The Role of Regulation in Health Care

LEGAL ASPECTS OF HEALTH CARE
The Role of Regulation in Health Care

THE ROLE OF
REGULATION IN HEALTH
CARE
THE ROLE OF REGULATION IN HEALTH CARE
▪ Canadian Health Law & Policy,

Fifth Edition (2017) by Joanna
Erdman, Vanessa Gruben, and Erin
Nelson (eds)
▪ Chapter 7: The Role of Regulation
in Health Care – Professional and
Institutional Oversight (textbook
pgs. 161-175)
THE ROLE OF REGULATION IN HEALTH CARE
▪ Health care is an essential but high-risk activity involving
considerable vulnerability for patients.
▪ The risks inherent in health care and the considerable public
investment it draws underpin the importance of appropriate
care.
▪ Regulation of both health care professionals and the institutions
in which they deliver care plays a critical role in promoting and
protecting quality and safety in health care.
PURPOSE OF REGULATION
Professional regulation is seen to serve two key purposes:
1. It promotes and protects the public interest. Drawing on consumer
welfare perspective, this view prioritizes the welfare of the public
served by members of the profession.
2. Professional regulation is seen to ensure a certain degree of
competence by restricting access to practice a profession which, in
turn, protects a potentially vulnerable public who might otherwise
not be able to distinguish the skilled provider from the unskilled. This
is particularly critical in health care where health care providers hold
specialized knowledge and training that their patients do not.
TYPES OF REGULATION
There are various types or “modes” of regulation of professionals and
institutions, falling into two general categories – input and output.
Input Regulation
▪ Licensure
▪ Certification
▪ Registration
Output Regulation
▪ Competence
▪ Professional discipline
▪ Civil liability
▪ Public accountability
INPUT REGULATION
INPUT REGULATION
Licensure Certification Registration

INPUT REGULATION
Input regulation refers to measures (e.g., academic qualifications, professional
training) which control who is entitled to identify themselves as a member of a
particular profession and/or to provide particular services.
Licensure
▪ Licensure systems are those in which legislation provides a framework for a
profession's activities, including the exclusive right of licensed members of
the profession to deliver profession-specific services.
▪ For example, in Canada only licensed physicians are permitted to practice
medicine; licenses are granted by provincial/territorial colleges of physicians
and surgeons or comparable entity.
▪ Licensure provides a limited degree of quality assurance to the public
because although it ensures the licensed individual possessed the requisite
qualifications upon entry to the profession, it does not necessarily ensure
continuing competence.
INPUT REGULATION
Certification
▪ Certification refers to systems of title protection in which only individuals
who meet particular standards or qualifications are permitted to use the title
of the profession.
▪ Unlike licensure, which creates a monopoly, in certification regimes non-
certified individuals are typically still free to provide the same services and
thus compete for market share, but without the advantage of using the
designated professional title.
▪ In certification regimes, the onus is on the public to exercise due diligence
when selecting their service provider.
▪ Title protection addresses many information asymmetries, in that it highlights
which providers do and do not have the particular qualifications required for
certification.
▪ It does not, however, restrict uncertified individuals from operating in the
same market.
INPUT REGULATION
Certification
▪ For example, in Newfoundland and Labrador it is an offence for anyone
other than a registered psychologist to use the title of psychologist, but
there are no restrictions around the provision of counseling or other
mental health services in general.
PROTECTED TITLES
 In Canada, health care professions are protected titles; not
anyone can hang up their ‘shingle’ claiming to be a health
professional
REGULATING HEALTH PROFESSIONS
INPUT REGULATION
Registration
▪ Registration systems often accompany other regulatory regimes (such as
certification) and provide a means for identifying individuals who belong to a
particular professional group.
▪ For example, the College of Physicians and Surgeons of Alberta has a
voluntary, non-regulated membership category for physician assistants who
can provide care only under the supervision of a registered physician in the
province.
▪ The College does not regulate the physician assistant profession, but does
impose criteria (specific training and credentials) necessary for registration.
INPUT REGULATION
Licensure Certification Registration

