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Regulating During the Irregular: Canadian Healthcare Professional Licensing Adaptations During COVID
By: Nataliya Zlotnikov, HBSc, MSc

What They Said: The CPA Said It Well

"There is evidence that exemptions can be developed, other relevant Colleges have been nimble and addressed the ongoing pandemic by changing regulation (for example changes to the Ambulance Act) as needed – we’re calling on the regulatory colleges across the country to consider this action."

What We Said

In our previous blog, Physiotherapy Competency Exam (PCE) Clinical Component Cancelled for Third Time – Is it Time for a Change? We discussed the third cancellation of the Clinical Component of the Physiotherapy Competency Exam (PCE) and the difficult position that so many physiotherapy graduates in our community were now in. 

We also mentioned that the CPA has called for The provincial Regulators (Colleges) to immediately suspend the requirement for completion of the clinical component of the PCE to be eligible for licensure in every province.

Today's Blog: A Guide for Brainstorming and Innovation

People are calling for change. Today's blog is meant to be a guide for that change and innovation. 

Here we summarize how a few other Canadian healthcare licensing regulating bodies have responded to the COVID pandemic.

It is our hope that this piece can spark some progressive conversations within our own profession and community. So that together, we are a part of a licensing process that protects our patients, practitioners, and is resilient, flexible and functional in the face of COVID-19 and beyond. 

Sometimes we have to look outside of our community for inspiration and guidance.

Associations, Governing Bodies & Levels of Government Reviewed:

  • College of Chiropractors of Ontario (CCO) 
  • Sonography Canada
  • College of Massage Therapists of Ontario (CMTO)  
  • Royal College of Physicians and Surgeons of Canada (RCPSC)
  • Government of Ontario (For Ambulance Act)
  • Canadian Alliance of Physiotherapy Regulators (CAPR)

Summary Table of Organizations and Changes 

Please continue reading below for more information on each of the bodies mentioned in the table above and their respective changes. 


1. College of Chiropractors of Ontario (CCO) - Provisional Certificate Initiative

  • CCO cancelled the Spring 2020 sitting of the Canadian Chiropractic Examining Board (CCEB) examination and CCO's Legislation and Ethics Examination due to COVID.
  • This prevented new chiropractic graduates and other applicants from being able to complete the requirements for registration. 
  • CCO rolled out a provisional certificate initiative which entitled new registrants to practice under the direct supervision of a CCO member until such time as they were able to sit the required exams  
  • Provisionally registering these applicants provided greater public access to chiropractic services and allowed graduates to further develop their competencies under appropriate mentorship and guidance.
  • CCO registered 128 new members between March 1, 2020, and November 15, 2020, 61% of whom first registered with a provisional certificate of registration and who have now successfully completed their CCEB and legislation and ethics examinations and may now practice without terms, conditions or limitations.
  • This initiative has been praised by the Ontario Fairness Commissioner who is responsible for ensuring registration practices across all Ontario colleges, professional bodies, and trade associations are fair, impartial, and transparent.

2. Sonography Canada - Virtual only examinations, practical assessment held in practicum, before graduation

  • Practical assessment completed in practicum: Sonographers complete their practical assessment, Canadian Clinical Skills Assessment (CCSA), at the end of their program during their practicum, before their graduation.
  • The educational programs inform students when it is time to begin the CCSA process. The assessment begins when both assessor and candidate feel the candidate is competent enough to work through a case independently.
  • Sonography Canada provides thorough guidance and information for all steps of the CCSA process. If the CCSA is failed, it can be repeated at the discretion of the educational program.
  • For all upcoming exam administration dates (until further notice), Sonography Canada exams will be administered online with remote proctoring.  

3. College of Massage Therapists of Ontario (CMTO) - Virtual Only Examinations

  • As of January 1, 2021, the development and administration of the Objectively Structured Clinical Evaluation (OSCE) and Multiple-Choice Question (MCQ) certification examinations is moving from the College of Massage Therapists of Ontario (CMTO) to Prometric.
  • CMTO has also granted a one-time extension equivalent to the time lost due to the certification examinations not being administered in 2020 in recognition of the impact the COVID-19 pandemic had on this timeframe.
  • A detailed and thorough handbook, A Candidate’s Handbook for Understanding Certification Examinations in Ontario, for the CMTO-Prometric partnership is also available.

