REGISTRATION OVERSIGHT FORUM

Foreign Credential Recognition Program Employment and Social Development Canada

Projects Funded – Highlights and Issues

2005-2014

June 8th, 2015

TABLE OF CONTENT

ACRONYMS ................................................................................................................................................... iii

INTRODUCTION .............................................................................................................................................. 1

I DESCRIPTION OF PROJECTS BY SECTOR AND PROFESSION ...................................................... 2

1.1 Law, Administration and Business ...................................................................................... 2

1.1.1 Financial Auditors – Accountants ........................................................................................ 2

1.2 Engineering, Planning and Science ..................................................................................... 3

1.2.1 Engineering Technicians ........................................................................................................ 3

1.2.2 Engineers .................................................................................................................................... 3

1.2.3 Architects .................................................................................................................................... 5

1.3 Health and Human Relations ................................................................................................. 5

1.3.1 Occupational Therapists ......................................................................................................... 5

1.3.2 Teachers ...................................................................................................................................... 6

1.3.3 Physicians ................................................................................................................................... 7

1.3.4 Medical Laboratory Technologists ....................................................................................... 9

1.3.5 Medical Radiation Technologists ....................................................................................... 10

1.3.6 Registered Nurses – Licensed Practical Nurses ............................................................ 10

1.3.7 Dentists ...................................................................................................................................... 11

1.3.8 Pharmacists .............................................................................................................................. 12

1.3.9 Physiotherapists ..................................................................................................................... 13

II PRELIMINARY ANALYSIS ............................................................................................................. 14

2.1 Limitations of the information collected ........................................................................... 14

2.2 Content of projects ................................................................................................................. 14

2.3 Main theory about the impact of projects ......................................................................... 15

2.4 Central technology platforms .............................................................................................. 15

III ISSUES RELATED TO GOVERNANCE ........................................................................................... 18

3.1 Characteristics of ESDC’s program ................................................................................... 18

3.2 Governance .............................................................................................................................. 19

3.2.1 Definition ................................................................................................................................... 19

3.2.2 Pan-Canadian Framework on the Assessment and Recognition of Foreign Qualifications (Framework) .................................................................................................. 20

3.2.3 Role of pan-Canadian third parties .................................................................................... 22

3.2.4 Accountability linked to the Framework and the FCRP ................................................ 23

CONCLUSION .............................................................................................................................................. 25

ACRONYMS ACOTRO Association of Canadian Occupational Therapy Regulatory Organizations

AFMC Association of Faculties of Medicine of Canada

AIPSO Association of International Physicians and Surgeons of Ontario

ASTTBC Applied Science Technologists and Technicians of BC

CACB Canadian Architectural Certification Board

CAMRT Canadian Association of Medical Radiation Technologists

CAOT Canadian Association of Occupational Therapists

CAPER Canadian Post M.D. Education Registry

CAPR Canadian Alliance of Physiotherapy Regulators

CCLB Centre for Canadian Language Benchmarks

CCTT Canadian Council of Technicians and Technologists

CDRAF Canadian Dental Regulatory Authorities Federation

CME Canadian Manufacturers and Exporters

CMEC Council of Ministers of Education Canada

CMLTO College of Medical Laboratory Technologists of Ontario

CNO College of Nurses of Ontario

CPA Canadian Pharmacists Association

CPAC Chartered Professional Accountants of Canada

CSMLS Canadian Society for Medical Laboratory Science

CTIN Canadian Technology Immigration Network

EC Engineers Canada

ESDC Employment and Social Development Canada

FCRP Foreign Credential Recognition Program

MCC Medical Council of Canada (CAPER)

NAIT Northern Alberta Institute of Technology

NAPRA National Association of Pharmacy Regulatory Authorities

NNAS National Nursing Assessment Services

OCT Ontario College of Teachers

RAIC Royal Architectural Institute of Canada

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INTRODUCTION This paper presents a general picture of projects funded through the Foreign Credential Recognition Program (FCRP) of Employment and Social Development Canada (ESDC), from 2005 to 2014. It serves to initiate reflection on the objectives, modalities and impact of the FCRP. The paper is based on an ESDC document, dated April 2014, presented in the form of a table that describes succinctly the 68 projects that have been funded from 2005 to 2014. It is also based on information collected on the web. The document made it possible to consult various websites, some reports, press releases, information on the FCRP, etc. The goal of the paper is to provide a clearer idea of the objectives sought by the FCRP and the nature of the projects, which are presented in the first part of the document. The projects are grouped by sector (e.g. Health and Human Relations). The title of the occupations are those used in ESDC’s list of the projects (e.g. Registered Nurses and Licensed Practical Nurses). In the second part, the document presents a preliminary analysis of some projects funded through the FCRP. It should be noted that the selected occupations for the projects funded through the FCRP were identified during the development of the Pan-Canadian Framework for the Assessment and Recognition of Foreign Qualifications (the Framework), which is particularly discussed in the third section. The Framework, a progress report on its implementation and an action plan adopted by the Forum of Labour Market Ministers were then consulted.

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I DESCRIPTION OF PROJECTS BY SECTOR AND PROFESSION

1.1 Law, Administration and Business 1.1.1 Financial Auditors – Accountants Four projects were funded between 2007 and 2014. The total amount of the grants is nearly $2.2 million, of which 94% was paid to Chartered Professional Accountants of Canada (CPAC), “the national organization established to support a unified Canadian accounting profession”.1 Over $2 million has been dedicated to the creation of a website, which is the result of the three projects of CPAC, providing information to foreign-trained accountants, for example:

general information on Canada and the provinces;

information for potential employers and on immigration;

information on procedures to become a Chartered Accountant in Canada;

information on applying for membership to the appropriate provincial institute or order;

information on international organizations which have signed Mutual Recognition Agreements or Reciprocal Membership Agreements.2

As the profession is regulated by the regulatory bodies of the ten provinces and two territories (Northwest Territories and Yukon), website users are invited to consult the websites of these organizations. Lastly, over $135,000 has been allocated to the Edmonton Mennonite Centre for Newcomers, which created a program to enable internationally educated accountants to integrate into the community labour market in their area of expertise.3

1 cpacanada.ca/en/the-cpa-profession/about-cpa-canada (consulted February 11, 2015). 2 www.becomeacaincanada.ca/index.html (consulted February 11, 2015). 3 emcn.ab.ca/services/career-employment-services/accountants-bridging-program-abp (consulted

February 11, 2015).

