulator has been assessed in all of the specific duties.

Comments

In May 2017, Ontario’s three accounting organizations, the Certified General Accountants of Ontario (CGA Ontario), Certified Management Accountants of Ontario (CMA Ontario) and the Institute of Chartered Accountants of Ontario (ICAO), completed their unification under the Chartered Professional Accountants of Ontario (CPA Ontario). Since its unification, CPA Ontario has been building its organizational competencies and working to enhance its processes. In this assessment, the OFC found that CPA Ontario shows a strong commitment towards developing and implementing fair registration practices. In particular, CPA Ontario has demonstrated all of the practices in the following specific-duty areas:

• Information for Applicants
• Timely Decisions, Responses and Reasons
• Documentation of Qualifications
• Assessment of Qualifications
• Access to Records

The OFC has identified four areas where the regulator needs to take further actions to meet their specific-duties obligations.

General Duty

Assessment method

The regulator selected the following method for the assessment of the general duty:

a.	OFC practice-based assessment (following the practices in the Assessment Guide)
b.	Regulator practice-based self-assessment (following the practices in the Assessment Guide)
c.	Regulator systems-based self-assessment (in which it explains systemically and holistically how it meets the general duty)

Principles assessed

The regulator has been assessed on all of the general duty principles: transparency, objectivity, impartiality and fairness.

Comments

CPA Ontario implements practical and logical measures to achieve transparent, objective, impartial and fair registration practices. In this assessment, however, the OFC has identified three areas related to transparency and impartiality, where further improvements are needed.

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 regulatory body is demonstrating commendable practices in the following areas:

Specific Duty

Information for Applicants

1. Soliciting regular feedback from web users through surveys, frequently asked questions and social media to enhance website content and ease of navigation. Additionally, tracking and monitoring user experiences and website performance on a quarterly basis for continuous improvement.

Timely Responses, Decisions and Reasons

1. Process mapping all internal reviews and appeals from registration decisions and benchmarking timelines against other regulators to further decrease response times for review and appeal decisions.

Training

1. Developing a CPA-specific training module on the Fair Access to the Regulated Professions and Compulsory Trades Act (FARPACTA) for staff and committee members involved in the registration process. The training module includes content on how the obligations under the legislation apply to CPA Ontario and provides opportunities for participants to practice what they have learned through interactive activities. The training module will help CPA Ontario staff and committee members to develop a better understanding of their legislative obligations and to identify practices that may impede applicants’ access to the profession.

General Duty

Transparency

1. Implementing a new telephone system with enhanced navigation and tools for tracking and reporting on requests and feedback received from students, applicants and members. The new system provides students, applicants and members with more efficient and effective responses to their specific needs.
2. Delivering pre-arrival webinars for internationally trained professionals that provide information on the certification program, registration requirements, and career opportunities for CPAs in Ontario. Webinars also include a checklist of pre-arrival documents that help internationally trained professionals to better prepare their applications before arrival to Canada.
3. Collaborating with Global Experience Ontario (GEO), Ministry of Training, Colleges and Universities, to deliver webinars for internationally trained accountants and finance professionals. Webinar content includes registration requirements and process, steps to take before arrival in Ontario, and a live question and answer session.

Fairness

1. Conducting a needs assessment for an organization-wide customer relationship management (CRM) system that will streamline key processes and improve experiences of students, applicants and members.
2. Engaging in activities that promote diversity and inclusion, such as partnering with post-secondary institutions, immigrant-serving agencies and employers to relay information to prospective students on the various pathways to registration and opportunities offered by the CPA designation. In 2017, these efforts also included collaborating with 72 immigrant-serving agencies in Ontario and 11 agencies abroad that deliver pre- and post-arrival employment services to newcomers, and hosting a Diversity Day that provided internationally trained professionals with networking opportunities and targeted supports.
3. Initiating a networking group of regulatory bodies from various industries in Ontario that promotes fair and consistent accommodations for applicants with special needs and provides opportunities to share best practices.
4. Working in conjunction with the World Education Services (WES) Alternative Credential Assessment pilot project to develop a formal and structured process for handling alternative credential assessment requests from Syrian refugees.
5. Providing targeted supports to individuals working full-time and meeting requirements for registration on a part-time basis. For example, launching a new pilot project to provide these individuals with more time to complete CPA PEP modules.
6. Undertaking initiatives that provide CPA PEP students with alternative options and increased flexibility to complete registration requirements. Initiatives include a fast-track program that allows eligible students to complete the two required modules concurrently and in less time, and a live webinar option for preparatory courses that enables students with other commitments and those in remote locations the chance to participate in these required activities.