OUTPUT REGULATION
OUTPUT REGULATION
Professional Public
Competence Civil liability
discipline accountability
OUTPUT REGULATION
Output regulation addresses the quality of services provided in a reactive
manner.
Competence
▪ Professionals are required to maintain particular standards to remain a
member in good standing of their profession.
▪ Typically, this requirement will involve compliance with continuing education
requirements, to help ensure regulated professionals stay abreast of new
developments in their fields and maintain a current knowledge of best
practices.
▪ For example, physician members of the various College of Physicians and
Surgeons across Canada must meet continuing professional development
(“CPD”) requirements, with programs established by the College of Family
Physicians of Canada and the Royal College of Physicians and Surgeons of
Canada.
OUTPUT REGULATION
Professional Discipline
▪ A key element of most professional regulatory structures – particularly self-
regulated professions – is a disciplinary process whereby regulators can
address member conduct that does not meet the standards of the
profession.
▪ Professional regulatory bodies generally derive authority to discipline
members from their empowering legislation.
▪ Although there is variation, the disciplinary process typically involves both
professional and public (i.e., lay member) representation.
OUTPUT REGULATION
▪ For example, the Alberta Health Professions Act prescribes the
framework for regulatory colleges in the province to regulate the
practice of the regulated profession by its regulated members.
▪ The Act outlines a compliance process that is engaged upon the receipt
of a written complaint by the complaints director.
OUTPUT REGULATION
Health Professions Act (Alberta)
Once a written complaint has been received, the complaints director has a
number of options as to how to proceed. These include:
▪ Encouraging communication between the complainant and the

member
▪ Referring the matter to an alternative complaint resolution process
▪ Requesting an expert assessment
▪ Triggering an investigation
▪ Dismissing the complaint
OUTPUT REGULATION
Health Professions Act (Alberta)
▪ After receiving the results of an investigation, the complaints director may
refer the matter to a hearing.
▪ The legislation sets out a hearing process, as well as possible outcomes if a
finding of unprofessional conduct is made including, though not limited to:
▪ Reprimands;
▪ Imposition of practice conditions (e.g., supervision, restrictions);
▪ Suspension;
▪ Cancellation of registration; and
▪ Any order that the hearing tribunal considers appropriate for the
protection of the public.
OUTPUT REGULATION
▪ Professional discipline is exercised pursuant to delegated statutory authority.
As such, it falls under the umbrella of administrative law, meaning that it is
bound by the principles of natural justice including the duty of fairness.
▪ Depending on the legislative framework, decisions may be subject to review
by an external body (e.g., Health Professions Review Board, an administrative
tribunal) and ultimately to appeal or judicial review by the Court.
▪ The professional discipline process is distinct from civil claims and can be a
faster and less expensive process.
▪ Unlike civil actions, professional discipline processes do not lead to damage
awards for the complainant.
OUTPUT REGULATION
Civil Liability
▪ Individuals in Canada who suffer harm or loss as a result of health care have
the option of suing the health care professional and/or his or her employer(s),
and/or the institution.
▪ The most common forms of actions in the health care context are tort claims
for negligence and battery.
▪ Both individuals and institutions can be directly liable for tortious conduct.
▪ For example, hospitals and other institutions may be liable for failing to ensure
safe systems or failing to exercise reasonable care in the selection of staff.
▪ Institutions can also be vicariously liable for torts committed by their
employees (e.g., a hospital being found liable for the actions of a staff nurse).
OUTPUT REGULATION
Public Accountability
▪ The growing interest in public accountability for safety and quality of care
provides another mode of regulation that is particularly relevant to health care
institutions and health systems.
▪ In 2002, Saskatchewan was the first province in Canada to establish a
provincial Health Quality Council (“HQC”), the objectives of which include
monitoring and assessing the quality of health services available in
Saskatchewan. Among other things this HQC maintains an interactive, publicly
accessible website that reports on the status of various health quality
indicators in health regions across the province.
▪ Other provinces and territories have since developed their own similar
organizations.
OUTPUT REGULATION
Public Accountability
▪ The Canadian Institute for Health Information (CIHI) and the Canadian Patient
Safety Institute (CPSI) are leaders at a national level when it comes to
reporting promoting quality of care.
▪ It is too soon to know what role, if any, these types of accountability-focused
mechanisms will have in improving the quality and safety of health care in
Canada.
▪ Nonetheless, they seem a logical invaluable accompaniment to the other
regulatory tools discussed, as they contribute to setting expected standards of
practice and provide a vehicle for identifying outliers.
OUTPUT REGULATION
Professional Public
Competence Civil liability
discipline accountability
REGULATORY
AUTHORITY
SOURCES OF REGULATORY AUTHORITY
▪ Under Canada's constitutional division of powers, the regulation of
health care services is largely seen to fall within provincial jurisdiction.
▪ Provincial governments often delegate their authority (by way of
legislation) to a regulatory body, such as the provincial colleges of
physicians and surgeons.
▪ The enabling statute usually creates the regulatory body, establishes its
governing structure and mandate, sets out particular elements of its
operations, and frames the boundaries of its jurisdiction.
▪ Regulatory bodies may only act pursuant to the authority granted to
them by the statute.
▪ Government retains ultimate regulatory authority, with the ability to
amend or even repeal the empowering legislation.
▪ Canadian jurisdictions take one of two main legislative approaches to
regulating health care professionals: umbrella legislation or profession-
specific legislation.
▪ Umbrella legislation refers to regulatory systems in which a single piece
of legislation governs all regulated professions in a global manner, with
profession–specific acts, regulations and by-laws addressing matters
particular to a single profession.
▪ In the more traditional profession-specific approach, each health care
profession has its own independent statute.
▪ One of the benefits of an umbrella approach is that it can allow for
overlapping scopes of practice so as to facilitate new models of care
including more collaborative, team-based strategies such as where
nurse practitioners work closely with physicians.
▪ The challenge lies in finding a balance between promoting seamless
collaborative and interdisciplinary care, while still restricting higher risk
activities to specific professional groups.
▪ Ontario’s Regulated Health Professions Act seeks to effect this balance
by outlining a number of “controlled acts” (e.g., setting a bone fracture,
administering injections, prescribing drugs) that may only be
performed by members of specific health professions.
REGULATED HEALTH
PROFESSIONS ACT
(ONTARIO)
REGULATING HEALTH PROFESSIONS
 In Ontario, the Regulated Health Professions Act, 1991 and
various health profession Acts (such as the Medicine Act,
1991) regulate health professions
Regulated Health Professions. Ministry of Health & Long-Term Care. Available at