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1.2 Engineering, Planning and Science 1.2.1 Engineering Technicians Organizations Seven projects were funded from 2007 to 2014. The total amount of the grants is nearly $2.3 million, 76% of which was paid to the Canadian Council of Technicians and Technologists (CCTT) and 24% to Applied Science Technologists and Technicians of BC (ASTTBC). The CCTT “establishes high standards of excellence for working professionals” and helps Canada to maintain its position as a world leader in the application of new technologies.4 Concerning the ASTTBC, its mission is to “serve the public by regulating and supporting Technology Professionals’ commitment to a safe, healthy, and sustainable society and environment”.5 Projects The achievement of the seven projects has resulted in the creation of two closely linked websites. One of two sites, the Technology Registrations Canada website, created with the support of Canadian Technology Immigration Network (CTIN) within the five CCT projects, has the following objective “to help qualified individuals become certified and registered as career professionals in Canada”. It allows candidates for certification in and outside Canada to self-assess their competency, to apply to one of the ten provincial associations and to monitor the status of their application.6

The other site, the CTIN website, which was created as part of the two projects of ASTTBC, “is a one-stop source for career information, programs and assistance to assist [in the] successful entry into Canada’s technology professions”.7 Employers can also consult it to find information on immigration, for example. 1.2.2 Engineers Organizations Six projects were funded from 2006 to 2013, while one is continuing to be implemented until 2016. The total amount of the grants is close to $4.4 million, nearly 60% of which was

4 www.cctt.ca/home.asp? (consulted February 12, 2015). 5 www.asttbc.org/about/corporate/mission.php (consulted February 12, 2015). 6 www.technologyregistrationscanada.ca (consulted February 12, 2015). 7 ctin.ca/en/immigrant-services (consulted February 12, 2015).

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paid to Engineers Canada (EC) and 40% to Canadian Manufacturers and Exporters (CME). EC “is the national organization of the 12 engineering regulators that license the country’s . . . members of the profession. Together, [they] work to advance the profession in the public interest”.8 CME’s mission is “advocating for manufacturers and exporters. Building a more competitive business environment. Providing critical and timely intelligence. Strengthening leadership through best practices and leveraging networks for success”.9 Projects Three of the projects of EC have resulted in the creation of a website, at a total cost of $1.5 million. “This website has information on a range of topics such as getting licensed, finding the right employment, fitting into the Canadian engineering profession, and immigration to Canada”.10 The fourth project of EC, at a cost of $1.1 million, has resulted in the creation of a program at the University of Manitoba which “is a pathway for internationally educated engineers to meet partial licensing requirements for professional engineering practice in Manitoba”.11

[It] is a program of university engineering courses, co-op work experience, cultural orientation, language and communication support, and professional networking. . . . Through the [Internationally Educated Engineers Qualification] Program, internationally educated engineers are considered “academically qualified” by [the Association of Professional Engineers and Geoscientists of the Province of

Manitoba], as part of the process of achieving a P.Eng. licence in Manitoba.12 Among the three projects of CME, the project continuing to be implemented until 2016, totalling nearly $640,000, is to create “a job matching service to connect internationally trained engineers, technicians and technologists with positions to help them gain certification”.13 The other two projects have been realized through the creation of a Job Search website.14 The current project appears to be an extension of the two that were completed.

8 www.engineerscanada.ca/ (consulted February 12, 2015). 9 www.cme-mec.ca/# (consulted February 12, 2015). 10 newcomers.engineerscanada.ca/about (consulted February 12, 2015). 11 umanitoba.ca/faculties/engineering/programs/ieeq/ (consulted February 12, 2015). 12 umanitoba.ca/faculties/engineering/programs/ieeq/whatisieeq.html (consulted February 12, 2015). 13 www.asttbc.org/services/docs/enews/ASTTeNewsApr14.html (consulted February 12, 2015). 14 www.linkedin.com/groups/EMAP-Engineering-Matching-Placement-Program-3138378/about (consulted

February 12, 2015).

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1.2.3 Architects Four projects were funded from 2006 to 2014. The grants totalled more than $3.3 million, paid to the Royal Architectural Institute of Canada (RAIC).

The RAIC is the leading voice for excellence in the built environment in Canada, demonstrating how design enhances the quality of life, while addressing important issues of society through responsible architecture. The RAIC’s mission is to promote excellence in the built environment and to advocate for responsible architecture.15

Among RAIC’s four projects, the three that are completed, at a total cost of more than $2.5 million, resulted in the creation of the Broadly Experienced Foreign Architect program, which:

. . . assesses broadly based experience of foreign architects against pan-Canadian standards of competency for practice in Canada. Foreign architects who meet the Program eligibility requirements can apply for [Broadly Experienced Foreign Architect] Certification through a process which consists of an online self-assessment and an interview with licensed architects. [It] streamlines the process for foreign-trained architects to become certified for licensure/registration in Canada.16

The provincial and territorial regulatory bodies of architects participated in developing the program. The evaluation program is available on the Canadian Architectural Certification Board (CACB) website. Regarding the project still being implemented, which totals over $800,000, the objective is to develop agreements with regulators in other countries to foster the free movement of qualified architects between territories; it appears to be an extension of previous projects.17 1.3 Health and Human Relations 1.3.1 Occupational Therapists Organizations Five projects were completed from 2006 to 2014. The total amount of the grants is more than $4.9 million, 55% of which was paid to the Canadian Association of Occupational Therapists (CAOT) and 45% to the Association of Canadian Occupational Therapy Regulatory Organizations (ACOTRO). 15 www.raic.org/raic/vision-mission-and-values (consulted February 12, 2015). 16 www.cacb-ccca.ca/index.cfm?Voir=sections&Id=18916&M=3943&Repertoire_No=660386109

(consulted February 12, 2015). 17 www.cacb-ccca.ca/index.cfm?Voir=sections&Id=8357&M=1357&Repertoire_No=660386109

(consulted February 12, 2015).

