the voice - compliance | issue 2 | spring, 2016

The VoiceSpring, 2016 | Volume 1 | Issue 2

PCC Compliance

What’s Expected of your institution?

Don’t get caught off guard. Familiarize yourself with the PCC Act, 2005, and understand the enforced regulations that affect your PCC.

One size does not fit all!

Read how one award-winning student achieved her dream of attending college through the Career College Pathway.

tIPS FROM Experienced Professionals

Whether you’re new to the sector or an experienced veteran, our experts have advice for career college operators of any level.

In This Issue:

155 Lynden Rd #2, Brantford, ON N3R 8A7

3 A message from your Assocaition’s CEO

“I hope you read with the same interest as I have the articles on compliance contained in this issue of The Voice...”

4 Compliance: A growing line item cost or an investment in your business?

“Regulatory compliance is not something that occurs in anticipation of an evaluation or an audit, but rather a basic principle of operating a successful...”

7 Navigating accreditation“There are many thoughts around accreditation; for many it can bring on distaste and for others a welcoming challenge...”

10 The consequences of non-compli-ance and Superintendent powers

“First, I would like to discuss the preamble of the Act. Education falls under the jurisdiction of provincial governments according to the Constitution 1867...”

13 The eSSential art of positive curriculum assessments

“Let’s face it: achieving positive curriculum assessments has its challenges. You have just finished the lengthy build of your new private career college curriculum...“

16 Countdown to KPI compliance“Back in the summer of 2015, I was sent an email by my own professional association, Chartered Professional Accountants of Ontario, Practice Advisory Department...“

18 Anthony DiLena Pathway Awards: Success in the face of adversity

“Ash Ayotte is not your typical 19 year-old college student. Last fall, Ash was the recipient of the Anthony DiLena Career College Pathway Award...”

CO N T E N T SCompliance

Sharon E. Maloney | Chief Executive Officer

I hope you read with the same interest as I have the articles on compliance contained in this issue of The Voice.

As with our January, 2016 issue, we have dedi-cated the articles in this edition of The Voice to one topic - compliance. This is our effort to give our members and readers a comprehen-sive overview of some of the key compliance challenges that career college operators must meet.

Compliance, as pointed out by our contribu-tors, is both the cost of doing business as well as an investment in our students. While regu-lation should serve the public good, it should not appear arbitrary or unnecessarily impede institutional innovation. Ultimately, compli-ance is the means of achieving quality perfor-mance for our students.

To achieve quality performance, the regulated sector needs to know and be prepared to meet compliance requirements, even if they some-times seems irrational or counterintuitive to the primary goal of protecting students. Similarly, the regulator needs to work with, and explain to, the sector the underlying reasons for the compliance requirements.

CCO has been working with the Ministry of Training, Colleges and Universities for many years in an effort to bridge the communication gap that sometimes exists between the sector and its regulator. The dialogue between your association, the ministry and the Superinten-dent has always been strong and reflects a real commitment by everyone to promote the best interests of our students.

The recent Superintendent’s Private Career Colleges’ Update published in April, 2016 demonstrates the effort being made to work with career colleges to make inspections and program approvals more seamless by provid-ing information on Best Practices. While Best Practices cannot, in and of themselves, change regulatory requirements, they can help career colleges prepare themselves to meet them.

In the next few months, CCO will be working to develop a Best Practices Guide on Key Perfor-mance Indicators in an effort to help our mem-bers meet and exceed those requirements.

It is a hard fought road to achieve quality performance. Fortunately, our sector has the benefit of the expertise these contributors and your association provide to meet this challenge.

A message from your Association’s CEO

“In the next few months, CCO will be working to develop a Best Practices Guide on Key Performance Indicators in an effort to help our members meet and exceed those requirements. “

Carol Bruni | Regulatory Matters

Our expert

Regulatory compliance is not something that occurs in anticipation of an evaluation or an audit, but rather a basic principle of operating a successful career college.

We work in a highly-regulated sector with interaction from federal, provincial, and municipal governments – in addition to programmatic requirements, as-sociations and accreditation governing bodies’ standards. It can be challenging navigating the regulations, and it is resource intensive, but non-compliance ultimately has greater costs to an operation.

Agreeing with the premise that regulatory compliance adherence is an ongoing aspect of good business is easy—getting there can be harder.

Carol Bruni, president of Regulatory Matters, is considered one of the foremost experts on academic program development and regulatory compliance in Canada. She brings an extensive background with over 25 years’ experience in the private career college marketplace.

Carol has been approved as an Adult Education pro-gram assessor, a Compliance Monitor and a Third-Par-ty Default Management Reduction Plan consultant by the Ontario Ministry of Training, Colleges and Univer-sities.

Carol currently serves as the Vice-Chair of the Training Completion Assurance Fund Advisory Board and as an external advisor to Career Colleges Ontario’s Board of Directors.

Compliance: A growing line item cost or an investment in your business?

1) Do your homework: Read the Act, Regulations, Fact Sheets and Policy Directives. This may not be as interesting as launching a new marketing campaign, but each operator needs to understand what you need to do and what you cannot do.

2) Know the regulatory layers in your College. All career colleges are subject to the Private Career Colleges Act, 2005, then

• Do you have programmatic requirements? They may specify equipment, additional instructor qualifications, class size maximums or a variety of reporting requirements.

