Balancing commitments to fair access with maintaining standards that protect the public
The Institute of Chartered Accountants of Ontario is one of the oldest, and largest professional regulatory bodies in Ontario. We currently have over 27,000 members and over 3,000 students. There is a significant international component to our membership. Over 1,500 of our members are working in 70 countries.
The Institute has long accepted that regulatory bodies have a responsibility to the public to ensure that the competency of applicants is assessed fairly and consistently, that the standard to be met is transparent, clearly communicated and measurable, and that no more is required of an individual with education and training from outside Canada than is required of a person who has qualified in this country. And we believe that we have put the acceptance of those principles into practice over many years now, through the access processes that we have had in place. In fact, 1,492 of our current members originally obtained their professional accounting designations in other countries and then obtained the CA qualification in Ontario.
It is vital that the discussion of PLAR as it relates to access to professional qualification proceed from an understanding of the self-regulatory responsibility that has been given to occupational regulatory bodies.
There has been a long tradition of professional self-regulation in Canada based on public accountability and protection of the public through the maintenance of high professional standards. It has generally served the people of Canada well. That is not to say, however, that there is no room for change or improvement. But, the simple fact of the matter is that the knowledge and expertise necessary to assess competence to practice a profession reside with the members of that profession. The establishment of a role for government that would weaken this fundamental principle must be avoided. Government or other individuals or agencies are not in a position to define for any particular profession what constitutes competence to practice. In the case of chartered accountants, like most other professions, provincial legislation delegates to the professional body the authority to educate, train, qualify and regulate the members of the profession. In our case, the Chartered Accountants Act, 1956, states the objects of the Institute as being:
Prescribe standards and tests of competency, fitness and moral character for the registration of CA students and for membership in the Institute; Provide for establishment and maintenance of classes, lectures, courses of study, systems of training, periods of service and examinations; Provide for the exercise of disciplinary authority over members and students; and Provide for rules of professional conduct.
International Nature of Accounting:
The international characteristic of accounting has long been evident by the movement of individuals from country-to-country to meet the business needs of their firms. Reflecting the evolution of a global economy, international accounting firms have existed for decades. As a result, reciprocity has existed for many years between accounting bodies in various countries. As we all know, governments are now responding to the rapid globalization of business by signing agreements to open borders and facilitate the movement of professionals. Added to this is the increasing expectation of the public that responsible professional bodies will ensure that they have processes that provide professionals from other countries with fair and reasonable opportunities to pursue their chosen careers. I believe that the structures and processes put in place by the accounting profession in Canada and internationally have put the CA profession on an excellent footing for responding to these developments.
THE ACCOUNTING PROFESSION IN CANADA
One of the particular challenges faced by the Institute in matters related not only to PLAR and reciprocity with accounting bodies in other countries, but to public perceptions generally, is that, in Canada, not all accountants are the same. In fact, the term "accountant" is generic. It might be used to describe a bookkeeper, a bank clerk, an accounts receivable clerk, the controller of a business, and to a chartered accountant. The name "accountant" can apply to those who never finished high school, to business college, community college or university graduates, or to those who are chartered accountants or members of other accounting professions in Canada. The term "accounting" is used to include everything from basic bookkeeping to preparing financial reports for a wide range of users-management, creditors, investors, government agencies and others.
It is only when a person wants to use a particular accounting designation after his or her name, such as "chartered accountant", that one must be a member in good standing of a professional body. There are also two other major accounting designations in Canada-the Certified Management Accountant (CMA) and the Certified General Accountant (CGA). Each has its own professional bodies, and qualification programs and requirements that are different from those of the CA-qualification program. Accordingly, someone coming to Canada with the intention of being an "accountant" here will have to meet the particular requirements of the respective accounting body if he or she wants to use that body's professional designation.
The licensing requirements for public accountancy vary from province-to-province. Under the Public Accountancy Act, the Institute is the sole qualifying body for access to a public accountants licence in Ontario. Members of other accounting bodies also have the ability to be licensed in several provinces. In one province, public accounting is not a regulated service and anyone can provide such services whether or not they are a member of one of the professional accounting bodies.