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CAOT:

. . . provides services, products, events and networking opportunities to assist occupational therapists in achieving excellence in their professional practice. [It] provides leadership to actively develop and promote the client-centred profession of occupational therapy in Canada and internationally.18

ACOTRO “is the national organization of occupational therapy regulators in Canada. [Its] goal is to promote consistency and excellence in regulating occupational therapy across Canada”.19 Projects The four projects of CAOT, which have been completed at a total cost of more than $2.7 million, resulted in the creation of a website and a program.

The focus of the Occupational Therapy Examination and Practice Preparation (OTepp) program is to assist internationally educated occupational therapists as they seek to transition into practice in Canada. Canadian re-entry occupational therapists may also join OTepp.20

The program has two modules designed to help internationally educated occupational therapists in their transition: the OTepp Certificate Program and the Work Readiness Module. However, the program does not seem to be offered every year; for example, it is not offered when there are not enough registrants. The objective of the ACOTRO project still being implemented, at a total cost of less than $2.2 million, is to identify a common way of assessing the academic credentials of internationally educated applicants (e.g. authenticity of diplomas), assess the competencies required for occupational therapy practice in Canada and ensure consistency among Canadian provinces in how English language abilities are assessed, except in Québec.21 This project and the others are interrelated. 1.3.2 Teachers Organizations Two projects were completed from 2005 to 2014. The total amount of the grants is more than $406,000, 72% of which was paid to the Council of Ministers of Education Canada (CMEC) and 28% to the Ontario College of Teachers (OCT).

18 www.caot.ca/default.asp?pageid=2 (consulted February 12, 2015). 19 www.acotro-acore.org/about-us (consulted February 12, 2015). 20 www.otepp.ca/about-otepp.aspx (consulted February 12, 2015). 21 www.acotro-acore.org/projects/project-summaries (consulted February 12, 2015).

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The CMEC “is an intergovernmental body founded in 1967 by ministers of education [which] provides leadership in education at the pan-Canadian and international levels and contributes to the exercise of the exclusive jurisdiction of provinces and territories over education”.22 OCT “regulates the teaching profession in Ontario in the public interest by setting and enforcing high ethical and professional standards for its members”.23 Projects The CMEC’s project is a report which “is intended to inform [the Registrars for Teacher Certification Canada] of key trends and issues that could potentially support the development of new and practical approaches to assessing the credentials of [internationally educated teachers] all across Canada”.24 Concerning the OCT’s project, the objective was to establish a Mutual Recognition Agreement for teachers, as then required by the Agreement on Internal Trade. 1.3.3 Physicians Organizations Four projects were funded from 2005 to 2013. The total amount of the grants was $7.4 million, 70% of which was paid to the Medical Council of Canada (MCC), 29% to the Association of Faculties of Medicine of Canada (AFMC) and the Canadian Post M.D. Education Registry (CAPER), and 1% to the Association of International Physicians and Surgeons of Ontario (AIPSO). MCC is looking:

. . . for the highest level of medical care for Canadians through excellence in evaluation of physicians, develops, validates and implements tools and strategies to evaluate physicians’ competence and maintains a national registry of physicians and their qualifications throughout their professional careers.25

The Medical Regulatory Authorities of the Canadian provinces and territories are members of MCC.

22 www.cmec.ca/11/About/index.html (consulted February 13, 2015). 23 www.oct.ca/about-the-college/mission-vision-values?sc_lang=en (consulted February 13, 2015). 24 Council of Ministers of Education, Canada (2014). “Certification and Workforce Integration: Experiences

of Internationally Educated Teachers”. Submitted to the Corporation of the Council of Ministers of Education, Canada (by Nancy Tran). Council of Ministers of Education, Canada, Toronto, p. 1.

25 mcc.ca/about/vision-mission-goals (consulted February 13, 2015).

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AFMC:

. . . represents Canada’s 17 faculties of medicine and is the voice of academic medicine in this country. [It] works to represent and support the mandates of . . . medical faculties – research, medical education, clinical care with social accountability. [Its] advocacy initiatives are tailored to keeping these issues high on the federal government’s agenda and ensure that Canada’s faculties of medicine serve as important resources to decision-makers in this country.26

CAPER:

. . . is the central repository for statistical information on postgraduate medical education in Canada. CAPER maintains individual-level data for all postgraduate medical residents and fellows. Data is gathered on an annual basis from all 17 Canadian Faculties of Medicine.27

AIPSO:

. . . is a non-profit, independent professional association which represents physicians and surgeons trained and licensed in jurisdictions outside Canada. AIPSO’s mission is to ensure that internationally trained physicians are integrated effectively and equitably into the Canadian health care system.28

Projects MCC’s project has resulted in the creation of a website:

. . . designed to allow qualified physicians to complete and submit an application for medical registration (i.e. applying for a medical licence in a Canadian province or territory) with medical regulatory authorities. . . . Once adopted by all the medical regulatory authorities, physiciansapply.ca will enable a physician to apply for a medical licence electronically to any of the 13 authorities in Canada using one system, instead of having to complete separate processes for each province and territory.29

The AFMC and CAPER’s project was to ensure that the collection of data related to international medical graduates in Canada eventually helps a greater number of them to practise medicine. Lastly, IAPSO’s project materialized in the form of a website that offers information on the situation of international medical graduates in Canada, allowing them to discuss the issues surrounding their situation, etc.

26 www.afmc.ca/about-e.php (consulted February 13, 2015). 27 www.caper.ca/en/about-us (consulted February 13, 2015). 28 aipso.webs.com/whowearecontact.htm (consulted February 13, 2015). 29 physiciansapply.ca/about-us (consulted February 13, 2015).