http://www.health.gov.on.ca/en/pro/programs/hhrsd/about/regulated_professions.aspx
REGULATED HEALTH PROFESSIONS ACT
▪ Legislative framework (RHPA and health professions acts) establishes
health regulatory colleges, which regulate the professions in the
public interest.
▪ Responsible for ensuring that regulated health professionals provide
health services in a safe, professional and ethical manner.
▪ Includes setting standards of practice for the profession and
investigating complaints about members of the profession and, where
appropriate, disciplining them.

[CONT’D]
The RHPA framework is intended to:

▪ Protect and serve the public interest;
▪ Be an open and accountable system of self-governance;
▪ Provide a modern framework for the work of health professionals;
▪ Provide consumers with freedom of choice; and
▪ Provide mechanisms to improve quality of care.

[CONT’D]
Key features of the RHPA include:

▪ Scope of practice – a statement that describes what the profession does.
▪ Controlled acts – procedures or activities which may pose a risk to the public if
not performed by a qualified practitioner.
▪ Health regulatory colleges – a corporation that governs each regulated health
profession responsible for regulating the practice of the profession and
governing its members according to the RHPA.
▪ Health Professions Regulatory Advisory Council – an independent, arms-length
advisory body to the Minister of Health and Long-Term Care with a mandate to
advise the Minister of a number of items related to the regulation of health
professions.
▪ Health Professions Appeal and Review Board – an independent third party with
a mandate to review registration and complaints decisions of the health
regulatory College.
[CONT’D]
▪ The Health Professions Procedural Code, Schedule 2 to the RHPA,

sets out a comprehensive set of rules that all health regulatory
colleges must follow when registering new members, investigating
complaints, and disciplining members of the profession.
▪ Rules ensure that health professional regulation in Ontario is:
o Open
o Transparent
o Accessible
o Fair
for those seeking to become regulated health professionals, for
the regulated health professionals who are governed by the
health regulatory colleges, for patients and members of the
public, whom the legislative framework is meant to protect.
[CONT’D]
▪ https://www.youtube.com/watch?time_continue=8&v=WNf0k1
R-duc&feature=emb_logo
▪ https://www.youtube.com/watch?v=PVyGg30QIWg
▪ https://www.youtube.com/watch?v=_kkfOVRaT98
▪ https://www.youtube.com/watch?time_continue=3&v=7XBcgqc
e1EI&feature=emb_logo
▪ https://www.youtube.com/watch?v=hF9gZaiHPow

