Timeline of Entry to Practice Advocacy during the COVID-19 Pandemic

The College of Physiotherapists of Ontario (CPO) updated the eligibility criteria for their Policy for Exempting Provisional Practice Registrants from the PCE-Clinical. This Policy provides guidance for the CPO’s Registration Committee to allow individuals under provisional practice to apply for an Independent Practice Certificate. 

OPA supports the CPO’s decision to expand eligibility criteria for PCE-Clinical exemption, as it will allow more Resident Physiotherapists to apply for Independent Practice. OPA continues to work with the College, Academic Leaders and other stakeholders to move forward solutions for all who have been impacted by delays in registration for independent practice in Ontario. 

On February 2, 2022, the Council of the College of Physiotherapists of Ontario (CPO) passed a motion to submit a proposed amendment to the Physiotherapy Act, 1991. If passed, those who failed the PCE-Clinical once will be able to apply to the CPO Registration Committee for provisional practice in exceptional circumstances such as when the practical examination is not available. Details on the amendment can be found in the materials for the meeting. 

We continue to work with the College, Academic Leaders and other stakeholders to move forward solutions for all who have been impacted by delays in registration for independent practice in Ontario. 

In response to the announcement by the Canadian Alliance of Physiotherapy Regulators (CAPR) regarding the discontinuation of the PCE-Clinical and the statement from the Canadian Physiotherapy Association (CPA), provincial Branches of the CPA have developed a statement to ensure that candidates have the information they need to understand the impact of this announcement. 

The discontinuation of the provision of the clinical component of the examination by CAPR does not remove any requirements referring to clinical or practical examinations within bylaws or regulations for entry to independent practice specific to each province and the Yukon. 

As a result there is no consistent, national process for entry to independent practice. With each province and the Yukon acting individually to determine how to meet their requirements, candidates face different challenges depending on where they are seeking licensing/registration. The loss of a component of a national examination, where it is still embedded in College bylaws and/or regulations, impacts most jurisdictions, especially smaller ones with more limited resources. In addition, for some candidates, including those who have previously failed the clinical examination, and who have not been eligible for alternate routes to independent practice proposed to date in most provinces, this announcement removes any hope that a clinical examination would be available nationally within the first months of 2022. 

Though we welcome the announcement as a clarification of CAPR’s intent moving forward, we call on all national stakeholders – association, regulators, academics, and accreditor – to work in partnership and engage with experts and candidates to determine a national process for entry to independent practice as soon as possible. In the interim the provincial/territorial Associations across Canada will continue to work together and with all stakeholders, sharing resources, advocating and working to remove barriers to independent practice in each region.

Manitoba Physiotherapy Association 
New Brunswick Physiotherapy Association 
Newfoundland and Labrador Physiotherapy Association 
Nova Scotia Physiotherapy Association 
Ontario Physiotherapy Association 
Physiotherapy Association of British Columbia 
Physiotherapy Association of Yukon 
Prince Edward Island Physiotherapy Association 
Saskatchewan Physiotherapy Association 

OPA submitted feedback and recommendations to the College of Physiotherapists of Ontario’s (CPO) consultation on their proposed registration regulatory amendments. The submission focused on areas of the regulation and proposed changes that would, or potentially could, create barriers to fair, timely, and safe entry-to-practice for applicants that are not necessary for public protection. OPA is committed to devoting resources to achieving pathways to registration for affected candidates.

We continue to work with stakeholders involved in this issue to move solutions forward.

Read the Submission

The CPO announced details of their Policy for Exempting Provisional Practice Class Registrants from the PCE-Clinical. OPA has met with the College to highlight serious concerns with the restrictiveness of this exemption policy, including the requirement for 600 hours with supervisor at same worksite and seek clarity on what timelines are being applied to the ‘1200 hours over a year’ requirement.  

OPA remains concerned about the timelines for implementation and the impact on candidates who, at this time, are not eligible for exemption. We continue to work with the College, Academic Leaders, and other stakeholders to expedite solutions for all who have been impacted by delays in registration for independent practice in Ontario.

The CPO’s Registration Committee approved a Policy for Exempting Provisional Practice Class Registrants from the PCE-Clinical. This policy will allow the waving of the requirement of the Physiotherapy Competency Exam (PCE) for some applicants with a current Provisional Practice Certificate and facilitate an application for Independent Practice.  The announcement set out specific eligibility criteria, and timelines, when further information will be available and when the application processes will begin. 
 

Given the lack of detail at this time, OPA conditionally supports this first step to address the needs of all candidates who are waiting for a pathway to independent practice. 

At their meeting on October 14, the CPO Council passed several motions to move forward the work to expedite the registration of candidates affected by the delays in the PCE-Clinical. The OPA supports the pursuit of multiple options to expedite the registration process and safe entry to practice for candidates.  

In a follow-up letter open_in_new to CPO President Theresa Stevens, OPA President Paulette Gardiner Millar shared our support on these steps and the critical importance of clarifying timelines for addressing these motions and regular communications on this work so that all, especially candidates, are informed of progress. OPA also proposes a multi-stakeholder meeting inclusive of the College, Association, five Ontario academic programs and IEPT bridging program to share resources and expertise in order to help move this work forward. 