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1.3.4 Medical Laboratory Technologists Organizations Ten projects were funded from 2005 to 2014. The total amount of the grants was nearly $2.1 million, 73% of which was paid to the Canadian Society for Medical Laboratory Science (CSMLS), 24% to Northern Alberta Institute of Technology (NAIT) and 3% to the College of Medical Laboratory Technologists of Ontario (CMLTO). CSMLS works with associations or regulatory bodies of the 10 provinces:

[It] is the national certifying body for medical laboratory technologists and medical laboratory assistants, and the national professional society for Canada’s medical laboratory professionals. [It is] a not-for-profit organization that is funded entirely by membership dues and revenues from goods and services. [It does] not receive operational funding from governments or other organizations.30

NAIT, a post-secondary institution, offers “technical training and applied education . . . designed to meet the demands of Alberta’s industries”.31 CMLTO “protects the public’s right to safe, competent, ethical health care. [It does] this by regulating the professionals who conduct lab tests across the province”.32 Projects The eight CSMLS projects, at a total cost of $1.5 million, took the form of a self-assessment online tool aimed, in particular, at internationally educated medical laboratory technologists. The tool is designed to prepare for eligibility for the national certification examination.33 NAIT’s project, at a total cost of $499,000, was to be in the form of a training program to allow internationally educated medical laboratory technologists to quickly get their certification and work in Alberta. Lastly, concerning the CMLTO’s project, at a total cost of $68,000, the objective was to revise the terms and conditions of the mutual recognition agreement for medical laboratory technologists to enable their mobility across Canada and facilitate their inclusion in Québec and other regulated provinces which have signed the agreement.

30 www.csmls.org/About-Us/Who-We-Are.aspx?lang=en-CA (consulted February 13, 2015). 31 www.nait.ca/44315.htm?utm_source=nait&utm_medium=template&utm_campaign=navigation&utm_

content=about (consulted February 13, 2015). 32 www.cmlto.com/index.php?option=com_content&view=article&id=1214&Itemid=68 (consulted

February 13, 2015). 33 www.c/smls.org/Certification/Certification-Process/IEMLT.aspx?lang=en-CA (consulted

February 13, 2015).

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1.3.5 Medical Radiation Technologists Five projects were funded from 2005 to 2014. The grants, totalling more than $1.5 million, were paid to the Canadian Association of Medical Radiation Technologists (CAMRT). CAMRT:

. . . is Canada’s national professional association and certifying body for medical radiation technologists and therapists across the country. . . . As the national professional association, the CAMRT is the national body in a partnership with ten provincial associations. . . . CAMRT develops and administers national certification exams for the four disciplines among its membership.34

To help internationally educated medical radiation technologists, “CAMRT has developed Readiness Self-Assessment Tools for [them]. These are online tools that help the CAMRT assess if they are likely to meet requirements to practise in a Canadian context, and what the Canadian work environment looks like”.35 However, the regulatory bodies in Québec, Ontario and Alberta have their own requirements concerning professionals who want to practise on their territory. The associations of the provinces remain separate organizations, each with its own regulations and board.36 1.3.6 Registered Nurses – Licensed Practical Nurses Organizations Twelve projects were funded from 2005 to 2014. The total amount of the grants is nearly $5.4 million, 63% of which was paid to National Nursing Assessment Services (NNAS), 21% to the College of Nurses of Ontario (CNO) and 16% to seven other organizations for various activities (e.g. organize a symposium or a meeting, awareness of internationally educated nurses to properly prepare for exams, development of a national approach to entrance examination to the profession, etc.) that we have not detailed in this section. NNAS:

. . . coordinates a consistent national approach for internationally educated nurses seeking registration/licensure to practise in Canadian jurisdictions. This includes: Registered Nurses, Licensed Practical Nurses, Registered Practical Nurses in Ontario and Registered Psychiatric Nurses.37

Québec, unlike other provinces, has no organization represented in NNAS, although each province has its own regulatory body and assessment process.

34 www.camrt.ca/aboutcamrt (consulted February 16, 2015). 35 www.camrt.ca/certification/international (consulted February 16, 2015). 36 www.otimroepmq.ca/Home/News/2008/12/Entente%20avec%20lACTRM.aspx (consulted

February 16, 2015). 37 www.nnas.ca (consulted February 16, 2015).

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CNO “is the governing body for registered nurses, registered practical nurses and nurse practitioners in Ontario, Canada. [It] works in partnership with employers, educators and government so that everyone in Ontario benefits from quality nursing services”.38 Projects The NNAS’s project, which is continuing to be implemented, at a cost of $4.4 million, is an online tool dedicated to “a harmonized approach to the initial assessment of internationally educated nurses. Significant features of the NNAS include:

“A single national web portal

A common approach to initial document collections, authentication, validation and fraud screening

A consistent competency-based assessment of the [internationally educated nurse] application file

A consistent format for advisory reports to regulatory bodies to inform eligibility assessments

A bilingual customer care centre for [internationally educated nurse] applicants

A national [internationally educated nurse] database providing enhanced reporting and analysis capabilities”39

The three projects of CNO, completed at a total cost of more than $1.1 million, are the first steps of the previous project, NNAS’s online tool. This means that more than $4.5 million was used for this online tool alone. 1.3.7 Dentists A project was funded from 2010 to 2011 at a cost of $820,000 paid to the Canadian Dental Regulatory Authorities Federation (CDRAF), of which the regulatory bodies of the 10 provinces are members. Its mandate:

. . . is to provide leadership and a responsive infrastructure and forum where dental regulatory authorities in Canada can anticipate and respond, in effective and efficient ways, to current regulatory challenges on interprovincial and territorial and national and global levels.40

The objective of the project was to develop and implement a national process to allow internationally trained dentists to establish whether they possess the same knowledge, skills and competencies as a graduate from an accredited Canadian dental program. The organization’s website provided some information on the subject but internationally trained dentists must contact the provincial regulatory body of their choice.

38 www.cno.org/en/what-is-cno (consulted February 16, 2015). 39 www.nnas.ca/about-us (consulted February 16, 2015). 40 www.cdraf.org/Home (consulted February 16, 2015).

