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Registration Practices Assessment Report 2016 - OCT

​Registration Practices Assessment Report
ONTARIO COLLEGE OF TEACHERS
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 the Ontario College of Teachers 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 Ontario College of Teachers (OCT) has been assessed in all of the specific duties, with the exception of provision of information.

Comments

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

  • 2. Timely Decisions, Responses and Reasons
  • 3. Internal Review or Appeal
  • 6. Assessment of Qualifications
  • 7. Training
  • 8. Access to Records.

General Duty

Assessment method

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

Comments

The OFC found that the OCT takes effective actions to meet its general duty obligations. Since the last assessment, the OCT implemented additional measures to move toward a transparent, objective, impartial and fair registration process.

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 OCT is demonstrating commendable practices in the following areas:

Specific Duty

Timely Decisions, Responses and Reasons

  1. Reducing the average certification timelines for internationally educated applicants who are eligible for certification from 53 days in 2014 to 37 days in 2015.
  2. Creating and distributing daily newsletters to the OCT Client Services Unit's staff to inform them about the volume of applicant inquiries and to show the average response times. The newsletter also includes information about upcoming legislative or policy changes. This proactive approach ensures that the OCT Client Services Unit's staff are aware of service levels, are kept up-to-date on new developments at the College, and can take actions, if necessary.
  3. Implementing procedures that help reduce timelines related to the OCT's appeals processes. For example:
    1. scheduling additional meetings for the Registration Appeals Committee to address the number of cases carried over from the previous year
    2. shortening administrative timelines for preparing the appeals packages for the Registration Appeals Committee
    3. enhancing internal tracking processes for monitoring the timelines.
  4. Assigning a decision writer and editor to support the Registration Appeal Committee's decision-writing process so that the committee can review more cases per meeting. The OCT anticipates that this change will help reduce timelines related to making decisions about appeals and giving written decisions and reasons to applicants.

Assessment of Qualifications

  1. Using proactive and creative strategies to ensure that information about educational programs is kept current and relevant. For example:
    1. providing assessors with "user-friendly" templates to help them request information from academic institutions; the template provides all of the possible questions/scenarios and the assessors select which items are appropriate for the file they are working on.
    2. in 2015, initiating a new practice to help facilitate faster response times from the institutions. This includes introducing an "easy" response form sent to the institution through verified email addresses and fax numbers rather than using regular mail. Automatic reminders will be sent to the institutions to encourage them to respond.
    3. using a process where the OCT contacts ministries of education and other educational authorities in various jurisdictions every three years to request information about any changes in accreditation status of teacher education programs in those jurisdictions.
  2. Re-evaluating applications from applicants who completed distance education programs as a result of the OCT's new distance education policy. In 2014, the College adopted a new distance education policy. Following this, the OCT decided to review the applications of applicants who were denied certification status as a result of the distance education component of their teacher education. Applicants who applied in the 30-month period preceding the new policy were eligible for re-evaluation. These actions were taken to ensure that internationally trained applicants are treated similarly to Ontario teachers who completed distance education programs.