WHAT DOES IT MEAN TO BE ‘REGULATED’?
 What does it mean to be ‘regulated’?
o Met certain standards, qualifications and criteria
o Provide services within a specific ‘scope of practice’
Aldridge, S. (2008). The regulation of health professionals: An overview of the British Columbia experience. Journal of Medical Imaging
and Radiation Sciences. 39; 4-10. Retrieved https://www.jmirs.org/article/S1939-8654(08)00002-7/pdf
WHY REGULATE?
 Why do we regulate health professionals?
o Individual patients can’t assess qualifications, competency or
fitness to practise of a health care provider
o Policy instrument to protect the public from unqualified,
incompetent or unsafe providers
o Recognizes a profession as legitimate
HOW DO WE REGULATE?
 How are health care professionals regulated?
o Regulated Health Professions Act, 1991
 Scope of practice (what the profession does)
 Controlled acts (e.g. activities which may pose a risk to the
public if not performed by a qualified practitioner)
 Communicating a diagnosis identifying a disease
 Prescribing a hearing aid for a hearing-impaired person
 Prescribing, dispensing, selling or compounding a drug
 Putting an instrument, hand or finger into an artificial
opening in the body
College of Nurses of Ontario (2018). Legislation and Regulation: RHPA: Scope of Practice, Controlled Acts Model. Retrieved
http://www.cno.org/globalassets/docs/policy/41052_rhpascope.pdf
Aldridge, S. (2008). The regulation of health professionals: An overview of the British Columbia experience. Journal of Medical Imaging and Radiation Sciences. 39;
4-10. Retrieved https://www.jmirs.org/article/S1939-8654(08)00002-7/pdf
HOW DO WE REGULATE? [CONT’D]
o Self-regulation by a professional College
 e.g. College of Nurses of Ontario, College of Physicians &
Surgeons of Ontario
o Professional practice and education standards for each
regulated health professional
o Health Professions Appeal and Review Board
College of Nurses of Ontario (2018). Legislation and Regulation: RHPA: Scope of Practice, Controlled Acts Model. Retrieved
http://www.cno.org/globalassets/docs/policy/41052_rhpascope.pdf
Aldridge, S. (2008). The regulation of health professionals: An overview of the British Columbia experience. Journal of Medical Imaging and Radiation Sciences. 39;
4-10. Retrieved https://www.jmirs.org/article/S1939-8654(08)00002-7/pdf
APPROACHES TO
REGULATION
DIFFERENT APPROACHES TO
REGULATION
 Health care professional regulation can be accomplished in a variety of
ways. Some jurisdictions adopt more direct forms of state control,
sometimes referred to as “command and control” approaches, while
others place control in the hands of the profession by way of self-
regulation.
 The term self-regulation can be used to describe regulatory approaches
with different balances of authority, accountability and involvement of
the state.
 Often it refers to a system whereby the profession is granted authority
by the state to regulate itself, usually via a college or board made up of
both professional and non-professional members charged with setting
entry standards and overseeing professional practice.
REGULATION
 Professional self-regulation is both a privilege and a burden and
demands diligence and ongoing efforts to maintain the public trust.
 A self-regulating profession typically undertakes various rules, including
to define the scope of competence of the whole profession and to
ensure the competence of individual practitioners within the profession
through a combination of processes that include:
 Original selection of candidates

