Sign In
Professions and Trades

Registration Practices Assessment Report 2016 - Veterinarians

​Registration Practices Assessment Report
COLLEGE OF VETERINARIANS OF ONTARIO
2016–2018 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 2016-2018 assessment of College of Veterinarians of Ontario is a full assessment.

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

  • duties that were assessed
  • an overview of assessment outcomes for specific duty practices
  • an overview of comments related to the general duty
  • commendable practices
  • recommendations

Top ›



Assessment Summary


Specific Duties

Specific duties assessed

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

Comments

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

  • Information for applicants,
  • Timely Decisions, responses and reasons
  • Internal Review or Appeal processes,
  • Information to applicants on Appeal Rights,
  • Documentation of Qualifications,
  • Internal Training for College’s staff and,
  • Access to applicants 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.

Commendable Practices

A commendable practice is a program, activity or strategy that goes beyond the minimum standards set by the OFC assessment guides, considering the regulatory body’s resources and profession-specific context. Commendable practices may or may not have potential for transferability to another regulatory body.

The regulatory body is demonstrating commendable practices in the following areas:

Specific Duty

Information for Applicants

  1. Comprehensive and up-to-date information is provided on the CVO website regarding the entire registration process

Assessment of Qualifications

  1. Communicating the results of the jurisprudence examination on the same day that applicants take the exam.

Training

  1. Licensure staff conducts a yearly orientation for the Registration Committee. This orientation covers fairness in decision-making, conflict of interest and confidentiality. The orientation session covers:
    • Anti-discrimination: New Committee members are required to complete a learning module in Human Rights principles.
    • Cultural Diversity: New Committee members are required to review the Managing Cultural Differences document by the Ontario Regulators for Access Consortium

Access to Records

  1. Applicants can find information about how to access their records related to their applications for registration on the College’s website under the "For Applicants" frequently asked questions section and directly from the licensing team, either face-to-face, over the phone or via email.

Assessment History

In the previous assessment, the OFC identified 9 recommendations for the regulator.

They have all been implemented.

Top ›



Detailed Report[2]


Specific Duty

1. Specific Duty — Information for Applicants

FARPACTA s. 7

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Suggestions for continuous improvement

The College is encouraged to continue to explore opportunities to help ensure plain language is used when communicating the reasons for rejecting an application.

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)
or
RHPA, Schedule 2, s. 15, s. 17, s. 19, s. 22.3

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

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)

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

Assessment Outcome

Demonstrated

6. Specific Duty — Assessment of Qualifications

FARPACTA, s. 10 (2)

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Not Applicable

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

Not Applicable

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

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

Not Applicable

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

Assessment Outcome

Not Applicable

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

Not Applicable

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

Assessment Outcome

Not Applicable

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

Assessment Outcome

Not Applicable

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

Demonstrated

7. Specific Duty — Training

FARPACTA, s. 11

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

Assessment Outcome

Demonstrated

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

Assessment Outcome

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. [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

Not Applicable

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

Legislation: FARPACTA, Part II, s.6. A regulated profession has a duty to provide registration practices that are transparent, objective, impartial and fair.

Transparency

A process is transparent if it is conducted in such a way that it is easy to see what actions are being taken to complete the process, why these actions are taken, and what results from these actions. In the regulatory context, transparency of the registration process encompasses the following:

  • Openness: having measures and structures in place that make it easy to see how the registration process operates
  • Access: making registration information easily available
  • Clarity: ensuring that information used to communicate about registration is complete, accurate and easy to understand

The College has demonstrated openness, accessibility and clarity in the registration practices by having measures and structures in place that make it easy to see how the registration process operates. Registration information is readily available on the college website in a complete, accurate and easy to understand way.

The College informs the OFC that, since 2011 the College has updated registration materials annually. This process involves reviewing the website materials, posted fees, the career map, the paper and online licensure application form and the College’s policies related to licensure. Each of the licensure policies indicates when it was implemented and/or revised. The College makes updates to materials throughout the year as well – when a new policy is brought into effect or revised or when new legal advice is received pertaining to registration matters.

The OFC supports the initiatives of the College and has not made any recommendations in this area at this time.

Suggestions for Continuous Improvement

The College informs the OFC that they are exploring opportunities to modernize and improve the existing Veterinarians Act:

  • The College is encouraged that any change in the registration practice is consulted with the OFC prior to implementation to ensure that the fair access principles (Transparency, Objectivity, Impartiality, and Fairness) are being met.

Objectivity

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

A process or decision is objective if it is based on formal systems, such as criteria, tools, and procedures that have been repeatedly tested during their development, administration and review and have been found to be valid and reliable. In the regulatory context, objectivity of systems encompasses the following:

  • Reliability: ensuring that the criteria, training, tools and procedures deliver consistent decision outcomes regardless of who makes the decision, when the decision is made, and in whatever context the decision is made
  • Validity: ensuring that the criteria, training, tools and procedures measure what they intend to

Reliability and Validity

In the assessment process of the principle of objectivity, the OFC has evaluated whether the college’s processes and decisions are based on formal systems, criteria and tools to ensure that the registration outcomes are consistent regardless of who makes the decision, when the decision is made, and in whatever context the decision is made. The OFC has also evaluated if the criteria, training, tools and procedures measure what they intend to and are appropriate for the practice of the profession.

The College has demonstrated that the registration conditions and requirements are clearly defined in their policies. These requirements are objective and have measurable criteria.

The OFC supports the initiatives of the College and has not made any recommendations in this area at this time.

