3. Ontario Community Support Association s (OCSA) standards

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1 Submission by PSW Educational Program Accreditation on the CONSULTATIONS ON EDUCATIONAL STANDARDS FOR PERSONAL SUPPORT WORKERS May 22, 2012 I. BACKGROUND / CONTEXT In May 2011, the government committed to the establishment of a Personal Support Worker (PSW) Registry in Ontario. The ministry is currently consulting with key stakeholders on the establishment of educational standards for PSWs for the purpose of inclusion on the Registry. There are currently a range of external criteria to designate a PSW. Generally, these cluster around work location (facility or community). Additionally, requirements in the community sector may vary by contractual obligations. By far the most specific of these requirements is contained in regulation under the Long-Term Care Homes Act, This regulation requires that, as of July 1, 2011, PSWs employed in long-term care homes, with limited exceptions, have completed a program that meets one of the three educational standards noted below. 1. Ministry of Training, Colleges and Universities PSW vocational standard (provided by Colleges of Applied Arts and Technology*) *Note: This Ministry standard only applies to vocational PSW programs provided by Ontario Colleges of Applied Arts and Technology (CAATs) and does not apply to vocational PSW programs provided by Ontario s private career colleges (PCCs). PCC PSW programs must adhere to one of the two standards below or provide a disclaimer, informing students that they will not be eligible for employment in long-term care. 2. National Association of Career Colleges standards 3. Ontario Community Support Association s (OCSA) standards 1

2 PEPA RESPONSE TO CONSULTATIONS ON EDUCATIONAL STANDARDS FOR PERSONAL SUPPORT WORKERS PEPA thanks Health Force Ontario for the opportunity to participate in the consultation process and for the interest displayed by Health Force Ontario representatives in the discussion held April 25, Below is a summary of some of our key points along with additional detail. BACKGROUND / CONTEXT 1. Are there any reasons why these three standards should not be adopted as currently written or with some modification as the core eligibility requirements for Ontario s PSW Registry? In short, there is no reason not to now adopt the three standards as written. In fact, in the near term (3-5 years) there are many reasons to adopt the standards as written. Among these are: The already fragmented support work criteria, as referenced above; The significant commonality among the 3 existing standards; Unresolved concerns with regard to workers who possess a PSW certificate of less than 600 hours, or have been educated outside Ontario, in programmes equivalent to one of these standards; The length of time required to conduct a credible review of existing Support Worker standards (encompassing an environmental scan and employer input, as well as other activities); and The amount of change currently impacting persons providing personal support. The advent of the Registry has introduced (as all new initiatives do) a level of uncertainty in the field. To embark on another significant standards revision initiative would compound uncertainty and potentially dissuade persons from entering or remaining in the field. In the Short Term In this period, stakeholders need to have some concrete information as to the preparation of certificated support workers (PSWs). PEPA urges the MOHLTC to convene meetings of representatives from all three referenced standards for the purposes of determining the knowledge and abilities common to all three. PEPA commits to assisting in this process. In addition to the tangible benefit (common training), such a process encourages the training 2

3 sectors to work together now and begin thinking about how to connect and collaborate on these efforts in the future. A cursory review of the three standards indicates significant consistency in content, but somewhat different philosophical bases underlying each. In the past, these have often been dismissed as turf issues, but the reality is that there are strong and well founded perspectives on all sides about scope. Ultimately, these have to be identified and examined in light of the sector s needs. In the Longer Term PEPA supports the development of a standard that melds the three current standards into a single consistent, coherent standard. As the guardians of the OCSA standard, PEPA is willing to participate and/or coordinate this process. To be credible, this process must bring together employers with educators and workers to ensure that standards are truly reflective of the needs of the sector and of the workers abilities. This takes time and commitment, but without a valid process, we risk repeating the fragmentation that currently exists. PEPA feels that it is essential to describe support work as a specific occupation and to clearly describe its scope of practise in the development process. We will always need someone to assist with routine activities of daily living and there is concern over what is seen as the medicalization of the support workers role an approach that PEPA feels is philosophically and financially untenable. Pressure to expand the role to undertake those skills more properly done by other health professionals like RNAs and RNs must be addressed within the current legislation (RHPA) and focus on the support worker s primary role to support persons in performing routine activities of daily living. We must make the distinction between scope of practise (the broad areas in which the support worker may work) and the current use of best practises within that scope. Consistency on scope of practise will facilitate the consistency of worker abilities and the use of best practises which will evolve over time. 3