Recommendations

The regulator can improve in the following areas:

Specific Duty

Internal Review or Appeal

1. Develop a dedicated webpage on the internal appeals process for applicants and other interested stakeholders that includes content on:
   • Applicants’ rights to appeal registration decisions;
   • Applicants’ rights to make submissions;
   • The format in which applicants must make their submissions; and
   • The steps and sequence, if applicable, that an applicant needs to follow to complete the appeals process. (Practice 3.3)
2. As part of a dedicated webpage on the internal appeals process, include content on any limits or conditions to internal appeals. (Practice 3.4)

Information on Appeal Rights

1. Explain that while the Membership Committee’s decision is final, applicants have the right to a jurisdictional review of appeal decisions through Ontario’s Divisional Court as part of web content on the internal appeals process. (Practice 4.1)

Training

1. Continue to develop and implement training opportunities for all staff and committee members involved in assessment and registration decisions that address the following topics:
   • Anti-discrimination;
   • Cultural diversity;
   • Objectives of fair-access law; and
   • Objective and impartial decision-making and what it means in the context of the registration process. (Practice 7.2)

General Duty

Transparency

1. Take further measures to enable interested stakeholders to understand how the registration process operates. Actions should include:
   • Publishing information on the structure of accountability for registration functions, including information on committees and positions responsible for registration policy- and decision-making; and
   • Providing more opportunities for interested stakeholders to be informed about how the registration process operates and how registration policy decisions are made.
2. Implement procedures to actively engage interested stakeholders and elicit ongoing feedback on substantive registration changes throughout the decision-making process.

Impartiality

1. Develop and implement proactive measures to identify and address factors that may improperly influence registration practices or decisions that may result from CPA Ontario engaging in potentially conflicting functions.

Assessment History

CPA Ontario was unified after the OFC’s second assessment cycle. This is therefore the first assessment of the registration practices for the regulator.

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Detailed Report^[2]

Specific Duty

1. Specific Duty — Information for Applicants

FARPACTA s. 7

1. The regulator describes requirements for registration on its website. [Transparency]

Assessment Outcome

Demonstrated

2. The regulator describes all the steps in the registration process on its website, including any processes for assessing qualifications. [Transparency]

Assessment Outcome

Demonstrated

3. The regulator provides information on its website about how long the registration process usually takes, including the time required for assessing qualifications. [Transparency]

Assessment Outcome

Demonstrated

4. The regulator publishes a fee scale on its website, showing all registration fees that are under the regulator's control, including the fees required for assessing qualifications. [Transparency]

Assessment Outcome

Demonstrated

5. The regulator ensures that the information required by practices 1-4 in this section is clear, accurate, complete and easy to find. [Transparency]

Assessment Outcome

Demonstrated

Commendable practice

Soliciting regular feedback from web users through surveys, frequently asked questions and social media to enhance website content and ease of navigation. Additionally, tracking and monitoring user experiences and website performance on a quarterly basis for continuous improvement.

