Organization
[April 17, 2023 10:28 AM]

Competition Bureau Canada
Response in PDF format.
Member of the public
[April 10, 2023 2:43 PM]

Hello,
As a member of the public and on the mailing list for Consultation Feedback, I have read the background and the online discussion page comments.
 
I noted a significant number of very early responses then set this aside until closer to the deadline.
 
My comments:
Proficiency in English is important.
Refer to responses including:
The external response by the World Education Services dated March 24, 2023.
Also response by the Ontario Trial Lawyers Association

 
Mandatory degree in medicine
 
Has the Canadian Medical Association prepared a similar document at the national level?
Have provinces, for example British Columbia, completed this?
Both suggested for reference only.

 
Consideration of priority welcoming back of Canadian / Ontario medical school graduates who were obligated to leave Canada / Ontario while international medical students occupy spaces at Ontario medical schools.
 
With known shortage of physicians in provinces across Canada, Ontario should consider not trying to actively recruit this group. Burn-out and shortage of doctors as well as shortage in most extra trained specialists - medical oncology, ophthalmology, general practice and others are established facts.
 
Increase the number of spaces in medical schools now.
For a qualified doctor who wants to relocate to another province, simplify any provincial boundary requirements.
Prefer not to say
[April 10, 2023 11:48 AM]

Good afternoon,

Please see the comments below regarding proposed regulation changes with respect to the Emergency Circumstances Practice Class of Registration:

The draft of the proposed changes to the legislation surrounding emergency circumstances appears to be primarily directed towards easing barriers, hurdles, and delays for recruitment of internationally trained physicians during a prolonged declared emergency (as occurred over the course of the entire pandemic), as well as addressing issues that arose due to delays in writing exams by current local trainees. However, the legislation should be further clarified and specified in greater detail. The long-term chronic shortage of health care providers including family physicians in Ontario should be addressed by other additional measures and mechanisms, and probably should not be addressed primarily through “emergency” legislation.

First, the legislation should explicitly specify that nothing in this legislation is intended to preclude or hinder assistance or intervention by any person (whether registered or not) in an emergency circumstance (e.g., a bystander providing care in the field due to emergency, providing assistance during a medical emergency that is potentially life-threatening or associated with significant morbidity). This mostly relates to nearby persons in emergency circumstances, rather than formal long-term registration of Canadian or foreign physicians for the paid practice of medicine. The legislation could either incorporate language in a clause which explicitly condones such assistance/intervention and provides immunity from the regulatory perspective, or explicitly clarifies that this legislation does not preclude or hinder such assistance/intervention.

Second, the draft proposes registration based on an MD and a single year of postgraduate medical education. In most cases, this level of education and experience does not prepare individuals for more specialized areas of practice including complex or high acuity situations. For example, it would not be reasonable, appropriate or consistent with the College’s mandate to expect that most or all recent MD graduates could provide more advanced emergency and ICU services, as might have been asked of them early in the pandemic. Indeed, it may be a fallacy to suggest that most physicians practice based on their MD degree. The vast majority of physicians practice based on knowledge, skills, and experience continuously developed after medical school. On the other hand, several recent graduates probably could make meaningful contributions in some areas using existing skills, under supervision, in the context of a public health emergency. Of course, there is significant variability across areas of practice and individuals, which complicates specification of uniform criteria in such a regulation. It may be helpful to distinguish between more generalized practice (e.g., family practice) and specialties in the legislation, although this may not completely achieve good specification. With the move towards competency-based education and evaluation, it is not clear that there should be a firm “non-exemptible” clause as drafted here, given that other qualifications, competency-based evaluations, and/or criteria could theoretically satisfy public needs (in some future emergency, the nature of which is not currently known) while remaining in keeping with CPSO mandate.

I agree with a comment on the CPSO website suggesting empowerment of the health care team. For example, a local NP who is skilled, experienced, and competent in provision of critical care services should be able to assist and practice in line with their competencies (under physician supervision if needed) in an abrupt emergency with an ICU crisis. This is more likely to provide good and prompt care and assistance (in line with CPSO mandate) than later recruitment of a PGY-2 inexperienced in that area. It is not clear to me whether this is best addressed in this legislation or through another mechanism.

Regards.
Member of the public
[April 09, 2023 8:40 PM]

I am encouraged by the proposed changes.
In an emergency,declared or apparent it is important
to have medical professionals avaialable
to care for patients.
These changes,although not guaranteed
most probably would reduce wait times and
prevent burnout of medical professionals.
I believe it may be a good idea to extend
the certification past the conclusion of
the emwrgency to allow for a smooth
transition to the quality of care
pre-emergency.
What is classified as an emergency?
Physician (including retired)
[April 09, 2023 10:09 AM]

I hope this includes allowing physicians who are already licensed specialists within Ontario who are experts in one area, to practice in other areas of needs like emergency and family medicine. This is providing that they are enough experience to provide such services.

This is important in rural communities.
Physician (including retired)
[April 08, 2023 12:37 PM]

In general this is a good and positive initiative and I support it. And I also support considering passing Canadian qualifying exams (and also English profeciency tests performance), and also any rael hands-on Canadian medical practice experience (as supervised and/or delegated medical practice) into account.
Physician (including retired)
[April 08, 2023 12:04 PM]

About "The standards and qualifications for a certificate of registration authorizing practice in emergency circumstances are as follows:"
-Paragraph 2: How accreditation of the medical school granting the "degree in medicine" is approved to meet the international standards for Medical schools? (example: WHO list of approved medical schools?)
-pragraph 3: To clarify the nature and componenets of the "one year of post graduate medical training" to meet the requirements needed during the emergency circumstances.
Physician (including retired)
[April 08, 2023 11:10 AM]

The criteria seem reasonable to allow these physicians to practice in emergency circumstances and possibly beyond if their supervisors are satisfied that they are safe and competent
Organization
[April 06, 2023 2:04 PM]

Ontario Trial Lawyers Association (OTLA)
Response in PDF format.
Physician (including retired)
[April 04, 2023 8:20 PM]

This is a great move to overcome shortage of physicians and to take advantage of international medical graduate skills and experience
Physician (including retired)
[March 29, 2023 8:51 AM]

I think this is a great stepping stone to allowing foreign trained doctors the ability to transition back to Ontario to practice as many have their U.S. qualifications but have a significant lag time in being able to obtain licensure in Ontario with the 3 month application review by the CPSO, the 3 months to review a document through the MCC and then also needing CFPC certification w/ or w/o exam. This could be especially integral to transitioning new family practice grads trained in the U.S. as they already have their board certification before graduating residency but have to wait for all these documents to be verified. This could allow them to start practicing under supervision until which time their remaining documents are verified and they can be transitioned to an Independent Practice License. I think there's an argument to be made to extend this to outside of the hospital such as GP clinics who are the frontline/first contact for all things medical including mental health. Thus, alleviating some burden on hospitals and ERs.
Physician (including retired)
[March 29, 2023 7:44 AM]

Based on this proposal an applicant must have a degree in medicine and completed a year of postgraduate medical education at an accredited medical school, being supervised by a responsible physician holding a certificate of registration authorizing independent practice in Ontario. However, the certificate expires either one year from the date the certificate was issued or renewed; or the ninetieth day after Council declares that the emergency circumstances have ended.