• Do you have International Student Designation? If so, add those additional regulations and reporting on top of the PCCA, 2005.

• Do you have OSAP Designation? If so, the OSAP Performance Requirements apply to both OSAP and Non-OSAP students.

3) Get organizedMap out a schedule of not only reporting deadlines but start dates to ensure you meet the deadlines. Know thyself, and if you are not the detailed person in your organization, assign this task to a key team member that will be master control on all reporting requirements.

Common pitfalls of non-compliance within the Private Career Colleges Act, 2005

• Not completing the Student Enrolment Agreement properly.

• Missing documentation in student files.

• Not calculating student refunds correctly and not processing within 30 days. Remember to keep a copy of the refund cheque in the student file.

• Incomplete instructor information and supporting docu-mentation on file: Each file must contain the completed Instructor Data Sheet, Copy of Credential and two letters that verify relevant experience. Some programs have additional requirements or, if the instructor’s education is outside of Canada, a 3rd party equivalency assessment is required.

• Following “how it has always been done”. This often hap-pens in a change of ownership. Be cautious as you may be repeating mistakes.

• Not following what you submitted on your program applica-tions. Remember, this was your submission – your request on how to run the program. You need to do what you said and thus what you were approved to offer. If you need to make a change, then you must submit and receive a program change approval.

• Believing in myths such as, ‘you can change up to 10% of a program without approval.’ All changes require a program re-approval.

Investing in compliance will take many forms, as compliance touches every aspect of the operation of a career college. An excellent practice is to inspect what you expect—it can be a self-review or by engaging a consultant with expertise in the area.

A gap analysis of the findings against the regulations will identify what is working well, as well as opportunities for improvement. Once you know where you stand, you can identify common mistakes and set a training plan in motion. Don’t forget to schedule a follow up to ensure the corrective action plan has been effective.

You have invested valuable time and financial resources in your college. Operating within the regulatory framework is critical for ongoing success and an investment in your business.

The key steps to understand the playing field

Contact:April Chato

Career Colleges Ontario 519-752-2124 Ext. 113

[email protected] visit

careercollegesontario.ca/conference2016

How to Register

Navigating accreditation

There are many thoughts around accreditation; for many it can bring on distaste and for others a welcoming challenge.

What is accreditation?

Accreditation is the public recognition that an educational pro-gram or institution has met national standards. It is a thorough review that looks at processes in place, actual practices and out-comes. Educational accreditation is a type of quality assurance process under which an educational institution or program is evaluated by an external body to determine if applicable stan-dards are met.

It is important to understand the types of accreditation and the differences between the types that impact private career colleges.

There are two basic types of educational accreditation: one referred to as “institutional” and the other referred to as “program-matic.”

Institutional accreditation normally applies to an entire institu-tion, indicating that each part is contributing to the achievement of the institution’s objectives, although not necessarily all at the same level of quality. The goal of accreditation is to ensure that education provided by institutions of higher education meet the acceptable levels of quality.

In the US, Institutional Accreditations by a nationally recognized accrediting agency is a requirement to access Title IV funding, which is the Federal student aid programs reauthorized under Title IV of the Higher Education Amendments of 1992.

In Ontario, the Ministry of Training Colleges and Universities (MTCU) does not mandate for PCCs to have an institutional accreditation. It is important to remember that MTCU is not an accreditor, and PCC’s should not refer to them as such. If a PCC would like to obtain institutional accreditation, they can achieve this through the Career College Accreditation Program (CCAP), which is operating under the umbrella of the National Associa-tion of Career Colleges.

Programmatic accreditation examines specific programs within an educational institution (e.g., Paralegal, Dental Hygiene, Pharmacy Technician and some IT programs). The standards by which these programs are measured have generally been developed by the professionals involved in each discipline and are intended to reflect

what a person needs to know and is able to do to function successfully within that profession. The goal is to ensure that programs enable their students to ac-quire the knowledge, skills and attitudes to function as competent individuals for the benefit of all Canadians.

Many professional associations require graduates to attend only accredited programs in order to have access to licensing/certification exams. Most of them will not recognize programs that have not met accreditation.

Whether the accreditation is institutional or programmatic, the goal is to emphasize quality assurance and a commitment to continuous quality enhancement.

No matter who the accreditors are, they will have critical stan-dards or criteria that the program or institution must meet.

By Cheryl Russell-Julien

“The goal is to ensure that programs enable their students to acquire the knowledge, skills and attitudes to function as competent individ-uals for the benefit of all Canadians. “

Reference:US Department of Education: http://www.ed.gov/Council for Higher Education Accreditation: http://www.chea.org/CMA conjoint accreditation: https://www.cma.ca/En/Pages/conjoint-accreditation.aspxLaw Society of Upper Canada: http://www.lsuc.on.ca/For-Paralegals/About-Your-Licence/Parale-gal-Education-Program-Accreditation/Association of Accrediting Agencies Canada: http://aaac.ca/english/index.php

Accreditation is a rigorous process and is more than assembling documentation for a program submission. It is a way of doing business, and it is meant to be a culture of continuous quality improvement.