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1.3.8 Pharmacists Organizations Four projects were funded from 2005 to 2014. The total amount of the grants is more than $6.7 million, of which 63% was paid to the National Association of Pharmacy Regulatory Authorities (NAPRA), 32% to the Canadian Pharmacists Association (CPA) and 5% to the Centre for Canadian Language Benchmarks (CCLB). NAPRA “provides national leadership in pharmacy regulatory practices that enhance patient care and public protection”.41 Pharmacy regulatory authorities of all provinces and territories are members of NAPRA. The CPA “advocates for pharmacists and supports its members to advance the profession and enhance patient outcomes”.42 Representatives of the various organizations of each province are part of its board of directors. CCLB “is the centre of expertise in support of the national standards in English and French for describing, measuring and recognizing second language proficiency of adult immigrants and prospective immigrants for living and working in Canada”.43 Projects NAPRA’s project, costing $4.2 million, is an online tool called:

. . ., Pharmacists’ Gateway Canada, [which] provides licensing information, self-assessment tools and a centralized document repository for International Pharmacy Graduates. [It explains] each of the steps in the [licensing] process [and] what requirements [can be completed before arriving in Canada].44

If we add CCLB’s project, at a cost of more than $300,000, more than $4.5 million was used for NAPRA’s project. The purpose of CCLB’s project was to develop, with NAPRA, a Canadian English Language Benchmark Assessment for Pharmacists.45 Lastly, according to reports, the two PCA projects, at a cost of more than $2.2 million, resulted in a comprehensive picture of the pharmacy workforce, both pharmacists and

41 napra.ca/pages/About/Vision.aspx (consulted February 16, 2015). 42 www.pharmacists.ca/index.cfm/about-cpha (consulted February 16, 2015). 43 www.language.ca/index.cfm?Repertoire_No=2137991327&Voir=corporatif (consulted

February 17, 2015). 44 www.pharmacistsgatewaycanada.ca/about.shtml (consulted February 17, 2015). 45 learnerpathways.files.wordpress.com/2012/03/language-training-key-initiatives-to-share-llc-

handouts.pdf (consulted February 17, 2015).

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pharmacy technicians, with a major emphasis on internationally trained pharmacy graduates.46 1.3.9 Physiotherapists

Three projects were funded from 2005 to 2011. The grant amount totalled more than $553,000, paid to the Canadian Alliance of Physiotherapy Regulators (CAPR), “the pan-Canadian federation of provincial/territorial physiotherapy regulators committed to the development and improvement of regulatory standards of practice for physiotherapists”.47 Regulatory bodies of the 10 provinces and Yukon are members of CAPR. The projects have resulted in reports:

1. that provide a “snapshot” of the labour market in Canada for physiotherapists in general and internationally educated physiotherapists in particular to improve access to the physiotherapy profession,48

2. that provide a review and redesign of information resources for CAPR to improve clarity and accessibility of materials used by Internationally Educated Physiotherapist applicants49 and

3. that evaluate CAPR’s credentialing program to identify potential concerns and make recommendations for improvements in standards50.

46 tools.hhr-rhs.ca/index.php?option=com_mtree&task=att_download&link_id=6136&cf_id=68&lang=fr

(consulted February 17, 2015) blueprintforpharmacy.ca/docs/default-document-library/2011/04/19/FINAL_EX_SUM_Feb_08_

ENGLISH_GP.pdf?Status=Master (consulted February 17, 2015) blueprintforpharmacy.ca/docs/pdfs/2011/04/19/96.pdf?Status=Master (consulted February 17, 2015). 47 www.alliancept.org (consulted February 17, 2015). 48 Canadian Alliance of Physiotherapy Regulators &Canadian Physiotherapy (2007). « Association

Integrating Internationally Educated Physiotherapists » (Prepared by Keith Johnson). Toronto: Canadian Alliance of Physiotherapy Regulators, March 2007, 60 p.

49 Canadian Alliance of Physiotherapy Regulators (2010). “Annual Report 2009”. Toronto: Canadian Alliance of Physiotherapy Regulators, p. 4.

50 Canadian Alliance of Physiotherapy Regulators (2012). “Annual Report 2011”. Toronto: Canadian Alliance of Physiotherapy Regulators, p. 12.

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II PRELIMINARY ANALYSIS 2.1 Limitations of the information collected The FCRP has funded the 68 projects presented in the previous section, 93% of which are pan-Canadian projects. The others (five projects) have a provincial, regional or municipal scope. Total subsidies reached nearly $42 million during the 2005-2014 period. The proportion of funds allocated was the same: 93% of funding was allocated to pan-Canadian projects and 7% to other projects. The Health and Human Relations sector received 71% of grants, followed by the Engineering, Planning and Science sector, with 24%, and the Law, Administration and Business sector, with 5%. Occupations that have received the largest grants were as follows: Physicians ($7.4 million), Pharmacists ($6.7 million), Registered Nurses or Licensed Practical Nurses ($5.4 million), Engineers ($4.4 million), Architects ($3.3 million) and Financial Auditors – Accountants ($2.2 million). That being said, because of the nature of the information consulted, it is obviously not possible to draw conclusions about the impact of projects on the admission pathways in targeted professions in provincial or territorial Canadian jurisdictions, whether they were involved or not. For the same reason, we cannot measure the impact of projects at a pan-Canadian level. Further research would be necessary to better understand the ins and outs of activities funded under the FCRP. 2.2 Content of projects Of the 68 projects concerning 13 professions, most were aimed at providing information on occupations (97%) or developing tools (94%) that, for example, allow an applicant to assess whether his or her training, skills and experience meet the criteria for an occupation.51 Furthermore, 54% of the projects involved support services by a pan-Canadian third party whose members are sometimes regulatory bodies. The third party could, in some cases, intervene in the area of standards for admission (43% of projects), evaluation of applicants (29% of projects) or management of their documents (12% of projects).

51 For example, visit: www.technologyregistrationscanada.ca/content/self-assessment-1 (consulted

February 24, 2015).

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Lastly, 22% of projects can be categorized as studies and 15% as concerted effort, as these aspects can be found in other projects, but less explicitly. It is important to note that, when the purpose of a project was to create a tool such as a technology platform, projects previously funded under the FCRP may have been stages that contributed to it (see subsection 2.4). However, we have not necessarily established a cause-and-effect relationship between these projects because we cannot say that this was planned from the first project funded. This would require a more detailed analysis, but it would undoubtedly have an impact on the percentages inherent to the project content. 2.3 Main theory about the impact of projects Despite the limitations just discussed, we are able to theorize that the primary objective of the projects funded under the FCRP is the harmonization52 and uniformization53 (50% of projects) of standards and practices. Furthermore, a centralizing54 vision seems to be at play in the way of organizing and implement actions in the case of a number of projects (50% of projects). 2.4 Central technology platforms It is common that activities constitute a step toward the creation of a platform, such as a website. This is the case for all projects related to Engineering Technicians, which we described in subsection 1.2.1. In this case, they resulted in the creation of two websites that are linked. This type of initiative can be interpreted as having a centralizing impact that seeks to ensure that the standards and practices specific to each of the professions are the same from “coast to coast”. Moreover, we must not forget that some projects seem more advanced than others, in terms of progress. For example, an online tool looks more accessible but also indispensable as the first step to be admitted to a profession. That is the case, for instance, of CSMLS’s online tool that certifies Medical Laboratory Technologists, as:

