Consultation: Emergency Class of Registration

Posted: February 16, 2023

Publié le 16 February 2023

CDO invites your feedback on proposed registration regulation amendments

The College of Dietitians of Ontario is undertaking a consultation of registrants and other stakeholders to obtain your feedback on proposed changes to the Registration Regulation. These changes include the introduction of an Emergency Class of Registration.

New emergency class will reduce barriers to registration
The Ontario government is continuing its efforts to increase human resource capacity in the healthcare system. A new Registration Requirements Regulation under the Regulated Health Professions Act, 1991 (RHPA) requires all health profession regulators to establish an Emergency Class of Registration. The new emergency class will reduce barriers and expedite the registration of applicants.

The amendments will be incorporated into the College’s existing Registration Regulation and will come into force on August 31, 2023. The proposed new Emergency Class of Registration provisions can be found here. A rationale table can be found here. Scroll down to read our answers to Frequently Asked Questions (FAQs).

As per the RHPA, all proposed regulation amendments require circulation to registrants and stakeholders for a 60-day period.
Your feedback is important to us
We invite you to provide your feedback by end of day on April 18, 2023. Your feedback will be considered by the College’s Board of Directors prior to approving the Emergency Class of Registration for incorporation into the College’s Registration Regulation.
If you have any questions related to the consultation or the proposed regulation amendments, please contact:

2019 proposed amendments to the Registration Regulation
The College will also put forward the proposed amendments to the Registration Regulation that were on hold due to changes in Ministry of Health staffing and pandemic priorities. These amendments were formerly circulated to registrants and stakeholders and were approved by the College’s Board in March 2019. The 2019 proposed amendments to the College’s Registration Regulation can be viewed here.

Frequently Asked Questions 

Why are health regulatory colleges being asked to establish an Emergency Class of Registration?
The purpose of the Emergency Class is to provide a mechanism for the College to expedite the registration of applicants during emergency circumstances.

What requirements must be included when establishing an Emergency Class of Registration?
The government’s requirements for establishing an Emergency Class of Registration are as follows:

5. (1) The regulations establishing an emergency class of registration required by section 16.3 of the Code [schedule 2 of the RHPA] must include at least the following requirements:
1.  They must specify emergency circumstances that will cause the class to be open for issuance and renewal.
2.  They must specify that the emergency class of certificates of registration expire no more than one year after they are issued but are renewable for the same period of time, with no limit on the number of times they may be renewed as long as the emergency circumstances persist.
3.  They must specify circumstances in which a member of the emergency class may apply for another class of registration and must exempt the applicant from at least some registration requirements that would ordinarily apply to the application.

What types of emergencies will open the College’s Emergency Class of Registration? The Emergency Class of Registration may be opened by a request from the Minister of Health and/or the College’s Board.  Some examples may include responding to health emergencies, natural disasters, and cybersecurity issues.
How did the College determine what should be included in its proposed Emergency Class of Registration?
The Emergency Class strives to strike a balance to meet the provincial government’s expectations for establishing an Emergency Class while ensuring that all those registered in this class can practise dietetics safely and ethically in the interest of public protection.

The Emergency class allows for unsupervised practice which allows registrants to contribute to the healthcare system to their full capacity in the circumstances.

Who will be eligible for the Emergency Class of Registration?
To ensure that the public continues to receive safe dietetic care in emergency circumstances, eligibility for the Emergency Class is proposed to be limited to applicants who have completed both accredited academic and practical training (or equivalent) and the College’s currency requirements (e.g., graduated from training within three years, or practised dietetics for at least 500 hours in another jurisdiction).

Applicants must not have failed the CDRE on any attempt as no supervision will be required for those in the Emergency Class of Registration.

How should registrants in the Emergency Class identify themselves as dietitians?
Registrants in the Emergency Class may use the dietitian/RD title (or French equivalent diététistes/Dt.P). Verification of licensure and class of licensure is available on the College’s Public Register of Dietitians.

How long will Emergency Class certificates of registration be issued for?
A certificate of registration in the Emergency Class will be valid for one (1) year, eligible for renewal by the Registrar for the same duration, provided the emergency circumstances continue to exist.

Emergency Class certificates will expire six (6) months after either the Minister of Health withdraws its request for Colleges to issue/renew Emergency Class certificates or the Board declares it’s no longer in the public interest to do so, whichever is earlier.

These timelines for issuance, renewal, and expiry of Emergency Class Certificates of Registration provide a reasonable period during and after the emergency ends to enable the holder to complete the process of transferring to another class without significant interruptions for registrants, their clients, and/or employers.

What happens to registrants in the Emergency Class once the emergency is over and their certificates expire?
The Emergency Class must also include a pathway for registrants to apply for another class of registration, waiving or temporarily waiving the registration requirements that would normally apply. This provides a mechanism for a registrant’s practice during the emergency to be recognized and to facilitate their ongoing registration once the emergency situation subsides.

The College is proposing that those who transfer from the Emergency Class to the Temporary Class would be eligible for a certificate that is valid for 24 months (versus the standard 16 months). The Temporary registrant is still required to write the CDRE to transfer to the General Class but with an extended period of time to register, pay and prepare for the CDRE upon licensure as a Temporary registration.

Once the Temporary Certificate holder wishes to register for the CDRE, they would be subject to the same requirements as a standard Temporary certificate (e.g., supervision requirement upon first exam failure, expiry after second exam failure, as applicable).

Why are the terms Council/member/he/she used in the proposed Emergency Class of Registration when the College’s Board adopted changes to this terminology at their September 30, 2022, meeting?
Until broader legislative changes to the RHPA are in place, terminology in proposed regulation amendments reflect language currently used in provincial legislation rather than that of the College.