Apparently this proposal designed for IMG physicians and I believe who designed this was totally successful to disrespect all physicians who are not eligible to practice independently in Ontario.
This proposal not only dose not take the humanitarian principles in to account but also is definitely considered an abusive act against the physicians in the emergency situations. CPSO cannot abuse the physicians and throw them away like toilet paper whenever it wants. They are either eligible for licensure or not. Please stop discrimination against IMG physicians.
Organization
[March 28, 2023 12:03 AM]

World Education Services (WES) and Internationally Trained Physicians Access Coalition (ITPAC)
Response in PDF format.
Member of the public
[March 19, 2023 9:33 AM]

I agree, in a deemed emergency situation this appears to be a solution to allow more practitioners into the field to serve patients.
In section 2(1), the ability to communicate effectively from a caregiver's perspective means more than a good command of the English/French Languages. It means the ability to actively listen to what patients are saying, be willing to answer questions and to speak at a level that is patient friendly.
Physician (including retired)
[March 17, 2023 6:32 PM]

I fully endorse the proposed amendments.
Physician (including retired)
[March 17, 2023 11:45 AM]

The biggest problem with these alternative registration classes is that they result in a dead end.

I entered Canada using the 3rd pathway registration for US graduates. Previously, I completed a 3 year ACGME certified residency in emergency medicine and practiced in the US for 7 years. I moved to Canada for my wife who is a Canadian physician.

Would I recommend that ANY physician outside of Canada use one of these pathways? Absolutely not. The reason - they all end with a RESTRICTED license and no pathway to an unrestricted license.

With a restricted license, CPSO places a literal red flag on the physician search page. This is the same flag that would appear if you had a negative action against you. With a restricted license, you will not be eligible for many jobs. You will NOT be able to advance your career.

The only way to deal with the restriction is to start the process over. I had to sit for MCCQE1, MCCQE2, CCFP written and oral exams. After about 4 years and ~$20k, I could apply for a new CPSO license.
Physician (including retired)
[March 17, 2023 11:31 AM]

s. 6.2 (1) subsection 3 should read:
3. The applicant must have completed a year of postgraduate medical education at an
accredited medical school or residency.

In the United States, many ACGME accredited residencies are not affiliated with a medical school.
Physician (including retired)
[March 17, 2023 10:03 AM]

It is very good idea to help.
Physician (including retired)
[March 17, 2023 8:48 AM]

Does the requirement for the Emergency certificate to practice include Applicants without Licence of Medical Council of Canada [LMCC]?

Also does it applies to International Medical Graduates [IMG] whose Medical Diploma is outside Canada and the USA?
Physician (including retired)
[March 14, 2023 4:15 PM]

Hello,
We can not compromise the standards of taking new MDs in to practice, just move fast, with the same criteria and standards, MD is very very important for the health if community, can not compromise it.
Thanks
Physician (including retired)
[March 13, 2023 4:51 PM]

Looks OK
Physician (including retired)
[March 12, 2023 7:08 PM]

I agree with the changes in principle, but the candidates should be limited to those who have graduated from a medical school with standards comparable to those of Ontario medical schools. This would require the generation and maintenance of a list of medical schools that meet that standard. A similar list would have to be generated and maintained for postgraduate programs at medical schools, and each program would have to be assessed independently. It quickly gets to be quite an onerous process, but a necessary one if the integrity, and the perceived integrity, of the College's Certificate of Registration is to be maintain.
Other health care professional (including retired)
[March 12, 2023 3:14 PM]

I don't think that race or gender in a country promoting equity and inclusivity is necessary and may even not be supported by Human Rights.
I am pleased to see the College responding. I wonder about the regulation only being for a year and if the emergency will actually be over. If an IMG or other physician is willing to commit a year under the guidelines, then will they commit to a longer period. I think if the year is left in the the proposed regulation then a review date should be put in the regulation.
I wonder if the IMG or physician is deemed qualified to work under supervision for a year then how do they become licensed thereafter. Does working under this regulation change and with positive references including a positive work experience allow them to quickly move into another pathway for licensing and working within Ontario and possibly Canada? I think that this should be thought out and stated clearly and I don't see that in the proposed regulation.
Proficiency in English and/or French is necessary within Canada. Knowledge of other languages is an asset.
Other health care professional (including retired)
[March 11, 2023 12:27 PM]

Hello,

This a great opportunity for the foreign medical graduates to help out under emergency circumstances.
Physician (including retired)
[March 10, 2023 1:33 PM]

This was discussed at our recent medical director's meeting at a hospital in a more rural setting - just want to ensure that when these designations are given, there is some recognition that these will be used equitably (from a geographic perspective) in settings where there is need (ie not just in medical training sites in larger urban settings). Thanks you.
Physician (including retired)
[March 08, 2023 2:15 PM]

Amendment necessary and should be a priority condition ,
with a 2 years fellowship in a Canadian University program to obtain their title of FRCPC
Physician (including retired)
[March 08, 2023 12:22 PM]

I find the inclusion of race and gender in the demographics is nothing short of bizarre and somewhat shocking in this day and age. The reasons can only be construed negatively. I believe that including a request for this information completely negates the value of this survey. The fact that there is a “prefer not to say” option does not redeem this transgression of the mores of the world we wish to inhabit.
Physician (including retired)
[March 07, 2023 7:12 PM]

There should probably be information about permissions regarding scope of practice, i.e. if a surgeon or family physician is recruited to do hospitalist work, or an anesthesiologist / family doc work in the emergency department, RCPSC specialists start providing primary care, etc.

I believe the policy aims to encompass international trained physicians by not specifying "within Canada" in the policy. Perhaps terminology about accepting internationally trained physicians could be incorporated for clarity. Physicians from certain countries could be made exempt from the need to have a supervisor (i.e. hospitalist trained in Australia/NZ/England/Ireland comes to work as a hospitalist in Canada - unlikely to require supervision) while those from other countries may be more likely to need supervision.

In general, this is a great move and I highly recommend the college to continue to consider other ways to expediate internationally trained physicians (i.e. especially our own Canadians who train abroad) from countries with high standards of medical school training obtain certificates of independent practice here in Canada in general - not just under emergency circumstances. Also, we should NEVER have unfilled residency positions in any specialty with the number of foreign trained doctors (ukraine, russia, africa, haiti) who are trying to get into a residency in Canada after moving here to escape hard times in their own countries.

Language - fluent in english or french recommended
Physician (including retired)
[March 07, 2023 4:15 PM]

this amendment looks reasonable.
Physician (including retired)
[March 07, 2023 1:58 PM]

Agree with proposal.
Physician (including retired)
[March 07, 2023 12:26 PM]

Agree! These candidates may enter to the system through supervised route is good idea.
Physician (including retired)
[March 07, 2023 10:26 AM]

Definitely it is great move forward to support the public and off the pressure on the practising physicians.
I like to have clarification of what does it mean with one year "accredited postgraduate training"? Is it limited to training in US, UK, Ireland, Australia and NZ?
- I was 45 when first landed in Canada willing along with my family to practice Pediatrics. Having full energy, enthusiasm, knowledge, and clinical medical exposure was denied to work in the most remote areas in Canada!
Physician (including retired)
[March 07, 2023 9:52 AM]

I believe this is a good step in the progress of credentialing physicians from abroad who have the qualifications to practice in Ontario. Being supervised is important. Being qualified by Royal College or College of Family Physicians does not really add anything as how would a physician in such circumstances complete those requirements. I believe there should be an addition that if the physician performs well under the emergency stipulation after one year that physician should be eligible for full licensure
Physician (including retired)
[March 07, 2023 6:54 AM]