2. Specific Duty — Timely Decisions, Responses and Reasons

FARPACTA, s. 8 and s. 9 (1)

1. If a regulator rejects an application, it gives written reasons to the applicant. [Fairness, Transparency]

Assessment Outcome

Demonstrated

2. The regulator makes registration decisions, and gives written decisions and reasons to applicants, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

3. The regulator responds to applicants’ inquiries or requests without undue delay. [Fairness]

Assessment Outcome

Demonstrated

4. The regulator provides internal reviews of decisions, or appeals from decisions, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

5. The regulator makes decisions about internal reviews and appeals, and gives written decisions and reasons to applicants, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

Commendable Practice

Process mapping all internal reviews and appeals from registration decisions and benchmarking timelines against other regulators to further decrease response times for review and appeal decisions.

3. Specific Duty — Internal Review or Appeal

FARPACTA, s. 7, s. 9 (2-3, 5)

1. The regulator provides applicants with an internal review of, or appeal from, registration decisions. [Fairness]

Assessment Outcome

Demonstrated

2. The regulator implements rules and procedures that prevent anyone who acted as a decision-maker in a registration decision from acting as a decision-maker in an internal review or appeal of that same registration decision. [Impartiality]

Assessment Outcome

Demonstrated

3. The regulator provides information on its website that informs applicants about opportunities for an internal review or appeal. [Transparency]

Assessment Outcome

Partially Demonstrated

OFC Comments

Although information on the appeals process is available on the CPA Ontario website, the OFC finds that it is not readily accessible or presented in a way that makes it easy for applicants or other interested stakeholders to understand.

CPA Ontario informed the OFC that it plans to create a dedicated webpage for the internal appeals process that will improve the ease of access to this information and provide further transparency. This web content is expected to be available in the coming year and will be periodically reviewed. CPA Ontario will also develop guidelines for staff members that handle applicant inquiries on the appeals process alongside the dedicated webpage. The OFC supports these commitments.

Recommendations

Develop a dedicated webpage on the internal appeals process for applicants and other interested stakeholders that includes content on:

• Applicants’ rights to appeal registration decisions;
• Applicants’ rights to make submissions;
• The format in which applicants must make their submissions; and
• The steps and sequence, if applicable, that an applicant needs to follow to complete the appeals process.

4. The regulator provides information on its website about any limits or conditions on an internal review or appeal*. [Transparency]

Assessment Outcome

Partially Demonstrated

OFC Comments

CPA Ontario’s Member’s Handbook informs applicants that they have the right to appeal a decision of the Registrar to the Membership Committee if they have been denied membership or if they have been admitted for membership subject to restrictions or conditions. This information on limits or conditions on an internal appeal, however, is not included on CPA Ontario’s website.

CPA Ontario informed the OFC that it plans to create a dedicated webpage for the internal appeals process. The OFC recommends that information about limits or conditions on an internal appeal be added to this webpage.

Recommendations

As part of a dedicated webpage on the internal appeals process, include content on any limits or conditions to internal appeals.

4. Specific Duty — Information on Appeal Rights

FARPACTA, s. 9 (4)

1. On its website, the regulator informs applicants of their right to request further review of, or appeal from, the review or appeal decision. [Transparency]

Assessment Outcome

Not Demonstrated

OFC Comments

The Member’s Handbook notifies applicants that any appeal decision made by the Membership Committee is final. Even so, CPA Ontario informed the OFC that an applicant, who is unsuccessful in their appeal to the Membership Committee, can seek a jurisdictional review of the appeal decision through Ontario’s Divisional Court. This information on an applicant’s right to an external review and any limitations to those rights, however, was not found on CPA Ontario’s website.

The OFC understands that CPA Ontario plans to inform applicants of their right to seek judicial review of appeal decisions as part of web content on the internal appeals process. CPA Ontario also stated that they will review communications with potential appellants for clarity, use of plain language, and ease of navigation. The OFC supports these commitments.

Recommendations

Explain that while the Membership Committee’s decision is final, applicants have the right to a jurisdictional review of appeal decisions through Ontario’s Divisional Court as part of web content on the internal appeals process.