 Their education and maintenance of competence
 Assurance of the discipline of practitioners
 The warrant that implementation of that competence serves the best
interest of patients
REGULATION
 Although self-regulation is now the most common mode of health
profession regulation in Canada, historical reviews demonstrate
considerable variation over time, both between and within provinces, in
terms of whether and how different professions have been regulated.
 Regulatory approaches are not static and often shift as philosophes or
circumstances change.
REGULATION
 Physicians in Canada self-regulate through their provincial colleges of
physicians and surgeons.
 The colleges are established by legislation which sets out their
governance structures.
 The regulatory colleges have considerable but not unlimited disciplinary
power.
 For example, under Ontario’s Regulated Health Professions Act, the
Minister enjoys a broad range of powers, including reviewing activities
and requiring the provision of reports, requiring anything that, in the
Minister's opinion, is necessary or advisable to carry out the intention of
the relevant legislation.
UN-REGULATED HEALTH
PROFESSIONS
REGULATED VS NON-RHPA
PROFESSIONS
 Unregulated health professions include:
o Personal Support Workers
o Physician Assistants
o Physiotherapy Assistants
 Not regulated under the Regulated Health Professions Act
but provide health or other care to clients and patients
 Not accountable to an external professional body or
regulatory college
Glauser, W, Tierney, M, Nolan, M (2016). Does Ontario have too many under-regulated health workers? Healthydebate. March 31..
Retrieved https://healthydebate.ca/2016/03/topic/health-professional-regulation
PROFESSIONS [CONT’D]
 Some non-RHPA health professionals are regulated to an
extent but rules and regulations are not consistent
 No provincial body to monitor training or investigate
complaints
 No provincial registries to report if a member of a non-
RHPA-regulated profession has been fired for misconduct
PROFESSIONS [CONT’D]
 Professions under RHPA decide on the skills members must
possess, standards they must follow, and disciplinary
processes
 Rules and regulations set by self-regulating professions are
approved by government
 When RHPA created in 1991, fewer professions than today;
some are new, others have evolved
 Chinese medicine practitioners granted self-regulating
status in 2013 and naturopaths in 2015
ADVANTAGES OF
SELF-REGULATION
ADVANTAGES OF SELF-REGULATION
 Self-regulation has a number of advantages that are particularly relevant in
medicine.
 It is often characterized as an efficient mode of regulation because it can
reduce the cost of regulation for both the public and the state and minimize
the state’s administrative burden that would be associated with, for example,
setting and enforcing standards for specialized fields and managing a
complaint and disciplinary process.
 It is also seen to have larger social value, with roots in protection of the
public interest.
 The roots of medical professional self-regulation have been described as a
social contract where the benefits associated with the protection of the
public interest are coupled with benefits the profession enjoys by virtue of
the market control regulation provides.
ADVANTAGES OF SELF-REGULATION
It has been suggested that:
▪ Self-regulation is part of what differentiates occupations from professions.
▪ Professional status is not only important to those who have it, but also to
those who depend on professionals for their services.
▪ It says something about the social importance that is attached to the work.
▪ It implies the presence of ethical and legal obligations that go beyond what
might be expected from others.
▪ In these regards, self-regulation resonates with the values that underlie the
Canadian health care system and with the importance that Canadian’s attach
to health care and to their health care system as one of Canada's
fundamental social institutions.
CRITICISM OF
SELF-REGULATION
CRITICISM OF SELF-REGULATION
Self-regulatory models also

attract vehement criticism
THE PROBLEM WITH SELF-REGULATION
Do you see any problems

with a profession self-
regulating?
Bias • Provider-centric
Lack of • Secrecy and protection

Transparency
• The tendency of regulators to identify

Regulatory more with those they regulate than
Capture with the public they are protecting
Potential • Where the regulator takes a protectionist approach

towards its members and is problematic if the
for under- regulator prioritizes protection of its members over
the public it serves
regulation
• Where, perhaps out of a desire to justify its

Potential existence, its growth, its influence, and its increased
professionalization, a regulator takes highly rigid
for over- approach which can have negative implications when
it comes to public accessibility by unnecessarily
regulation limiting the number of providers available
 Do you see any problems with a profession self-regulating?

o Assumes that a College will behave altruistically and in the
best interest of the public
o Potential conflicts of interest regarding the duties of the
College to set minimum competency levels, establish
standards of practice, evaluate credentials
o Duty to protect the public vs. benefiting the profession by
increasing the number of registrants or creating professional
esteem
[CONT’D]
 Policy implications of scope of practice and health

human resource planning, supply and demand on:
o Access to health care
o Wait times
HOW SHOULD NON-RHPA PROVIDERS BE
REGULATED?
 Focus on government regulation of health professions