OPA is pleased that the CPO has expressed a priority on finding a solution to quickly address the barriers faced by approximately 1000 physiotherapy graduates in registering for independent practice. However, we are concerned that in a special meeting of the College Council held on September 20, 2021, the solutions proposed focused primarily on continuing with a clinical exam component and not on the full exploration of options that would expedite solutions to this crisis. Those solutions include changes in regulation, discretionary authorities of the Registration Committee to grant exemptions for those who qualify, or other avenues to assess competency at the entry to practice level. The urgency of the issues requires a strategy consisting of multiple options moving forward at the same time so that viable solutions are available as soon as possible. 
 
In a letter to the College and shared with the Fairness Commissioner and the five Ontario physiotherapy academic programs we have set out regulatory changes and concurrent options available within regulation including our support of the proposed solutions outlined in the open letter from the five Ontario Physiotherapy Programs.

The Canadian Alliance of Physiotherapy Regulators (CAPR) announced that all future scheduled virtual clinical exams are cancelled and that they would be returning to in-person examinations at a future date (to be determined). 
 
OPA has been meeting with the CPO prior to the announcement by CAPR to find solutions that expedite the full licensing of qualified candidates. We are pleased to receive the notice from the CPO of the Special Meeting of Council which will be held on Monday to consider options to address the cancellations. View information about the meeting. 
 
We affirm our position that there needs to be an expedited path to full registration for qualified candidates.

OPA joins with the CPO to express our deep disappointment with the challenges with the Canadian Alliance of Physiotherapy Regulators (CAPR) exam held on September 8, which left many candidates unable to complete their examination. 

OPA will continue to work with the CPO and all stakeholders on the most expedient path to allow full registration of our candidates to provide safe and competent care to Ontarians. 

We also restate our call for a multi-stakeholder approach to address the critical questions surrounding the future of entry to practice processes and examinations in Ontario and nationally. So much has been learned through these challenges and together we can find a better way forward for the physiotherapy community of Canada.

The Fairness Commissioner of Ontario (FCO) has written to the CPO and the letter can be seen on pages 17-22 of the Council package. 
 
The OPA strongly supports the letter’s statement that “It is not acceptable, for example, that registration processes stop applicants ‘in their tracks’ during a pandemic.” 
 
OPA wrote on June 18, 2021, to the College to offer our full cooperation and assistance in acting on the advice tendered in the letter of the FCO.  
 
At the College Council meeting on June 22, 2021, the CPO Council passed a motion to now begin exploring whether the approaches taken in BC and Alberta would be feasible as an alternate approach or if another approach is needed. We are very pleased to see this critical work being prioritized by the CPO.

In response to OPA’s letter, we were pleased to meet with the Fairness Commissioner of Ontario (FCO), Irwin Glasberg, to discuss the delays and need for an interim solution from the College of Physiotherapists of Ontario to expedite entry to practice. As a result of the meeting with the FCO, OPA has written to the Assistant Deputy Minister (ADM) responsible for health professions at the Ministry of Health and requested a meeting. 

Despite the OPA’s longstanding relationship with the CPO and our repeated efforts to highlight issues faced by examination candidates and the public due to delayed national examinations, the CPO has not offered sufficient solutions. Consequently, OPA has no option but to elevate this matter to the Fairness Commissioner of Ontario on behalf of candidates and the public. We will update members when we have more information. 

Letter to the Fairness Commissioner open_in_new – May 12, 2021 

Letter to the College of Physiotherapists of Ontario open_in_new – May 5, 2021 

Letter from the College of Physiotherapists of Ontario to OPA – May 11, 2021 

On March 20-21, 2021, the PCE-Clinical was postponed for a third time since the beginning of the pandemic, this time due to technical issues. OPA affirms that these delays are not acceptable and have resulted in significant personal and professional hardship for candidates. 
 
OPA supports the call to action by the Canadian Physiotherapy Association (CPA) and associations across Canada to ensure that any exam fees paid by candidates be reimbursed and that regulatory Colleges in each province engage in processes to facilitate entry to practice by candidates as soon as possible. OPA also calls on the Council of the College of Physiotherapists of Ontario (CPO) to:

• Petition the Minister of Health for regulatory changes to Ontario Regulation 532/98 section 23 to allow for the up to 77 candidates who were not successful in their challenge of the clinical exam in November 2019 to practice under a renewed provisional license; and 

• Set and approve the Qualifying Exam (the written examination) given and adjudicated by the Canadian Alliance of Physiotherapy Regulators (CAPR) as the examination that fulfills the requirement for Independent Practice. 
   

These are extraordinary times. Where regulation becomes a barrier to meeting the needs of Ontarians and our health system, it must be addressed. We request the Council of the College of Physiotherapists of Ontario consider and implement these proposed actions and steps that both meet the bar for public safety and allow the profession of physiotherapy to respond to the challenges of today and the future on behalf of all the people of Ontario.