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Registration Practices Assessment Report 2016 - OAA

​Registration Practices Assessment Report
ONTARIO ASSOCIATION OF ARCHITECTS (OAA)
2016–2017 Assessment Cycle (Cycle 3)



AVAILABILITY OF REPORT

The Office of the Fairness Commissioner (OFC) provides this report to the regulatory body and posts the full report on its website, www.fairnesscommissioner.ca. In the interests of transparency and accountability, the OFC encourages the regulatory body to provide it to its staff, council members, other interested parties and the public.



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 2016-2017 assessment of Ontario Association of Architects 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, with the exception of provision of information.

Comments

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

  • Timely Decisions, Responses and Reasons
  • Internal Review or Appeal
  • 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)Checked
b.Regulator practice-based self-assessment (following the practices in the Assessment Guide)Unchecked
c.Regulator systems-based self-assessment (in which it explains systemically and holistically how it meets the general duty)Unchecked

Principles assessed

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

Comments

The OFC found that since the last assessment, the Ontario Association of Architects (OAA) implemented measures to achieve more transparent, objective, impartial and fair practices. The OFC identified two areas where the OAA needs to take further actions steps to demonstrate its obligations under the general duty (see the Recommendations section).

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:

General Duty

Transparency

  1. To enable interested stakeholders, including the public and applicants, to understand how the registration process operates, the OAA does the following:
    1. publishes complete packages of documents included for discussions during council meetings. By providing these documents, the OAA helps interested stakeholders and the public to better understand the issues discussed and decisions made.
    2. publishes their decision-making logic model. This document explains how the OAA makes decisions about various issues it faces.
  2. The OAA established an Interns’ Forum to strengthen and improve the pathway to the profession from school to licensure. The goals of the 2015 Interns’ Forum was to enhance the intern/student relationship with the regulator, the internship process, the mentorship and experience process, and to facilitate collaboration between the schools and the profession. The OAA established a permanent Interns Committee to continue work in this direction.
  3. The OAA created a non-voting council seat for interns to include their voice and perspective in substantive registration decisions.

Fairness

  1. The OAA helped facilitate the following Mutual Recognition Agreements (MRA):
    1. between Canada and the United States. The new agreement took effect on January 1, 2014, updating the long-standing relationship related to reciprocal licensure between Canada and the United States.
    2. between Canada, Australia and New Zealand. The agreement allows for fast-track registration of senior architects who have met a number of criteria.
    3. between Canada, the United States, and Mexico. The agreement allows mutual recognition of architect credentials in all three countries, making it possible for architects to work across North American borders. Qualified architects from each country who satisfy the requirements of the agreement will be granted a credential that will lead to a license to practice architecture in the host country.

Recommendations

The regulator can improve in the following areas:

Specific Duties

Assessment of Qualifications

  1. In guidelines for staff and volunteers who assess work experience, include content that identifies:
    1. types of bias that may occur in assessments (other than conflict of interest) and/or
    2. circumstances that may potentially lead to biased assessment decisions and/or
    3. factors to consider with intention to avoid bias in assessment decisions. (Practice 6.11)
  2. Provide the OFC with any documentation that illustrates actions taken by the OAA to hold the CACB accountable for its assessment practices. This may include excerpts from internal reports or any other records describing the OAA’s actions and/or illustrating how the CACB accounts to the OAA for its assessment practices. (Practice 6.15)

General Duty

Transparency and Objectivity

  1. Develop more specific procedures for guiding decisions related to “past conduct” of applicants and for exempting an applicant from an academic or experience requirements (e.g., include details about factors to be considered and steps to be taken). [Transparency]
  2. When these procedures are developed, make those criteria and guidelines available to staff and volunteers who make such decisions. [Objectivity]

Assessment History

In the 2013-2014 assessment, the OFC identified six recommendations for the OAA. They have all been implemented.

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Detailed Report


Specific Duty

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

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

Demonstrated

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

Demonstrated

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

Not Applicable

OFC Comments

The OAA does not collect or keep information about educational programs because it does not assess academic credentials or educational programs.

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

OFC Comments

The process for completing the Canadian Experience Record Book (CERB) requires that the Supervising Architects respond to questions on page 5 of the CERB. Responding to these questions requires the Supervising Architects to assess and comment on the interns’ levels of responsibility, attitudes, and on the extent to which the interns have been exposed to the activities outlined for each practice category. The OFC didn’t find detailed guidelines that would direct the Supervising Architects on how to provide reliable and accurate responses. In the absence of detailed guidelines, there is the potential that different Supervising Architects will have varied interpretations of what “level of responsibility” or “level of involvement” means. This potentially may result in inconsistencies in how similar experiences of different interns are presented by the Supervising Architects to the OAA, thus potentially leading to inconsistent assessments of the experience.

