Health Workforce Regulatory Oversight Branch

Summary Report: College Performance Measurement Framework


Self-Regulation of Health Professions in Ontario

In Ontario, the primary model for regulation of health professions is based on self-governance 1. The Regulated Health Professions Act, 1991 (RHPA) establishes 26 health regulatory Colleges (Colleges) that govern 28 professions in the public interest. Under the (RHPA) and profession specific Acts, Colleges are responsible for ensuring their respective professions provide health services in a safe, professional and ethical manner. In order to practice in Ontario, regulated health professionals must be registered with a College.

Central to their mandate, Colleges ensure that their registrants are skilled, qualified to practice, maintain their competence, comply with standards of practice and are disciplined, where necessary. They vary widely in size and resources, as well as in the scope of practice and controlled acts that registrants are authorized to perform.

The Colleges are structured like corporations, with councils that function as a Board of Directors. College councils are comprised of members of the profession, who are elected by their peers, and lay persons who are appointed by the Lieutenant Governor in Council. Professional members make up 51% of the council with public appointees comprising 49%. Councils meet quarterly and meetings are open to the public.

Each council appoints a Registrar who is an employee of the College and functions as a Chief Executive Officer. The Registrar performs statutory duties outlined in the (RHPA) and is also responsible for managing the operations and overseeing College staff.

Colleges are financially independent from government and are financed through fees collected from their membership bases.

What is the College Performance Measurement Framework?

The College Performance Measurement Framework (CPMF), was developed collaboratively by the ministry, health regulatory colleges, members of the public and subject matter experts. It is intended to strengthen the accountability and oversight of Ontario’s health regulatory Colleges by providing publicly reported information that is transparent, consistent and aligned across all 26 regulators. Reporting performance on a standardized set of measures also enables Ontario’s health regulatory colleges to continuously improve performance by identifying and reporting on commendable practices among peers.

Colleges also report specifically on their registration processes through an annual Fair Registration Practices Report submitted to the Office of the Fairness Commissioner 2. Additionally, Colleges are required by legislation to publish annual reports that highlight their activities over the previous year. The only mandatory information that must be included in the annual report is an audited financial statement and the content of the reports vary from College to College. The CPMF is distinct from these reports and unique in that it provides a broad overview of the Colleges’ governance and operations.

The CPMF has the following components:

  • Measurement domains: Critical attributes of an excellent health regulator in Ontario.
  • Standards: Performance-based activities that a College is expected to achieve and against which a College will be measured.
  • Measures: More specific requirements to demonstrate and enable the assessment of how a College achieves a Standard.
  • Evidence: Decisions, activities, processes, or the quantifiable results that are being used to demonstrate and assess a College’s achievement of a standard.
  • Context Measures: Statistical data Colleges report that will provide context about a College’s performance related to a Standard.
  • Planned Improvement Activities: Initiatives a College commits to implement over the next reporting period to improve its performance on one or more standards, where appropriate.

The CPMF has seven Measurement Domains that contribute to a College effectively serving and protecting the public interest. The Measurement Domains are Governance, Resources, System Partner, Information Management, Regulatory Policies, Suitability to Practice, and Measurement, Reporting and Improvement. The 2020 reporting period is the first year Colleges have completed a report. During initial reporting cycles a College’s regulatory performance will not be assessed or ranked.

Each College has posted its completed 2020 CPMF Reporting Tool on its website.

What is the Ministry’s Summary Report?

This Summary Report (Report) provides a system level overview of all 26 Colleges’ self-reported results organized by Measurement Domain. The Report highlights some commendable College practices, areas where Colleges are collectively performing well, potential areas for system improvements, and the various commitments Colleges have made to improve their performance.

The commendable practices included in this Report were identified by a Working Group comprised of representatives from the Colleges, the public and experts in performance measurement. For the purposes of this Report, a commendable practice is defined as a system, tool or method intended to improve a regulatory practice. The Working Group reviewed all 26 reports against selection criteria to identify 52 commendable practices across all Measurement Domains. Selection criteria considered the following:

  • importance to regulating in the public interest,
  • the flexibility/adaptability of the commendable practice,
  • the effectiveness/applicability to all health regulatory Colleges, and
  • the efficiency of the practice.

This Report highlights the top six commendable practices identified by the Working Group. The Collective Strength sections of the Report will also identify notable practices where Colleges reported performing well.