Accreditation is a team approach, and it cannot rest on one in-dividual. All program personnel, from senior administration to faculty, practicum coordinators to clinical personnel, contribute to the quality of an educational program and therefore can have an impact on the accreditation status awarded to a college.

The accreditation will usually start with a self study or pre-survey report. The primary purpose of this procedure is to advance institutional/programmatic self-understanding and self-improvement. The self-study report is most useful when it is analytical and forward-looking rather than descriptive or defensive. This report should be used to identify problems and to develop solutions, which will recognize opportunities for growth and development.

Be Prepared

When applying for accreditation and planning a new program, it is strongly recommended to carefully review all requirements, and to consult with the accreditor and other established programs to make sure that you are ready to proceed. The time commitment involved in preparing for accreditation varies with each program. Make sure you begin your preparations early enough to effectively complete your program’s self-assessment with allotted time for review by an outside individual.

Achieving Success

Most accreditors will ask for evidence to support the program-matic/institutional submission. It is important to ensure that the evidence is clear, concise and adequately complies to the stan-dard/criteria. Lack of policies and procedures that consider the student’s best interest, insufficient academic and clinical resour-ces to accomplish program goals and objectives, inappropriate facilities to deliver the program, insufficient human resources to provide the education and supervision of students, inadequate practicum sites, or the absence of stakeholder feedback through formal evaluations will hinder a successful accreditation.

Benefits of Accreditation

• Helps institution and educators to increase the quality and

performance of their programs;

• Offers an external measure of credibility, which assists in attracting quality students, faculty and staff;

• Provides opportunity for overall evaluation and a chance to step back and look at the “big picture”;

• Provides opportunity and stimulus to review and revise policies;

• Offers universal recognition of program quality, often by professional organizations, which may increase recruit-ment potential;

• Enhances the reputation of the program/college;

• Provides valuable feedback from many stakeholders, includ-ing employers and graduates.

Impact of Accreditation on a Private Career College

• The college may require additional faculty to meet the cri-teria and maintain compliance;

• Cost to offer the program can increase up to 40%;

• The college must operate under stricter guidelines;

• The self evaluation can be difficult and challenging;

• Possible loss of program if accreditation is not granted;

• Publicity (positive or negative)

• Access to licensing exams is determined by accreditation outcomes

• Maintaining accreditation is an ongoing process

More associations and regulatory bodies are now turning to accreditation as the benchmark to identify quality education programs and gateways to certification/licensing exams. Stu-dents want to know that the education they are getting is of the highest quality.

Cheryl Russell-Julien, President of Hands on Practical Solutions, brings with her over 27 years’ experience in post-secondary education. Cheryl has held senior positions as the Curriculum Manager and then as Director of Health Care for one of the largest Private Career Colleges in Canada.

She played an active role in several successful program accreditations and site visits across Canada. She actively participates as a curriculum reviewer with the Canadian Addiction Counsellors Certification Federation education review committee.

Special thanks to our expert:

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Full curriculum in alignment to the Ministry program application and supporting detailed appendices for regulatory compliance

o 1000 hours of theory and practical activities o 160 hours of practicum o Access to instructor resources, test bank and assignments via the

purchase of referenced textbooks in the curriculum Customization of specific appendices including appendix A (market

research and job ads within a designated area); appendix B (maintenance documentation specific to your college); appendix D (inventory at your college); appendix M (comparative schools).

RICC system entries and PDF of application and Appendix H files Packaging of all documentation for the Ministry and college files

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The eSSential Medical Office Administration Toolkit About Dr. Jerry Bishop

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PCCsshall comply with the regula-tions respecting the providing of security or other methods of protecting the financial

interests of its students

First, I would like to discuss the preamble of the Act. Education falls under the jurisdic-tion of provincial governments according to the Constitution 1867. Section 93 of the

Constitution Act clearly states that provinces have exclusive jurisdiction to pass law regarding educa-tion under the doctrine of division of powers. Thus, the Ministry of Training, Colleges and Universities in Ontario is responsible for providing and regulating post-secondary education in the province, including private career colleges. For this reason, the Ontario Legislative Assembly passed the Act in order to make sure that private career colleges comply with the rules and regulations established for the ben-efit of the public. The Act tables responsibilities of private career colleges and possible consequences of noncompliance with the same.

In accordance with sec. 2 (1) of the Act, the Ontario government appoints a Superintendent of private career colleges in Ontario. Under the Act, the gov-ernment’s Superintendent of private career colleges can issue Notices and Orders to colleges that are not conducting their business in accordance with the law. For instance, sec. 6 of the Act states that, “every private career college shall comply with the regulations respecting the providing of security or other methods of protecting the financial interests of its students”. This means a registered private career college in Ontario must make sure that its students are financially secure and risk free while they are studying towards their respectful careers. If the Superintendent is in the opinion that one of the

career colleges is under financial hardship or risk of bankruptcy, he or she has the power to revoke the licence of the institution to operate as a private career college in order to protect the students.

With respect to supra (above) section regarding the powers of the Superintendent, I am going to give a real life example to make it better understood. Most of us do remember the sad news that one of the pri-vate career colleges, Everest Colleges Canada Inc., in Ontario closed its doors to the public because its licence was revoked by the ministry. On February 19, 2015, the Superintendent of the private career colleges issued the following notices to Everest Col-leges Canada Inc.:

• A notice of immediate suspension of Everest’s registration as a private career college under the Private Career Colleges Act, 2005 effective 9:07 a.m. February 19, 2015, and

• A notice of proposal to revoke Everest’s regis-tration as a private career college.