General Duty

Transparency

  1. Using a process called Proactive Evaluation Status Update (PESU) to inform applicants about the status of their applications when there is a delay. PESU requires the OCT's staff members to engage in ongoing proactive communications with applicants to advise them that there is delay when their registration outcome for initial certification is delayed beyond six weeks. This practice demonstrates the OCT's commitment to serve applicants and members.
  2. Launching the Applicant Eligibility Assessment tool to help internationally educated teachers interested in applying for certification with the OCT to determine how likely they are to meet certification requirements. Using this free, online self-assessment tool, applicants are able to input their own credential information into the tool to receive information that is tailored to their circumstances. The tool also provides background information on the certification process and directs the user to contact the College should they have any questions.
  3. Adding to the OCT's website two instructional videos that provide useful information for internationally educated applicants who cannot attend the monthly information sessions held at the College. Both videos are available in English and French. The first video, "Applying to the College", is for applicants who have not yet applied. Applicants learn about the basic requirements for certification, required documents and useful tips for completing their application. The second video, "Evaluating your Application", is designed to help applicants at various stages of the application process. They learn about the requirements for a successful application, the evaluation process, and how their credentials were assessed.
  4. Introducing a program that allows for public presentations at quarterly Council meetings and the Annual Meeting of Members. Two presentations may be scheduled for each meeting. Those who would like to present a topic related to the OCT's activities or work are invited to complete an online request form 15 days prior to a scheduled Council meeting. Once accepted, approved presenters have up to 10 minutes to speak and a further 10 minutes to respond to questions from Council members.
  5. Developing and implementing a comprehensive transition plan, which included effective communication, to ensure that prospective registrants were well informed about the new requirements. In 2015, teacher education programs in Ontario expanded their curriculum from two semesters to four, including doubling the practice teaching time from 40 to 80 days. This transition was the focus of the OCT's work over the last two years. Although the increase in length of study may be perceived as a barrier, the OCT put forth a commendable effort to inform those who may be affected by this change.
  6. Creating and implementing a variety of methods and tools for engaging with the public and interested stakeholders to inform them about the work of the OCT, including the certification process and requirements. This includes:
    1. a comprehensive print, radio and online communications program that, through a series of ads, educates the public about who the OCT is, what it does, and how the OCT regulates teaching in Ontario
    2. a "Speakers Bureau" program that allows stakeholders and the public to connect with the OCT's staff to request a speaker who has expertise in the protection of the public interest and who can speak on a wide variety of professional standards and regulatory governance topics
    3. presentations across Ontario, including presentations to community agencies, newcomer groups, cultural or ethnic associations and other interested audiences.
    4. monthly, on-site information sessions that provide prospective applicants with information about the OCT's certification process
    5. visits and presentations to teacher candidates at Ontario's faculties of education, which provide them with information about the OCT's work and its certification process

Fairness

  1. "Cross-training" staff to increase the number of assessors who conduct evaluations of applications. This was done in order to ensure that applicants were certified prior to the September 1, 2015 introduction of the new Enhanced Program. As a result, in 2015, the OCT certified 2,500 more applicants than the total number of applicants certified in 2014.
  2. Minimizing the effect of implementation of the Enhanced Program on applicants by:
    1. amending the Teachers' Qualification regulation to allow for those certified with conditions to have more time to satisfy the conditions associated with the introduction of the Enhanced Program. The time period in which conditions must be satisfied has been increased from three years (with two possible one-year extensions) to five years (with one possible one-year extension). These amendments were made to prevent a negative impact on internationally trained applicants and applicants who entered the teaching program recently.
    2. amending the Teachers' Qualifications regulation to create exceptions to the general requirement that all Ontario and internationally trained applicants must meet new Enhanced Program requirements on September 1, 2015. These exceptions apply to those applicants who were:
      1. enrolled in concurrent or multi session programs as of August 31, 2015
      2. unable to complete a program prior to September 1, 2015 due to exceptional circumstances (e.g., medical issue or military service)
      3. enrolled in a Native program or French as a Second Language program and satisfied the requirements for the old Certificates, Limited or Certificates Limited Restricted that existed in the old regulation for teachers' qualifications (Regulation 184/97) or
      4. enrolled in a specialized consecutive program
    3. using a robust communications strategy aimed at letting current and potential applicants know about how they would be impacted by the new requirements. In its communications, the College emphasized the importance of applying as soon as possible and submitting outstanding application documents.

Recommendations

The OFC has not made any recommendations for this assessment period. The OFC expects that the OCT will continue maintaining its standards in the future. In the spirit of continuous improvement, the OFC encourages the OCT to continue its efforts towards more transparent, objective, impartial and fair registration processes.

Assessment History

In the 2013-2014 assessment, the OFC did not identify any recommendations for the OCT.

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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

Commendable practice

1. Reducing the average certification timelines for internationally educated applicants who are eligible for certification from 53 days in 2014 to 37 days in 2015.

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

Assessment Outcome

Demonstrated

Commendable practice

2. Creating and distributing daily newsletters to the OCT Client Services Unit's staff to inform them about the volume of applicant inquiries and to show the average response times. The newsletter also includes information about upcoming legislative or policy changes. This proactive approach ensures that the OCT Client Services Unit's staff are aware of service levels, are kept up-to-date on new developments at the College, and can take actions, if necessary.

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

Assessment Outcome

Demonstrated

Commendable practice

3. Implementing procedures that help reduce timelines related to the OCT's appeals processes. For example:

  1. scheduling additional meetings for the Registration Appeals Committee to address the number of cases carried over from the previous year
  2. shortening administrative timelines for preparing the appeals packages for the Registration Appeals Committee
  3. enhancing internal tracking processes for monitoring the timelines.

