Following the October 13, 2016 notice on the College website, feedback had been received from stakeholders and members of the profession. This follow up notice is to clarify misunderstandings and provide factual information. The College continues to work in balance with ensuring public safety as well as providing support and information to it’s members.
The Council and College operates in an open and transparent manner. All decisions made by Council have proceeded with proper protocols and have fully been open for discussion at the Council table in a fair and objective process.
With this in mind we are pleased to provide additional clarification on the following points.
The College is currently in the review stage of the current Language Fluency Policy, and has not formulated a “proposal” to make amendments. The College has always operated in a fair, transparent and objective manner. It does not intend to create barriers but have the obligation to ensure that applicants are assessed appropriately.
As previously communicated, if the College were to establish a new benchmark for language fluency, it would only be applied to “New” applicants. This benchmark would not apply to existing members, including those in the General and Grandparented classes.
Grandparented members transferring to the General Class with a written language plan, are treated on a case by case basis. The Registration Committee determines if members should continue practicing with a written language plan. However, if a new benchmark is established, those that are under a written language plan, may choose to use it as method to demonstrate that they are reasonably fluent in English or French in order to remove the TCL on their certificate of registration. They would not be required to pass the new assessment unless they choose to use it to demonstrate their own individual language skills.
The College agrees that the use of the Jurisprudence Course, the Safety Program and the Pan Canadian Examination are the current tools to assess if an applicant is reasonably fluent. If a new assessment tool was established it would address a current gap where an applicant would not be required to take the Pan Canadian Examination or the Safety Program, such as a labour mobility applicant.
In regards to the “consultation”, the College is currently conducting research on how this would impact the profession should a new benchmark be established. The College has not formulated a proposal, changed the requirements, nor has committed to any language benchmark. We assure you, if the College develops a proposal for a new benchmark, a full public consultation will be available.
The Doctor Title
The College is in no way disregarding the importance of the doctor title and is planning to pursue the class. However, the College must demonstrate a position that would be supported by the Ministry of Health and Long Term Care, which is in the public interest.
One of the primary recommendations from the Heath Professions Regulatory Advisory Council report in 2006, is that a doctor class would be reserved to those individuals who have completed advanced training from an accredited educational facility. The regulatory body in British Columbia also require that their applicants graduate from an accredited educational institution in advanced TCM training.
In Ontario, the Ministry of Advanced Education and Skills Development, formerly known as the Ministry of Training, Colleges and Universities, does not have a program to provide accreditation for TCM education programs. Discussions have occurred with the Ministry but there has been no formal indication that they wish to establish these plans.
A Doctor Title Working Group meeting is being scheduled to discuss next steps in pursuing the doctor title for this profession.
Professional Member Representation
The College wishes to be clear that in no way by stating General class members demonstrating their competencies through PLAR, reflect or imply that Grandparented members are not competent. The PLAR process was established to demonstrate that a Grandparented member is competent, based on the entry level competencies.
When Registration regulations were drafted, a traditional grandfathering process for experienced practitioners was not a feasible option, which is the reason the regulation was developed to have provisions for the Grandparenting class and the PLAR process. The 5-year period between April 2013 to April 2018 was to permit Grandparented members, if necessary, to upgrade and ensure they are current with best practices in TCM in order for them to pass the PLAR assessment. The practitioners have “demonstrated” their competencies. The statement, is not intended to diminish the qualifications of those in the Grandparented class.
To serve on Council, it is essential for the protection of the public that the College have General Class members. Again, these are individuals who have demonstrated that they have met the competencies to be a General Class member. Council members will be involved in making recommendations and decisions on standards of practice, the qualifications of applicants, as well as assessing the conduct of members.
Additionally, the College circulated the proposed amendments in May of 2015. Through the 60-day consultation, the College only received one response and it was in support of the amendments. The College did not receive negative feedback or comments that did not support the amendments.
The College has released audited financial statements which are included in the Annual Report. The College’s 2015-2016 Annual Report is available for viewing on the web-site.
The College has only made one bylaw amendment in December 2014 to stipulate an increase in membership fees. The other amendments related to membership fees were to freeze the increase for 2015-2016 and the current proposal being circulated for consultation. The current proposal is purely an operational amendment to improve College efficiency and align the membership renewal year with the College’s fiscal year.