Hon. David Caplan
Ministry of Health and Long-Term Care
56 Wellesley Street West, 12th Floor
Toronto ON M5S 2S3
January 29, 2009
Dear Mr. Caplan,
Thank you for the opportunity to respond to the September 2006 Report to the Minister of Health and Long-Term Care on Regulatory Issues and Matters respecting the use of the “Doctor Title” in Traditional Chinese Medicine. The Registered Nurses’ Association of Ontario (RNAO) and its members are very supportive of the RHPA and the fundamental concepts that underlie the legislation: protection of the public and self-regulation. This legislative context has accommodated many advances in the health professions over the last 16 years. While the structure of the legislation with overlapping scope of practice, self-regulation and protection of the public remains sound, the legislation does require changes to keep up with changing practice environments.
RNAO supports the use of the term “Doctor” for all regulated professionals who possess a doctorate degree, or PhD. We are concerned that nurses, who hold a PhD or Doctorate Degree, are currently unable to use their title as it infringes on RHPA. We ask that the “Doctor title” be available for use by Nurses and other regulated professionals who possess a PhD or doctorate degree.
RNAO strongly endorses regulatory and legislative changes that will facilitate implementation of the recommendations surrounding the regulation of Traditional Chinese Medicine (TCM) in Ontario. In so doing, the RNAO agrees that Ontario’s standards for use of the doctor title should be at least equivalent to the highest standards in other jurisdictions where TCM is regulated. Generally, RNAO feels that it is in the best interests of the public that every self-regulated profession be responsible for their own minimum educational requirements, levels and assessment of competence and appropriate credentialing.
RNAO supports the establishment of a minimum standard for an educational program leading to a Doctor of Traditional Chinese Medicine (Dr. TCM) degree as outlined in the summary of recommendations.
The ideal candidate should have completed a rigorous and coherent course of undergraduate study, which would provide evidence of an independent, self directed and mature learning style.
RNAO encourages the Transitional Council of the College of Traditional Chinese Medicine Practitioners of Ontario to continue the development of written examinations for both current and new TCM practitioners in Ontario, as well as establishing guidelines for the assessment of credentials for those applicants to the Dr. TCM class educated in other jurisdictions. RNAO further encourages the continuing collaboration with Ryerson University and the Ministry of Citizenship and Immigration to develop bridging
program requirements for those individuals who require education upgrades in order to qualify for the Dr. TCM title.
RNAO supports requiring the Transitional Council to establish an education committee, with a view to establishing an accreditation standard for educational institutions offering programs leading to the Dr. TCM degree. Recognizing there currently is no accredited professional program in Ontario, evaluation of the standards and accreditation of new and existing educational facilities offering professional TCM programs is critical.
RNAO fully endorses the requirement for candidates for registration in Dr. TCM class to pass a competency examination following presentation of earned credentials and completion of a course in ethics and jurisprudence as approved by the College.
Non-exemptible and Other Requirements
RNAO fully endorses the non-exemptible requirements for a certificate of registration similar to those established for other professions such as mental competency, knowledge, skill and judgement, and the absence of investigations or proceedings involving an allegation of professional misconduct, incompetence or incapacity in Ontario or another jurisdiction.
However, RNAO would ask HPRAC to consider a transitional period or ‘grand parenting’ the requirement of English or French proficiency in recognition that most current TCM practitioners are from abroad and have built up a practice almost exclusively serving their community.
RNAO supports the use of the “Doctor title” for all regulated professionals who possess a doctorate degree, or PhD.
We are hopeful that the perspective we have provided is helpful to HPRAC’s deliberations and we are confident that this important work will have a positive impact on patient care and advancing the implementation and integration of additional regulated professionals throughout Ontario’s health-care system.
Wendy Fucile, RN, BScN, MPA, CHE
Registered Nurses’ Association of Ontario
Doris Grinspun RN, MSN, PhD (cand), O.ONT.
Registered Nurses’ Association of Ontario