First of all. I think it’s a great idea. However definition of “ emergency “ must clearly described.
Secondly I think a contract of only 1 year is too short. Amend it to allow up to 3 years as this will act as an incentive for would be applicants.
Allow for a clear path for them to obtain a full license depending partly on recommendations by the supervisor as well as their completion of the licensure exams.
Physician (including retired)
[March 07, 2023 6:00 AM]

I recommend that they also at the very least pass a competency or license exam and a language exam

There could also be a class of physician assistants/extenders that can extend and help work in case of emergency or need.
Physician (including retired)
[March 06, 2023 7:37 PM]

There are so many international clinical fellows who are currently working in the academic centers and were a huge part of patients’s care during the pandemic time. They have already worked under supervision and are ready to practice in community or academic centers as clinicians and not necessarily researchers or teachers.
Physician (including retired)
[March 06, 2023 7:34 PM]

For the sake of college satisfaction, one chance should be given to physicians who have licentiate of Medical Council of Canada but not registered with CPSO due to lack of training in Canada.
Physician (including retired)
[March 06, 2023 7:28 PM]

It will be very helpful to get help from physicians already present in the country but are not eligible to work as physicians. We have seen the result of shortage of healthcare workers during the Covid. We could mobilize our local resident physicians as other countries did.
It is a good idea that such physicians should be given a chance to prove themselves.
Physician (including retired)
[March 06, 2023 6:03 PM]

Absolutely agree.
Physician (including retired)
[March 06, 2023 6:00 PM]

The best candidates for this pathway will be the current international clinical fellows who already have been working under supervision and have a clear traceable records of academic evaluation by PGME. They are already trusted enough to manage patients under minimal supervision.
Physician (including retired)
[March 06, 2023 5:58 PM]

I don't think there is enough clarity:
1. What qualifies as "accredited". There may be some places where accreditation standards are not acceptable here. Not all accreditation bodies have the same standards. Also will there be a process to verify qualification? A time limit - would we grant this to someone who graduated 10 years ago and has not practiced?
2. Canadian medical graduates cannot even practice here with one year of postgraduate training so I am not sure why this would be allowed with other physicians.
3. Is this fair to IMGs who are doing exams and residencies?
4. Who will the supervising physicians be? Will these physicians be able to bill OHIP? How will supervising physicians have time to provide adequate supervision and office space?
5. What constitutes an "emergency"? We are always in an emergency. Need to be clear of the parameters in which this emergency circumstances regulation would take effect.
6. It should be easy to move between provinces within Canada but I personally would be wary of seeing a physician who had gone to a medical school, perhaps many years ago, in a place whose accreditation standards are unknown to me, had only one year of post graduate training, and a supervisor who was not in a teaching practice type environment or hospital and not able or used to providing supervision and teaching.
Physician (including retired)
[March 06, 2023 3:21 PM]

I like to suggest;
1. Some basic training in EMR working under a supervised setting for approx 2 months prior to work, to get familiarized with the system can greatly enhance the output.

2. Remove the uncertainty with ending after the emergency period is over. Have a proper integration pathway at the end to integrate them into the workforce. Then they will actually contribute to the country's economy.
Physician (including retired)
[March 06, 2023 3:20 PM]

I support this changes and presume it could be made renewable yearly.
Physician (including retired)
[March 06, 2023 3:12 PM]

I am wondering why the certificate expires 90 days after the end of the emergency period. This seems like quite a long time for someone to hold their certificate once the emergency is over. Otherwise definitely in support
Physician (including retired)
[March 06, 2023 3:02 PM]

The determination of the emergency needs to be clearly defined as this initiative could simply lead to more dumbing down of physician competency. What we really need is to open up Canadian medical schools to train up a lot more doctors rather than creating bandage solutions. Pay for their tuition for the 4 or so years, and they provide 5 years of service in underserved areas following approval to practice independent practice. Creating other scenarios of unsupervised practice among those with medical training overseas or Canadian students with insufficient practice experience prior to being unsupervised is a recipe for more iatrogenic harm. First do no harm, then do good.
Physician (including retired)
[March 06, 2023 2:45 PM]

Note: Some content has been edited in accordance with our posting guidelines.
I am an IMG who has completed my medical oncology training in Spain (5 years of medical oncology residency). Given that medical oncology is a specialty instead of a subspecialty in Spain, we do not require internal medicine training and for that reason I do not meet the criteria for performing the exams here. I also finished my phd and I’ve completed almost 2 years of fellowship at [hospital] now and I’m planning to stay in Canada given that my partner is Canadian. The issue is that I can only apply to academic positions. I wish I was also able to apply to community positions which sometimes are difficult to cover. I honestly think you should review the requirements for IMG. I recently had an job interview in a community centre and they said I was the best candidate for the position but they couldn’t hire me because I don’t have an independent practice license. This position has not been covered yet and it’s been 6 months since I did that interview. I don’t understand why I can’t get if no other physicians from Canada want it and the hospital is struggling to find someone. That doesn’t make any sense to me.
 
I think this proposal is a step forward but it’s not fair to cancel this certification after 1 year. It should be an option to transition to a permanent independent license.
 
Hopefully things change sooner than later.
Physician (including retired)
[March 06, 2023 2:19 PM]

Hi , I do support this license but I still do not know what would emergency situation be defined as ?
I definitely encourage this registration and extend it more as well he community needs to.
Physician (including retired)
[March 06, 2023 1:51 PM]

I support the above-mentioned proposed regulation change. Given my experience as an Ontario resident, I have experienced paucity of primary practice physicians throughout Ontario. There are experienced physicians including those, who have done few years of residency training in Europe but had to re-locate to Canada due to family reasons. Here in Canada, they have scored really high on Canadian exams including QE2, which speaks for their strong clinical practice potential. Lot of Ontarians suffer from long wait times and lack adequate health care because of physician shortage. I think this decision not only supports our patients, but also provides our regulatory authorities to get a chance to select individuals with excellent clinical expertise.
Prefer not to say
[March 06, 2023 1:48 PM]

Excellent initiative, however, as many others already highlighted, there has to be something better for those who will come to help with the "emergency" in Canada. Can not be only beneficial to the Canadian health system and after time is over, physicians will have to leave. Also, after the "Emergency" time period, if they are good, well-adapted, and successful in delivering health services,.......why would you like to end the working relationship? How will this be a fair deal or a long-lasting meaningful outcome for the healthcare system?

IMG fellows have to go through a Pre-entry assessment program in Academic centers. Maybe Academic Centers and non-Academic centers can have a similar program to evaluate clinical competence after all credentials are verified (same as a fellow), and once they pass that assessment, have them stay under supervision for 6 months to make sure the process of incorporation into the system is successful.

Physicians will need training period on the Canadian healthcare system, paperwork, administration, etc. One year as an "emergency" will not be successful or helpful and too much effort and taxpayers money will be lost. It is quite a waste of human resources that we see IMG fellows for 3 or 4 consecutive years with fellow responsibilities in Ontario, that later have to enter residency again to be able to work.

Ontario needs people to survive the "emergency" but political work needs to be done to offer outstanding physicians willing to come, something much better than a 1-year license.