Key Observations from the 2020 CPMF

The ministry recognizes and would like to thank the Colleges for the significant effort required to complete the CPMF reporting tool, particularly given the disruptive impact of COVID-19 on College operations during the 2020 calendar year. Many Colleges needed to reallocate resources to support health professionals in providing safe, competent and ethical care to their patients throughout the pandemic. The ministry notes that COVID may have caused variation in some of the information reported when compared with other operating years.

All of Ontario’s 26 health regulatory Colleges completed and posted their Reports on their websites. Collectively, they have demonstrated a strong commitment to transparency regarding how they operate and make decisions, and to improving their performance.
On a system-wide basis, Colleges reported:

  • A commitment to strengthening and modernizing governance structures. This included ensuring that their Councils and Committees have the knowledge and skills necessary to strategically guide them and ensure they are meeting their public interest mandate.
  • Strong performance related to the administration of their registration and complaints and discipline processes, as well as those related to the provision of guidance to the professions they regulate.
  • That they have implemented processes and policies to protect information that they collect from unauthorized disclosure.

The ministry would like to commend the Colleges on their efforts to collaborate as broader health system partners. This helps support alignment of practice expectations across the health system and ensures that Colleges can respond to changing public expectations in a timely manner.

Potential areas for system improvement include enhancing how Colleges measure their performance and use that information to better ensure public protection. Colleges can also continue to build on the significant work underway to modernize governance. This will ensure consistency with respect to competency-based selection of Council members, transparent and accessible communications about conflict of interest and how Council decisions reflect the public interest, among other things. Formalizing policies and processes for the review and development of guidance to registrants will also support the delivery of quality care. Further, the integration of “right touch regulation” in the administration of Quality Assurance Programs and their complaints and discipline processes will help ensure that regulators use effective and efficient processes that are proportionate to the level of risk to the public. Lastly, clearer linkages between a College’s budget and actions/deliverables in their strategic plan could help increase transparency, and formal policies regarding financial reserves will ensure the sustainability of the College.

During initial reporting cycles, a College’s regulatory performance will not be assessed or ranked. The CPMF is a journey towards the assessment of regulatory excellence where, in future reporting cycles, Colleges will be assessed and scored based on established performance benchmarks. The baseline data that is being collected over the initial reporting cycles will be used to set benchmarks. The ministry looks forward to receiving the Colleges’ 2021 reports in March 2022.

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Domain 1: Governance

Effective governance is essential for a College to meet its public interest mandate. A College’s Council and its Statutory Committees are responsible to determine the strategic direction of the College and to ensure the overall financial stability of a College. Furthermore, Council and Statutory Committee members must have the required knowledge and skills to provide informed contributions for effective oversight.

Commendable Practices

The Working Group identified two commendable practices that are included in this Report.

  • Ensuring Council and Statutory Committee members have the knowledge, skill and judgement to effectively meet their fiduciary duties.
  • Competency of Council and committee members is a critical part of any high performing organization. For Colleges, it ensures that public interest questions brought before the Council are considered by individuals who have the knowledge and skills to determine the best solutions to serve the public.
  • The Royal College of Dental Surgeons of Ontario (RCDSO) has established a set of competencies for its Council and Statutory Committees against which professionals wishing to serve are assessed by an independent committee. Additionally, these individuals must complete an eligibility course and a 21-question assessment. This is followed by an orientation for those elected to Council or appointed to Committees.
  • The Working Group felt this model supports improved decision-making.
  • Transparently communicating the public interest rationale and evidence supporting Council decision-making.
    • Council and Committees are expected to make decisions in the public interest, free from influence by professional or other interests.
    • The College of Midwives of Ontario’s Council meeting materials are publicly available on its website and clearly identify the public interest rationale and evidence supporting each topic brought to Council. In addition, topics are accompanied by a regulatory impact assessment that identifies risks and assesses potential impacts and regulatory options to mitigate those risks.
    • The Working Group felt this practice supports transparency in the College’s decision-making processes and clearly connects decisions to the public interest.