February 19 was a sad day for many, including the students and the staff of Everest College. However, the point is that the Superintendent has significant powers under the Act, and he or she will use the same if there is a reason to believe that the Act is not complied with. I used this example in order to relate to sec. 6 of the Act that financial security of the students matters to the Superintendent.

It is crucial to understand the role the Superintendent plays in regulating career colleges, the responsibility a college has in complying with the regulations, and the consequences of non-compliance.

The consequences of non-compliance and Superintendent powers

By Joseph Basaran

Joseph Basaran

Special thanks to:

Joseph Basaran is a licensed paralegal in Ontario since 2008. Mr. Basaran completed his practicum with the Toronto Police Services legal depart-ment as a legal researcher under the direct supervision of a senior law-yer, including two weeks of provincial prosecutor training at the Old City Hall. Joseph shares his professional experience by working as a paralegal instructor at private career colleges in Ontario and continues to make a difference in students’ lives.

an Order. If, on reasonable grounds, the judge believes that the Order is necessary to restrain a person from acting contrary to the Act, he or she will grant the Application. Thus, sec. 47 of the same Act, gives powers to the Superintendent to seek assistance of Superior courts of the province.

Under sec. 48 of the Act, there are two possible outcomes if a person is found guilty of committing an offence against the Act. According to sec. 48 (2) of the Act, the maximum monetary penalty is $50,000.00 or imprisonment not more than a year. Depending on the circumstances, both the monetary penalty and imprisonment may apply.

In case of a corporation other than a person, the maximum mon-etary punishment is $250, 000.00.

The last example I am going to give is also a related to a private career college named Toronto College of Technology Inc. Ac-cording to the Ministry of Training, Colleges and Universities, on September 2012, the Superintendent of Private Career Colleges issued a notice of refusal to renew this school’s registration as a private career college. On July 5, 2013, the Licence Appeal Tri-bunal upheld the Superintendent’s decision. The school appealed LAT’s decision to the Superior Court of Justice Divisional Court. However, the appeal is dismissed.

After all, the ministry acts as an administrative agency in the province and regulates education, including private career col-leges. The decision of the ministry is binding on the parties and can be appealed to the License Appeal Tribunal. If the decision of the Tribunal is unsatisfactory, Divisional Court may hear the case, which is the branch of the Superior Court of Justice in Ontario under the notion of judicial review.

In conclusion, the law is aimed to protect the public, and non-compliance of the same may result in disciplinary actions. Thus, each and every private career college must make sure that they are up to the standards established in order to prevent unwanted and unnecessary actions taken by the Ministry.

The Superintendent or designate may, without a warrant, do any of the following things in the course of making an inquiry or conducting an examination: According to sec. 38 (8) of the Act, a Superintendent may;

• Enter and inspect any premises used in connection with the registrant’s or person’s business or activities.

• Photograph the premises.

• Inspect documents or other things that may be relevant to the inquiry or examination.

• Require a person to answer questions about anything that may be relevant to the inquiry or examination.

• Require a person to produce a document, record or other thing and provide whatever assistance is reasonably neces-sary, including using any data storage, processing or retrieval device or system to produce information.

• In order to produce information, use any data storage, pro-cessing or retrieval device or system that is used in connec-tion with the registrant’s or person’s business or activities.

• Remove for examination and copying anything that may be relevant to the inquiry or examination, including removing any data storage, processing or retrieval device in order to produce information.

• Observe instruction given in a program and activities of stu-dents in producing or creating goods and providing services that appear to be part of the program.

• Take samples of materials, books, lessons and equipment used in providing a program

In case of non-compliance of the requests of the Superintendent, the Superintendent, in accordance with sec. 47 (1) of the Act, may make an Application to Ontario Superior Court of Justice for

Over 10 years of providing assurance to the Private Career College Community and auditing over 30 Private Career Colleges (PCCs) in Ontario. The types of PCCs range from large PCC’s with multiple cam-puses encompassing foreign students to small scale PCCs with single owner managers.

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We are committed to the betterment of the PCC industry. Provided lectures at various work-shops and contribution of written articles to Career Colleges Ontario. Consultation to MTCU policy advisors with respect to audit matters as well as standards relating to KPI audits. Con-tributed guidance to compliance committees organized by CCO.

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The eSSential art of positive curriculum assessmentsBy Jerry BishopThe eSSential Art of Positive Curriculum Assessments 2016

Dr. Jerry Bishop ~ Busiiness Assessment Solutions Inc | 1100 Burloak Drive, Suite 300, Burlington ON L7L 6B2

1

LET’S FACE IT: achieving positive curriculum assessments has its challenges. You have just finished the lengthy build of your new private career college curriculum. Your next goal is to have your program approved by the Superintendent. To achieve this, it’s time for you to undertake the required independent third-party assessments. Depending on your program assessment requirements, Fact Sheet #3 will guide your process.

