Introduction

This report contains an assessment of registration practices of the College of Registered Psychotherapists of Ontario.

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.

As this is the first assessment of the College’s registration practices, all of its registration practices are under review.

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Assessment Summary

The Office found the College in compliance with the OFC’s fair registration practice standards, and has not made any recommendations in this assessment cycle.

Specific Duties

Specific duties assessed

The regulator has been assessed on all of the specific duties identified in Schedule 2 of the Regulated Health Professions Act.

Comments

The regulatory body has demonstrated compliance with all of the practices in the following specific-duty areas:

• Information for Applicants
• Timely Decisions, Responses and Reasons
• Internal Review or Appeal
• Information on Appeal Rights
• Documentation
• Assessment of Qualifications
• Training
• Access to Records

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 demonstrated compliance with all of the general duty principles: transparency, objectivity, impartiality and fairness.

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

None

General Duty

Transparency

1. The Registration Examination Resource Manual is a useful resource for applicants in preparing for the registration examination.

Objectivity

1. Registration staff confer with one another on a regular basis, as well as in meetings of the full registration team, to discuss cases and questions that occur on a repeated basis. When policy decisions or precedents are established, staff receive notice of this as soon as possible.

Fairness

1. The College is developing policies and procedures for the Indigenous Registration Pathway, proposed by College Council in 2015. The intent of the pathway is to support the registration of appropriately qualified Indigenous practitioners of psychotherapy through consultation and collaboration with Indigenous (First Nations, Inuit and Métis) communities.

Opportunities for Improvement

The OFC has not identified substantive opportunities for Improvement in registration practices in this assessment.

Assessment History

This is the first assessment of the College’s registration practices by the OFC.

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Detailed Report^[1]

Specific Duty

1. Specific Duty — Information for Applicants

FARPCTA s. 7
RHPA, Schedule 2, s. 22.3

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

Assessment Outcome

Demonstrated

2. Specific Duty — Timely Decisions, Responses and Reasons

FARPACTA, s. 8 and s. 9 (1)
RHPA, Schedule 2, s.20 (1)
*Only applies to regulatory bodies governed by FARPACTA

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

Not Applicable

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

Assessment Outcome

Not Applicable

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

Assessment Outcome

Not Applicable

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

Assessment Outcome

Not Applicable

3. Specific Duty — Internal Review or Appeal

FARPACTA, s. 7, s. 9(2-3, 5)
RHPA, Schedule 2, s. 15, s. 17, s. 19, s. 22.3
*Only applies to regulatory bodies governed by FARPACTA

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

Not Applicable

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

Assessment Outcome

Not Applicable

4. Specific Duty — Information on Appeal Rights

FARPACTA, s. 9 (4)
RHPA, Schedule 2, s. 20, s. 21, s. 22

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

Demonstrated

5. Specific Duty — Documentation of Qualifications

FARPACTA, s. 10 (1)
RHPA, Schedule 2, s. 22.4(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)
RHPA, Schedule 2, s. 22.4(2)
*Only applies to regulatory bodies that develop and administer their own exams.

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

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.
RHPA, Schedule 2, s. 22.4(3)

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

Demonstrated

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
RHPA, Schedule 2, s. 16

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

Not Applicable

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
RHPA, Schedule 2, S.22.2

Transparency

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

Assessment Outcome

The College has implemented policies that demonstrate transparency in assessment processes and practices.

Openness

• The College publishes an annual report that is available on its website. The report includes a Registration Committee report with statistics on international applicants, cases referred to Registration Committee for review, and cases appealed to the Health Profession Appeal and Review Board.
• The College conducts public consultation to seek input from stakeholders on issues related to College governance and registration processes, such as a proposal to require applicants to submit a criminal record check as part of the application package.
• Consultations are posted to a dedicated page of the College’s website.
• Policies and decision-making criteria are readily available to staff and registration committee members.
• An examination blueprint is included in the Registration Examination Resource Manual that identifies the competencies tested in the exam and their respective weights in the overall marking scheme.

Access

• The College advises applicants of the progress of their application through a web based user account, including application approval, examination results, and Registration Committee decisions regarding applications and requests for review.
• A Professional Practice and Jurisprudence handbook is available to applicants to assist in completion of the Jurisprudence e-learning module.

Clarity

The College communicates effectively with applicants throughout the registration process. For example:

• advises applicants of the progress of their application through e-mailed status updates.

Commendable Practice

The Registration Examination Resource Manual is a useful resource for applicants in preparing for the registration examination.

Objectivity

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

Assessment Outcome

The College uses a variety of methods to achieve objectivity in its assessment processes. These methods support a consistent approach to assessments, by promoting a shared understanding of policies, procedures and methodologies among college staff and the registration committee. This is evident from policy documents, examples of tools for decision-makers, and information posted on the College’s website.

To achieve consistent and reliable decisions, the College takes the following steps:

• develops policies to guide discussion at Registration Committee when discussing whether applicants meet registration requirements
  • The Registration Committee developed a policy that outlines the relevant factors for the Committee to consider when determining if an applicant meets the requirement for good character and suitability to practice.
• provides annual training to all Committee members and staff involved in assessment processes

Commendable Practice

Consistent application of registration criteria

Registration staff confer with one another on a regular basis, as well as in meetings of the full registration team, to discuss cases and questions that occur on a repeated basis. When policy decisions or precedents are established, staff receive notice of this as soon as possible.

Impartiality

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

Assessment Outcome

The College demonstrates processes and procedures that are designed to reduce the potential for impartiality in assessment and decision-making processes.

Identification of Bias

• The College’s annual training for council and committee members addresses conflict of interest in the context of Committee roles and responsibilities.
• In 2016 College staff attended a workshop on Managing Cultural Differences delivered through the Ontario Regulators for Access Consortium.

Strategies

The College strategies to mitigate bias include:

• Committee Members receive specific training for conducting panel hearings, based on training originally provided by CRPO’s legal counsel.
• Committee members are required to declare conflict of interest prior to each Registration Committee meeting
• The College’s annual training for Council and Committee explains conflict of interest in relation to Committee roles and responsibilities.

Fairness

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

Assessment Outcome

The College exhibits fairness in its registration practices, supported by evidence from policies, annual reports, and Fair Registration Practice reports.

Substantive Fairness

• College Council has committed to the development of policies that support the registration of qualified Indigenous practitioners

Procedural Fairness

• College Council has committed to the development of policies that support the registration of qualified Indigenous practitioners

Relational Fairness

The College takes the following actions to promote relational fairness:

• has a process for considering alternate sources of documentation where the applicant is unable to provide an original form of a document required for registration
• ensures the registration exam administrator has comprehensive policies and procedures to review and make necessary accommodations for applicants with documented disability.

Commendable Practice

The College is developing policies and procedures for the Indigenous Registration Pathway, proposed by College Council in 2015. The intent of the pathway is to support the registration of appropriately qualified Indigenous practitioners of psychotherapy through consultation and collaboration with Indigenous (First Nations, Inuit and Métis) communities.

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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

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 Improvement.

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References

1. ^ 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.