Suggestions for continuous improvement[2]

Develop instructions or guidelines for the Supervising Architects that would enable them to provide reliable and accurate assessment of the interns’ experience.

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

Assessment Outcome

Demonstrated

OFC Comments

Experience obtained by interns or applicants outside the Internship in Architecture Program (IAP) is assessed by the Experience Requirements Committee (ERC) members. Only licensed architects in good standing can apply to be members of the Committee. The selection process includes an interview with the Committee chair and the OAA’s staff member(s). The interview follows standardized questions and the process is the same for each candidate.

Suggestions for continuous improvement

In the future, it would be useful to review the required qualifications standards for the ERC members and consider any other qualifications the ERC members should have. The OAA could also establish a more direct link between the interview questions and the required qualifications standards for the ERC members. By linking questions to the qualification standards the OAA will further ensure that it selects only qualified assessors to conduct assessments of work experiences.

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

Partially Demonstrated

OFC Comments

When assessing this practice, the OFC was looking for documented evidence that the OAA takes the following actions:

  1. identifies and documents characteristics or types of bias (other than conflict of interest), and/or sources of bias, and/or circumstances that may compromise impartial assessment decisions;
  2. informs assessors about these characteristics or types of bias, and/or sources of bias, and/or circumstances that may compromise impartial assessment decisions;
  3. informs assessors about what to do if they identify situations of bias;

On its website, the OAA provides a reference to the Human Rights Code which identifies individuals’ rights to equal treatment with respect to membership in a self-regulated profession. However, the OFC did not find other evidence illustrating how the OAA demonstrates actions (a) to (c).

Recommendations

In guidelines for staff and volunteers, for example, in the ERC Manual, include content that identifies:

  1. types of bias (other than conflict of interest) that may occur in assessments; and/or
  2. circumstances that may potentially lead to biased assessment decisions; and/or
  3. factors to consider with intention to avoid bias in assessment decisions.

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

Partially Demonstrated

OFC Comments

The OAA relies on the Canadian Architectural Certification Board (CACB) for the assessment of applicants’ qualifications. When assessing this practice the OFC was seeking documented evidence of measures taken by the OAA to hold the CACB accountable for its assessment of qualifications. In particular, the OFC was seeking evidence of actions taken by the OAA to verify whether the CACB’s assessments are transparent, objective, impartial and fair.

The OAA informed the OFC that it does the following to hold the CACB accountable for its fair assessment practices:

  1. receives and reviews annual reports in which the CACB describes its assessment activities and provides relevant statistics for the reporting period
  2. regularly communicates with the CACB to keep abreast of any changes or to resolve arising issues
  3. shares information about applicant’s files using a common web-based document management system.

The OFC has yet to receive any documentation from the OAA illustrating its actions in this regard and asks that it provide the requested documents to the OFC.

The CACB informed the OFC that it is considering developing a formal memorandum of understanding (MOU) between the CACB and all architecture regulators across the country, including OAA. The MOU could set out service standards, the CACB’s obligations to the OAA, procedures for monitoring the service standards, and procedures for holding the CACB accountable for transparent, objective, impartial and fair assessments. The OFC supports this plan and suggests that the OAA follow up on this initiative with the CACB.

Suggestions for continuous improvement

Consider developing an MOU with the CACB that would establish service standards and procedures for monitoring the CACB assessment practices. Follow up with the CACB on its plan to initiate the MOU.

Recommendations

Provide the OFC with any documentation that illustrates actions taken by the OAA to hold the CACB accountable for its assessment practices. This may include excerpts from internal reports or any other records describing the OAA’s actions and/or illustrating how the CACB accounts to the OAA for its assessment practices.

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

Demonstrated

OFC Comments

The OAA provides training to staff and committee members with training that addresses topics of objectivity and impartiality. To improve on these efforts, the OFC suggests that the ERC members review the OFC’s online learning modules 2, parts 1 and 2. These learning modules explore how regulators can meet their obligations by applying all four fair-access principles to their registration processes and provide a series of sample scenarios that help participants learn more about the practical application of the fair-access law. The modules may be accessed through the OFC’s website at: https://ofcweb.runstraight.com/en/Learning_Modules/Pages/default.aspx​​.

Suggestions for continuous improvement

If they have not done so already, the OAA could encourage its registration staff and ERC members to review the OFC’s online learning module 2, parts 1 and 2.

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

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

Not Applicable

OFC Comments

The OAA does not charge a fee for making records available.

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

The OAA takes measures to achieve transparency of its registration practices. Areas for further improvement are identified below.