4. Royal College of Physicians and Surgeons of Canada (RCPSC) - Oral Exams Not Required

  • RCPSC has made the decision to postpone the spring 2020 exams to the fall.
  • RCPSC has decided that oral exams will not be required for the spring 2020 specialty exams and the fall 2020 subspecialty exams.
  • Requirements for written exam: To take the exam, graduates need a signed re-affirmation from their program director that they have met the required competencies to attempt the written exam. This will be organized between the Royal College and Canadian universities for the spring 2020 candidates. Repeat exam takers, international medical graduates or U.S. graduates, will have to provide the necessary documentation for re-affirmation from an appropriate supervisor.

5. Ontario Emergency Health Services - Regulatory Changes to the Ambulance Act

  • To ensure that there are sufficient paramedics and emergency medical attendants to provide care during a provincial health emergency the Ambulance Act has been amended. 
  • Primary Care Paramedic (PCP) program graduates will be able to work for a longer period of time without passing the ministry's exam as long as they are certified by base hospital physicians to work within their competency and scope of practice and also are provided training by ambulance services.
  • Students enrolled in approved PCP college programs will also now be able to work for certificate ambulance services as emergency medical attendants when paired with a certified paramedic. 
  • In addition, certified ambulance services will be provided with a six-month transition period to continue to employ PCP program students as emergency medical attendants beyond the date identified as the end of the COVID-19 emergency and future public emergencies under the Emergency Management and Civil Protection Act.
  • Advanced care paramedic graduates will be able to work without passing the ministry's exam, as long as they are certified by base hospital physicians to work within their competency and scope of practice.
  • An additional regulatory change waives the annual CPR recertification requirement for the duration of the COVID-19 emergency to allow existing paramedics to continue working.

Canadian Alliance of Physiotherapy Regulators (CAPR)

So what has CAPR decided to do?

About a month after the last Clinical Component PCE cancellation, CAPR sent out an e-mail (19 April 2021) that they have reached a decision. 

Below, we outline the contents of this e-mail and decision:

"The CAPR Board of Directors has made the decision to cancel all administrations of the Clinical Component in 2021 as they are currently scheduled."

  • Clinical Component administrations will be rescheduled working with local partners in each region to deliver smaller, more frequent virtual and in-person exam administrations, which will take place starting in the late summer or early autumn. Details will be provided when they are available.
  • Candidates will be given at least 2 months' notice in advance of proposed exam dates. 
  • CAPR plans to continue with the 12-station Clinical Component developed in response to COVID to allow for both in-person and online delivery, use an updated version of Education Management Solutions (EMS) or another platform. 
  • They also plan to partner with universities and clinics or use other locations to run small, pandemic-safe face-to-face exams when possible. 
  • CAPR plans to return to the traditional, larger-scale, face-to-face administrations of the Clinical Component as soon as the lifting of the pandemic restrictions allows. 
  • CAPR has stated that these plans support a single, national standard of licensure across the country and comply with the principles of fairness and labour mobility. CAPR's goal is to provide regulators with a path forward to continue to treat Internationally-educated and Canadian-educated candidates in an equitable manner.

What Will We Do?

There is a wealth of excellent ideas and options available here. It is not one size fits all. 

Perhaps none of these options are perfect for us, but could maybe serve as a guide and starting point for our own conversation and changes. 

We see what others have done across the Canadian healthcare communities, and we applaud your forward-thinking and innovation.

Do you think CAPR's decision reflects forward-thinking and innovation?

Darryl Yardley invites us all to complete this 100% anonymous, 2-minute survey on the impact of the 'Impact of the 3X (now 6X) Cancelled Physiotherapy Competency Exams': [click here]

What will physiotherapy in Canada look like in the next 5, 10 years? What kind of talent do we want to attract? The changes we make today will determine the face of our profession for years to come.

Let's start a conversation.

You can continue the conversation in Darryl Yardley's 3rd PCE webinar on April 24th at 11 am EST. [register here]

What will we do?

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