5. Specific Duty — Documentation of Qualifications

FARPACTA, s. 10 (1)

1. The regulator provides information on its website about the documents that must accompany an application to demonstrate qualifications. [Transparency]

Assessment Outcome

Demonstrated

6. Specific Duty — Assessment of Qualifications

FARPACTA, s. 10 (2)

1. On its website, the regulator informs applicants about the process, criteria, and policies for the assessment of qualifications. [Transparency]

Assessment Outcome

Demonstrated

2. The regulator communicates the results of qualifications assessment to each applicant in writing. [Transparency]

Assessment Outcome

Demonstrated

3. The regulator gives its assessors access to assessment criteria, policies and procedures. [Transparency]

Assessment Outcome

Demonstrated

4. The regulator shows that its tests and exams measure what they intend to measure*. [Objectivity]

Assessment Outcome

Not Applicable

OFC Comments

CPA Ontario does not develop and administer its own examinations.

5. The regulator states its assessment criteria in ways that enable assessors to interpret them consistently. [Objectivity]

Assessment Outcome

Demonstrated

6. The regulator ensures that the information about educational programs that is used to develop or update assessment criteria is kept current and accurate. [Objectivity]

Assessment Outcome

Demonstrated

7. The regulator links its assessment methods to the requirements/standards for entry to the profession or trade. [Objectivity]

Assessment Outcome

Demonstrated

8. The regulator requires that assessors consistently apply qualifications assessment criteria, policies and procedures to all applicants. [Objectivity]

Assessment Outcome

Demonstrated

9. The regulator uses only qualified assessors to conduct the assessments. [Objectivity]

Assessment Outcome

Demonstrated

10. The regulator monitors the consistency and accuracy of decisions, and takes corrective actions as necessary, to safeguard the objectivity of its assessment decisions. [Objectivity]

Assessment Outcome

Demonstrated

11. The regulator prohibits discrimination and informs assessors about the need to avoid bias in the assessment. [Impartiality]

Assessment Outcome

Demonstrated

12. The regulator implements procedures to safeguard the impartiality of its assessment methods and procedures. [Impartiality]

Assessment Outcome

Demonstrated

13. The regulator gives applicants an opportunity to appeal the results of a qualifications assessment or to have the results reviewed. [Fairness]

Assessment Outcome

Demonstrated

14. The regulator assesses qualifications, communicates results to applicants, and provides written reasons for unsuccessful applicants, without undue delay. [Fairness]

Assessment Outcome

Demonstrated

15. Regulators that rely on third-party assessments establish policies and procedures to hold third-party assessors accountable for ensuring that assessments are transparent, objective, impartial and fair. [Transparency, Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

7. Specific Duty — Training

FARPACTA, s. 11

1. The regulator provides training for staff and volunteers who assess qualifications or make registration, internal review or appeal decisions. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

2. The regulator addresses topics of objectivity and impartiality in the training it provides to assessors and decision-makers. [Objectivity, Impartiality]

Assessment Outcome

Partially Demonstrated

OFC Comments

CPA Ontario informed the OFC that it provides training on diversity and inclusion in the regulatory environment to staff members responsible for processing applications from internationally trained accountants. Training on fair-access legislation is also given to staff members responsible for transcript assessments and student registration. All staff members are additionally provided mandatory training on the Accessibility for Ontarians with Disabilities Act (AODA) as part of their orientation.

The OFC found, however, that the training described was not altogether provided to committee members involved in the registration process. The OFC noted as well that training for staff and committee members did not address the topic of anti-discrimination.

The OFC understands that in the coming year CPA Ontario will roll out an online training module that they have developed on FARPACTA to registration staff and committee members. CPA Ontario plans to provide this training in conjunction with the OFC’s learning modules on fair-access legislation. The OFC supports this commitment.

Recommendations

Continue to develop and implement training opportunities for all staff and committee members involved in assessment and registration decisions that address the following topics:

• Anti-discrimination;
• Cultural diversity;
• Objectives of fair-access law; and
• Objective and impartial decision-making and what it means in the context of the registration process.