Hope this helps
Physician (including retired)
[March 06, 2023 1:12 PM]

I feel that it's hard to accept these changes when the shortages are caused by the actions of the CPSO itself.
Physician (including retired)
[March 06, 2023 1:01 PM]

I think there is very scant detail as to the scope of practice for such a licence. Also, will such a physician be able to cope with an emergency situation? We would like to see some anticipated emergency situations….will this be restricted to certain practice locations?
Physician (including retired)
[March 05, 2023 12:30 AM]

Physicians with 2/3 or more years of international medical practice should also be granted this kind of license.
Physician (including retired)
[February 25, 2023 10:44 AM]

The proposal is good but extending the termination day to at least 6 months will be ideal for proper transition for both parties. Thank you for your time and effort putting this together.
Physician (including retired)
[February 18, 2023 4:41 PM]

I agree with you and also, I recommend as College de Medecins de Quebec does for the Supervising Family physician with restriction license after 5 years of the practice (that restriction license was renewed annually) they allow them to apply the Independence Practice without the requirement of the exams.
Member of the public
[February 18, 2023 9:04 AM]

A member who holds, or held within the previous year, a certificate of registration in the emergency class may be issued a certificate of registration in the independent practice category despite
not having successfully completed the registration examinations, if a member provides satisfactory evidence based on their practice for at least two-years full time under the certificate of registration
in the emergency class.
Physician (including retired)
[February 17, 2023 9:09 PM]

Why is only 1 year of postgraduate medical education required? What if the person was in a 5 year program and only completed 1 year? This point needs to be expanded upon
Physician (including retired)
[February 17, 2023 10:21 AM]

I am currently supervising a very experienced ER MD from the UK who is obviously very competent, yet he is having to drop his shift commitment significantly in order to study for a difficult Royal College emergency medicine exam. There should be a way to avoid this hardship for MDs like this. We are in a time of great staffing need, and taking a very competent and experienced MD out of the hospital to require them to study for a test that will ultimately prove very little about his clinical abilities/competency is unfortunate. I would like to see an alternate pathway to certification where these types of MDs do not need to write the same exams as their FR resident counterparts.
Physician (including retired)
[February 16, 2023 10:56 AM]

Why doesn't the College start working on supporting National Licensure with appropriate safeguards -- then there would be no need for emergency privileging.
Physician (including retired)
[February 15, 2023 7:30 PM]

I have wondered why a physician with a fellowship and years of experience is put through the ringer when they decide to move to Canada. Most of these doctors have excellent experience in their specialties. Doctors going to New Zealand, Australia and UK etc do not go through the same pain. It is fairly straight forward to move between these countries with no further exams. The practice in these countries like the UK is very similar to Canadian practice and a fellowship exam requirement will put many people off. Most training programs in the UK in the past stipulated 6 months each of different specialties. Why does and fellowship exam from say the UK not count as a US or Canadian fellowship. Why does Canada want t reject seasoned doctors from UK, Australia, New Zealand, Ireland etc putting them through unnecessary stress that some people doctors cannot cope with and eventually decide to go back. Why is a GP accepted from the UK AZ NZ Ire SA without fellowship exams, but a specialist who has been working for for many years with a fellowship exam with loads of teaching, leadership skills and hospital management experience take a step back to spend years writing unnecessary exams which will not change their practice? Why does the Canadian system want to put an extremely skilled Dr through this. Is a colorectal surgeon, ER consultant, Internal Medicine, Cardiologist etc from the UK NZ AZ Ire not as good as good as their counterparts here. Why does the US fellowship and the GP fellowship from these commonwealth countries get recognized but the hospital medicine fellowships get treated as second class? What is the explanation for that. These GPs from say the UK work with their consultant counterparts in these places with utmost respect as the training and exams are no joke. To ask them to go through this horrendous process when they could be doing clinical work and offering insight to improving Canadian services, does not make any sense. I know of many top doctors who have gone back to these commonwealth countries because they just thought it was too much to ask. You would think Canada wants to attract the best. A short period of supervision will suffice and if there are an issues then recommendations can be made. To ask a 45 -55 year old to go through this process of royal college exams is wrong and will put off some of he best and brightest who may even want to just come for a year or 2 of Canadian experience like most people do going to NZ AZ UK. The Canadian system is too convoluted and punishing even for a doctor at the top of his game coming from a developing country

I hope this consultation can do something about the royal college exams because it does not add any value to a Dr already with a fellowship particularly from a developed country as the systems are so alike.
Physician (including retired)
[February 15, 2023 4:46 PM]

Dear Sir/Madam,
Thank you for taking the time to read my comment regarding this class of registration. I am currently working as an emergency physician under this class. In my opinion, the change of the duration of the licence to one year is necessary since it is difficult to renew appointments in one-month periods.
Physician (including retired)
[February 14, 2023 10:35 AM]

nevertheless!
Physician (including retired)
[February 14, 2023 10:01 AM]

Good to know that the Government of Ontario and CPSO are looking in this direction to ease the burden of millions of Ontarians without a family physician and its attendant consequences in our emergency rooms.
I have come across many IMGs who have passed the MCCQE1 and NACosce but can't move forward because of the so many barriers they are faced with. They end up driving uber, working at Walmart and doing all sorts of survival jobs but wasting away their skills acquired over the years.
That said I believe there should be minimum requirements to qualify for this registration.
May I suggest that these doctors should have at least one of the following:
1. MCCQE1
2. LMCC qualification
3. NAC OSCE

Proficiency in french or english , i would recommend
Member of the public
[February 14, 2023 9:46 AM]

Proposed Emergency Circumstances Practice guideline is the best way to proceed in Ontario except the proposed amendment to Independent Practice class which seems like another barrier for IMGs those who have one year postgraduate experience. The College of Family Physicians of Canada needs five years experience for IMGs to qualify for the certification exam. That five years experience requirement must be amended to two years Canadian experience.
Physician (including retired)
[February 12, 2023 2:17 AM]

So glad some policy is finally in place. We are loosing so much RICH talent in medicine. Giving people opportunity to work under supervision is a great way for them to get to know the system and gain experience.
I look forward to more policies where physicians hired through emergency act get a chance to integrate and help the system thereafter as well.
Physician (including retired)
[February 11, 2023 9:37 PM]

There is no doubt that the proposed by law is needed to fill the gaps in service. It will be wonderful if Ontario can use so many available well trained landed immigrants that are already trained as doctors abroad with so many years of experience to alleviate Health need of the Ontarians. Never the less, I would like to emphasize that ensuring the applicants have required language skills for delivery of safe health care is as important as their clinical skills for success of this by law.
I wonder if college have plans for language testing. Considering that it is effectively bypassing the safeguards that is in place through CMA exams.
I personally witnessed the effect of poor language skills in UK after EU wide freedom of movement and work come to effect, there were initially no language requirements, applicants Just needed to meet clinical requirements to get a licence in UK. After so many clinical incidents and court cases, it has gradually downed on regulatory bodies that language skills are essential in delivery of care, which lead to reinstatement of language proficiency tests.
Physician (including retired)
[February 11, 2023 6:00 PM]

I think this is a step in the right direction but every physician given a license (as temporary as it may be) has to have a route for making this license permanent if they choose to continue working in the province (which does not include doing all their residency exams from the beginning). I don't think that any reasonable person would decide to come and live with his family in a place where they are guaranteed employment in medicine only for one year and then will need to relocate their family again to another province/country. This license has to serve as an opening to get familiarized with the medical system in the province and be supervised.
Physician (including retired)
[February 11, 2023 11:09 AM]

This is a step in the right direction for strengthening healthcare throughout Canada and addressing areas of need in a timely fashion. My two concerns are (1) the time limit is too restrictive - not sure why there has to be an 'expiry' date. Would it not be in the best interests to have the physician continuing to practice after the emergency period, given all other requirements for licensing are met? (2) unclear why these qualified physicians would need supervision, adding another layer of tasks to the supervising physicians who are already stretched.
Physician (including retired)
[February 10, 2023 9:50 PM]

i wonder if the ideas from this process will be shared for discussions on national qualifications and not just provinicial registration , agree most Residents in training are known to have capabilities from many avenues of evaluation along the way
Physician (including retired)
[February 10, 2023 5:28 PM]