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

4. Assigning a decision writer and editor to support the Registration Appeal Committee's decision-writing process so that the committee can review more cases per meeting. The OCT anticipates that this change will help reduce timelines related to making decisions about appeals and giving written decisions and reasons to applicants.

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

Not Applicable

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)

*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

Not Applicable

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

This practice doesn't apply to the OCT because the OCT doesn't conduct tests or exams.

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

Assessment Outcome

Demonstrated

OFC Comments

The OCT uses easy to understand, measurable units, such as percentages, to describe the criteria used in assessing the composition of an acceptable teacher education program. For example, the teacher education program must include 10% on teaching foundations, 20% on teaching methods, 50% in any other areas of education to support methodology coursework, and 80 days of practice teaching supervised by the program provider.

The OCT also assesses work experience for applicants applying to teach technological education. Applicants need to demonstrate that they have a total of five years of work experience in the area in which they want to teach. Depending on the nature and complexity of the work experience completed, applicants may develop similar competencies within different timelines. What some individuals can learn to do after completing five years of experience, others may learn to do in less time; and yet for others it may take longer. Because of this, stating the criteria in number of years may be challenging from an objectivity perspective. The OCT informs that it is starting research into competency assessment. The OCT is undertaking this initiative to prepare itself for the regulatory environment in the future.

Suggestions for continuous improvement[2]

The OFC suggests that as part of this work, explore options for assessing work experience required to teach technological education using assessment methods other than counting the number of years.

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

Commendable practice

1. Using proactive and creative strategies to ensure that information about educational programs is kept current and relevant. For example:

  1. providing assessors with "user-friendly" templates to help them request information from academic institutions; the template provides all of the possible questions/scenarios and the assessors select which items are appropriate for the file they are working on.
  2. in 2015, initiating a new practice to help facilitate faster response times from the institutions. This includes introducing an "easy" response form sent to the institution through verified email addresses and fax numbers rather than using regular mail. Automatic reminders will be sent to the institutions to encourage them to respond.
  3. using a process where the OCT contacts ministries of education and other educational authorities in various jurisdictions every three years to request information about any changes in accreditation status of teacher education programs in those jurisdictions.

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

Commendable practice

2. Re-evaluating applications from applicants who completed distance education programs as a result of the OCT's new distance education policy. In 2014, the College adopted a new distance education policy. Following this, the OCT decided to review the applications of applicants who were denied certification status as a result of the distance education component of their teacher education. Applicants who applied in the 30-month period preceding the new policy were eligible for re-evaluation. These actions were taken to ensure that internationally trained applicants are treated similarly to Ontario teachers who completed distance education programs.

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

Not Applicable

OFC Comments

The OCT's processes related to assessment of qualifications are closely intertwined with processes related to making registration decisions. The OCT doesn't have a separate process for applicants to appeal the assessment decisions. To avoid redundancy, the OFC assessed this practice together with practices in section 3 of this report. Please refer to section 3 for the assessment details.

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

Assessment Outcome

Not Applicable

OFC Comments

The OCT's processes for informing applicants about assessment and registration decisions are closely intertwined. The College doesn't have a separate process for informing applicants only about the assessment decisions. To avoid redundancy, the OFC assessed this practice together with practices in section 2 of this report. Please refer to section 2 for the assessment details.

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

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

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

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

Transparency

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

The OCT demonstrates a strong commitment to public accountability and transparency. The evidence of this commitment comes in many forms, including the following:

  • publishing reports and making presentations at industry conferences about what it means to be transparent in the regulatory environment
  • identifying transparency as a key strategic priority
  • proactively engaging with stakeholders on issues related to certification
  • creating opportunities for public presentations at its council meetings
  • providing clear and comprehensive information about its certification process.

Openness:

The OCT uses effective strategies to ensure that:

  • interested stakeholders and applicants are informed
    • of key developments in registration practices
    • about the OCT's governing structure and the structure of accountability for registration functions
  • documented policies are followed and registration decisions are made on the basis of written criteria and procedures
  • public input is included in decisions about significant registration changes.