[all] of the regulated provinces, with the exception of Quebec, require CSMLS certification. Most employers in the unregulated provinces and territories (British Columbia, Newfoundland and Prince Edward Island, Northwest Territories, Yukon,

52 Harmonize: “The act of making systems or laws the same or similar in different companies, countries,

etc. so that they can work together more easily”. Ref: dictionary.cambridge.org/dictionary/business-english/harmonization (consulted March 16, 2015)

53 Uniformize: “To make uniform”. Ref: www.merriam-webster.com/dictionary/uniformize (consulted March 16, 2015)

54 Centralization: “Organizing support services, such as word or data processing, in a central location. The term implies that the service is shared among several users, and may not be directly supervised by any of them” Ref: www.btb.termiumplus.gc.ca/tpv2alpha/alphafra.html?lang=fra&i=1&srchtxt=centralisation &index=frt (consulted March 16, 2015)

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Nunavut) require CSMLS certification. In New Brunswick, the New Brunswick Society of Medical Laboratory Technologists requires CSMLS membership as a condition of licensure. Some employers require CSMLS membership as a condition of employment.55

Of course, a website is a tool built by stakeholders, but its use could contribute to the institutionalization of new pan-Canadian standards and practices that are homogeneous for all provinces and territories. Although provincial or territorial regulatory bodies were involved in the creation of such tools, we noted that the jurisdiction of the provinces or territories over several activities is not always apparent. One theory is that the development of such tools could contribute to accentuating this phenomenon, if the tools became the gateway for admission to a profession. This could be the case of a tool such as CPAC, mentioned in subsection 1.1.1, consisting in the creation of a website providing information to foreign-trained accountants. In that case, if we can say that some services are supported by a third party (CPAC), harmonization, standardization and centralization are perceptible, although in an embryonic manner, they could have, in the long run, an impact on the standards specific to the profession, on the document management of applicants and on their evaluation. This would also be the case of MCC’s project presented in subsection 1.3.3. It will be recalled that MCC’s wish was that medical regulatory authorities from all provinces and territories adopt the tool physiciansapply.ca,56 so that applicants use it, including to fill out an application form for licensure. The initial draft indicates that the tool should provide support to physicians trained abroad. But it also targets people trained in Canada. We should also mention CACB’s website, which was discussed in subsection 1.2.3, concerning the “certification for Broadly Experienced Foreign Architects”. This is undoubtedly the most advanced tool in terms of harmonization, standardization and centralization. It includes “the Canadian standard of academic training”57 and, in addition, the site makes it possible to manage documents accompanying applications from people trained abroad and evaluate them. CACB includes two other components that confirm this evolution: “Certification of academic training candidates with degrees or diplomas in architecture” and “Accreditation of professional programs of Canadian university schools of architecture”.58

55 www.csmls.org/Certification/What-is-Certification.aspx?lang=en-CA (consulted February 20, 2015). 56 It can be presume that this is to short or medium term. 57 It “consist of standards and procedures for the assessment of both professional degrees accredited by

the CACB, and professional degrees or diplomas not accredited by the CACB”. Ref: http://www.cacb-ccca.ca/index.cfm?Voir=sections&Id=7197&M=1358&Repertoire_No=660386109 (consulted February 20, 2015).

58 www.cacb-ccca.ca/documents/2012_CABC_Procedures_for_Accreditation.pdf (consulted February 20, 2015).

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Provinces and the Northwest Territories regulatory bodies contributed to the development of CACB’s website in a context where passing a national exam, the Examination for Architects in Canada, is a condition for practising in the provinces and territories, at least insofar as:

The Alberta Association of Architects, the Ontario Association of Architects and the Ordre des architectes du Québec agreed to develop a new Canadian licensing/registration examination, over which they would have complete control, including its development, updates and administration.59

Although regulatory bodies did not express it, we can theorize that these organizations want to assume directly the registration responsibilities assigned by their respective legislatures. In short, it is in this context, and even in this state of mind, that the FCRP awards grants. Although it is known that the professions have been targeted in the Pan-Canadian Framework for the Assessment and Recognition of Foreign Qualifications (see next section), it is unclear how the projects were chosen and how they were evaluated during their implementation or once completed.

59 www.exac.ca/en/examen.html (consulted February 20, 2015).

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III ISSUES RELATED TO GOVERNANCE 3.1 Characteristics of ESDC’s program ESDC considers that the FCRP:

. . . is a key component of the Government of Canada’s commitment to attract, select and integrate skilled immigrants into the Canadian economy and society. Through contribution agreements, the FCRP offers strategic financial support to provincial and territorial governments and various organizations to facilitate the assessment and recognition of credentials acquired in other countries. Partnering organizations frequently include regulatory bodies, national associations and credential assessment agencies.60

It was pointed out in the previous sections that very little “strategic financial support” has benefited provincial and territorial governments. In fact, as we have seen, 93% of the funding has benefited national associations mainly for pan-Canadian projects. This was also the case of a provincial organization, CNO, which received three grants to help create the NNAS website presented as a tool that coordinates a consistent national approach for internationally educated nurses seeking registration/licensure to practise in Canadian jurisdictions. It can be assumed that the FCRP will continue to focus on pan-Canadian projects. Thus, although not the only ones, the following objectives concerning the FCRP are specified by ESDC:

To contribute to developing fair, transparent, consistent,61 and timely foreign credential assessment and recognition capacity;

. . .

Standardization of pan-Canadian FCRP processes and tools in targeted occupations and other sectors.62

As we have already mentioned, the main objective of the projects funded under the FCRP seems to be to contribute to the harmonization and uniformization of standards and practices, sometimes with a centralized approach. However, in most cases, it is up to the provinces and territories to assess credentials, as the regulation of professions and education are within their jurisdiction. Furthermore, ESDC states that “priorities for funding under the [FCRP] include projects that respond to the Pan-Canadian Framework on the Assessment and Recognition of Foreign Qualifications and that:

60 www.esdc.gc.ca/eng/jobs/credential_recognition/foreign/index.shtml (consulted February 24, 2015). 61 Our emphasis. 62 www.esdc.gc.ca/eng/jobs/credential_recognition/foreign/index.shtml (consulted February 24, 2015).

