CPSO Registration in Light of COVID-19

As the COVID-19 pandemic continues in Ontario, the Province has expressed concern about a potential shortage of physicians (and other medical staff) available to treat patients.

Currently, HealthForceOntario has an online recruitment tool by way of which the Province is seeking to identify “health care providers who are working part time”, “former healthcare providers who are retired” or those with “inactive status with their regulatory college” who may be willing to return to practice. The recruitment tool can be accessed here: http://www.healthforceontario.ca/en/M4/COVID19

Similar initiatives have been implemented by other Provinces.

At the same time, the College of Physicians and Surgeons of Ontario (“CPSO”) is putting in place an expedited registration process for a Short Duration Certificate for applicants. This process can provide short-term 30-day supervised licenses to applicants. The CPSO’s statement on this issue can be accessed here: https://www.cpso.on.ca/News/COVID-19-Updates/Information-for-Physicians

Senior residents due to transition into independent practice in the spring/summer 2020 face particular obstacles in registration, as numerous credentialing authorities, such as the Royal College of Physicians and Surgeons of Canada (“RCPSC”), College of Family Physicians of Canada (“CFPC”), and Medical Council of Canada (“MCC”) have postponed certification exams. As RCPSC or CFPC certification is a requirement of obtaining an independent certificate of registration with the CPSO for graduating Canadian residents, the COVID-19 pandemic creates regulatory uncertainty for this cohort of physicians at a time when front-line medical staff are greatly needed. The CPSO appears to be actively trying to resolve this issue. According to a recent statement, the CPSO is currently “working on a special provisional license that we could offer to any resident in the 2020 cohort who has finished their training and is exam-eligible.” In addition, the College amended a number of rules to allow our residents to continue to practice unabated, including reducing supervision requirements and waiving registration fees. The College’s statement on this issue can be accessed here: https://www.cpso.on.ca/Physicians/Your-Practice/Physician-Advisory-Services/COVID-19-FAQs-for-Physicians

It would appear that applications for the above-noted provisional and restricted certificates of registration are still be subject to the usual non-exemptible requirements of registration, including the “character” requirement of section 2(1) of O. Reg. 865/93 under the Medicine Act, 1991, SO 1991 c.30. This provision mandates that it is a pre-requisite of issuance of a certificate of registration that the applicant has “sufficient knowledge, skill and judgment to engage in the kind of medical practice authorized by the certificate”, “will practise medicine with decency, integrity and honesty and in accordance with the law,” and “can communicate effectively and will display an appropriately professional attitude.” Depending on the applicant, it may be prudent to address any issue with non-exemptible requirements at the earliest opportunity in order to prevent delay.

We regularly assist physicians with Registration Applications at the CPSO. We are continuing to monitor the changes to the standard registration process as the COVID-19 situation develops.