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Office of the Manitoba Fairness Commissioner


In response to the Fairness Commissioner’s Recommendations, the College of Occupational Therapists of Manitoba proposed an Action Plan as of June 2011, which was subsequently updated April 2012. 

Action PlanComplete
COTM shared the Fairness Commissioner’s concern regarding the Canadian Association of Occupational Therapists’ (CAOT) appeal policy with the other Canadian occupational therapy regulators at the June 13th and 14th, 2011 Association of Canadian Occupational Therapy Regulatory Organizations (ACOTRO) meeting. In February 2012 COTM and the College of Occupational Therapists of Ontario (COTO) began to meet to identity our shared questions on the CAOT processes. In April 2012, COTM and COTO were able to meet with representatives of CAOT. There is a commitment on behalf of CAOT to review their policies, their web-based materials and their Exam Preparation Manual to determine if information can be communicated in a more fulsome manner. CAOT has provided a rationale for their processes. CAOT has also committed to reviewing their process with their examination provider agency.

COTM will be able to review all CAOT materials and any proposed changes by December 2012.

COTM will develop proper wording to communicate the appeal rights of applicants. At minimum COTM has included this in all applicant letters where relevant. Appeals information will be introduced into COTM’s Internationally Educated Occupational Therapists (IEOT) application guide by December 2012. COTM will also work with the OMFC to develop an Information Sheet on the Reconsideration and the Appeals process. The timelines on this piece will depend upon the ability of the OMFC to prepare this information for all regulators under The Fair Registration Practices in Regulated Professions Act (Act).

With regard to the Fairness Commissioner’s recommendation concerning an applicant’s access to the COTM record on their application file, COTM will add information to the IEOT Initial Application Guide by December 2012. COTM will amend the COTM Policy on Member Information by December 2012 to be explicit on procedures regarding the applicant’s access options. COTM will amend the COTM Initial Registration letters effective June 1, 2012 to communicate this information to applicants.

COTM will review the manner in which it currently assesses and recognizes work experience as it relates to qualifications recognition. Any necessary changes to policies and procedures and to the initial registration (IEOT) guide will be made. This review will be shared with ACOTRO given that an IEOT’s work experience will be relevant to the proposed Competency Assessment Tool (CAT). The CAT will unfold over the next two years as part of the national OT Harmonization Project. As this work progresses, COTM may need to reconsider how it utilizes work experience to fill gaps identified in an applicant’s qualifications recognition process.

In June 2011 COTM committed to adjusting its Criminal History policy to address the option for an IEOT to submit a copy of their Federal Criminal History check regardless of its date along with a current Criminal Records check that would meet the COTM requirement (i.e. it includes the Vulnerable Sector Search and be no older than three months). Over this past year, we have learned that some of what we anticipated regarding Federal Criminal History checks may not be possible. We will work with the OMFC over this next year to gather information and determine if the federal process provides COTM with the information it requires to meet its public protection mandate. It is hoped that this work could be concluded by December 2012.

Using the OMFC resource document, To the Point: A Plain Language Guide for Regulators, COTM will conduct a review of its Initial Application Form, Guide and main registration letters templates, and key Information Sheets. This work was to have been part of an IEOT website overhaul – a project that COTM anticipated commencing in early 2012. This will now begin in the fall of 2012. Once all of the policy and document modifications have been completed, COTM will conduct a plain language review. This will be completed by March 31, 2013.

We continue to recommend that the MB Immigration Resource Guide for Occupational Therapists be retired and removed from the MB Immigration website. COTM will work with MB Immigration and the OMFC to identity critical links to their sites that should be posted on COTM’s website. The Resource Guide will be reviewed to determine if any information needs to be added to COTM Information Sheets or COTM Initial Registration Guide (for IEOTs). This will be part of the larger review of all IEOT registration documents which we plan to begin in the fall of 2012. A formal confirmation of retiring the Resource Guide will hopefully be concluded by December 2012 once we can show evidence that all necessary information has been incorporated into other documents and resources.


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