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are national in scope;

address priority occupations and sectors representing skill shortages in Canada and/or high numbers of immigrants coming to Canada; or

have been identified as a priority by provincial and territorial governments.63

In a summative evaluation of the FCRP, covering the period from spring to autumn 2008, ESDC stated that:

Most stakeholders believe that the most appropriate roles for the federal government in addressing foreign credential recognition-related issues include a “coordinating”, “facilitating” and ”supporting” role, i.e. coordinating key players and initiatives and supporting organizations to address the issue of foreign credential recognition at a national level.64

These various quotes may suggest a desire by the federal government to be the initiator of a “system” that would include all the regulatory bodies in Canada. This raises issues of governance in a context where it seems be taken for granted that this will have a positive impact on economic development, as “the skills and experiences”65 of internationally trained individuals will be fully utilized in the workplace “across Canada”.66 3.2 Governance 3.2.1 Definition Although the concept of governance has multitude meanings, we accept the following definition:

Way to design and to exercise authority at the head of a company, organization, State . . . Governance is analyzed not only by taking into account the degree of organization and efficiency, but also and especially according to criteria such as transparency, participation, and shared responsibility.67

Among other things, this definition suggests that an approach that sometimes appears centralizing, as we have seen, is probably not the best strategy to adopt in all cases.

63 ww.esdc.gc.ca/eng/jobs/credential_recognition/foreign/index.shtml (consulted February 24, 2015). 64 www.esdc.gc.ca/eng/publications/evaluations/skills_and_employment/2010/april.shtml (consulted

February 25, 2015). 65 Forum of Labour Market Ministers (2014). An Action Plan for Better Foreign Qualification Recognition -

to better help new Canadians have their qualifications recognized faster. Forum of Labour Market Ministers, November, p. 3.

66 Ibid., p. 10. 67 Unofficial translation from: gdt.oqlf.gouv.qc.ca/ficheOqlf.aspx?Id_Fiche=115205 (consulted

February 25, 2015).

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3.2.2 Pan-Canadian Framework on the Assessment and Recognition of Foreign Qualifications (Framework)

Among other things, the Framework68 specifies the following:

Governments agree to work together and in collaboration with affected stakeholders to apply the principles of the Framework, establish service standards, and to help support the labour market needs of immigrants across Canada.

The following implementation strategies will guide federal, provincial and territorial government efforts so that the joint commitments and desired outcomes articulated in the Framework are achieved.69

It may be assumed that, through the FCRP, the federal government seeks to develop a pan-Canadian approach that would link regulatory bodies of all provinces and territories. One can be tempted to believe that the Framework serves the FCRP so it can achieve its own objectives and not the contrary. Therefore:

Initiating joint work among jurisdictions to develop and implement the Pan-Canadian Framework is a critical step for Canada in addressing these national challenges.70 The Framework provides a shared vision, guiding principles, and desired outcomes for improving the assessment and recognition of foreign qualifications in regulated occupations in Canada.71

As seen in previous sections, projects funded under the FCRP are not necessarily only dedicated to immigrants trained abroad, but also to people trained in Canadian colleges or universities. However, the “Framework complements and coordinates the efforts of governments and their foreign qualification recognition partners, as well as being a reference point for individual federal, provincial and territorial strategies”,72 while the federal strategy appears to dominate, at least as suggested by the projects that have been funded under the FCRP. But the Framework recognizes that “qualification recognition for regulated occupations is mainly a provincial and territorial responsibility that has often been delegated in legislation to professional regulatory authorities”.73 Despite that:

Governments will work in collaboration with affected stakeholders to map common, occupations-specific, pathways with service standards that reflect all of the

68 According to the Forum of Labour Market Ministers (2014), Québec has not endorsed the Framework,

but it supports the principles. 69 Forum of Labour Market Ministers (2009). “A Pan-Canadian Framework for the Assessment and

Recognition of Foreign Qualifications”. Gatineau: Human Resources and Skills Development Canada, p. 11.

70 For example, the integration of immigrants into the labour market. 71 Forum of Labour Market Ministers (2009), op. cit., p. 2. 72 Loc. cit. 73 Loc. cit.

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principles of the Framework. These may evolve over time as system-wide improvements take effect.74

The objectives are more clearly described toward the end of the document. “Project-based funding will be made available to:

enhance collaboration of regulatory bodies and assessors, and to develop processes and tools to improve the assessment and recognition of foreign qualifications across Canada, and

improve the consistency and portability of assessment results across Canada”.75

This type of contradiction is found in the action plan discussed above. On the one hand, it says that “the responsibility for occupational regulation and implementation, as well as workforce integration programs, rests within the jurisdiction of provinces and territories”.76 On the other hand:

Collaboration of governments, regulators and assessment agencies is required to better align information, supports and assessment in the licensing process with changes to the immigration selection processes, including the launch of the Express Entry system in January 2015.77

But the framework could have been interpreted otherwise than as an instrument that seems dedicated to building a “system” that would link all the regulatory bodies in Canada. Indeed, “[the] implementation of the Pan-Canadian Framework will require a collaborative, supportive, and respectful environment”78 between governments, in a context where there is “a continued need to review the effectiveness of newly established self-assessments, examination preparation and examinations to support the alignment of pre-arrival assessment with immigration processes”.79 The vocabulary used in the Framework is a reflection of the realities and the sensibilities of the political and institutional construct of the Canadian federation. Therefore, the Framework presents a common commitment in a context of respect for the responsibilities and duties of all parties. This means that the particularities of the provinces and territories’ regulatory occupations should not only be considered but should predominate over a centralizing vision that the FCRP seems to convey, particularly because of its close links with pan-Canadian third parties.

74 Forum of Labour Market Ministers (2009), op. cit., p. 7. 75 Ibid., p. 11. 76 Forum of Labour Market Ministers (2014), op. cit., p. 4. 77 Ibid., p. 5. 78 Forum of Labour Market Ministers (2009), op. cit., p. 9. 79 Forum of Labour Market Ministers (2014), op. cit., p. 5.