Collective Strengths

In 2014, the College of Nurses of Ontario (CNO) initiated an extensive review of all aspects of its governance. In 2016, it published its vision for governance in a report called “Final Report: A vision for the future”. Since this time, numerous Colleges have dedicated significant time and resources to strengthening their governance structures. For example, the Working Group identified notable practices by the Ontario College of Pharmacists, the College of Physicians and Surgeons of Ontario, the College of Medical Radiation and Imaging Technologists of Ontario, the CNO and the RCDSO, who have taken steps to modernize and improve their governance structures.

All Colleges reported initiating work on governance modernization, including developing and implementing core competencies for Council and Committee members, strengthening training and orientation for Council and Committee members, and evaluating the effectiveness of Council meetings and Council itself.

Colleges collectively self-reported strong performance in transparently communicating their strategic plans or objectives, as well as policies and procedures regarding Council conduct and conflict of interest. The majority of Colleges also reported they provide information about Council meetings and discipline hearings in a timely manner.

System Improvement

Even though multiple commendable practices were identified in this Domain, there is still an opportunity to drive consistency and improved governance structures across all colleges. The Working Group noted that the commendable practice regarding Council and Committee competencies is adaptable and could be expanded across most, if not all, Colleges.

Additionally, ministry review of College reports identified that the process used by Colleges to identify, monitor and make public declarations of conflict of interest could be strengthened. Conflict of interest processes may benefit from continued work to increase the transparency and accessibility of this information across the system of regulators as a whole.

Lastly, while significant work is underway already, the review also identified that Colleges can continue to strengthen methods to:

  • clearly communicate how Council decisions reflect the public interest,
  • provide updates on the College’s process in implementing Council decisions, and
  • identify the activities and/or projects that support its strategic plan and how these are linked to the College’s financial plan and budget.

Improvement Commitments by Colleges

Colleges made commitments to improve in the following areas:

  • Implementation of competencies for professional Council and Committee members,
  • Evaluation of Council meetings and Council itself, including a third-party assessment at a minimum of every three years,
  • Transparent identification of the public interest rationale in Council meeting materials, and
  • Transparent and accessible communication of Council member’s conflict of interest declarations.

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Domain 2: Resources

For a College to be able to meet its statutory objects and regulatory mandate, now and in the future, it requires effective planning and management of its financial and human resources. It is important to demonstrate that appropriate financial management policies are in place and followed, including a plan to meet unanticipated financial demands. Furthermore, the CPMF asks Colleges to demonstrate how their strategic plan and budget complement and support each other. Lastly, recognizing that staff is a key resource for effective College operations, Colleges are asked to show how they maintain their workforce now and for the future.

Collective Strengths

The majority of Colleges reported that their strategic plan was costed with resources allocated accordingly. The most common evidence provided included a copy of the College’s budget, along with its strategic plan, and confirmation that the strategic plan is considered in the annual budget planning process.

While none of the top commendable practices identified by the Working Group in this Domain are included in this report, the Working Group highlighted a notable practice by the College of Massage Therapists of Ontario (CMTO) related to learning development processes for College staff. The CMTO reported that it uses an internal learning management system to ensure it has a capable and competent staff complement. The CMTO’s learning management system provides a curated and self-directed learning program to all staff on administrative and management topics to ensure skill development and the development of a shared leadership culture. The Working Group noted that human resources are central to day to day operations and managing an organization’s workforce is required to support organizational success.

System Improvement

Colleges’ self-reported results identified two main areas for continued growth related to financial reserves, and support of a sustainable workforce.

Many Colleges reported that they allocated financial reserves as part of the budget planning process and that the reserve amounts were approved by an external auditor. There is an opportunity to strengthen transparency of these processes and enhance consistency across Colleges by encouraging the development and implementation of formal financial reserve policies. Policies should identify the amount of financial reserves the College should hold and criteria for how the reserves would be used.

Additionally, many Colleges reported that Council approved staff resources through budget planning. However, few Colleges provided detail regarding Council’s role in ensuring that there is a formal process for professional learning and development for staff and succession planning for senior leadership.

Lastly, clearer linkages between a College’s budget and actions/deliverables in the strategic plan could help increase transparency.

Improvement Commitments by Colleges

Colleges made commitments to improve in the following areas:

  • Development of formal reserve fund policies that are validated by a financial auditor,
  • Establishment of robust reserve funds,
  • Development of policies and processes to address succession planning, and
  • Consultation amongst Colleges to identify best practices in human resource planning.