From reading your feedback, I have to say some of the physicians here are undermining the capabilities of some of their colleagues. I understand you as Canadian graduate doctors don't like IMGs to be certified from CPSO and LMCC. Yeh you are always superior ha!! See how many licensed IMG physicians are going throughout lengthy wait from CPSO because of allegations that were not proved yet. They are sitting home for years. Why not the CPSO can bring those doctors back and let them work under supervision if they deem necessary??? Race, genger, ethnicity should not be factors to talk about but it looks like the the racism in this country is undeniable.
Physician (including retired)
[February 10, 2023 11:48 AM]

In no order of importance, I would point out
- The proposed regulation is focused on institutional care, despite mentioning Ambulatory Care.
- Professionalism is not mentioned.
- Ability to work in inter/multi/transdisciplinary teams is not mentioned.
- No mention is made whether this class affords any greater likelihood of independent licensure in Ontario. This concern is a significant policy issue.
- There should be cross-reference to compliance with Ontario laws and standards, as well as fluency in the medical terminology used by one of Canada's official languages.
Physician (including retired)
[February 10, 2023 10:55 AM]

I disagree with this proposal in its entirety. The issue is we do not have enough healthcare, and Physicians are only one element of the solution. Ontario residents do not deserve an inferior quality of care at any time. We have many NPs, PAs, RNs, who are adequately able to work under Physician supervision - who are licensed in Ontario. They need to be empowered and Physicians need to be supported to oversee their care as appropriate.

This Regulation will create more problems than it will solve. It is baked with unfairness, Charter of Rights and Freedoms appeals, and not to forget there is much more to providing care than medicine - there is a steep learning curve with the practice environment and equipment that needs to be considered.

Overall - I do not support this; I'm an IMG who successfully navigated the system. I have seen what is out there, and I would prefer a local NP to care for me.
Physician (including retired)
[February 09, 2023 11:27 PM]

Having read the amendment, I am still unclear as to what is being proposed
Are we referring to IMGs who may have completed medical school training in an accredited medical school e.g. RSCI/UCD/UCG etc, plus 1 year post graduation (i.e. internship?)?? who can then practice without having passed MCQE1 examinations as long at they have a supervising MD?

I believe there are many such candidates who would fit the bill and where we in Ontario would be best served by not putting barriers in their way. This 'transition year' would allow them to apply for residency training etc in the normal way. The MCQE1 should not be a barrier to highly capable MDs fro reputable schools in UK, Ireland, Australia etc. We are loosing Canadians with good qualifications to other countries such as UK and Australia who will accept their qualifications without the need for another exam.
Physician (including retired)
[February 09, 2023 8:37 PM]

I whole-heartedly agree with this comment.
The proposed emergency license is clear and reasonable but including licensed physicians who have passed their specialty/family practice certifications for the US, UK, Ireland, Australia and NZ would be even more helpful.
Physician (including retired)
[February 09, 2023 5:22 PM]

The country from which the degree in medicine should should be specified. The amendment should be restricted to those whose degree in medicine would normally be accepted at par with a Canadian degree, such as those who trained in the US, UK, Australia, New Zealand etc. The same should apply to the year of postgraduate training, which also should be specific to the specialty area in which the applicant is expected to practice.
Canadian medical training is of high quality and Canadians have come to expect that level of excellence in their physician practitioners and trust that it will remain so. Quality should not be diluted based on perceived or real "emergencies." I agree with the other comments that licensure in one province should be acceptable to other provinces. I also support consultation with the Canadian medical schools and postgraduate programs before acceptance of any licensure decision. If that has not occurred, I am concerned that this amendment merely improves numbers without consideration of quality. Gender and race should not enter into this discussion.
Physician (including retired)
[February 09, 2023 3:27 PM]

This would be a welcome change and help reduce the immense stress our health care system is in currently. The are many foreign specialist physicians trained outside Canada, who are very skilled and can easily transition into the Candian Health Care System, given they receive a little guidance and mentoring. Also, there are foreign specialist physician who have already completed Fellowships program or are actively pursuing fellowship programs currently in Canada, and so are already well trained to be integrated into the health care system, given the opportunity. Having a smooth-running robust health care system will be beneficial to all provinces and will certainly cut down on patient waiting time province wide.
Physician (including retired)
[February 09, 2023 2:13 PM]

Excellent proposal to meet the shortage also a definite number of years to transition to full license would incentivise more people to come
Physician (including retired)
[February 09, 2023 9:04 AM]

I like the fact that this is potentially contributing to the public good, and moving towards practice ready assessments in Ontario; however, I don't see any involvement of medical schools or residency programs as helping to set the standards. Perhaps I am missing that. Something as important as this should go beyond simply having an independent practitioner "vouch" for someone, in my view.
Physician (including retired)
[February 08, 2023 5:08 PM]

Before any license of any sort is granted to any physician under any circumstances be it for temporary or permanent reasons two main attributes must be demonstrated and confirmed by the licensing body:-
1, Proficiency in one or both official languages, French/English which includes understandable communication.
2, Proven knowledge base in the area of medicine the individual is being licensed to practice.
Requesting another physician to supervise and therefore take responsibility for on going care provided by a physician without the above would be detrimental to patient care since (He/She/They) would be rendered inefficient, presumably something to be avoided in emergency situations.
Physician (including retired)
[February 08, 2023 3:55 PM]

Note: Some content has been edited in accordance with our posting guidelines.
Good afternoon,
I'm emailing you regarding the proposed regulation change of the emergency circumstances practice class of registration. I believe this should be expanded to include family physicians/GP offices. The current state of access to primary care itself is an emergency. For example, in Sarnia there's 18% or over 23,000 residents without a GP and 29% of the population has a family physician over the age of 65. This is not unique to Sarnia-Lambton. I'm a family medicine resident completing my final 5 months of a 3 year family medicine residency training program in [US State]. I have a [Redacted] old daughter and wife on mat leave at home who I need to provide for. I have a contract to take over for a family physician in [Redacted] asap, however, due to the excruciatingly long process to return to practice in Ontario I'm not sure he will remain in practice for much longer for his 1500 patients. This adds another 1500 to the over 23,000 already without a GP. Again, this is not unique to [Redacted]. I have passed the NAC, MCCQE Part I, I have my LMCC designation, I've passed all of my USMLE exams and I'm taking my ABFM Board Certification April 14th with results by mid-June. In order to receive my Certification without examination from the CFPC I have to have my final 2 documents: ABFM BC and Diploma of Residency Graduation source verified by the Medical Council of Canada. In 2023 it's very frustrating that the source verification process by the MCC takes 12 weeks. In addition, the CPSO's processing times of ~3 months for issuance of Licensure will result in me being out of a job and unable to practice medicine during such a time of need for at least 6+ months from the time I complete residency in June. I could seek employment in the U.S. however, this requires a visa and I'd be signing a contract for 2+ years, delaying my return to Ontario, home, and my family for at least that long as my ethics and integrity would not allow me to ditch my U.S. contract after 6 months when I receive my Ontario license. I believe the Emergency Circumstances should apply specifically to cases such as my own where I've essentially met all the criteria, I'm on track to complete residency and I'm board eligible and will have my ABFM BC by June but I'm held up by the verification process. If I was able to submit my application to the CPSO in March-April in order to be issued the Emergency License with Supervision for July 1st I would not have a gap from training to practicing and could begin practicing under supervision with the expectation that my remaining documents will be verified, the CFPC will issue the Cert w/o Exam and I can transition my license/application to an Independent Practice License. It is my understanding that Canada has hundreds if not thousands of us trying to return home who are young and eager to return to their hometowns to practice, who have the energy to take on larger rosters and to serve our community for 30+ years. I urge you to consider this in your review of the regulation change as I think this is a low hanging fruit that could help ease the burden on the sinking primary care situation in Ontario.
Physician (including retired)
[February 08, 2023 3:37 PM]

I think it is more safe to allow PGY1 in Family Medicine to practice under supervision.
Physician (including retired)
[February 08, 2023 2:32 PM]

I wonder if there is going to be any movement of creating a medical licence that is good “country” wide.
Meaning- my ONT licence going to be usable in every province without restrictions or special application and vice versa for others coming to this province.