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3.2.3 Role of pan-Canadian third parties In a report published in 2014,80 the Commissaire aux plaintes en matière de reconnaissance des compétences professionnelles (Québec government) revealed that, in Québec, a majority of regulatory bodies do business with third parties for activities related to the evaluation of applicants for the profession, mainly for practical or technical reasons. But often, any agreement is signed between regulatory bodies and third parties in order to measure their activities. The report pointed out that some regulatory bodies in Québec had confessed to being ill-equipped to structure their supervision of a third party. This is said to have an impact on public protection, for which regulatory bodies are responsible, and the governance of the system for regulating professions in Québec. Nevertheless, also according to the report, several regulatory bodies in Canada centralize resources, tools, activities or stages in the admission and registration process with the same third party of the “profession-related body” type. Thus, in regulatory bodies in Canada:

. . . counterparts cooperate to harmonize standards and processes across Canada as much as possible, with a view to facilitating consistency between players and professional mobility. However, depending on the dynamic in place, a professional order may end up abdicating its responsibility as a result of the existence or creation of an entity that takes charge of, for example, the professional order’s candidate assessment activities or candidate files.81

Our preliminary analysis, presented in the second part of this document, tends to confirm this situation, especially in a context where the “centralization of equivalence recognition and admission-type activities is on the rise in regulated professions . . . due in part to the financial support made available by the federal government” under the FCRP.82 This is why, in the report, there are words of caution about the pitfalls of centralization, which could engender a lack of accountability from regulatory bodies in the exercise of their duties and obligations. This situation worried not only the Québec Commissioner, but also the commissioners of Ontario, Manitoba and Nova Scotia. In December 2013, the four commissioners also expressed concerns about the intervention of third parties in the admission process. As

80 Commissaire aux plaintes en matière de reconnaissance des compétences professionnelles – Office

des professions du Québec (2014). “Investigative Monitoring Report (Rapport de vérification particulière) – Subject monitored: Parameters agreed on between professional orders and third parties respecting the involvement of third parties in the processing of applications for equivalence”. Record No. 5300-14-001. Sent to 18 professional orders targeted, September, 17 p. (click on the following link: Available online).

81 Ibid., p. 8. 82 Ibid., p. 9.

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early as 2009, a study83 produced by the Office of the Fairness Commissioner (Ontario government) recommended, among other things, a better way to oversee the intervention of third parties in the registration process for regulated professions and trades. All of these concerns should notably lead to greater consistency and a more rigorous accountability for the activities funded by the FCRP. 3.2.4 Accountability linked to the Framework and the FCRP The Framework provides that governments report annually, on pan-Canadian commitments, to say that each government would “report to their residents on the progress relevant to their unique contexts and programs”.84 Up to now, the only reporting document we could consult was a progress report, which included the content of the framework document and reports on initiatives related to the recognition of foreign qualifications. The progress report provides little specific information on the current situation of the projects funded under the FCRP, which nevertheless declares itself to be connected with the Framework, particularly because of the professions that have been prioritized. In fact the progress report mentions some of the projects that we presented in the first part and when it does, it is only a brief description. That is the case, for example, of the RAIC’s project we presented in subsection 1.2.3. As the progress report indicated:

The Royal Architectural Institute of Canada is developing a national system for assessing the qualifications of internationally trained architects who have at least seven years of professional experience. This project is being undertaken in collaboration with provincial and territorial regulatory authorities and will contribute to a more efficient, fair and timely assessment process for internationally trained architects.85

We may recall that the RAIC received more than $3.3 million from 2006 to 2014, while in 2009, nearly $550,000 was spent on this project, which was funded again in July 2010, to the tune of close to $2 million. The least that can be said is that the report is short on details. The progress report includes initiatives that are not funded under the FCRP and do not necessarily have a connection with the professions that have been prioritized by the Framework. This is not a problem, as the Framework would, in principle, have a broader

83 Office of the Fairness Commissioner (2009). “Study of Qualifications Assess”. Toronto, March, 42 p.

(click on the following link: Available online). 84 Forum of Labour Market Ministers (2009), op. cit., p. 9. 85 Forum of Labour Market Ministers (2011). “A Pan-Canadian Framework for the Assessment and

Recognition of Foreign Qualifications – Progress Report, November 2009 to December 2010”, p. 14.

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vision than the FCRP. For example, it is stated in the report that the “Saskatchewan [government] is preparing a toolkit of resources for internationally trained workers and career counsellors to help determine if entrepreneurship is a good option”.86 Also, an online job search tool from the federal government is reported, namely, www.workingincanada.gc.ca, which provides “pan-Canadian and provincial/territorial information about regulated occupations, and includes links to regulatory and provincial websites”.87 A brief look at the website did not allow us to confirm if this is the case. Lastly, unless other reports are available on the web or elsewhere, for example on demand, the progress report does not give us the impression that the criteria defined above to assess governance (transparency, participation and shared responsibility) are applied.

86 Forum of Labour Market Ministers (2011), op. cit., p. 17. 87 Ibid., p. 11.

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CONCLUSION It is important to remember the current limitations of sources of information. That is why we have qualified our analysis as preliminary, since we have little information in terms of accountability on projects funded under the FCRP. As transparency, participation and shared responsibility are important elements of governance, we can question the ability of the Forum of Labour Market Ministers and its Foreign Qualifications Recognition Working Group to guide and support the Framework implementation. That implementation is supported by the FCRP, whereas it appears to have a separate approach that is more uniformized or centralized than the Framework. One may also ask whether the Forum, the working group and the FCRP have lost sight of the fact that the social and economic realities are not necessarily or always pan-Canadian. Yet it is obvious when we think about the relationships that the regulatory bodies have with the professionals they supervise in their respective territories, the relationship that each has with its population, not to mention those that all of them have with their own provincial or territorial governments. This is also evident when looking at the regional economic and industrial structures in Canada, which determine the labour market in these areas and thus whether people who can practise a regulated profession are hired or not. We can only praise the efforts concerning the socio-professional integration of people trained abroad, those seeking to facilitate their admission to regulatory bodies and even those whose objective is to establish collaboration between provinces or territories. However, in terms of governance and efficiency, organizing and exercising responsibilities in order to harmonize the standards and registration practices through centralization and uniformization do not appear to be a ready-made solutions that could be applied to all cases.