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Domain 3: System Partner

Colleges are one of several actors that oversee Ontario’s regulated heath workforce. By partnering with other health regulatory Colleges and system partners, such as hospitals, and educational institutions, a College can:

  • align practice expectations across practice settings and professions (where relevant),
  • address issues proactively, and
  • support continuous improvement in the quality of care.

To effectively respond to changing public expectations, a College must be informed by, and partner with, the broader health system, including patients and their families.

Commendable Practices

The Working Group identified three commendable practices that are included in this Report.

  • Responding to changing public expectations.
  • A College’s regulatory activities need to be in-step with changing public expectations, population health needs, and models of care, as well as evolving clinical evidence and advances in technology.
  • The College of Audiologists and Speech-Language Pathologists of Ontario (CASLPO) implemented several initiatives in response to changing public expectations. This includes Trust Matters and Patient Rights campaigns to build public confidence and awareness when receiving care from a CASLPO professional. It also includes developing an internal Diversity, Equity and Inclusion (DEI) strategy and initiating an anti-BIPOC racism working group with other regulatory partners to influence a broader anti-BIPOC approach across all Colleges. CASLPO’s strategy is diverse and includes a dedicated webpage, appointment of a DEI Officer, training for all Council and staff, and an e-forum for registrants.
  • The Working Group identified this commendable practice as critical to the public interest mandate of Colleges.
  • Establishing system focused quality indicators for the profession.
  • Collaborating with system partners enables Colleges to be sensitive to changing patient and system needs, and positively impacts a College’s ability to plan for the future.
  • In 2018, the Ontario College of Pharmacists (OCP), in partnership with Ontario Health (Quality), started developing quality indicators for the profession that are aligned with Ontario health system indicators. The goal of this work is to focus on the impacts of health care on patient and system outcomes and provide the public and stakeholders with a clearer picture of the overall quality of care being provided by pharmacists. Partners from across the health system were engaged, and included academia, the Ministry of Health, physicians, registrants of the OCP, professional associations, data and analytics experts, and patients.
  • The Working Group noted that collaboration and development of well-defined partnerships can produce positive results in terms of public protection and health system planning.
  • Notification tool on the Public Register.
  • Engaging collaboratively with system partners enables Colleges to identify initiatives that support continuous performance improvements and meeting changing public expectations.
  • The College of Dental Hygienists of Ontario has implemented a notification tool that will allow a member of the public, or an employer, to sign up to receive notifications about changes to information posted on the Register for specific dental hygienists. This initiative was started as a result of collaboration with the public via a Citizen Advisory Group (CAG), that identified an interest in the ability to find current information about their practitioner. The CAG noted that information on a website was only current as of the day you accessed the register. The College has developed a video that provides information about what the tool is and how to use it. Notifications are sent by email and include changes to information relating to a registrant’s registration status and conduct.
  • The Working Group noted that this feature is the first of its kind for a regulator in Ontario and a commendable practice that improves transparency and timely communication of information about registrants to the public.

Collective Strengths

Colleges provided diverse examples of how they collaborate with system partners to improve the alignment of practice expectations and to respond to changing public expectations. Many Colleges identified broad and targeted stakeholder engagement strategies to respond to changing system and public needs in a timely manner.

Throughout the COVID-19 pandemic Ontario’s health regulatory colleges have worked to ensure that regulated health professionals have the information they need to provide competent and safe care during the pandemic. A notable practice identified by the Working Group was the collaborative effort to create return to practice guidance between the College of Kinesiologists of Ontario, the College of Occupational Therapists of Ontario, the College of Massage Therapists of Ontario and the College of Physiotherapists of Ontario.
The Working Group also identified a notable practice by the College of Opticians of Ontario. The College is working with several other Colleges to build joint resources related to procurement and shared data collection and analysis services. This will address challenges faced by small and medium-sized Colleges.

Lastly, the Working Group identified notable practices related to public safety by the College of Nurses of Ontario (CNO). The CNO has worked to implement the recommendations of the 2018 Long-term Care Homes Public Inquiry, developing and sharing multiple resources on preventing intentional patient harm that are relevant to all regulated health professionals. Additionally, the CNO is collaborating on the development of a national database for sharing nurse registration and discipline information. The database will enable proactive sharing of information about nurses across jurisdictions and will enhance public safety in a time of increasing labour mobility.

