Education and Supervised Clinical Training Requirements During the COVID-19 Pandemic

Dear Students and Applicants,

As you are aware, the Ontario Government has enacted a declaration of emergency to help contain the spread of COVID-19 and protect the public. Earlier this month, the Chief Medical Officer of Health (CMOH) issued a letter requesting that Ontario colleges and universities immediately look to virtual options to provide services. The College has subsequently contacted all known traditional Chinese medicine programs in Ontario, recommending that TCM schools take the CMHO request into consideration. Since then, the College has received numerous questions regarding this recommendation. We are contacting you now to provide further clarification on the College’s position with regard to online education, and the implications of COVID-19 on applicants’ eligibility to write the October 2020 Pan-Canadian examinations.

Online Courses

In consideration of the challenges posed by the COVID-19 pandemic, the College will recognize, on an interim basis, online didactic courses1 offered during the pandemic as equivalent to classroom theoretical instruction, as described under section 9 of the Registration Regulation. That is, one of the registration requirements for the General class being the successful completion of a post‐secondary program in traditional Chinese medicine (TCM). Under the Registration Regulation, the program must:

  1. in the case of a full traditional Chinese medicine program, consist of at least four years of full-time education, or education that is of equivalent duration, and
  2. in the case of a traditional Chinese medicine acupuncture program, consist of at least three years of full-time education, or education that is of equivalent duration.

The regulation further defines full-time education as “a program of study that annually consists of at least 480 hours of classroom theoretical instruction or at least 620 hours of practical instruction or some combination of the two where, for every hour of classroom theoretical instruction that is less than 480 hours there must be a corresponding increase of 1.3 hours in the number of hours of practical instruction”. O. Reg. 27/13, s. 1.

The online didactic courses offered during the pandemic will also be accepted for the purpose of approving candidates for the Pan-Canadian Examinations.

Practical Instruction and Supervised Clinical Training

In addition, to the theoretical and practical requirements listed above, applicants for the General class must also successfully complete a program of supervised clinical training, which consists of at least 45 weeks of clinical experience involving at least 500 hours of direct patient contact.

It is the College’s position that all practical instruction and supervised clinical training must be provided in person. Consequently, while the declaration of emergency remains in effect, all practical instruction and supervised clinical training should be suspended at this time.

October 2020 Pan-Canadian Examinations

To be eligible to write the Pan-Canadian Examinations, candidates must meet the education and supervised clinical training requirements described above. However, due to COVID-19, some students may not be able to complete their clinical training before the July 15, 2020 examinations application deadline.

Recognizing the challenges posed by the current situation, the College will grant provisional approval to write the October 2020 Pan-Can Examinations to all students whose supervised clinical training is delayed because of COVID-19, provided that:

  • the candidate’s application for the Pan-Canadian Examinations meets all other requirements;
  • the College receives confirmation from the program director or coordinator that the candidate meets all the requirements for graduation with the exception of the supervised clinical training; and
  • the student is in the process of completing the supervised clinical training requirement.

The purpose of this provisional exemption is to allow students whose clinical training is delayed because of COVID-19 to write the Pan-Can Examinations in October 2020 only. The exemption does not apply to the supervised clinical training requirement which is required to obtain a General Class certificate. To be granted the General Class Certificate, applicants must meet all the requirements listed under section 9 of the Registration Regulation, this includes completion of the supervised clinical training.

Lastly, please note that it remains the responsibility of each school to ensure that they are delivering quality education and that any online or remote method of delivering education should not impact its quality. TCM schools should continue to provide their programs in a meaningful way that will ensure that students learn the necessary competencies to provide safe, ethical care, and equip the students to demonstrate the competencies required at entry-to-practice.

The College is monitoring the unprecedented situation posed by COVID-19 and will continue to provide updates to our members, applicants, education providers and other stakeholders. This is undoubtedly a difficult time for everyone, and we are grateful for the understanding and patience shown by all of our stakeholders.


Ann Zeng
Registrar & CEO



1 For example, schools can provide online interactive teaching classes which permit the teacher to teach the students the curriculum.