Commendable practice

Developing a CPA-specific training module on the Fair Access to the Regulated Professions and Compulsory Trades Act (FARPACTA) for staff and committee members involved in the registration process. The training module includes content on how the obligations under the legislation apply to CPA Ontario and provides opportunities for participants to practice what they have learned through interactive activities. The training module will help CPA Ontario staff and committee members to develop a better understanding of their legislative obligations and to identify practices that may impede applicants’ access to the profession.

3. The regulator identifies when new and incumbent staff and volunteers require training and provides the training accordingly. [Objectivity, Impartiality, Fairness]

Assessment Outcome

Demonstrated

8. Specific Duty — Access to Records

FARPACTA, s. 12

1. The regulator provides each applicant with access to his or her application records. [Fairness]

Assessment Outcome

Demonstrated

2. If there is a fee for making records available, the regulator gives applicants an estimate of this fee. [Transparency]

Assessment Outcome

Demonstrated

3. If there is a fee for making records available, the regulator review the fee to ensure that it does not exceed the amount of reasonable cost recovery. [Fairness]

Assessment Outcome

Demonstrated

General Duty

FARPACTA, Part II, s.6

Transparency

• Maintaining openness
• Providing access to, monitoring, and updating registration information
• Communicating clearly with applicants about their status

Assessment Outcome

CPA Ontario takes a number of effective measures to achieve transparent registration practices. To take these efforts even further, the OFC identified two recommendations and one suggestion for continuous improvement. Three commendable practices have also been identified.

Openness

CPA Ontario takes various actions to enable interested stakeholders to understand how the registration process operates and how registration decisions are made. Key highlights include:

• Conducting an organization-wide review of governing documents to ensure use of plain language and that documents are up to date;
• Consolidating information on CPA Ontario’s regulations, policies and procedures into a single guide for students and applicants applying for a transcript assessment; and
• Delivering a range of supports to prospective students and applicants, such as individual and group information sessions, webinars with interactive question and answer sessions, and networking events with CPA professionals.

CPA Ontario also surveys students at select points in the registration process, such as at the completion of preparatory courses and CPA PEP modules. Most recently, CPA Ontario launched the Student Experience Survey to gather feedback from students on their registration experiences. The OFC understands that CPA Ontario has further plans to insert experience surveys into their communications with students to gather real-time feedback and to make registration process improvements, where needed. The OFC supports these efforts.

In addition to the actions described above, the OFC was looking for evidence to show how CPA Ontario:

• Publishes information about the structure of accountability for registration functions (i.e. information that identifies positions and committees responsible for registration policies and decision-making);
• Seeks input from interested parties when proposals are made to amend registration regulations or bylaws and/or registration requirements; and
• Provides sufficient opportunities for interested stakeholders to be informed of key developments in registration practices and/or how the registration process operates.

The OFC found that CPA Ontario’s website provides a list of its Council members and identifies those that have been publicly appointed. However, the website does not specify positions responsible for registration functions and how the Council and committees operate and make their decisions. The OFC also did not find details indicating whether committees responsible for registration policy- and decision-making included public representation. CPA Ontario informed the OFC that they will extend the web content to clearly identify the positions and committees responsible for registration functions in the coming year. The OFC supports this commitment and recommends that CPA Ontario complete these actions (see Recommendations section below).

CPA Ontario explained that they use several means to add public input into decisions about substantive registration changes, such as through public representatives on registration decision- and policy-making committees and collecting feedback from front-line staff that work with internationally trained accountants. Though these measures are important, transparency requires a formal and structured process to solicit ongoing input from interested stakeholders during the development of substantive registration rules and bylaws. The OFC did not find sufficient evidence of these actions.

It is the position of the OFC that public access to Council and/or committee meetings is the most effective way to provide sufficient opportunities for interested stakeholders to be informed of key developments and decisions about registration practices. Currently, CPA Ontario Council’s meetings are not open to the public and decisions made at those meetings are not published. The OFC recommends that CPA Ontario take steps to facilitate further transparency, such as providing public access to Council / committee meetings and/or publishing meeting materials on their website, to enable those interested to understand how CPA Ontario makes its registration policy decisions and to observe how the regulator acts in the public interest.

