Overview

Colleges strive to ensure that those who practice the profession are qualified, skilled and competent to practice. Colleges achieve this by registering qualified practitioners, setting requirements for continuing education and professional development, supporting registrants in meeting practice expectations and investigating complaints and disciplining registrants where necessary. Colleges should apply a “right touch regulation” to its registration, quality assurance, and complaints and discipline processes to ensure that the regulatory activity undertaken is proportionate to the risk to patients and the public posed by the registrant.

Commendable practices

The working group identified one commendable practice that is included in this Report.

  • Transparency of the complaints process.
  • A college must ensure that all complaints, reports and investigations are conducted in a timely manner and that necessary actions are taken to protect the public. When a complaint about a regulated health professional is received, a college should ensure all parties receive timely communication to support both the registrant’s and the complainant’s ability to participate effectively in the process, increase transparency and improve procedural fairness.
  • The College of Physiotherapists of Ontario (CPO) transparently outlines the different stages of its complaints process on its complaints webpage. Information on how to submit a complaint is clearly identified and accessible in 10 different languages. This includes information about how to apply for funding for therapy and counselling for patients who have been sexually abused by a physiotherapist. Complaints can be submitted by mail, electronically (through the website or by email) or by phone if accommodations are required.
  • The working group noted that the practice of providing information about the complaints process in several languages shows a willingness to tailor its complaints process to accommodate a diverse population and ensure confidence in the process.

Collective strengths

All colleges reported having processes in place to ensure that those who are registered meet applicable registration requirements. This includes processes to review and validate documents and confirm information submitted by third parties on behalf of an applicant. Additionally, the majority of colleges have processes in place to ensure that the assessment of registration requirements is periodically reviewed against best practices. The working group identified a notable practice by the College of Medical Radiation and Imaging Technologists of Ontario (CMRITO). The CMRITO has developed a career map for international applicants that provides step by step instructions on the application process, the evaluation process and sets out what documentation is required to support an application for registration. This career map also provides the timing associated with registration and what is required of applicants at each stage of registration.

The majority of colleges identified that they have processes to assess ongoing competency of registrants who are practicing the profession. The processes also ensure that registrants who required remediation after participating in the college’s Quality Assurance (QA) Program subsequently demonstrate the required knowledge, skill and judgement.

The working group identified multiple notable practices related to the delivery of college’s QA Programs. These included the College of Occupational Therapists of Ontario’s (COTO) and the College of Optometrists of Ontario’s (CoptO) risk-based processes for selecting registrants to undergo a continuing competency assessment as part of the QA Program. The Working Group noted that these processes are aligned with the principles of right touch regulation and identify higher risk registrants. The COTO’s process includes categorizing risks into four categories, assigning a risk rating to registrants and using this data as a basis for selection of registrants who will undergo a competency assessment. The CoptO uses its complaints data to identify areas of practice that may pose a higher risk and incorporates this into how it selects registrants to participate in the QA Program. Additionally, QA activities focus on areas of practice that provide the most accurate picture of a registrant’s practice and allow for less intensive reviews unless an assessment identifies a comprehensive review is needed. The College of Dietitians of Ontario and the RCDSO have incorporated methods for registrants to self-assess risk and follow up on areas that need improvement into their QA processes.

The majority of colleges reported robust processes that ensure that individuals involved in complaints processes are supported and receive regular updates on the progress of their complaint or discipline case. Colleges also reported that they transparently and clearly communicate about the stages of the complaints process and the supports available to complainants. The working group identified a notable practice by the College of Massage Therapists of Ontario (CMTO). The CMTO makes information about the complaints process available in multiple languages, and also provides information in an audio format. The College of Naturopaths of Ontario (CONO) publishes anonymous complaint information on its website, including the date when the complaint was filed, the issues or concerns included in the complaint and the current stage of the complaints process. When a complaint is closed, the college provides the outcome of each matter and the date of closure.

System improvement

Colleges are encouraged to continue integrating a “right touch regulation” approach to their QA Programs, as well as to aspects of their complaints and discipline processes. Increased consistency in the use and development of policies and processes that support the identification of higher risk practice areas and proportionate remediation will support colleges in improving their performance. Additionally, while many colleges communicate changes to standards of practice or practice guidelines to registrants, many do not provide additional tools or advice to support them in implementing required changes or expectations in their practice. To support the delivery of up to date, safe, effective, efficient and patient-centered care, registrants must be able to apply relevant guidance provided by colleges to real-life practice and issues within their individual practice.

The working group noted that the commendable practice related to provision of information about the complaints process in multiple different languages is appliable, and could be implemented, across all colleges. There is also opportunity to improve consistency amongst colleges in providing responses to inquiries about the complaints processes within 5 business days. A college could also provide additional transparency about how they assess risk and prioritize investigations, complaints and reports. Lastly, greater consistency can be achieved regarding colleges’ collaboration with other relevant regulators and external system partners (such as law enforcement or other governments) where concerns about a registrant are identified. To support robust public protection, colleges are encouraged to develop formal policies outlining criteria for sharing this information with other relevant regulators and external system partners, within the existing legal framework.

Improvement commitments by colleges

Colleges made commitments to improve in the following areas:

  • development of policies and processes regarding the education and support provided to registrants in applying standards of practice and practice guidelines
  • revising QA Programs to incorporate a “right touch” and risk-based approach
  • improving processes to track response times to inquiries about the complaints process
  • development of policies and consistent criteria for sharing concerns about a registrant with relevant regulators and external system partners, within the legal framework