That would be a meaningful change

thanks
Physician (including retired)
[February 08, 2023 11:40 AM]

I am glad College is making progress on this matter as we are facing a crisis. I do have lot of colleagues who have already immigrated to Canada, done their LMCC exams, NAC and still not able to get through CaRMS and currently doing their Master's Degree, some are working as PSW in Nursing homes.
This will open the door for an opportunity ; a win win scenario improving accessibility to health care. I strongly agree with practice under supervision and reviewing annually.

Also wants to comment -we need more spots on Medical school admission for Canadian Students, Encouraging them to choose Family Medicine, also should recognize Family Medicine as a specialty by College and Regulatory Institution in Canada encouraging Canadian applicants to choose Family Medicine.
Recently I got my Fellowship in Family Medicine, attended the convocation of future Family Physicians, however only handful of graduates are educated in Canada. Majority are foreign trained doctors, which is good helping the new comers. however, I can see the culture of Medicine changing, only few people are choosing Family Medicine as their career. I wish College can advocate on this matter with medical schools to recognize Family Physicians as a specialty and to change the existing culture among medical students as every one wants to be a specialist in some other field than family medicine. The reason behind Family Medicine two year program where as specialty 4 to 5 yrs this has created an impression among students and specialist that Family doctors are lower than them in knowledge and skills; Family doctors are also less paid than specialists, so less and less students choosing the field of family medicine as their career. Some of them leave to US as well once they specialize or other provinces such as BC or Great City like Toronto.

I did specialize in Care of the Elderly and did a 3rd year. Opening up more opportunity in Family Medicine to focus on Geriatrics is a great way to gear interest in subspecialty; Specially in Rural areas this will address the need of shortage of doctors in other specialized fields. Giving more incentives for Family Physicians will improve Canadian Students choosing Family Medicine as their career.
Lot of patients who don't have family physicians are regularly visiting ER for simple medical issues and also we are well experienced and capable of managing complex issues as well.
Huge shortage of psychiatrists I encourage College of Family Physicians should open up doors in training family physicians in the field of psychiatry as their PGY3 training. because less and less students wants to choose Psychiatry as well. "Everybody wants to be a plastic surgeon! "

We need to review the Family Health Organization model as personally know many family physicians abuse this model; they work only 3 days a week as they get a salary monthly. They work less hours and get the same money or more we earn working every day and after hours. This model not only give poor quality of care as they have to see their patients 6 times or something in a year. So most of these physicians don't even bother to call their patients who needs regular follow up. For example my children and my husband go to a physician who is part of the FHO model, unless the patient walks in and ask for help no follow up from the other end as my husband has Hypertension and other health issues, not a single call from the doctor's office caring for their health and wellbeing. Where as in my practice every chronic disease patient (such as patient with Diabetes, Chronic Kidney disease, hypertensives, Cancer patients, CHF patient) is asked to book follow up apt. Every special investigations I send, I book them ahead of time ensuring they are followed to ensure patient safety. we need to review this model and put mandatory requirements so these patients will not end up in ER with complications and it is a huge impact on health care money too as preventive care is not done properly. Thank you for listening to me. I thought this is good opportunity to convey my views.
 
Physician (including retired)
[February 08, 2023 10:25 AM]

These are great amendments. The removal of licence transportability between Commonwealth trained physicians was a huge mistake, but understandable when it was to prevent the brain drain from other nations in need. This category should be reinstated, as long as the training is still deemed similar to Canada. I agree with another comment here that years of experience make a massive difference compared to the ability to pass a Board examination right out of medical school. The arrogance and discrimination in Canada's health educational system is appalling. You can easily do a web search and find that a student's chances of being accepted to a Canadian medical school is highly favoured to those from wealthy families. Such students have the luxury to pad their resumes while the others must work to support themselves or family. In the same way, I sympathize with experienced immigrant physicians who try to support themselves and their families while trying to study and pass all the examinations. I had a family friend work for two years as a hospital orderly, who studied and then passed the LMCC, and only able to work as a family doctor in rural Canada. He was a General Surgeon in Germany, with over two decades experience! What a waste of talent, and what abuse on him.
Physician (including retired)
[February 08, 2023 9:23 AM]

This regulation is to give an option to employ a group of physicians under emergency circumstances that don't have current licensure capabilities. The regulation would have these physicians employed under critical need to support current physicians.

For providing, emergency circumstances this regulation is sufficient.

However, as many others have commented, it leaves the much broader question around "why do we loosen the bar" when emergency circumstances occur only? And do we have to look at the broader registration process?
Physician (including retired)
[February 08, 2023 9:20 AM]

The one year limitation seems very short as the it takes more time to have a patient-doctor relationship and if the applicant is not allowed to renew ,where does that leave the patient?
Other jurisdictions notably NS and Nl/Lab (and others) have a much easier access policy for foreign medical graduates and have seen a high level of retention of doctors long term. Surely the requirement for supervision will allow assessment of care in family practice where the need is more acute.
Why put in "when the emergency has passed" and what is the def of "emergency"?
Physician (including retired)
[February 08, 2023 9:12 AM]

I would appreciate if CPSO could allow foreign trained IMG to practice in setting outside of hospital
under direct supervision from already accredited CPSO MD as long as supervisor MD feels IMG can practice safe and can handle delegated responsibilities well.
Physician (including retired)
[February 08, 2023 8:11 AM]

I do not believe the purpose of this change in regulation is clear. From the document, it suggests that this particular regulation would permit a PGY-2 resident to be granted a license under supervision if there were a declared emergency. The only example listed was "cancelled examinations" but there are many other scenarios that might help members respond more effectively to this request for feedback.
Additionally, there are no details to indicate where the Medical Degree is from (Canada, US, UK, anywhere?) nor where the 1 year of post-graduate education was obtained. I do not know whether the College intended to offer emergency registration to refugee medical graduates with 1 year post graduate education in a home country but the information in this document does not limit an application from such an individual.
I would appreciate the opportunity to offer feedback with the benefit of more background and detail. As it sits, it is fine, provided the intent was to offer this class of registration to anyone worldwide.
Physician (including retired)
[February 08, 2023 7:33 AM]

I think this is an excellent amendment and happy
that my college is forward thinking. This
Amendment will ease the pressures on pending
surgeries and availability of FPS for our acute
Backlog in these 2 specialities in addition
to others
Physician (including retired)
[February 08, 2023 12:30 AM]

That’s very generous proposal, it lacks the most important factor, the public safety, as I agree with proposals of emergency situations requirements, the proposed changes are too vague, I think it needs to have more credentials to be considered to be safe for public in general and to the health system viability
Physician (including retired)
[February 08, 2023 12:23 AM]

It is very reasonable. There are thousands of doctors holding MCC certificaties.
They can get priority.
After 1 year to take exams for CPSO license
Physician (including retired)
[February 07, 2023 11:57 PM]

I AGREE. WITH ALL THE PROPOSALS
Physician (including retired)
[February 07, 2023 10:59 PM]

The requirement of paragraph 3 of subsection (1) of section 6.2, "The applicant must have completed a year of postgraduate medical education at an accredited medical school." is suggested to be amended to "The applicant must have completed a year of postgraduate medical education at an accredited training centre according to local accrediting authorities, should this postgraduate medical education take place in other countries."