Access

CPA Ontario takes proactive measures to ensure that students and applicants have access to the relevant information they need to take the appropriate steps in the registration process. For example, CPA Ontario provides web content on:

• Registration requirements subject to exemptions and the steps a student or applicant needs to take to request an exemption;
• Steps internationally trained professionals can take to pursue registration before arrival in Canada; and
• Resources and supports that are available to students and applicants, including those specifically designed for internationally trained professionals.

CPA Ontario has also recently developed a new web infrastructure and updated web content for improved navigation, readability and accessibility on mobile devices. Feedback from student surveys that highlighted issues in navigating the website was also taken into consideration when implementing changes, updates and adjustments to CPA Ontario’s web content and design. Additionally, CPA Ontario has formal processes to regularly review web content for accuracy, relevance and consistent use of plain language.

Clarity

CPA Ontario takes effective measures to communicate with students and applicants throughout the registration process and to ensure that the information provided is complete, accurate and easy to understand. For instance, CPA Ontario:

• Regularly reviews its communications for use of plain language and clarity; and
• Promptly informs students and applicants about any potential delays and actions that can be taken to avoid delays in the process.

Recommendations

Take further measures to enable interested stakeholders to understand how the registration process operates. Actions should include:

• Publishing information on the structure of accountability for registration functions, including information on committees and positions responsible for registration policy- and decision-making; and
• Providing more opportunities for interested stakeholders to be informed about how the registration process operates and how registration policy decisions are made.

Implement procedures to actively engage interested stakeholders and elicit ongoing feedback on substantive registration changes throughout the decision-making process.

Suggestions for continuous improvement

Implement procedures to seek input from the OFC when developing and revising key registration policies and requirements.

Commendable practices

Implementing a new telephone system with enhanced navigation and tools for tracking and reporting on requests and feedback received from students, applicants and members. The new system provides students, applicants and members with more efficient and effective responses to their specific needs.

Delivering pre-arrival webinars for internationally trained professionals that provide information on the certification program, registration requirements, and career opportunities for CPAs in Ontario. The webinar also includes a checklist of pre-arrival documents that an internationally trained professional can prepare to support their application before their arrival to Canada.

Collaborating with Global Experience Ontario (GEO), Ministry of Training, Colleges and Universities, to deliver webinars for internationally trained accountants and finance professionals. Webinar content includes registration requirements and process, steps to take before arrival in Ontario, and a live question and answer session.

Objectivity

• Designing criteria and procedures that are reliable and valid
• Monitoring and following up threats to validity and reliability

Assessment Outcome

CPA Ontario takes several effective measures to achieve objectivity in its registration process.

Reliability

To ensure that registration decisions are reliable, CPA Ontario:

• Provides its decision-makers with access to relevant regulations, policies and procedures;
• Promptly informs decision-makers about changes to criteria, policies and procedures through various means that include team meetings, internal staff communications and teleconferences;
• Requires that decision-makers use documented guidelines and a range of tools to arrive at registration decisions;
• Uses peer reviews and group discussions to reach consensus in decision-making for high-risk assessments and in exceptional circumstances; and
• Takes previous assessment decisions and reasons into consideration, where appropriate, in the decision-making process.

Validity

CPA Ontario takes the following steps to ensure validity of its decisions:

• Performs regular audits of assessment and registration decisions;
• Escalates application files to management in cases where inconsistencies are identified by quality control checks;
• Facilitates mentoring opportunities between experienced and lesser experienced assessors;
• Monitors assessment and registration outcomes using an analysis tracking system; and
• Reviews requests and outcomes of appeals with staff members involved in the assessment and registration processes.

Impartiality

• Identifying bias, monitoring, and taking corrective action
• Implementing strategies

Assessment Outcome

CPA Ontario implements reasonable measures to achieve impartiality in its registration decisions. To further these efforts, the OFC has identified one recommendation and one suggestion for continuous improvement below.