Impartiality

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

A process or decision is impartial if the position from which it is undertaken is neutral. Neutrality occurs when actions or behaviours that may result in subjective assessments or decisions are mitigated. Impartiality may be achieved by ensuring that all sources of bias are identified and that steps are taken to address those biases. In the regulatory context, impartiality encompasses the following:

  • Identification: having systems to identify potential sources of bias in the assessment or decision-making process (for example, sources of conflict of interest, preconceived notions, and lack of understanding of issues related to diversity).
  • Strategies: having systems to address bias and enable neutrality during the assessment and decision making process (for example, training policies that address conflict of interest, procedures to follow if bias is identified, and using group deliberation and consensus strategies to come to decisions

The College informs the OFC that measures are taken to identify bias and strategies are in place to ensure the principle of impartiality is adhered to in the registration process. Such initiatives include:

  • The Registration Committee receives an orientation yearly. The Registration Committee Manual includes Council’s policy on Conflict of interest and appearance of bias related information.
  • The Committee is to advise staff and the Chair in advance of the meetings if, on review of the meeting package, any conflict of interest/appearance of bias issue has been identified. The Committee member with conflict of interest/appearance of bias will leave the room while the application is being reviewed and this is recorded in minutes. The basis for conflict of interest/appearance of bias is not to be discussed in the room.
  • If a Committee is unsure if they have a conflict of interest or appearance of bias they are advised to talk to staff.
  • Bias and conflict of interest is discussed at every meeting.
  • Ongoing education throughout the year.

The OFC supports the initiatives of the College and has not made any recommendations in this area at this time.

Fairness

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

A process or decision is considered fair in the regulatory context when all of the following are demonstrated:

  • Substantive fairness: ensuring fairness of the decision itself. The decision itself must be fair and to be fair it must meet pre-determined and defensible criteria. The decision must be reasonable and the reasoning behind the decision must be understandable to the people affected.

Each CVO applicant must meet the same requirements and are considered on the same basis, meaning on their qualifications, regardless of where they may have been educated. This helps ensure that all applicants are treated in the same manner and that no advantage or disadvantage is conferred on a particular group (e.g., internationally educated versus domestically educated).

  • Procedural fairness: ensuring fairness of the decision-making process. There is a structure in place to ensure that fairness is embedded in the steps to be followed before, during and after decisions are made. The structure ensures that the process is timely and that individuals have equal opportunity to participate in the registration process and demonstrate their ability to practice.

The College has a policy for ensuring fairness of the decision-making process. There is a structure in place to ensure that fairness is embedded in the steps to be followed before, during and after decisions are made. This structure ensures that the process is timely and that individuals have equal opportunity to participate in the registration process and demonstrate their ability to practise. While all applicants must meet the CVO registration requirements, there are pathways to registration. The College has clear registration processes, which are accessible to the public, designed to provide information on the application process as it applies to graduates.

  • Relational fairness: ensuring people are treated fairly during the decision making process and by considering and addressing their perception about the process and decision.

The College 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
  • Allow applicants to submit further documentation to support their application where it may be beneficial to the applicant

The OFC supports the initiatives of the College and has not made any recommendations in this area at this time.

Suggestions for Continuous Improvement

The College informs the OFC that the College’s council ordered a review of the licence categories and requirements for licensure in March 2018; Council is expected to receive a final report in September 2019.

  • The College is encouraged that any change in the registration practice is consulted with the OFC prior to implementation to ensure that the fair access principles (Transparency, Objectivity, Impartiality, and Fairness) are being met.

Top ›



Background


Assessment Methods

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

A regulatory body’s practices can be measured against the fair access legislation’s specific duties in a straightforward way. However, the general duty is broad, and the principles it mentions (transparency, objectivity, impartiality and fairness) are not defined in the legislation.

As a result, the specific-duty and general-duty obligations are assessed differently (see the Strategy for Continuous Improvement of Registration Practices).

Specific Duties

The OFC can clearly determine whether a regulatory body demonstrates the specific-duty practices in the assessment guide. Therefore, for each specific-duty practice, the OFC provides one of the following assessment outcomes:

  • Demonstrated – all required elements of the practice are present or addressed
  • Partially Demonstrated – some but not all required elements are present or addressed
  • Not Demonstrated – none of the required elements are present or addressed
  • Not Applicable – this practice does not apply to the College’s registration practices

General Duty

Because there are many ways that a regulatory body can demonstrate that its practices, overall, are meeting the principles of the general duty, the OFC makes assessment comments for the general duty, rather than identifying assessment outcomes. For the same reason, assessment comments are made by principle, rather than by practice.

For information about the OFC's interpretations of the general-duty principles and the practices that the OFC uses as a guideline for assessment, see the OFC's website.

Commendable Practices and Recommendations

Where applicable, the OFC identifies commendable practices or recommendations for improvement related to the specific duties and general duty.

Sources

Assessment outcomes, comments, and commendable practices and recommendations are based on information provided by the regulatory body. The OFC relies on the accuracy of this information to produce the assessment report. The OFC compiles registration information from sources such as the following:

  • Fair Registration Practices Reports, audits, Entry-to-Practice Review Reports, annual meetings
  • the regulatory body's:
    • website
    • policies, procedures, guidelines and related documentation templates for communication with applicants
    • regulations and bylaws
    • internal auditing and reporting mechanisms
    • third-party agreements and related monitoring or reporting documentation
    • qualifications assessments and related documentation
  • targeted questions/requests for evidence that the regulatory body demonstrates a practice or principle

For more information about the assessment cycle, assessment process, and legislative obligations, see the Strategy for Continuous Improvement.

Top ›



References

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


Top ›