Reasons:
1. The postgraduate medical education programs may not happen at a medical school in other countries where the training system is different.
2. These programs in other countries will still need to be properly accredited in their countries/regions.

I am from Taiwan, where many accredited teaching hospitals do not have direct affiliation with medical schools. These teaching hospitals receive the same accreditation process by the same authority.
Physician (including retired)
[February 07, 2023 10:31 PM]

I think the new proposed regulation change are quite clear. Given the shortage of physicians especially in Family Practice in Ontario, the proposed change is both appropriate and timely.
Physician (including retired)
[February 07, 2023 9:23 PM]

I agree , I think it is good idea to help our community in the Emergency situation and that should be under direct supervision of Licensed physician .
Physician (including retired)
[February 07, 2023 9:18 PM]

I feel,the propsed ammendment is reasonaable. The time should be one year, a shorter period may put the applicant into a difficult position.
Physician (including retired)
[February 07, 2023 9:12 PM]

This will lower the standards of care in Medicine
There should be no exemption to local training or assessment
There should be some sort of Canadian exam or assessment or evaluation prior to licensing locally
This will not guarantee increased family doctors who will take family patients
Doctors who already got license in Alberta without proper Canadian residency or training then moving to Ontario after 5 yrs are already showing lack of knowledge/substandard care
Worlds post graduation training is different everywhere and is based on practice readiness for their country.
The only exception could be American training. Some sort of proper residency in North America must be must for everyone’s safety!
No substitute!!
Physician (including retired)
[February 07, 2023 8:51 PM]

I believe that the license should be issued with conditions to include the region the physician must work in to include just the under serviced region also it shooed have a term till this physician be able to relocate meanwhile the physician must finish his qualifications and evaluations otherwise will decline the quality of care also there will be condensation of high number of physicians in one region
Also not to include physicians already practicing in other provinces otherwise the under serviced provinces will suffer from lack of physicians unless they go through the regular pathways as usual
Physician (including retired)
[February 07, 2023 7:48 PM]

The powerful earthquake in Turkey caused so much damage and loss of life. This kind of disaster can happen any time to British Columbia. Ontario is not immuned from regional natural disasters. Unless all levels of health care team can be called up to come from other provinces to step in to help without slightest delay, we are sitting on a ticking time bomb. Emergency registration is not the answer, only total free movement of health care professional is. There are too many interprovincial hurdles.
Physician (including retired)
[February 07, 2023 7:26 PM]

Need clarification of emergency regulation,
Who decides if emergency exists?
Is there any debate around emergency status?
We hear all the time that health care is in crisis,
Does that constitute a general emergency state?
Does supervising physician receive support?
(Remuneration,guidelines.)
Supervised physician would need to be credentialed by hospital,credentials committee etc.
Supervising physician would collaborate with department chief , chief of staff to address any issues arising.
Terms of service of supervised physician ,
Are they given full billing privileges?
Office expenses?
Physician (including retired)
[February 07, 2023 7:04 PM]

As a fmg,who has been aware of some doubious/and or fake so-called medical schools around the world,and having completed ,many decades ago, internship and family med residency ,here in Canada, I have very serious concerns for this so called blanket registration to practice here in ontario,without adequate safeguards for the public.I would be hesitant,in some cases for my family to be treated by such practitioners. Cpso needs to think carefully,before going in this mass hysteria.
Physician (including retired)
[February 07, 2023 6:21 PM]

The proposed regulation change meets an important acute need, is well considered and highly appropriate.
Physician (including retired)
[February 07, 2023 6:17 PM]

I believe that this class of certificate is very important to address the health care crisis, as we are in desperate need for doctors of all specialties.
The wait time is unbelievably long and the standard of care has declined in Canada, especially after COVID 19 pandemic.
Adding new doctors will also decrease the burden on other doctors who are struggling to meet the standard of care because of the excess work load.
Physician (including retired)
[February 07, 2023 5:56 PM]

There seems to be no provision for G.P. Non specialized
Physician (including retired)
[February 07, 2023 5:16 PM]

I think the regulatory changes made for emergency situations is acceptable. The only point that requires clarification is 6.2 (1) 4.
If I am understanding that a supervising physician will be responsible for the continued care of the patients seen by the applicant I feel that there will be difficulty recruiting supervising physicians.
Physicians that already have stretched practices will have difficulty incorporating the continued care of an 'emergency' physician once their year is up and not renewed.
Physician (including retired)
[February 07, 2023 5:15 PM]

The requirements do not adequately address what is acceptable post-graduate medical training. The training should take place at an appropriately accredited facility/hospital/medical school.
Physician (including retired)
[February 07, 2023 5:11 PM]

The requirement to royal college/family… defeats the purpose that the emergency license fascilitates

Consider instead after the year is completed the physician is eligible for restricted registration for 3-5years the eligible for independent licensure after a review by their peers
Physician (including retired)
[February 07, 2023 5:02 PM]

I have concerns about expediting IMGs as the variability of their training is extensive. I've seen this for myself as a long time examiner for the MCC for both the NAC exams and the LMCC. I'm also a clinical supervisor for IMGs and CMGs. Some of the off-shore medical training is often not in keeping with standards that are expected in Canada. Other times it is significant language barriers that make it almost impossible for those individuals to develop their clinical skills to become on par with EBM within this province and follow the guidelines for standards of care. The disparity is too much to bridge and patient care will suffer I'm afraid.
Instead, we should be putting more efforts to increase medical school trainees here and try to retain the physicians we do have.
Physician (including retired)
[February 07, 2023 4:58 PM]

There are many physicians with credentials available with years of experience and rich scientific backgrounds who are put on the shelf and given routes for registration that are literally vicious circles or black holes with no end.

Why don't you first identify specialists across Canada who have an eligibility letter from the RCPSC and integrate them into the system rather than putting them on hold?