Access:

The OCT 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 2015, the OCT:

  • launched an online Applicant Eligibility Assessment tool. The tool was created to help internationally educated teachers interested in applying for certification with the OCT to determine how likely they are to meet certification requirements.
  • added two instructional videos to its website about the certification process that are especially useful to applicants who cannot attend the monthly information sessions held at the College.

Clarity:

The OCT implements effective measures to communicate with applicants throughout the registration process. For example:

  • there are processes to communicate with applicants about their applications before, during and after application
  • The OCT implements procedures to ensure that applicants know how their application is progressing and understand the reasons for all decisions taken during the registration process.
  • In 2015, the OCT augmented its existing system for allowing applicants to track the progress of their application.
  • To obtain feedback from applicants about their registration experiences, the OCT asks applicants that attend information sessions to complete evaluation forms. The evaluation forms ask applicants to rate content and format of the information sessions and to provide any other comments.

The OCT informs that, in the future, the OCT will consider conducting a survey of applicants or new members regarding their experiences in the registration process. The OFC supports this plan.

See specific examples of these actions in the Commendable practices section below.

Commendable practice

The OFC identified the following commendable practices:

  1. Using a process called Proactive Evaluation Status Update (PESU) to inform applicants about the status of their applications when there is a delay. PESU requires the OCT's staff members to engage in ongoing proactive communications with applicants to advise them that there is delay when their registration outcome for initial certification is delayed beyond six weeks. This practice demonstrates the OCT's commitment to serve applicants and members.
  2. Launching the Applicant Eligibility Assessment tool to help internationally educated teachers interested in applying for certification with the OCT to determine how likely they are to meet certification requirements. Using this free, online self-assessment tool, applicants are able to input their own credential information into the tool to receive information that is tailored to their circumstances. The tool also provides background information on the certification process and directs the user to contact the College should they have any questions.
  3. Adding to the OCT's website two instructional videos that provide useful information for internationally educated applicants who cannot attend the monthly information sessions held at the College. Both videos are available in English and French. The first video, "Applying to the College", is for applicants who have not yet applied. Applicants learn about the basic requirements for certification, required documents and useful tips for completing their application. The second video, "Evaluating your Application", is designed to help applicants at various stages of the application process. They learn about the requirements for a successful application, the evaluation process, and how their credentials were assessed.
  4. Introducing a program that allows for public presentations at quarterly Council meetings and the Annual Meeting of Members. Two presentations may be scheduled for each meeting. Those who would like to present a topic related to the OCT's activities or work are invited to complete an online request form 15 days prior to a scheduled Council meeting. Once accepted, approved presenters have up to 10 minutes to speak and a further 10 minutes to respond to questions from Council members.
  5. Developing and implementing a comprehensive transition plan, which included effective communication, to ensure that prospective registrants were well informed about the new requirements. In 2015, teacher education programs in Ontario expanded their curriculum from two semesters to four, including doubling the practice teaching time from 40 to 80 days. This transition was the focus of the OCT's work over the last two years. Although the increase in length of study may be perceived as a barrier, the OCT put forth a commendable effort to inform those who may be affected by this change.
  6. Creating and implementing a variety of methods and tools for engaging with the public and interested stakeholders to inform them about the work of the OCT, including the certification process and requirements. This includes:
    1. a comprehensive print, radio and online communications program that, through a series of ads, educates the public about who the OCT is, what it does, and how the OCT regulates teaching in Ontario
    2. a "Speakers Bureau" program that allows stakeholders and the public to connect with the OCT's staff to request a speaker who has expertise in the protection of the public interest and who can speak on a wide variety of professional standards and regulatory governance topics
    3. presentations across Ontario, including presentations to community agencies, newcomer groups, cultural or ethnic associations and other interested audiences.
    4. monthly, on-site information sessions that provide prospective applicants with information about the OCT's certification process
    5. visits and presentations to teacher candidates at Ontario's faculties of education, which provide them with information about the OCT's work and its certification process

Objectivity

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

The OCT uses effective strategies for achieving consistency and accuracy in its registration decisions. This is evident from a variety of sources, including policy documents, examples of tools for decision-makers, and records of the OCT's periodic reviews of its own registration criteria, policies and procedures.

Reliability:

To achieve reliability in the registration decisions, the OCT:

  • expresses its registration criteria in measurable units. Where criteria are complex it establishes specific conditions for meeting the criteria (e.g., professional suitability)
  • has a process for reviewing criteria for clarity
  • provides decision-makers with the tools and information they need to do their job.