System Improvement

Colleges are encouraged to continue to build upon the system partnerships they have established and to use examples reported by other regulators to identify new relevant opportunities.

The Working Group noted that the commendable practices identified above are applicable to all Colleges. The Working group also highlighted that the necessary resources and tools for patients are well defined on the CASLPO’s website to support adaptation and implementation in other Colleges. Additionally, Colleges are encouraged to continue to find ways to incorporate patient and public perspectives and feedback into their work.

Improvement Commitments by Colleges

The System Partner Domain did not request Colleges to provide specific evidence to demonstrate how they met a Standard, given that all Colleges interact with the health system differently based on the profession they regulate. Many Colleges provided information about projects that were in the process of being implemented. Where a College provided an example of work that was underway, they have been asked to provide an update on their progress in future reports.

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Domain 4: Information Management

Colleges collect and hold confidential information that must be retained securely and used appropriately in the course of administering their regulatory activities and legislative duties and objects. Colleges must ensure that they have policies and processes in place to govern the collection, use, disclosure, and protection of information that is of a personal (both health and non-health) or sensitive nature.

Collective Strengths

The majority of Colleges reported that they have policies and processes to govern the collection, use, disclosure, and protection of sensitive information. Colleges used a variety of methods to achieve this, including the use of Privacy Codes, confidentiality undertakings signed by staff, data protection policies for information collected through websites, and data retention and safeguarding. The majority of Colleges noted that the disclosure of data was done in accordance with requirements set out in the Regulated Health Professions Act, 1991 (RHPA) and was limited to the information posted on the Public Register.

The Working Group noted the Royal College of Dental Surgeons of Ontario (RCDSO) had a notable practice regarding its implementation of a range of privacy and confidentiality policies intended to ensure the College’s legal obligations are met. Policies include a focus on information security, acceptable use of systems and related services, records management, and workplace social media conduct. The College also provides information technology (IT) security awareness training for staff and planning for the possibility of IT security breaches. Lastly, the RCDSO has a designated Privacy Officer and privacy lead who consults with staff regarding the management and disclosure of confidential and private information.

System Improvement

Disclosure of information by Colleges, within the existing legal framework, is a potential area of improvement for Colleges. Since Colleges are not subject to privacy legislation, it is important that they have formal and transparent policies and processes governing the disclosure of information. This includes the development of criteria for disclosure and actions in response to unauthorized disclosure. The development of robust formal policies regarding the disclosure of information is important to support public accountability.

Improvement Commitments by Colleges

Colleges made commitments to improve in the following areas:

  • Development and implementation of formal policies and processes related to the collection, use, retention and disclosure of data where Colleges reported informal policies and processes,
  • Development and implementation of formal policies and processes for managing any unauthorized disclosure of confidential or private information, and
  • Processes for the regular collection of statistics regarding any unauthorized disclosure to support identification of patterns can be used to prevent further incidents wherever possible.

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Domain 5: Regulatory Policies

Colleges are required to develop and maintain practice expectations for registrants. This enables the public and patients to be aware of what behaviours they should expect when receiving high quality care from a regulated health professional. In order to keep expectations current and up-to-date, Colleges must have a process in place to identify when standards of practice, policies or guidelines need to be updated or when new guidance is required. When updating expectations, Colleges should consider relevant evidence, changing public expectations, risks to the public, and alignment with other relevant health professions. This process should include consideration of feedback from relevant stakeholders, including patients and their families.

Collective Strengths

All Colleges reported that they regularly monitor the broader health and regulatory environment to assess the need to develop or revise their policies, standards of practice, and practice guidelines. Additionally, the majority of Colleges reported using a variety of sources of evidence to inform the development and revision of practice guidance.

The Working Group identified the principle-based policy development process by the College of Midwives of Ontario (CMO) as a notable practice. The CMO uses a rigorous and structured process for the development and revision of guidance that is based on the principles of good regulation. This ensures that:

  1. Regulation is proportionate to the risk of harm being managed,
  2. Regulation is evidence-based and reflects current best practice, and
  3. Regular and purposeful engagement is undertaken with partner organizations, midwives, and the public throughout the policy making process.

The process is intended to encourage use of regulatory tools to mitigate risk only when other non-regulatory options are not able to produce the desired results.