From my experience, all of the regulations being issued have no practical sense to them and are just beautiful theories.
Physician (including retired)
[February 07, 2023 4:58 PM]

I think the amendment should include a statement re : "The applicant must be fluent in English"
Physician (including retired)
[February 07, 2023 4:57 PM]

These are good suggestions to address the health care needs.
What will be the status of physician after 1 year. Do they have to write the exams e.g for CFPC or go back to residency for certification or they have to renew the supervision contract?
Physician (including retired)
[February 07, 2023 4:51 PM]

These are really necessary amendments for the current registration 30 days licence class, however this path leading to an independent practice certificate should be more clear and potentially comes with some changes in Canadian Colleges of Family physician regulations, as if an IMG who has worked one under this type of license should still have Certificates of Examination from CCFP which they do not allow this IMG to write the exam.
Physician (including retired)
[February 07, 2023 4:50 PM]

I am not sure these regulations do anything to improve recruitment or retention of physicians to Ontario which I believe is the government's goal. Requiring a year of supervision negates any real value they can offer. If a supervisor is responsible for reviewing all their care, then little extra care will be offered to the community. Further, after this year there is no indication that there is a pathway to independent license and the ability to contribute to the physician supply. All the amendments offer is more supervision.
Even for those physicians with full Canadian based certification appear to have to do a full year of supervision under the proposed amendment to Independent Practice. This does not facilitate the physician crisis.
The CPSO needs to accept those with a provincial license from another jurisdiction at par if there is to be any progress made. Ontario is no more or less diligent in monitoring and maintaining standards for physician competence. Having held licenses in 3 different provinces, I can speak with experience on that topic. Trimming the paperwork and time to have those credentials recognized is something the CPSO could do to deal with the crisis in physician supply.
For IMG's these regulations may hold some value to ensure Canadian (not Ontarian) education standards are met. This is to the time to be thinking nationally and not provincially in addressing the Canadian wide shortage of physicians and any amendments should reflect those goals
Physician (including retired)
[February 07, 2023 4:49 PM]

A laudable step in the right direction. This would help reduce the workload load of physicians already experiencing burnout, reduces the number of ontarians without a family physician and reduce wait time in the ER
Good move CPSO
Physician (including retired)
[February 07, 2023 4:33 PM]

I think that there are many retired mds who would help out if they could have some sort of disability insurance for being harmed while on the job
Ie if they get a needle pick injury re immunizations, and need meds. OR assists. Knee injections
But this type of insurance cannot be had at an older age, must buy before age 65 in iontario and not available for say 3 6 hour shifts per week
Part time is 25 hours per week
Correct me if I am wrong but this is what I was told last week re oma insurance
I am not yet retired but it seems my hands are being tied if I was retired and the province needed emergent care, there is no protection for me
Note I did not look at private insurance
Physician (including retired)
[February 07, 2023 4:24 PM]

It is not specified that the applicant have a degree in medicine from an accredited medical school, but the year of postgraduate education must be from an accredited medical school. This is backwards. The degree should be from an accredited school but there are many excellent residency positions in the US which are not affiliated with a medical school.

If we are going to be forward thinking about exemptions we should accept British, Australian and American certifications as well as the Canadian Royal College and College of Family Physicians.
Physician (including retired)
[February 07, 2023 4:19 PM]

this amendment looks good - should help to ease some of the work load in certain areas of the health care system. Would however recommend that the emergency circumstances certificate be only entertained for emergency medicine. Providing this emergency circumstance across all areas of medicine would not be overly practical - especially in family medicine, internal medicine, pediatrics and psychiatry - unless being provided in an emergency or I.C.U. setting. Just having licensure for only a year or less does not lend itself to the therapeutic relationship necessary to properly practice the aforementioned specialist fields. Also, does the time spend providing care in emergency circumstance count toward supervised training hours / days required to ultimately meet licensure needs for non Canadian certified physicians ?
Overall, an excellent step forward to provide more critical help to an overburdened work force.
Thank you.
Physician (including retired)
[February 07, 2023 3:47 PM]

1. considering that there are thousands of IMGs who have already passed the qualifying exams, it seems fair to include these exams (or at least one of them ) as a requirement for emergency circumstance registration.

2. Exemption from qualifying exam 1 AND 2 (for independent practice registration) seems to be unfair to other IMGs. Most IMGs spend a couple of years to pass the qualifying exams 1 and 2, NAC OSCE exam and language proficiency tests and then, they may wait a couple of more years to match to CaRMS or provincial programs.
It seems reasonable exemption includes one exam or language proficiency test.

3. I would also like to know how the emergency situation is defined.
Physician (including retired)
[February 07, 2023 3:39 PM]

If a physician is already licensed by any other college of physicians and surgeons of any province in Canada, there is no justification whatsoever for the CPSO to deny them immediate licensure in Ontario as all the relevant training and professional standards have already been confirmed by that other college. The current stance of the CPSO, which can only be explained by such unprofessional motivations as disrespect for colleagues in other colleges, protectionism to reduce competition for existing Ontario physicians, or just greed for power and money by the CPSO, is completely unacceptable.
Physician (including retired)
[February 07, 2023 3:35 PM]

I support this proposed change. It is a great idea to help our patients when the situation such as emergencies are called for. I support the CPSO in taking leadership in this regard especially since we have many qualified physicians who have no job because they are foreign trained. It would be a travesty to waste such precious resources.
Physician (including retired)
[February 07, 2023 3:27 PM]

I think it's important to define what qualifies as an accredited medical school and if the accreditation body is a reputable one. Also is there a language requirement?
Physician (including retired)
[February 07, 2023 3:05 PM]

Let me see if I understand the whole process
1. During an emergency, you will recruit physicians to help to solve a problem.
After they are useful for determined time period
Their qualifications and experience gained during the emergency
state will mean absolutely nothing for the future of these physicians.
2. This proposal is not different that using black soldiers during the WW 2
You will use them but after the need is resolved you can dispose them with no benefits what do ever.
3. By the way, why would be important for this consultation to ask the sex and the background of the person giving the feedback.
Will this change the value of the opinion that I’m giving?
Physician (including retired)
[February 07, 2023 3:01 PM]

I would like to add , the physician will be granted the class of registration of independent practice.
Physician (including retired)
[February 07, 2023 2:54 PM]

This is an important proposal. Good to see this on the radar. As a specialist, I observe that hospitals have the desperate need for coverage lately.
1. If someone is licensed in good standing anywhere in Canada, why not give immediate licensure for up to three months in the same Scope do practice?
2. What if someone has US, British, Irish, ANZ, but not Canadian Royal College specialty certification? Given the similarity of the training to Canadian Royal College standards, for emergency purposes, could they also be given immediate emergency licenses?
3. The Hosptial privileges application process currently duplicates much of the CPSO annual licensure application. The Public Hospitals Act needs to be revamped to harmonize with what is being proposed. The last thing we need is a licensed physician waiting for hospital board approval. Chief of staff / VP Medical approvals for Temporary privileges in the context of an emergency license would go a long way to helping with short term physician staffing shortages.
Prefer not to say
[February 07, 2023 2:41 PM]

For people with several years of experience in a particular field post residency elsewhere out of Canada I believe qualifies for supervised walk into the field in Canada can be supervised for initial 5 years and be available for practise especially in our rural and remote communities. Asking 40 and 50 year olds to sit for royal college exams after experience of 10-15 years in their field of study as an international graduate is not justifiable is my thoughts especially when the need is high and if superb skills can be found amongst these physicians.can we not make use of these qualifications for our favour? It maybe the best welcome that we can we give to these people who have chosen our country..?
Physician (including retired)
[February 07, 2023 2:19 PM]

This needs to be more detailed.
This proposal will have lasting impacts.
Physician (including retired)
[February 07, 2023 2:12 PM]

Thank you for your efforts to create a streamlined process that can be utilized in an emergency.
Physician (including retired)
[February 07, 2023 1:55 PM]

We should be careful not to cease the license as soon as the emergency circumstances end, leaving the physician unable to work. This would not be a good look. This should help them continue to work if that is what they wish.
Physician (including retired)
[February 07, 2023 1:54 PM]

I support these changes. I think extending the duration of these emergency circumstance practice class of registration will allow greater certainty in scheduling these providers.

I would also ask the College to look favorably upon allowing these classes of registration to be able to practice in settings outside of hospital in communities settings/practices with demonstrated need.