Openness

The OAA implements measures to enable interested stakeholders, including the public and applicants, to understand how the registration process operates. For example:

  • on its website, the OAA publishes:
    • information about the structure of accountability for registration functions. It lists committees involved in registration of applicants, describes their roles and identifies members of these committees
    • a complete packages of documents included for discussions during council meetings
    • its decision-making logic model.
  • the OAA includes the public and interns’ input in decisions about significant registration changes.

There is one area where the OAA should take further actions to ensure full openness of its registration decisions. Openness requires that the regulator records all procedures that govern the registration process in policy documents, and makes registration decisions on the basis of written criteria and policy.

This is especially relevant to criteria and procedures for deciding about whether the “past conduct” of an applicant affords grounds for belief that the applicant will not engage in the practice of architecture in accordance with the law and with honesty and integrity. Without having these criteria and procedures recorded, there is a risk that the objectivity and impartiality of the OAA’s registration practices may be compromised. This risk could be minimized if the OAA had more specific criteria and procedures for guiding decisions related to the “past conduct” of applicants. Currently, the criteria used in making decisions about refusing an applicant’s application for licensure on the basis of the applicant’s “past conduct” is recorded only in the Architect’s Act, 1990 (see s. 13(2)). The OFC finds that the OAA needs to improve in this area (see Opportunities for improvement section).

Access

The OAA takes measures to ensure that applicants have all relevant information at the time and in the way needed to take actions appropriate to their individual circumstances. For example, in 2014, it revised Appendix B, Specific Ontario Requirements. The OAA’s examination website is regularly updated with the most recent information related to the exam.

Clarity

The OAA implements measures to communicate with applicants throughout the registration process. There are processes to communicate with applicants about their applications before, during and after application. To create even further clarity and transparency, it would be useful for the OAA to have a process to periodically review its written policies and procedures. This would ensure that they are clear, address key decision areas and remain relevant and current. The registration materials for applicants should reflect the existing practices.

For example, it seems that there is a disconnect between the practices related to recognition of international experience and the information that is provided about these procedures publicly. There is limited public information about the process related to exempting applicants from the experience and academic requirements. More detailed and clearer information about this process, criteria and procedures would be useful (see Suggestion for continuous improvement below).

Commendable practice

The OFC identified the following commendable practices:

  • The OAA helps interested stakeholders, the public and applicants, to understand its registration process by publishing on its website the following:
    • a complete package of documents used for discussions during council meetings. These documents inform about the issues discussed and decisions made during these meetings.
    • the internal decision-making logic model. This document explains how the OAA makes decisions about various issues it faces.
  • The OAA established an Interns’ Forum to strengthen and improve the pathway to the profession from school to licensure. The goals of the 2015 Interns’ Forum was to enhance the intern relationship with the regulator, the internship process, the mentorship and experience process, and to facilitate collaboration between the schools and the profession. As an outcome of this and other initiatives, the OAA established a permanent Interns Committee to continue work in this direction.
  • The OAA created a non-voting council seat for interns to include their voice and perspective in substantive registration decisions.

Suggestions for Continuous Improvement

Identify intervals at which it will be feasible for the OAA to review its written policies and procedures to ensure that they remain relevant and current. Once the OAA sets up a review cycle, the OAA should conduct these reviews in accordance with those timelines. If the review identifies that the written policies and procedures need to be updated, identify the policies and procedures to be revised, and update them within the specified timelines. Update registration materials for applicants to ensure that the existing materials reflect the existing practices.

Recommendations

Develop more specific procedures for guiding decisions related to “past conduct” of applicants and exempting an applicant from an academic or experience requirements. For example, include details about factors to be considered and steps to be taken.

Objectivity

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

The OAA takes some measures to achieve objective registration practices. However, further actions are necessary. These actions may have to be combined with actions identified for improving transparency as they address similar areas (See General Duty – Transparency section).

When assessing how the OAA meets its general duty obligations related to objectivity, the OFC was looking for documented evidence of written guidelines for staff and volunteers who make decisions about an applicant’s “past conduct” and about exempting an applicant from an academic or experience requirement. The guidelines should enable the decision-makers to make consistent and accurate decisions. These decisions must be based on evidence that directly demonstrates how the applicant meets or doesn’t meet the requirement and be confined only to evidence that is specifically related to the decision itself.

The OFC looked at measures taken by the OAA to achieve and monitor consistency and accuracy of its registration decisions in the absence of written guidelines. The OFC identified the following measures:

Reliability

  • The Registration Committee hearings follow the requirements of the Statutory Powers Procedures Act. The same procedures apply to all applicants and to all hearings.

Validity

  • The OAA’s counsel is present at each Registration Committee hearing. In this way, the Registration Committee has a resource each time it needs to guarantee that the committee follows the required procedures and is maintaining the standards required of an administrative tribunal.