The first important challenge will be selecting your assessor(s) and following the key qualifications to ensure the assessments are accepted by the Ministry. “Subsection 11 (2) of Ontario Regulation 415/06 mandates, as part of the program approval process, that PCCs have their programs assessed by a third party program assessor who has expertise in the evaluation of such programs and has been approved by the Superintendent of Private Career Colleges.” (Fact Sheet #3) Assessors must be free from conflict of interest with the PCC operator, as defined in Appendix N: Conflict of Interest Policy for Assessors. The PCC operator is required to sign Appendix N: Conflict of Interest of the Application for program approval declaring no conflict with the assessor(s) engaged to review their program. We will focus on vocational programs delivered in the classroom and supporting short independent periods of independent learning with the assessment process.

eSSential Tips for Working Effectively with Assessors

1. Locate and confirm you have the most recent Program Assessment Reports (Adult Education Matters and Subject Matters) in the Ministry’s Central Repository of Forms and share this with your selected assessors.

2. Pre-qualify potential assessors following the critical qualification guidelines ensuring credentials, academic criteria and work experience match the program area being assessed.

3. Gather all required documentation ensuring all files are in meticulous order and are accurate to share with the assessors. Follow the requirements for documentation outlined in the reports.

4. Be sure to append the application rather than entering the program inside the RICC system to submit to the ministry. Appending will allow you to make any required changes by the assessors.

5. Build your appendices inside the fillable PDF of the application, and support this with the detailed Appendix H files clearly articulated. This will allow you to make any changes required by the assessors and then subsequently enter all data approved inside the RICC system. Where possible, provide a number schemes to preserve the sequence and flow of materials and ease of reviewing the competencies (Appendix F) and objectives throughout the subjects, list of subjects (Appendix G), topics and sub-topics.

KEY AREA: Determine and agree upon a timeline for assessor reviews and subsequent updating of the program application. This will allow you to target a completion date for upload to the RICC system based on verbal positive assessments while the assessors complete and submit their reports directly to the ministry. Keep in mind, assessors are required to document all iterations of recommended changes in their assessment reports, and the final version of the application must be submitted to the assessor documented by the date of receipt.

eSSential “Missed” Curriculum Assessment Items

Facilitating Program Approvals: The Role of An Assessor An assessor’s role is specific to being an adult education expert or a subject matter expert. Assessors must secure sufficient information to review sections of the application that are relevant to their role and to assess all materials against statements in the program assessment report by marking Yes, No, or N/A. Additional supporting notes are then crafted within the report to support the assessment of findings. There are specific program requirements for assessment along with assessor qualifications that must be met before being engaged by the College. See Fact Sheet #3.

The eSSential Art of Positive Curriculum Assessments 2016


1

LET’S FACE IT: achieving positive curriculum assessments has its challenges. You have just finished the lengthy build of your new private career college curriculum. Your next goal is to have your program approved by the Superintendent. To achieve this, it’s time for you to undertake the required independent third-party assessments. Depending on your program assessment requirements, Fact Sheet #3 will guide your process.

The first important challenge will be selecting your assessor(s) and following the key qualifications to ensure the assessments are accepted by the Ministry. “Subsection 11 (2) of Ontario Regulation 415/06 mandates, as part of the program approval process, that PCCs have their programs assessed by a third party program assessor who has expertise in the evaluation of such programs and has been approved by the Superintendent of Private Career Colleges.” (Fact Sheet #3) Assessors must be free from conflict of interest with the PCC operator, as defined in Appendix N: Conflict of Interest Policy for Assessors. The PCC operator is required to sign Appendix N: Conflict of Interest of the Application for program approval declaring no conflict with the assessor(s) engaged to review their program. We will focus on vocational programs delivered in the classroom and supporting short independent periods of independent learning with the assessment process.

eSSential Tips for Working Effectively with Assessors

1. Locate and confirm you have the most recent Program Assessment Reports (Adult Education Matters and Subject Matters) in the Ministry’s Central Repository of Forms and share this with your selected assessors.

2. Pre-qualify potential assessors following the critical qualification guidelines ensuring credentials, academic criteria and work experience match the program area being assessed.

3. Gather all required documentation ensuring all files are in meticulous order and are accurate to share with the assessors. Follow the requirements for documentation outlined in the reports.

4. Be sure to append the application rather than entering the program inside the RICC system to submit to the ministry. Appending will allow you to make any required changes by the assessors.

5. Build your appendices inside the fillable PDF of the application, and support this with the detailed Appendix H files clearly articulated. This will allow you to make any changes required by the assessors and then subsequently enter all data approved inside the RICC system. Where possible, provide a number schemes to preserve the sequence and flow of materials and ease of reviewing the competencies (Appendix F) and objectives throughout the subjects, list of subjects (Appendix G), topics and sub-topics.

KEY AREA: Determine and agree upon a timeline for assessor reviews and subsequent updating of the program application. This will allow you to target a completion date for upload to the RICC system based on verbal positive assessments while the assessors complete and submit their reports directly to the ministry. Keep in mind, assessors are required to document all iterations of recommended changes in their assessment reports, and the final version of the application must be submitted to the assessor documented by the date of receipt.

eSSential “Missed” Curriculum Assessment Items

Facilitating Program Approvals: The Role of An Assessor An assessor’s role is specific to being an adult education expert or a subject matter expert. Assessors must secure sufficient information to review sections of the application that are relevant to their role and to assess all materials against statements in the program assessment report by marking Yes, No, or N/A. Additional supporting notes are then crafted within the report to support the assessment of findings. There are specific program requirements for assessment along with assessor qualifications that must be met before being engaged by the College. See Fact Sheet #3.