instead of self-regulation
 UK, Australia have moved away from self-regulation
towards government oversight
 RHPA is old, needs review and updating
HOW SHOULD NON-RHPA PROVIDERS BE
REGULATED? [CONT’D]
 Allow smaller professions that cannot afford RHPA-defined
College to have title protection
 E.g. physician assistants in Ontario could be regulated by
the College of Physicians & Surgeons like in Manitoba and
New Brunswick
CONCLUSION
 The regulation of health care professionals and institutions is a complex field
that requires balancing of diverse and sometimes competing priorities.
 Goals relating to protection of the public interest, including safety and
quality of care, are paramount but are pursued alongside professions
operating with their own interests and priorities.
 The desire to maintain public trust and promote responsible stewardship of
publicly funded health care has increasingly become part of the public policy
discourse regarding health system governance, as has a recognition of both
the opportunities and risks presented by new forms of health technology,
novel models of care, of human resource mobility, to name just a few.
 Regulation in its various forms of both health care professionals and the
institutions where they provide their services, has a vital role to play in
shaping the future of our health care system.
 Thoughtfully crafted regulation is critical for facilitating safe, efficacious and
responsible health care delivered with the public interest as a first priority.
RECAP
Joint responsibility models of professional regulation are:
1. Based on a regulatory partnership between the public and the profession
2. Are used to distribute the cost of professional regulation
3. Are a means for the government to abdicate responsibility for professional
regulation
4. None of the above
RECAP
The controlled acts model is intended to:
1. Identify the health care activities that place the public at risk
2. Prevent unqualified people from performing health care activities that
have an element of risk
3. Restrict the performance of risky health care activities to those who have
the appropriate training to perform them safely
4. All of the above
RECAP
The RHPA:
1. Set out the Minister’s responsibility to administer the Act
2. Establishes the Health Professions Regulatory Advisory Council and the
Health Professions Appeal and Review Board
3. Defines controlled acts
4. Contains the restricted titles for all regulated health professions
RECAP
Profession-specific acts:
1. Establish each health profession’s college and its governing council
2. Defines the scope of practice of the profession they govern
3. List the controlled acts that professions are authorized to perform (if they
can perform controlled acts)
4. Has the Code deemed to be part of them
5. All of the above
RECAP
The Minister of Health and Long-Term Care is responsible for administering
the Regulated Health Professions Act (RHPA):
▪ True
▪ False
RECAP
What is the role of the Health Professions Appeal and Review Board?
1. Review appeals of decisions of Inquiries, Complaints and Reports
Committees
2. Review appeals of decisions of Registration Committees
3. Review appeals of decisions of Discipline Committees
4. Review appeals of decisions by Fitness to Practise Committees
RECAP
The Fairness Commissioner's role in the RHPA to ensure that colleges register
every applicant who applies
▪ True
▪ False
RECAP
The role of the College’s Council is to:
1. Act as the College’s Board of Directors
2. Approve regulations
3. Approve by-laws
4. Provide staff with advice on the day-to-day operations of the College
RECAP
Because of the way the Code defines their duties, College Registrars play an
important role in colleges
▪ True
▪ False
RECAP
When carrying out the objects required of it, a regulatory college has a duty
to ensure the goodwill and happiness of its members
▪ True
▪ False
RECAP
Controlled acts are health care activities that are potentially harmful if
performed by unqualified people
▪ True
▪ False
RECAP
Which of the following apply?
Authorized controlled acts:
1. Are controlled acts that members of some health professions are
authorized to perform
2. Must be performed within the scope of practice of a profession
3. May be delegated to another person in certain circumstances
4. All of the above
RECAP
The RHPA requires regulated health professionals to make mandatory reports
in which of the following circumstances?
A mandatory report is required:
1. If a member has obtained information while practicing that another
regulated health professional has sexually abused a patient
2. If a member has been found guilty of professional negligence or
malpractice
3. If a member has been found guilty of an offence
4. All of the above
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LEGAL ASPECTS OF HEALTH CARE

The Role of Regulation in Health Care

▪ Canadian Health Law & Policy,

Licensure Certification Registration

Licensure Certification Registration

▪ Encouraging communication between the complainant and the

Regulated Health Professions. Ministry of Health & Long-Term Care. Available at

Regulated Health Professions. Ministry of Health & Long-Term Care. Available at

The RHPA framework is intended to:

Regulated Health Professions. Ministry of Health & Long-Term Care. Available at

Key features of the RHPA include:

▪ The Health Professions Procedural Code, Schedule 2 to the RHPA,

Regulated Health Professions. Ministry of Health & Long-Term Care. Available at

 Original selection of candidates

Self-regulatory models also

Do you see any problems

Lack of • Secrecy and protection

• The tendency of regulators to identify

Potential • Where the regulator takes a protectionist approach

• Where, perhaps out of a desire to justify its

 Do you see any problems with a profession self-regulating?

 Policy implications of scope of practice and health

 Focus on government regulation of health professions

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