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Frequently Asked Questions - Emergency Class of Registration

Frequently Asked Questions

Bill 106, the Pandemic and Emergency Preparedness Act, aims to ensure, among other things, that certain Ontario sectors have the human resources they need to respond to emergency circumstances. The Bill contains amendments to the Regulated Health Professions Act, 1991 (RHPA) related to the registration of healthcare providers in Ontario so that Ontarians continue to have uninterrupted access to safe and high-quality healthcare services.

Among other changes, the Act requires all health regulatory colleges in Ontario to create an Emergency Class of Registration for qualified practitioners. The intent is to create an alternative pathway to register individuals during an emergency.



The College is proposing to register individuals in an emergency class, without fulfilling the exam requirement, to expedite the process in emergency circumstances. However, for an individual to transition to a general class of registration, they would still need to have successfully completed the exam.



The emergency class will only be available when the Board of Directors decides that it is in the public interest to open the Emergency Class of Registration.  This may include:

  • Circumstances that would create a significant interruption or lengthy delay to the ability of applicants to become registered;
  • At the direction of the Minister of Health


When the College Board declares an emergency and authorizes the College to open the Emergency Class of Registration, anyone who is trained in occupational therapy and meets all the Emergency Class of Registration requirements outlined in the regulation, can apply.

This may include individuals who are able to demonstrate evidence of having practised 300 hours as an occupational therapist in the previous 5 years, internationally trained occupational therapists whose credentials have been approved under the Substantial Equivalency Assessment System (SEAS) program, and registered occupational therapists in other Canadian jurisdictions.



The Emergency Class of Registration will initially be issued for six months. There is no limit on the number of times the registration may be renewed however, this is contingent on the emergency conditions continuing to be met.



The College appreciates finding a supervisor can be a challenge and will be working with employers to implement flexible arrangements.



This means that registrants registered in Emergency Class shall practice only within the scope of practice of occupational therapy.