System Improvement

All Colleges reported that they have processes to develop or update guidance that they provide registrants. In some instances, these processes were formal, whereas in others they were informal. There is opportunity to improve transparency across all Colleges by formalizing policies and processes for the review and development of guidance.

There was variability in the process used by Colleges to identify the need to revise or develop guidance. Colleges are encouraged to implement a variety of methods, in addition to a regular review cycle, to monitor whether revisions or new guidance is necessary. This would help Colleges to provide their registrants with timely, up-to-date and relevant guidance.

Improvement Commitments by Colleges

Colleges made commitments to improve in the following areas:

  • Formalizing policies and processes for policy, standard and guideline review and development, where processes are currently informal,
  • Incorporation of a risk assessment in the development of standards, guidelines and policies, and
  • Updating review processes to enable timely review of all standards, guidelines and policies to ensure relevancy to current and evolving professional practice, as well as changing public expectations.

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Domain 6: Suitability to Practice

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 3.

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.  Colleges 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 (e.g. law enforcement, other governments, etc.) 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, and
  • Development of policies and consistent criteria for sharing concerns about a registrant with relevant regulators and external system partners, within the legal framework.

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Measurement, Reporting and Improvement

Performance measurement and evaluation are vital concepts of regulatory excellence. This includes how a College measures, analyzes and reports its performance against its strategic goals and regulatory activities. Additionally, it includes how a College identifies and assesses risks and how it uses the information to continuously improve its regulatory performance.

Collective Strengths

Colleges reported that they are dedicated to transparently reporting on their performance against their strategic objectives and regulatory activities. Many Colleges provide regular updates at Council meetings using a variety of tools to communicate their progress (e.g. briefing notes, balanced score cards, dashboards, etc.).

The Working group identified a notable practice by the College of Medical Laboratory Technologists of Ontario (CMLTO) regarding the use of a publicly available governance risk register. Approximately every two years the CMLTO’s Council reviews risk trends to update its governance risk register and to ensure there are no key gaps in its policy parameters or in actions Council should be taking. The Working Group noted that the use of a risk-based approach drives regulatory effectiveness by clearly articulating the College’s role in understanding and addressing the current and emerging risks to clients/patients. Additionally, it was noted that regular review of regulatory and profession-specific risks can be done using both internal and system-level data and allows Colleges to identify and proactively respond to risks to the organization.

System Improvement

While the majority of Colleges report performance outcomes, there is opportunity for greater consistency in how Colleges communicate how regulatory performance is measured and how results are used to drive improvement. Key performance indicators can be more consistently identified, including why those particular indicators are important. Additionally, it is possible to better communicate how performance and risk review findings have translated into improvement activities.

Improvement Commitments by Colleges

Colleges made commitments to improve in the following areas:

  • Development of and implementation of key performance indicators to measure performance against the strategic plan, for Colleges using informal measures,
  • Implementation of a formalized approach to risk, as well as the use of risk-based data, and
  • Development of formal processes for using the key performance indicator data to identify areas for improvement.

1 Ontario has recently adopted an additional model of oversight under the Health and Supportive Care Providers Oversight Authority Act, 2021 (HSCPOAA) which received Royal Assent on June 3, 2021. The HSCPOAA will implement a new regulatory framework for the oversight of individuals providing health and supportive care services, beginning with Personal Support Workers (PSWs) in Ontario. The framework would create a new designated administrative authority-type entity named the “Health and Supportive Care Provider Oversight Authority” (the ‘Authority’) for the purpose of overseeing individuals providing supporting care and services. This approach is distinct from the existing self-regulatory college model under the Regulated Health Professions Act, 1991 (RHPA). At this time, the CPMF does not apply to the Authority. Any future application of the CPMF to this new oversight body would need to consider how the role of the Authority differs from a health regulatory college.

2 The Office the Fairness Commissioner works with the regulated professions and compulsory trades in Ontario to ensure that they have registration practices that are transparent, objective, impartial and fair. The Office is independent of the Ontario government and regulated professions and compulsory trades.

3 Cornelissen, E, Mitton, C, Sheps, S. Knowledge translation in the discourse of professional practice. International Journal of Evidence-Based Healthcare 2011 June; 9(2): 184-188. Published online 2011 May 23. Doi: Retrieved at on August 7, 2019.


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