by Mina Karabit March 11, 2021 3 min read

It is no surprise that the COVID-19 pandemic continues to affect the delivery of health services and the regulation of various health professions.

In a welcomed move, the College of Physicians and Surgeons of Ontario (CPSO) Council recently approved a new registration policy allowing the Registration Committee to issue a Certificate of Registration authorizing Independent Practice to applicants who have not completed Part II of the Medical Council of Canada Qualifying Examination (MCCQE).

Typically, an applicant must meet these criteria to obtain a certificate of Independent Practice:

  • A degree in medicine;
  • The Licentiate of the Medical Council of Canada (LMCC);
  • Certification by examination from the Royal College of Physicians and Surgeons of Canada (RCPSC) or the College of Family Physicians of Canada (CFPC); and
  • One year of postgraduate medical education or one year of active medical practice or completion of a clerkship.

To obtain an LMCC, residents must successfully complete two examinations: the MCCQE Part I (a written exam) and the MCCQE Part II (a clinical exam). Typically held three times a year, the MCCQE Part II was cancelled in 2020 as in-person clinical examinations were too risky given the rising case counts. The Medical Council of Canada (MCC), the body administering the exams, has not provided alternative testing methods and postponed the tests to February 2021. The February 2021 tests were also cancelled.

The postponement of the exam and lack of an immediate alternate means to complete the exam created a significant backlog of candidates that continues to grow. The MCC has indicatedthat it plans to deliver virtual exams beginning in May 2021. For now, they have indicated that testing will occur over 20 days to deal with the four cohorts (Spring 2020, October 2020, February 2021, and the upcoming graduating cohort of Spring 2021). 

When the pandemic began in March 2020, the CPSO determined that candidates who were unable to sit their examinations due to the pandemic but were otherwise eligible for licensure may be registered under a Restricted Certificate. This enabled final-year residents to practice under supervision.

Unlike the MCC, the RCPSC and the CFPC adjusted and have provided alternative means to hold their examinations and certify candidates (virtual exams and suspension of in-person requirements). Both the RCPSC and the CFPC anticipate completing their 2021 examinations in a virtual format using a semi-continuous delivery model. The MCCQE Part II is the only requirement that prevents residents from holding a Certificate of Independent Practice.

Rather than continue to issue Restricted Certificates (which results in a significant pay cut and requires supervision), CPSO changed its registration policy.

Applicants to the CPSO can be issued a certificate authorizing Independent Practice even if they have not completed the MCCQE Part II, where:

  • The applicant was eligible to challenge the exam at the May 2020, October 2020, and/or February 2021 sittings;
  • The applicant is registered in Ontario or was registered at the time of the above sittings;
  • The applicant was within 24 months from completion of their postgraduate training when they were eligible to challenge the exam at the above sitting; and
  • The applicant otherwise meets the prescribed requirements for independent practice, including the non-exemptible standards in the regulations.

The CPSO has indicated that it may extend this policy to apply to future scheduled sittings of the MCCQE Part II as required during the pandemic. The policy is, however, not intended to eliminate the MCCQE Part II requirement across the board, although some residents and advocacy groups have questioned the utility of the exam in recent years.

Right now, Nova Scotia is the only other province that has a similar policy in place (and did so before Ontario). It is too soon to tell whether this policy will be honoured by other colleges when physicians register for certificates in other provinces as the LMCC was designed as a national standardized qualification to enable the ease of moment of physicians between regulatory jurisdictions in Canada.

Note: Our blog does not replace legal advice tailored to your specific situation, particularly when circumstances are changing rapidly. At Wise Health Law, we have extensive experience in guiding physicians with registration matters. We would be pleased to assist you.



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