2

Commonly Missed Documentation Items Appendix A Market research: tasks and sub-tasks in alignment to frequency, complexity and importance;

job ads. Appendix B Subject matter experts and design experts not articulated; program maintenance are

general in nature. Requires clearly defined statements and timelines. Appendix C Mature tests not outlined as per ministry approved selection; advanced standing policy is

unclear. Appendix D Inventory items do not correlate to the maximum class size; hours allocated in the various

modes of delivery do not equal the totals found in the Appendix H files. Appendix E Evaluation methods identified do not correlate to the evaluation methods selected in

subjects in the Appendix H files and do not total 100%; evaluation prior to the half-way point does not meet compliance requirements of a documented formal meeting between educator and student.

Appendix F Statements of competencies missing the relevant knowledge verb and corresponding skill verb for clear articulation; inconsistencies in the number of knowledge competencies without supporting skill competencies and vice versa. For every knowledge competency statement, there should be a corresponding skill statement.

Appendix G Totals do not add up to the totals of all subject H files; pre-requisite subjects are incorrectly documented.

Appendix H Topic hours do not equal subject hours; weightings do not equal 100%; sub-topics are not identified and hours allocated; inconsistency in the application of teaching methods within each subject and overall subjects in alignment to Appendix D.

Appendix I Practicum handbook: orientation and placement site agreements confirming the number of placements, attendance sheets and full details in each question.

KEY AREA: Ensuring your documentation is as complete as possible will save time, plus it greatly enhances and streamlines the assessment process.



2

Commonly Missed Documentation Items Appendix A Market research: tasks and sub-tasks in alignment to frequency, complexity and importance;

job ads. Appendix B Subject matter experts and design experts not articulated; program maintenance are

general in nature. Requires clearly defined statements and timelines. Appendix C Mature tests not outlined as per ministry approved selection; advanced standing policy is

unclear. Appendix D Inventory items do not correlate to the maximum class size; hours allocated in the various

modes of delivery do not equal the totals found in the Appendix H files. Appendix E Evaluation methods identified do not correlate to the evaluation methods selected in

subjects in the Appendix H files and do not total 100%; evaluation prior to the half-way point does not meet compliance requirements of a documented formal meeting between educator and student.

Appendix F Statements of competencies missing the relevant knowledge verb and corresponding skill verb for clear articulation; inconsistencies in the number of knowledge competencies without supporting skill competencies and vice versa. For every knowledge competency statement, there should be a corresponding skill statement.

Appendix G Totals do not add up to the totals of all subject H files; pre-requisite subjects are incorrectly documented.

Appendix H Topic hours do not equal subject hours; weightings do not equal 100%; sub-topics are not identified and hours allocated; inconsistency in the application of teaching methods within each subject and overall subjects in alignment to Appendix D.

Appendix I Practicum handbook: orientation and placement site agreements confirming the number of placements, attendance sheets and full details in each question.

KEY AREA: Ensuring your documentation is as complete as possible will save time, plus it greatly enhances and streamlines the assessment process. The eSSential Art of Positive Curriculum Assessments 2016


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eSSential Difference between an Adult Education Matters and a Subject Matters Assessment Report It’s critical to understand the documentation variances between the two reports. The examples of Appendix B, G and H will highlight the differences in how the adult education assessor and the subject matter assessor document their findings and the key areas of attention. Consider this: Each appendix has unique questions, so it is important to clearly understand what is asked as well as the documentation required of the assessors you engage. Taking time in this area will ensure the documented findings support the positive assessment outcomes. Appendix B Example: The adult education assessor will be asked to comment on:

1. Provisions are in place to ensure that the program content will be assessed and revised frequently to remain current,

2. Program maintenance and evaluation methods are sufficient to ensure the program’s relevancy for the vocation, and

3. Program development and maintenance. The subject matter assessor will be asked to comment on:

1. Subject matter experts listed have sufficient credentials and expertise to develop a meaningful program for this occupation, and

2. The academic admission requirements enable students to progress through the program.

Appendix G and H Example:

The adult education assessor will be asked to comment on: 1. The knowledge and skills listed on the job profile match those listed on the Ministry standard or if there is no

standard, on the NOC, 2. In a program with multiple entry points, the learning sequence is preserved; for each subject/module,

grading system and evaluation results’, weights are clearly defined, and 3. Overall program content.

The subject matter assessor will be asked to comment on: 1. The program design proposes an appropriate learning sequence; for student with prior learning, the

modified subject sequence will allow students to graduate with the same knowledge and skills as other students,

ADULT EDUCATION ASSESSORS

SUBJECT MATTER ASSESSORS

Report on the design rather than on the subject details of the Private Career College Vocational Program.

Report on the subject details rather than the design of the Private Career College Vocational Program.

Adult education assessors report on whether the proposed program is sufficient to meet the educational needs of adult learners whereas subject matter assessors report on whether the proposed program is sufficient to meet the subject-specific needs of the program.



