Emergency class regulation consultation summary

Under the Pandemic and Emergency Preparedness Act, 2022, the Ministry of Health is requiring all Ontario health regulatory colleges to develop a new emergency class certificate of registration. The aim is to reduce registration barriers for new applicants in emergency situations.

The RCDSO developed a regulation amendment and invited feedback for a mandatory 60-day consultation period, starting on January 23, 2023 and closing on March 24, 2023.

The College would like to thank all 144 participants for their participation.

Out of the 144 participants, 65 provided substantive feedback on the proposed regulation. This includes feedback obtained through the RCDSO’s consultation and feedback obtained via the Ministry’s posting on the Regulation Registry.

Of those responses,

• 84% were from dentists;
• 4% from dental students;
• 8% from members of the public;
• 4% from other health care providers;
• 8% from an organization; and
• 6% preferred not to identify themselves.

Summary of feedback:

1. Some respondents noted that there is no need for an emergency class of licensure and that there is no shortage of dentists.
2. A number of respondents raised questions and concerns about eligibility: what education will be required of an applicant; should licenses be limited to general dentistry only; and how will RCDSO assess requirements.
3. Several respondents requested clarity on what qualifies as an emergency.
4. A number of respondents raised supervision as a key area of concern—how that would work and who would be responsible.
5. A few respondents commented on the expansion of scope—e.g. provision of vaccinations during an emergency.
6. Some respondents raised questions about whether the College could require emergency class licensees to practice in underserviced areas.
7. Respondents commented on the process of transition from emergency class to full licensure—consideration should be made to reducing barriers to transition to full licensure.
8. Respondents advocated for an extension of the ‘grace period’ between when the emergency ends and when emergency class licenses are revoked to allow sufficient time to manage employment transitions and continuity of care.

The College reviewed and considered all feedback. A revised draft, which included a revision that allows the grace period to be extended up to 60 days, was approved by Council and then submitted to the Ministry.

As part of the process to finalize the draft regulation, it is typical for the Ministry’s legislative counsel to re-word and re-structure draft regulations.