Identification of Bias

CPA Ontario takes steps to help its decision-makers identify sources of potential bias in the registration process. Examples of these measures include:

• Implementing a code of conduct for staff and a conflict of interest and confidentiality policy for Council and committee members;
• Equipping staff and committee members with guidelines to avoid and mitigate situations of bias in assessment and registration decisions;
• Providing staff and committee members with regular training activities that increase their understanding of issues related to bias, diversity, inclusivity and fair-access in the context of the registration process; and
• Requiring new staff to complete a series of mandatory compliance courses as part of their orientation, including content on providing supports to individuals requiring special accommodations.

In addition to the actions described above, the OFC was seeking evidence to demonstrate how CPA Ontario ensures that decisions are made in the public interest and are not compromised by internal or external interests and/or competing functions. To achieve this, CPA Ontario informed the OFC that they implement the following measures:

• Require the Governance and Nominating Committee to review recommendations for changes to governing documents before they are presented to the Council;
• Include one publicly appointed member on the Governance and Nominating Committee and as part of a quorum; and
• Implement a conflict of interest policy and guidelines on avoiding or minimizing bias that require staff and committee members, when making policy decisions, to:
  • consider internal and external factors that may improperly influence policy;
  • consider why a policy change is in the public interest and/or what particular issue it intends to resolve; and
  • explore what positive and/or negative impacts the policy change may have on those affected by it and whether these impacts will be felt consistently or single out particular people.

While CPA Ontario’s guidelines on avoiding or minimizing bias require decision-makers to take into consideration the factors described above, they do not specify or explain how to apply them in practice. In the absence of clear guidance on how to implement these factors, it may be difficult for decision-makers to critically assess the conditions in which they operate and to ensure that those conditions do not improperly influence the decision-making process (see Suggestions for Continuous Improvement section below).

Furthermore, CPA Ontario has three functions. It acts as an educational institution, as a regulator, and as an advocate for the profession. Potentially, these three distinct activities might create pressures and improperly influence registration practices or decisions. It is unclear from the information provided how CPA Ontario addresses such potential conflicts. It is important for CPA Ontario to recognize that such potential conflicts exist and to mitigate them with appropriate actions (see Recommendations section below).

Strategies

CPA Ontario uses the following strategies to avoid and mitigate situations of bias in its decision-making:

• Basing assessment and registration decisions on documented regulations, policies and procedures;
• Obtaining various levels of approval from senior management before decisions are finalized by the Registrar;
• Conducting peer- and blind reviews as well as group discussions on unusual files to arrive at some assessment and registration decisions; and
• Committing staff members to values and behaviours that are based on integrity, inclusivity and include anti-discriminatory practices.

CPA Ontario informed the OFC that they will be introducing a whistleblower policy in the coming months that will require staff to report certain incidents, such as violations of the code of conduct and discrimination, to further their commitment to impartial registration practices. The OFC supports this commitment.

Recommendations

Develop and implement proactive measures to identify and address factors that may improperly influence registration practices or decisions that may result from CPA Ontario engaging in potentially conflicting functions.

Suggestions for continuous improvement

Provide staff and committee members with specific guidance on how to apply considerations related to factors that may improperly influence decisions in practice and how to embed public interest considerations into the decision-making process.

Fairness

• Ensuring substantive fairness
• Ensuring procedural fairness
• Ensuring relational fairness

Assessment Outcome

CPA Ontario takes a number of significant measures to promote fairness in its registration practices. Six commendable practices have been identified below.

Substantive Fairness

CPA Ontario takes the following actions to promote substantive fairness:

• Describes the enabling and technical competencies and proficiency levels required for each element of the certification program;
• Conducts reviews of its required competencies and proficiency levels to verify that they continue to align with current entry-to-practice standards for the profession; and
• Offers a range of alternatives pathways for meeting the requirements of the CPA designation.

