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Mar 21, 2018

Reminder: New Self-Reporting Requirements

New Self-Reporting Requirements

The College has a duty to protect the public and ensure that occupational therapists practise in a safe, ethical and competent manner. That’s an ongoing expectation of OTs, and it happens in many ways.

One is by having OTs share information about changes that could affect their suitability to practise. OTs have a legal requirement to provide that information, which covers a range of events or circumstances – and which now includes health conditions or disorders. Here’s what you need to know.

Do OTs have to report any and all health issues?

No. Only those, whether physical or mental, which do or will have an impact on their ability to practise occupational therapy safely, effectively and professionally.

When is self-reporting required?

During renewal or, if there’s a change, within 30 days of the occurrence of a health event/circumstance that affects the OT’s suitability to practise.

Once annual renewal opens on March 29, 2018, OTs can do this by logging in to their profile on the College website.

OTs, like anyone, might deal with various physical and mental health issues over time. Often, these issues have no impact on an OT’s professional abilities. Or the OT has minimized any impact, for instance by putting in place safeguards (like taking the appropriate medication or adapting or limiting their practice). In such cases, self-reporting is not required.

Why have these self-reporting requirements been added?

It’s part of public protection. The College isn’t concerned about the health condition or disorder itself. The College only considers an OT’s health in relation to the effect it has or might have on their practice, to determine if the OT meets the College’s conduct and competence standards

What if the OT isn’t certain of the effect of their health condition or disorder on their ability to practise?

They should report this information to the College in any case. Provide as much information as possible so that the College can assess what impact, if any, the health issue may have on the OT’s practice.

Similarly, an OT might be unsure whether they can effectively safeguard against any impact a condition or disorder may have on their ability to practise. OTs must still report information about the condition or disorder to the College.

Is it mandatory to self-report certain conditions or disorders?

No. The focus is on the suitability to practise, not on the condition or disorder itself.

For example, the same health condition may affect an OT’s ability to practise differently. *Consider two OTs who each have epilepsy. It illustrates what to report and why.

One OT has been taking the same medication for years, hasn’t had a seizure during this time, and has implemented plans for working with this condition. That includes telling colleagues about it and having an action plan in the event of a seizure, (for example, the need for recovery/rest after a seizure or when colleagues should call an ambulance). With the OT’s grasp of their condition, and by taking responsibility for their treatment, the epilepsy shouldn’t affect their ability to practise occupational therapy in a safe and professional manner. This OT would not have to self-report.

The other OT with epilepsy has been prescribed medication by their doctor to help manage their condition. However, this OT often avoids taking it due to side effects. Because of this, the OT has had seizures recently. The OT is unwilling to discuss with their doctor ways of better managing their epilepsy. In this case, the condition is likely to affect the OT’s ability to practise. This OT would have to self-report.

Does an OT have to report to the College if they stopped practising for health reasons?

No. However, the OT may have to report when planning their return to practice only if the condition or disorder continues to affect their ability to practise, and they haven’t limited or adapted their practice to lower the associated risks to their clients.

Can an OT contact the College to discuss stopping practise or returning to practice?

Absolutely. We welcome the opportunity to speak with OTs and encourage OTs to contact the College with their questions and concerns.

What will the College do when it receives self-reported health information?

The College will make preliminary inquiries to determine if there’s a risk to the public. When considering an OT’s health, we will:

  • Seek to discover what impact, if any, the condition or disorder has on the OT’s ability to practise.
  • Examine any management strategies or adjustments the OT may have made in their practice to safeguard against unsafe and incompetent service.
  • See whether the OT has shown insight and understanding into their condition or disorder, and whether the OT has medical or other support.

What can happen to an OT who self-reports health information?

It depends on the results of the inquiry. The College might find that the condition or disorder has no impact on the OT’s ability to practise safely and professionally. Or that the OT is already fulfilling their professional obligation to proactively enact necessary safeguards to ensure the public is protected. In such cases, the College won’t take any regulatory action.

Other times, the Office of the Registrar might ask the OT to enter into what’s called an “undertaking” with the College. Complying with those terms would protect the public. All information about such undertakings is confidential and never made available through Find an Occupational Therapist (the College’s public register).

OTs might not always agree to adopt the safeguards that the College believes are warranted for it to fulfil its statutory duty to protect the public. If the Registrar believes the OT may be “incapacitated” (as defined in the Regulated Health Professions Act, 1991), the Registrar will make appropriate inquiries, with the results reported to the Inquiries, Complaints and Reports Committee (ICRC).

The ICRC may also offer the OT an opportunity to enter into an undertaking with the College. Those details would be kept confidential. If the OT isn’t showing sufficient insight into their condition or disorder and is unwilling to cooperate to ensure the public’s safety, the ICRC may make a referral to the Fitness to Practise Committee.

What else do OTs have to self-report?

Self-reporting isn’t new. In Ontario, OTs are already required to report to the College if they:

  • are facing a proceeding or had a finding made against them for professional misconduct, incompetence, incapacity or a similar issue;
  • have had a finding of professional negligence or malpractice made against them;
  • have been charged with or found guilty of an offence; or
  • have had conditions or restrictions (like a bail condition) imposed on them by a court or other lawful authority (such as a justice of the peace, public authority or government agency).

Just like the self-reporting requirements for health conditions and disorders, these requirements are all part of ensuring the public are protected.

* These examples have been adopted from  How we consider information applicants and registrants declare: Guidance on health and character, (amended on August 2017)Health & Care Professions Council

If you any questions regarding self-reports, please contact Leandri Engelbrecht at 416-214-1177/1-800-890-6570 x229 or [email protected].