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Office of the Manitoba Fairness Commissioner

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In response to the Fairness Commissioner’s Recommendations, the College of Registered Psychiatric Nurses of Manitoba proposed the following action plan as of July 2013. 

1. With regard to the assessment and registration information, that CRPNM provide clear, complete and accurate information about:

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a.Graduate registration in the information dedicated for internationally educated psychiatric nurses (IEPNs);

The section of the CRPNM website that is dedicated to Internationally Educated Psychiatric Nurse (IEPN) applicants already includes information about Graduate registration under the link titled “Registration.” Graduate registration is briefly explained. The page also includes direction for IEPNs who have not yet arrived in Canada.

The CRPNM acknowledges that the Graduate registration information found on the pages designed for Canadian applicants is clearer and more complete. On that basis, the CRPNM will update the graduate registration information on the IEPN pages so that similar information can be easily found.

b.Assessment result timelines and more elaborate time range information;

The RPN Guide was initially developed in collaboration with the Department of Immigration and, later with the OMFC. Consultation with a communications/marketing/design company was facilitated through the OMFC in 2011/2012. During that time, there were several conversations about how to best represent a realistic time line for the assessment and registration processes. The RPN Guide was published in May of 2012 after extensive consultation and collaboration.

Acknowledging that this representation may no longer meet the OMFC requirements, the CPRNM will include an update of the timelines section in its overall action to review and update the RPN Guide.

c.Access to records and the possibility of alternative documentation.

The CRPNM will include a statement on the website with respect to the possibility for alternative documentation.

The CRPNM will ensure that the information on the website is complemented by appropriate policies. This will include policies related to alternative documentation and a policy on access to records.

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2. That the CRPNM update the RPN Guide with respect to financial support opportunities and the fee for the Registered Psychiatric Nurses of Canada Examination.

The CRPNM will undertake a review of the RPN Guide in consultation with our Immigration and OMFC partners. The CRPNM will update any relevant assessment and registration information and will ensure that the fees in the RPN guide are current. The CRPNM will consult with the department of Immigration and the OMFC for current and accurate information regarding financial and other supports available to IEPNs.

3. With respect to the appeal process, that the CRPNM:

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a.Provide complete, clear and accurate appeal information in the registration material and in its assessment result letters, including timelines and the process to initiate appeal;

The CRPNM will provide appeal information in the registration material by including a statement on appeals on the CRPNM website.

The CRPNM currently provides applicants with information on its reconsideration process when it communicates a registration decision. The CRPNM will provide additional information about appeals by referring the applicant to the website and the Registered Psychiatric Nurses Act.

The CRPNM will develop a fact sheet to outline the process and timelines for the appeal of registration decisions as outlined in the Registered Psychiatric Nurses Act. This will be complimented by registration policy development.

b.Ensure the CRPNM Board of Directors has appropriate appeal training or access to appropriate expertise to conduct an appeal.

The CRPNM Board of Directors is always interested in any education or training that would assist them in their roles and responsibilities to govern the organization and carry out the mandate of the Registered Psychiatric Nurses Act. While the Board is aware of their role as the appellant body for registration decisions, these types of appeals have been extremely rare. Irrespective of appeal training, the Board always has the option of accessing CRPNM legal counsel for advice in conducting an appeal.

The CRPNM Governance Committee, responsible for identifying the Board’s education needs, will work with the Board to assess their current and ongoing education needs in this area. The Board will develop and implement an education plan considering issues related currency, sustainability and resources.

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4. That CRPNM place a moratorium on the new, higher English and French language proficiency levels until such time as better research can be produced that warrants increasing the requirements and that CRPNM commit to resolve this issue.

The CRPNM is unable to comply with this recommendation at this time. The CRPNM provides the following clarifications and rationale:

- A high degree of language proficiency (reading, writing, listening and speaking) is extremely important in providing safe psychiatric nursing care. The core of psychiatric nursing practice is therapeutic communication and the therapeutic relationship. The domains of emotion, behaviour and cognition are a major focus in psychiatric nursing practice and many psychiatric nursing interventions are performed through interaction with the client. The CRPNM understands that the relationship between language and communication is complex but believes language proficiency is foundational to communication.

- In 2011, in an effort to achieve harmonization among and between the regulated nursing professions in Canada, the CRPNM reviewed, considered and accepted the language proficiency requirements recommended by the National Language Fluency Working Group (NLFWG). The NLFWG conducted a national standard setting exercise facilitated by language experts.

- Approving the NLFWG recommendations did not raise the requirements for the CRPNM’s IEPN applicants; it changed the tests that the CRPNM was using. Prior to this, the CRPNM was using TOEFL and TSE. The NLFWG recommended tests include more comprehensive testing in reading, writing, speaking and listening.

- The vast majority of IEPN applicants apply for registration with the CRPNM while they are still in their home countries. For this reason, CELBAN is virtually unused for IEPN applicants coming to Manitoba.

- Section 5(1) (d) of the Registered Psychiatric Nurses Regulation identifies that if the applicant’s first language is not English or French, the applicant must be able to demonstrate …. appropriate skills in oral and written English and French. The CRPNM Board of Directors reviewed, considered and accepted the OMFC recommendations for revision to the definition of first language. The CRPNM notes, however, that there are ongoing issues to be resolved. In particular, self-declaration of first language cannot be verified. The only objective way to determine language proficiency would be through a language proficiency test.

5. That the CRPNM implement a strategy to assess qualifications evident in professional work experience.

The Registered Psychiatric Nurses Act and regulation require that an applicant for initial registration who has not completed a program of psychiatric nursing education in Manitoba, complete a program of psychiatric nursing education that is deemed to be substantially equivalent to a psychiatric nursing education program offered in Manitoba. For this reason, education is the basis of the qualifications assessment process. Academic preparation is evaluated against the CRPNM’s Guidelines for Education Assessment document.

The CRPNM recognizes that there might be occasions where an assessment of the applicant’s academic preparation is insufficient or impossible. The CRPNM further recognizes the need for competency based assessment models to compliment the assessment of academic preparation. To date, the CRPNM has had limited capacity to develop such models but expect to be in a better position to work towards the development of complimentary models and practices when the profession’s new entry level competencies are completed in 2014.

The CRPNM has and will continue to examine the issues and to explore possible options over the long term.

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