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Jerry Bishop, Ph.D., CTDP, FCIP


Jerry earned her PhD in Lеаrnіng аnd Dеvеlоpmеnt, is a Fellow Chartered Insurance Professional (FCIP) and is a Certified Training and Development Professional (CTDP). She also holds many certifications including DiSC® Certification in the Work of Leaders and Six Sigma Professional Black Belt. Jerry has served on several boards and committees, including The Institute’s Presidential Advisory Panel tasked with the Future State of Certification.



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2. Each competency and skill listed in the Ministry Standard/NOC is sufficiently covered in the program subjects,

3. The sequence of subjects/modules accurately reflects the complexity of tasks and sub-tasks identified in the Ministry Standard/NOC; the program duration is no less than the duration required by the related Ministry Standard; the time spent for theory verses practice (practicum, lab) is sufficient to prepare students for the occupation; the curriculum supports the credential awarded, and

4. Overall program content. Even with what appears to be complex outlines set by the Ministry that Private Career Colleges are required to meet, the good news is, following guidelines to source a suitable adult education expert and subject matter expert skilled in the area of your program will lead you to the best opportunities for a positively assessed curriculum and subsequent approval by the Superintendent. eSSential References from the Ministry of Training, Colleges and Universities Program Assessment Report (Adult Education Matters)

Program Assessment Report (Subject Matters)

Fact Sheet #3 Third Party Program Assessment

Fact Sheet #10 Approval of Distance Education Programs at Private Career Colleges

Now that we have this deadline set in stone, it would be advantageous to understand what timing works best for your PCC as well as with your auditor so that the process is as smooth and efficient as possible.

C O U N T D O W N T O K P I C O M P L I A N C EPlanning and timing strategies to work with the 2015 KPI reporting cycle

By Edmund Leong

Back in the summer of 2015, I was sent an email by my own professional associa-tion, Chartered Professional Accountants of Ontario, Practice Advisory Department. Everyone has to deal with regulatory mat-ters one way or another as well as manage compliance. Fortunately, the email was not a matter relating to my own professional compliance, but rather an email asking for my opinion on reporting deadlines as well as a one-time-per-year alignment of the KPI audits for all PCC’s.

I found it highly respectful that MTCU, along with our professional association, had reached out to select auditors to pro-vide some guidance with respect to dead-lines for KPI’s and for comments in relation to a one-time-per-year KPI audit require-ment for all PCC’s. In the past, for those PCC’s that were OSAP designated, the KPI audit used to be conducted in conjunction with the PCC’s respective year-ends, and as a result the KPI audit was typically spread out throughout the year.

My comment to the one-time-per-year ap-proach was that it would create a bottle-neck of KPI audits all occurring at the same time. Auditors also are typically very busy during the months between February and June each year dealing with December year-ends as well as other filing deadlines

that end in April or June. My other com-ments were that if the PCC did not have a December year-end, then the auditor could potentially have to come out twice a year to conduct audits. The first time to conduct the year-end audits (Year-end, PUR, Rev-enue by source, International and Domestic student enrolment, PCCA trust account) and then another time to conduct the KPI audit. This would be time consuming for both PCCs as well as auditors. On the flip side, the consistency and comparability of having all the KPIs submitted at the same time would provide more useful informa-tion to the general public.

Ultimately, after MTCU had considered all the variables, an annual September 1st deadline was struck for the KPI audits to be completed. Now that we have this dead-line set in stone, it would be advantageous to understand what timing works best for your PCC as well as with your auditor so that the process is as smooth and efficient as possible.

As you will recall, for those PCC’s that are not OSAP designated, the first KPI audit will encompass 200% of the longest voca-tional program on January 1, 2015. The first year would take about 2 times as long as it would take in future years due to student population size being 2 times as large. You

C O U N T D O W N T O K P I C O M P L I A N C E

Edmund Leong: Tator, Rose & Leong


Edmund Leong, CPA, CA, has been servicing both large and small PCCs in Ontario. His contributions to the PCC industry include various best practices lectures on behalf of CCO and at various PCCs. He has also provided consultation with MTCU policy advi-sors and CPA Ontario regarding effective and efficient audit standards.

Those PCCs with year-ends between July 2016 and September 2016 would likely need to have the auditor come out 2 times a year: once to prepare the audits for re-newal of registration and again for the KPI reporting cycle. The year-end audits be-tween September 2016 to February 2017 and the KPI audit say between May 2016 and August 2016.

Ultimately, this discussion with respect to the timelines should be made with your auditor to determine what works best based on your own timelines as well as your auditors timelines. If this is your auditor’s first time conducting the KPI audit, it will take considerably more time for the auditor to understand the terminology, deal with Forum Research’s portal, and adhere to their obligations to report errors. Budget enough time to allow your auditor to be-come comfortable with their obligations.

I also have had the opportunity to con-duct the KPI audit in isolation of the year-end audits. However, in terms of audit ef-ficiency, it would be best to have all the audits worked on by a single auditor at the same time. The economies of scale will al-low for reduced time by the single auditor, which should translate to reduced fees.

should be able to work some arrangement with your auditor to come to some middle ground with respect to audit fees for this one time transitional occurrence as the future years should normalize, assuming relatively constant student populations.

