CSHBC has received a number of questions regarding the Practice Hours module required under the College’s Quality Assurance & Professional Practice (QAPP) program. The following provides answers to common questions about practice hours.
1. What are the modules in the QAPP program for ensuring competency?
The QAPP program modules include the following:
- The practice hours requirement specifically looks at whether registrants have practiced their profession(s) in a 3-year period. This ensures public trust that registrants have recent practice.
- Reporting of continuing competency credits (CCCs) ensures that registrants are keeping current in their knowledge.
- Participation in performance-based practice reviews ensures that professional and clinical standards are being met in practice.
- Completion of certified practice certification programs ensures that registrants possess the required knowledge, skills, and abilities necessary to perform practices that are higher risk and required under the Speech and Hearing Health Professions Regulation and CSHBC Bylaws.
2. What authorizes CSHBC to require practice hours?
The College’s Quality Assurance & Professional Practice Committee administers the QAPP program, including the Practice Hours module, pursuant to the Health Professions Act (HPA) and the CSHBC Bylaws. Section 16(2) of the HPA stipulates that CSHBC has an obligation to:
- establish, monitor, and enforce standards of practice to enhance the quality of practice and reduce incompetent, impaired, or unethical practice amongst
- to establish and maintain a continuing competency program to promote high practice standards amongst registrants.
Sections 161 and 162 of the CSHBC Bylaws prescribe practice hours and deficiency plan requirements.
3. What notification was given to registrants that this was occurring?
Notification began in 2019 via email communications, a website posting, in person events such as the 2019 Public Engagement Forum, and a 90-day public consultation providing notice of proposed bylaw amendments that included the practice hour requirement.
4. Why does this practice hours cycle only have 18 months instead of the full three years?
CSHBC operates on a 3-year reporting cycle for requirements including Continuing Competency Credit (CCCs). For consistency, aligned reporting cycles for both CCCs and practice hours was determined to be the best approach. Timelines for when bylaw amendments are brought into force are subject to Ministry of Health approval. The amendments for practice hours were posted in late 2019 but did not come in force until June 29, 2020. Consequently, the current cycle, which ends December 31, 2021, is shorter and the required practice hours have been pro-rated accordingly.
5. How many hours are required?
For a full 3-year cycle, the required hours are 750 for the first registration held. There are additional hours required if you hold more than one registration. For this shorter cycle, the base number of required hours are 360 for the first registration. The pro-rated hours for this cycle (July 1, 2020 – December 31, 2021) are as follows:
| First Full Registration | Second Full Registration | Third Full Registration |
|---|---|---|
|
360 hours |
An additional 125 hours |
An additional 125 hours |
|
Of these, a minimum of 120 hours must be specific to this professional registration |
These hours must be specific to this second registration |
These hours must be specific to this third registration |
6. I registered with CSHBC and went on the College’s Public Register after July 2020 – what is my practice hours requirement?
If you register with CSHBC and go on the Public Register after July 1, 2020 the College will pro-rate your practice hours requirement, based on the number of months remaining in the current cycle. You will be able to see your pro-rated practice hours requirement in the Registrant Portal when you log in.
7. How was the base number of hours set?
An environmental scan was completed of other health professions in BC as well as with our professional counterparts across Canada. The number set by CSHBC is similar to many other professions but has more latitude in what can be reported as practice hours.
8. Why are more hours required if I hold two or three licenses to practise?
It is important to be current in all professions that you are licensed to practise. However, it is also important to recognize that registrants may not practise multiple professions in equal amounts, so the number of hours for a second or third registration are less. For the public, this ensures that a registrant does not hold a registration for a profession they have not practised for many years, or at all.
9. What factors were considered in setting the hours?
CSHBC working groups, committees, and the Board considered a number of factors in addition to the requirements of other professional regulators, including:
- The number of registrants who work part-time;
- That a registrant may hold a Non-practicing registration classification for an entire cycle;
- The variety of practice settings across the province;
- That some practicing registrants do not see clients of their own (e.g., supervisors, educators, etc.);
- The diversity of registrants within and across all 3 professions.
10. Do I have to keep a detailed log of everything I do?
No. If you work a certain number of hours per week or per month, that may be all you need to know in order to enter your hours through the Registrant Portal. You do not need to report more hours once you have fulfilled the minimum requirement.
11. If you hold more than one registration, how do you decide which is your “primary” profession for practice hours?
If you spend more time practising one profession than another profession(s), you could consider the one you practise more as your primary registration. If you practise multiple professions equally, you can simply choose one as your “primary” profession.
12. Are client specific hours the only kind of practice hours that can be reported?
No. There are a variety of practice hours that can be included, and they are listed in Appendix B on page 13 in the Attaining & Maintaining Practice Competence standard of practice (PDF).
13. For this partial cycle, what happens if I cannot work or am away from work for the remainder of the cycle?
If you have a special situation you would like to discuss, please contact the College at: [email protected].
14. At the end of the cycle, a random audit will be conducted. What constitutes proof of my hours if I am audited?
In many instances, a record of employment or service contract would be sufficient proof. For sole practitioners, business records that are routinely kept may suffice (e.g., billable hours). For registrants who work in one or more settings, there may be a need to have more than one document.
15. At the end of the cycle, what happens if I have not reported the required practice hours?
CSHBC will contact registrants who are deficient in practice hours and provide two options:
- Complete an approved plan that addresses how you will remedy the deficiency, or
- Practice under supervision of another Full registrant for a period of time to be determined by the QAPP Committee, or
- Complete a practice review.
Completed deficiency plans must be submitted for approval in advance of the January 31, 2021 plan approval deadline. Approved plans must be completed no later than March 31, 2021 the deadline for registration renewal.
16. Are all registrants required to participate in the practice hours module?
Yes. All CSHBC registrants have a duty to comply with their professional requirements. Refusal to participate may result in professional discipline.
17. Is the College’s QAPP Committee subject to the Freedom of Information and Protection of Privacy Act (FIPPA)?
Generally no, although CSHBC is monitoring ongoing legal developments in this area. Pursuant to section 26.2(1) of the HPA, FIPPA does not apply to records and information the QAPP Committee receives as part of the QAPP program. Such records are confidential, apart from the exceptions contained within that section. For more information, please contact CSHBC at [email protected].