Regulation Matters 2019 - Issue 1

Proposed Amendments to the Registration Regulation

Summary of Consultation Results

The proposed amendments to the Registration Regulation were circulated to members for the mandatory minimum 60-day consultation period from December 21, 2018 to February 19, 2019 and to other stakeholders (the Federation of Health Regulatory Colleges of Ontario, the Ontario Fairness Commissioner and the Alliance of Canadian Dietetic Regulatory Bodies) from January 8 – February 19, 2019.
A total of 155 responses (4% of total membership) were received from the online consultation survey. An additional two responses were received via email from Dietitians of Canada, in collaboration with the Dietetic Education Leadership Forum of Ontario; and the College of Dietitians of Manitoba.

Summary of Feedback

Of the feedback received, the majority related to clarifying the meaning of the proposed amendments. We have provided explanations below for some of the frequently-asked questions and comments:
1. Are the written details for not having liability insurance within two calendar days or two business days?
It will be expected that a member provides written details to the College within two calendar days of becoming aware they do not carry professional liability insurance. The written notice can be emailed to the College.
2. Using the term clinical experience doesn’t fully capture the varying types of practical training completed by applicants. Feedback suggested wording to reflect the national Integrated Competencies for Dietetic Education and Practice or indicating the practicum requirement as completion of a practical training program.
The College agrees with this suggested revision and has revised the regulation accordingly (see revisions section below).
3. Is it the College’s place to revoke registration if a member ceases to have authorization to work in Canada? 

Currently, authorization to work in Canada is a requirement for registration, but it is not a term, condition and limitation for ongoing registration. The College is recommending this amendment to ensure all members are authorized to work in Canada and to enable the College to take action if a member ceases to be authorized to work in Canada.

4. Will the Independent Practicum still be available?
The requirements for registration with the College include an accredited academic degree (or equivalent) and the completion of an accredited practical training program (or equivalent). The proposed Registration Regulation amendments will still permit applicants to do an unaccredited practicum (e.g. Independent Practicum), but the way in which the College will conduct its assessment to determine whether the practicum is substantially equivalent to an accredited practical training program may differ. The Registration Committee may decide that these applicants must undergo a Prior Learning Assessment and Recognition (PLAR) process to assess the equivalence of their practical training, rather than have a panel assess the practicum submission through the current credential assessment process.

Recommended Revisions

In addition to the circulated proposed amendments to the Registration Regulation, Council approved the following additional revision:
“Registration Requirements for Every Certificate
6.(1)  An applicant for the issuance of a general or temporary certificate of registration must satisfy either of the following non-exemptible requirements:
  1. The applicant has satisfied both of the following requirements:
  1. The applicant has graduated from, a program in dietetics that was offered at the bachelor level at a Canadian university and which was at least four years in duration and, at the time of graduation, accredited by an accredited agency approved by Council, and
  2. The applicant must have successfully completed a program of  practical training in the profession that is structured, comprehensive, supervised and evaluated and, at the time of completion, accredited by an accrediting agency approved by Council.”
Removing “clinical experience” in section 6.(1)1.ii. better reflects the types of practical training completed by applicants.
Please note that the current Registration Regulation remains in place until all the proposed amendments are passed by the Ministry. We are unsure of the specific timelines of when this would occur. We will communicate any updates regarding the proposed Registration Regulation amendments as they become available.  

 Next Steps

  1. The College will prepare and submit the proposed Registration Regulation amendments to the Ministry of Health and Long-Term Care (Ministry), according to their required framework.
  1. Following the submission, we will continue to liaise with the Ministry regarding the status of the Registration Regulation approval and respond to further questions as requested.
  1. Once the Registration Regulation has been passed by the Ministry, the amendments will be incorporated into College program tools such as the Registration Policies and website information.