If your PCC year end is between the months of October 2015 to February 2016, then the year-end audit could coincide with the year-end audit occurring between Febru-ary 2016 and August 2016. The year-end audits would be submitted in time for the renewal of registration, and the KPI audit would also be in time for the September 1, 2016 deadline. In this time frame, the auditor should start the year-end audits between the period of February 2016 (to allow for the upload of the fall 2015 KPI files) and June 2016.

If your year-end is between March 2016 and June 2016, then it would be feasible to still have both the year-end and KPI audit conducted at the same time. However, there would be some pressure to complete the year-end audit information early enough so that the KPI audit is done in conjunction. This is most relevant to those remote PCC’s that have an out of town auditor to mini-mize audit costs of traveling. In this time frame, all the audits should be conducted between May 2016 and August 2016.

The Anthony DiLena Awards

celebrate student success

in the face of adversity and

reminds us that, when it comes

to education, one size does

not fit all.

Ash Ayotte standing behind her artwork, presented at the Ontario Legislative Building

By Dyson Wells

Ash Ayotte is not your typical 19 year-old college student. Last fall, Ash was the recipient of the Anthony DiLena Career College Pathway Award. The Anthony DiLena awards, which are organized by the Counsellors for At-Risk Students of Ontario, recognize recent at-risk graduates who have “demonstrated the exemplary ability to succeed in the face of adversity.” True to this definition, Ash’s story is a testament to her determination and the value of alter-native postsecondary pathways for Ontario students.

Like many students, grades were not always a priority for Ash in high school. Instead, she found her passion lay outside of the con-ventions of a typical classroom. But, unlike most students, Ash experienced severe anxiety during tests and examinations that poorly impacted her grades. The stress that each test brought forth caused her to cast doubt on her ability to succeed.

Yet, there was a creative streak that ran through her, and she found solace in the extracurriculars that allowed her to develop her artistic skills. She began to take part in art shows at her school. She took pride in her work and even, through a project put on by the creative youth program at her school, had her art displayed in the government’s Legislative Building in Toronto—a moment she takes particular pride in. “I was always able to show my work through art, rather than standard school,” Ash says. But despite her progression in the arts, nearing the end of her high school studies, Ash faced a chal-lenge she did not at once anticipate—Ash wanted to go to college. She recognized the importance of an education but, with her

aversion to tests and lectures that she found to be more of a hindrance to her education than a measurement of her knowledge, she knew that the road ahead of her would be demanding.

As a junior, Ash recalls a moment when her anxiety had stopped her in her tracks. She had failed the literacy test. “I left school and I didn’t go back for a week because I felt I couldn’t do it, I wasn’t important enough, I shouldn’t be here, and there was no point in trying because I couldn’t get there,” she says. “Those thoughts were constantly cycling through my head.”

This self-doubt was troublesome and a current in her journey to postsecondary education that was amplified by changes in her personal life. Ash is openly gay. As she admits, her announcement to her family

Anthony DiLena Pathway Awards: Success in the face of adversity

when she was 14 was not received well, and she was kicked out of her father’s home. As a result, her grandmother took her in for the year until her family issues could be resolved and she could move back. Understandably, she recalls feeling estranged at home as well as at school, which further affected her performance.

But despite the resulting wave of doubt accompanied with feeling as though she did not fit in with much of the world around her, Ash was more than capable of succeed-ing, and—though it took some time—she eventually came to know it, too. “A big part of it was telling myself I was worth it, and that I was not going to be just another grad-uate—I worked for it.” Ash’s newfound con-victions were reaffirmed when she retook the test and received her results. She had received a score well beyond a passing grade.

She credits her friends in supporting her through her difficult times in school and at home. “My friends’ support was a big thing for me because I never really had family support growing up, so my friends were always my grounding,” she says.

Moving into her senior year, Ash still strug-gled to overcome her anxiety. However, she did have a vision of what she wanted to study after graduation. She was determined to become a hairstylist. Just like her passion for art and painting, Ash had always loved to style hair, whether it was simply giving her friends braids as a kid, or even styling her fellow classmates’ hair for graduation.

When Ash received a notice that she had won the Anthony Di Lena Award, she was reminded of how far she had come. “After everything I’ve gone through, I thought, ‘I’d failed the literacy test, but now I’m winning this award,’” she said. “I was completely

excited and told everyone, of course!” Ash put the $500 scholarship towards tuition to attend career college and become a hair-stylist. “The money was a big deal for me,” she says. Ash’s grandmother had given her some money to go to college; however, her OSAP hadn’t come in yet, and it began to look like she would need to wait an addi-tional year to go to school. The award changed that, giving her the confidence and financial support needed to attend her college of choice.

Ash is excelling in her program and will

soon celebrate yet another graduation. As she prepares to reach this new milestone, she’s already beginning to map out the future. “I see myself working in a salon that has more of an urban, uplifting environ-ment,” she says. One day, she hopes to help others like herself to become empowered through a creative outlet just as she had.

Career Colleges Ontario

The Anthony DiLena Career College Pathway Award is

proudly sponsored by:

A close-up photo of Ash’s artwork.

the voice - compliance | issue 2 | spring, 2016

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