Additionally, in the future, it may be useful for the OAA to review its procedures to identify any potential factors that may compromise the objectivity of the OAA’s registration decisions.

Suggestions for Continuous Improvement

In the future, review procedures for making key registration decisions to identify the potential risks to the consistency and accuracy of the decisions. Identify any factors that may compromise their objectivity. If any factors are identified, develop resources and/or modify procedures to address those risks.

Recommendations

When procedures for guiding decisions related to “past conduct” of applicants and for exempting an applicant from an academic or experience requirements are developed, make them available to staff and volunteers who make these decisions. (See General Duty - Transparency section)

Impartiality

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

The OAA implements measures to achieve impartial registration decisions. The OFC identified the following measures:

Identification of Bias

The OAA implements measures to identify some potential sources of bias. For example, the OAA documents and informs decision-makers about what constitutes a conflict of interest and what they should do if they find themselves in a conflict of interest.

Strategies

The OAA implements strategies to avoid bias. For example, the OAA:

  • bases its registration decisions on concrete evidence
  • uses group deliberation and consensus strategies to come to decisions
  • provides the Registration Committee with a legal counsel who, at each hearing, ensures that the Registration Committee maintains the standards required of an Administrative tribunal.

Fairness

  • Ensuring substantive fairness
  • Ensuring procedural fairness
  • Ensuring relational fairness
Assessment Outcome

The OAA takes measures to promote fairness. This is evident from the OAA’s legislative documents, registration materials for applicants, reports published on the OAA’s website, and internal guidelines for decision-makers.

Substantive Fairness

The OAA takes the following measures to promote substantive fairness:

  • grounds its registration decisions in pre-determined criteria
  • reviews its registration requirements to identify alternative pathways for meeting the requirements and implements acceptable alternatives when feasible
  • has procedures in place to ensure that the reasoning behind its decisions is evidence-based.

To take these efforts further, the OAA could continue identifying alternative ways in which applicants could meet the Ontario work experience requirement (See Suggestions for continuous improvement section).

Procedural Fairness

The OAA takes actions to promote procedural fairness. For example, it is continuously reviewing its registration practices to identify opportunities for improvement and streamlining. Currently, the OAA is in the process of pursuing a few initiatives related to the OAA’s Admission Course and registration exam. When changes identified through these initiatives are implemented, they will result in a more flexible and streamlined process for interns.

Procedural fairness requires that the OAA has a process to verify that its registration practices do not unjustifiably prevent applicants from demonstrating their ability to practice. In 2016, the OAA created a permanent Interns Committee. The OAA also created a council seat for a non-voting intern member. These actions help prevent the potential for exclusion as the Intern Committee’s work focuses on enhancing the interns’ mentorship and experience processes. These initiatives may play an important role in ensuring that the Ontario work experience requirement doesn’t unjustifiably limit some applicants from becoming fully licensed. For example, it may be useful to explore why some interns have been in the IAP for more than five years, the specific causes of these trends, and what can help the interns to complete the IAP’s requirements sooner. It may also be useful to conduct a broader survey of interns and members about their registration experiences to identify any further initiatives towards a fairer registration process (See Suggestions for Continuous Improvement section).

The OFC also suggests that the OAA continue exploring acceptable alternatives to its work experience requirement (See Suggestions for Continuous Improvement).

Relational Fairness

The OAA takes the following actions to promote relational fairness:

  • has a process for taking applicants’ circumstances into consideration
  • has a process for providing accommodations to applicants.

Commendable Practices

The OAA helped facilitate the following Mutual Recognition Agreements (MRA):

  • between Canada and the United States. The new agreement took effect on January 1, 2014, updating the long-standing relationship related to reciprocal licensure between Canada and the United States.
  • between Canada, Australia and New Zealand. The agreement allows for fast-track registration of senior architects who have met a number of criteria.
  • between Canada, the United States, and Mexico. The agreement allows mutual recognition of architect credentials in the three countries, making it possible for architects to work across North American borders. Qualified architects from each country who satisfy the requirements of the agreement will be granted a credential that will lead to a license to practice architecture in the host country.

Suggestions for Continuous Improvement

  • Identify factors that require Ontario experience, such as type of materials used in construction, climate conditions, legal environment, etc. Explore whether competencies necessitated by these factors may be developed through means other than Ontario work experience.
  • Explore the feasibility of introducing a competency-based assessment in place of, or in addition to, the existing assessment that is based on counting hours of experience completed.
  • Explore the specific causes of why some interns have been in the IAP for more than five years. Review these trends to identify initiatives towards a more streamlined and inclusive registration process.

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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 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 the OAA'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 Improvement of Registration Practices.

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References

  1. ^ These include: 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. ^ 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. Suggestions for continuous improvement appear only in the detailed report.


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