Procedural Fairness

CPA Ontario takes a number of steps to support procedural fairness in its registration practices, such as:

• Performing internal audits of assessment and registration decisions to verify that they comply with established criteria, policies and procedures, and to identify and implement corrective actions, where needed;
• Monitoring procedures and analyzing statistics to identify trends and/or variances that would indicate the potential for excluding certain groups of applicants from the registration process;
• Reviewing its registration practices to identify opportunities for improvements and streamlining. Examples include removing the residency requirement, expanding the range of accepted experience to satisfy the practical experience requirement, and providing an alternative option for meeting the Canadian business law entry requirement for the CPA PEP;
• Engaging in a series of information sessions, webinars and special events, some of which are specifically tailored to internationally trained professionals, with the aim to enhance the diversity of its membership; and
• Enabling applicants to complete all steps of the registration process from outside of Canada.

Relational Fairness

CPA Ontario takes several measures to ensure relational fairness for its students and applicants during the registration process. These actions include:

• Allowing applicants’ requests for special accommodations at the various stages of the registration process; and
• Considering alternative documentation and providing accommodations to applicants in cases where required documentation cannot be obtained for reasons beyond their control.

On a final note, the OFC recognizes that CPA Canada is continuing to renegotiate many of the Mutual Recognition Agreements, Reciprocal Membership Agreements and Memoranda of Understanding currently in place with international accounting bodies. CPA Ontario explained to the OFC that it supports the continuity of these agreements, both to facilitate the international mobility of accounting professionals and to protect the public interest. The OFC encourages CPA Ontario to continue to exert its positive influence on CPA Canada to safeguard the pathways to registration that are currently available under these existing agreements. However, if in the future any of these agreements are discontinued, the OFC recommends that CPA Ontario provide alternative pathways to ensure that individuals seeking registration are not adversely affected.

Commendable Practice

Conducting a needs assessment for an organization-wide customer relationship management (CRM) system that will streamline key processes and improve experiences of students, applicants and members.

Engaging in activities that support diversity and inclusion in its members, such as partnering with post-secondary institutions, immigrant-serving agencies and employers to relay information to prospective students on the various pathways to registration and opportunities offered by the CPA designation. In 2017, these efforts also included collaborating with 72 immigrant-serving agencies in Ontario and 11 agencies abroad that deliver pre- and post-arrival employment services to newcomers, and hosting a Diversity Day that provided internationally trained professionals with networking opportunities and targeted supports.

Initiating a networking group of regulatory bodies from various industries in Ontario that promotes fair and consistent accommodations for applicants with special needs and provides opportunities to share best practices.

Working in conjunction with the World Education Services (WES) Alternative Credential Assessment pilot project to develop a formal and structured process for handling alternative credential assessment requests from Syrian refugees.

Providing targeted supports to individuals working full-time and meeting requirements for registration on a part-time basis. For example, launching a new pilot project to provide these individuals with more time to complete CPA PEP modules.

Undertaking initiatives that provide CPA PEP students with alternative options and increased flexibility to complete registration requirements. Initiatives include a fast-track program that allows eligible students to complete the two required modules concurrently and in less time, and a live webinar option for preparatory courses that enables students with other commitments and those in remote locations the chance to participate in these required activities.

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Background

Assessment Methods

Assessments are based on the Registration Practices Assessment Guide: For Regulated Professions and Health Regulatory Colleges. The guide presents registration practices relating to the specific duties and general duty in the fair access legislation.

A regulatory body’s practices can be measured against the fair access legislation’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 the College’s registration practices

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 OFC's website.

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 Impr​ovement.

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References

1. ^ These includes: all practices from Information for Applicants, practice 3 from Internal Review and Appeals, practice 1 from Information on Appeal Rights, practice 1 from Documentation of Qualifications, practice 1 from Assessment of Qualifications, practice 2 from Access to Records, and practices 4-11 from Transparency of the Registration Practices Assessment Guide.
2. ^ Please note: Suggestions for continuous improvement appear only in the detailed report. Suggestions for improvement are not intended to be recommendations for action to demonstrate a practice, but are made solely to provide suggestions for areas that a regulatory body may consider improving in the future.