ACCESS TO THE PROFESSIONS
History of the Institutes Involvement:
We believe that the CA profession has taken seriously our professed commitment to ensure fair, merit-based access to CA qualification by foreign-trained accountants. This has been demonstrated by a number of initiatives over many years. In 1989, for example, we responded positively when the Ontario government released the recommendations of the Access to Professions and Trades Task Force. The Task Force had been established to investigate whether there were systematic barriers that prevented individuals with education and experience acquired in other countries from entering into or practicing their chosen profession or trade. Some of the task force's recommendations were already encompassed in Institute admission processes:
We did not support some aspects of the Task Force's recommendations, including the one that suggested that the prior learning assessment function should be conducted by a government agency with only an advisory role to be played by the professional bodies. We maintained then, and do so now, that such an approach would be an encroachment on the legislative rights and responsibilities of professional self-regulation.
A little over a year ago, we agreed to participate in a pilot project launched by the Ministry to develop an occupational fact sheet on access to chartered accountancy qualification. It was one of the first of a number of fact sheets on different professions that have been developed because many foreign-trained individuals and regulatory bodies have frequently reported that immigrants arrive in Ontario without fully understanding the registration requirements or process they must complete in order to pursue their occupation here.
The Institute is also participating in a research project funded by the Ministry and carried out by the Centre for Applied Social Research (CASR), at the Faculty of Social Work, University of Toronto. It is studying the experiences of newcomers to Canada in attempting to access professions and trades in which they have trained in other countries. It is anticipated that a roster of individuals will be created from which about 400 will be randomly selected for telephone interviews. The objective is to identify issues and needs that could be addressed to better assist individuals who are planning to immigrate to Canada.
The Institute is also working in partnership with Skills for Change, a Toronto agency that assists new arrivals to Canada in becoming settled and finding employment. We are participating in a mentoring program that matches CA mentors with accountants having education or training received in other countries. And we will be sponsoring and participating in a soon-to-be launched program offering information sessions to give foreign-trained accountants information on the accounting profession so that they are better able to plan their future
ACCESS PRINCIPLES FOR PROFESSIONAL BODIES
The access principles were based on two overriding general principles:
The International Qualifications Appraisal Board (IQAB) is an independent body comprised of representatives of the provincial CA institutes. Since the late 1960's, IQAB has assessed the designations of accounting bodies outside Canada on behalf of, and at the request of, the provincial institutes. It makes recommendations, through the Canadian Institute, on the status to be accorded to members of foreign accounting bodies by the provincial institutes. IQAB's findings and recommendations are not binding on the provincial institutes but ordinarily are accepted and implemented by them.
The purpose of these reviews is to determine whether the education, examination and experience requirements of an accounting body outside Canada are substantially the same as those of the provincial institutes in this country. If IQAB determines that this is the case, it recommends to the provincial institutes that the members of any such body who seek CA qualification in Canada by exempted from writing the Uniform Final Examination (the national qualifying examination). Reciprocity is then ordinarily granted to members of these "designated accounting bodies" if they also grant similar recognition to Canadian CA's.
In other cases, IQAB recommends that reciprocity should not be granted to members of accounting bodies because of substantial differences between the content, knowledge levels or other requirements of their qualification programs and those of the CA program in Canada. These are called "non-designated" accounting bodies, as are bodies outside Canada in respect of which IQAB has not completed an assessment.
Re-reviews are undertaken approximately every five years. In the case of a re-review, IQAB will assess the nature and impact of any process changes implemented since the previous assessment was completed.
For the purpose of determining the degree of equivalency of a foreign accounting body's qualification requirements and processes, IQAB assesses the other body's requirements as a whole rather than assessing the extent to which each component of its program equates to the respective Canadian component. Whenever feasible, IQAB will utilize other external sources in the conduct of its assessments. These other sources could include, but are not limited to, discussions with persons who have acquired business experience both in Canada and the respective country; and other available data on the cultural, business and economic environment in which accountants work in their respective country.
The specific assessment criteria used by IQAB are:
There is also another dimension that is important it is not often addressed-the resources, human and financial, that are required to fulfil the responsibility of ensuring fair, merit-based access. Staff are needed to develop and administer the processes, to produce information materials, review documentation and respond to inquiries. As our processes involve interviews or hearings at which applicants attend, members of the profession need to be enlisted as decision-makers, as volunteers who take time away from their practices or employment. Staff support to provide written reasons and legal advice to ensure fulfillment of the requirements of law and due process are also required.
OVERVIEW OF CA PROGRAM REQUIREMENTS
At this point, I will provide a brief overview of the CA program requirements to serve as an introduction to specific examples of how PLAR has assisted foreign-trained accountants in becoming CA'S in Ontario.
Each provincial institute's CA-qualification program consists of three basic components:
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