Validity:

To achieve validity in the registration decisions, the OCT:

  • has a process for assessing the extent to which registration decisions are accurate
  • when corrective actions are necessary, the OCT grounds them in analysis and research.

Impartiality

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

The OCT implements effective strategies for achieving impartial registration decisions. This is evident from a variety of sources, including policy documents, examples of tools for decision-makers, and records of the OCT's periodic reviews of its own registration criteria, policies and procedures.

Identification of Bias:

The OCT documents and informs decision-makers about:

  • what constitutes a conflict of interest and what they should do when they find themselves in a conflict of interest
  • what constitutes discrimination and what to do to prevent discrimination.

Strategies:

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

  • has a process for monitoring its policies and procedures in order to identify potential sources of impartiality
  • identifies and implements corrective actions when needed
  • considers internal and external factors prior to introducing registration changes when developing or amending its registration policies. These considerations are included in the analysis that the OCT conducts prior to implementing a change.

The OCT informs the OFC that when it conducts its next review of its guidelines and policies, the OCT will consider establishing the following:

  • an impartiality lens to provide further guidance on impartial decisions making; and
  • an inventory of external and internal factors that may compromise registration policy decisions.

The OFC supports these plans.

Fairness

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

The OCT takes appropriate measures to promote fairness. This is evident from a variety of sources including the OCT's legislative framework, measures taken by the OCT to monitor and review its own registration practices, and policy documents.

Substantive Fairness

The OCT takes the following measures to promote substantive fairness:

  • grounds its registration decisions in pre-determined criteria
  • regularly reviews the registration requirements to verify that they continue to be relevant and necessary
  • regularly conducts review of its fees for their reasonableness.

To ensure that its practices remain fair and relevant, the OCT uses a long term forecasting strategy to identify and develop initiatives that prepare the organization for the regulatory environment of the future. As part of this work, the OCT is starting a research into competency assessments and is exploring options for implementing alternatives for meeting certification requirements. The OFC supports the OCT's plans to start researching other possible forms of assessment.

Procedural Fairness

The OCT takes the following actions to promote procedural fairness:

  • conducts internal audits and reviews its systems to verify compliance with its own registration criteria, policies and procedures, and implements corrective actions as necessary
  • identifies procedures or steps that may be simplified or eliminated
  • reviews the alignment of its own practices with best practices to identify opportunities for improvement and streamlining.

Relational Fairness

The OCT 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
  • considers and provides accommodations where an applicant indicates that he or she cannot get the required documents.

See specific examples of these actions in the Commendable practices section below.

Commendable practice
  1. "Cross-training" staff to increase the number of assessors who conduct evaluations of applications. This was done in order to ensure that applicants were certified prior to the September 1, 2015 introduction of the new Enhanced Program. As a result, in 2015, the OCT certified 2,500 more applicants than the total number of applicants certified in 2014.

  2. Minimizing the effect of implementation of the Enhanced Program on applicants by:
    1. amending the Teachers' Qualification regulation to allow for those certified with conditions to have more time to satisfy the conditions associated with the introduction of the Enhanced Program. The time period in which conditions must be satisfied has been increased from three years (with two possible one-year extensions) to five years (with one possible one-year extension). These amendments were made to prevent a negative impact on internationally trained applicants and applicants who entered the teaching program recently.
    2. amending the Teachers' Qualifications regulation to create exceptions to the general requirement that all Ontario and internationally trained applicants must meet new Enhanced Program requirements on September 1, 2015. These exceptions apply to those applicants who were:
      1. enrolled in concurrent or multi session programs as of August 31, 2015
      2. unable to complete a program prior to September 1, 2015 due to exceptional circumstances (e.g., medical issue or military service)
      3. enrolled in a Native program or French as a Second Language program and satisfied the requirements for the old Certificates, Limited or Certificates Limited Restricted that existed in the old regulation for teachers' qualifications (Regulation 184/97) or
      4. enrolled in a specialized consecutive program
    3. using a robust communications strategy aimed at letting current and potential applicants know about how they would be impacted by the new requirements. In its communications, the College emphasized the importance of applying as soon as possible and submitting outstanding application documents.

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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 OCT 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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