4 Accountability is Key PEPA urges the MOHLTC to support efforts to ensure accountability among all providers, both in the immediate (through commitment to the common training components) and longer term (to a single standard). PEPA feels strongly that accountability should extend to all aspects affecting education; the school s resources, teacher preparation, student support and community responsiveness, as well as the program content. 2. What are the key challenges or opportunities in implementing these educational standards as a requirement for PSWs? In the near term, a tremendous opportunity exists to provide some consistency to what is seen as a divergent field. This can assist employers, students and other care providers in identifying and respecting the support worker s role. Through this process, we may also be able to address two categories of workers currently disengaged from the LTC homes sector: those students trained in Ontario and under one of the 3 standards, but at a time when the provincial requirement was 510 hours; and workers educated outside Ontario. These workers, although potentially eligible for registry inclusion as PSWs may not work in Ontario s LTC Homes as PSWs, unless they meet the relatively narrow exceptions listed in the regulation. This will create a great deal of confusion and must be addressed. Furthermore, there is no research that identifies an additional 90 hours as essential to competency to work in LTC homes. Many schools have traditionally placed emphasis on personal care, team work and provided extensive facility placements, all of which are directly applicable to work in LTC homes. To require additional training for the sake of a number and without consideration of what training has been provided may not yield any benefit in relevant ability. Identifying consistency in Ontario education can also set the stage for the fair and accurate assessment of the learning of these two worker groups. An interim assessment process compliant with one of the three Ontario standards that is recognized and respected would 4

5 enable additional, competent workers to enter Ontario s workforce and help to address the critical shortages that exist in many areas. In the long term, an equivalence mechanism for workers trained outside of province would continue that process and help to ensure interprovincial portability. OCSA, the organization with which PEPA is affiliated, has been called to provide leadership and has policies and procedures in place for this task. 3. Are there other issues we should consider when developing educational standards for PSWs? Educational standards are the educators knowledgeable and realistic response to the requirements of employers within the bounds of legislation. Educators should not dictate to employers what their requirements should be. Any common standard must focus on education that directly supports the need to know vs. nice to know. We have been made aware that another organization is recommending that anatomy and physiology be emphasized in PSW education. We have no evidence that this translates into a more competent worker. In fact, we frequently hear from employers and graduates that theoretical aspects of anatomy and physiology comprise a significant amount of time in the classroom, yet have little (direct or indirect) relevance to the support worker s role. The focus should shift to how the worker supports function. We must ensure that workers are truly prepared to work in all support sectors. This includes reinforcing requirements to include true community placement in all PSW programs. We have identified instances where community placement has been defined as working in a housekeeping or dietary department of a LTC home. This approach denies the unique characteristics of community support in people s homes. We must balance cost with outcome. Several attempts at implementing e-learning programs for PSWs have been developed, many with little success. While these programmes are seen as less expensive to operate and as increasing accessibility, we must also consider development costs and the validity of the learning attained. We must carefully examine what components of the program can appropriately be taught outside traditional classroom/practicum delivery before developing a framework to deliver it. We must provide a clear updating path for those with partial training and experience. This includes a valid assessment of the student s prior learning, as well as the ability to adapt programs to meet the needs of those who do not require a full program. 5

6 We must provide PSWs without current practise (or who wish to refresh skills) with the opportunity to so do. At present, a PSW who graduated in 2004 from a program exceeding 600 hours and that meets one of the three sets of standards is eligible to work in LTC homes, even if s/he has not set foot in a LTC home since graduation. At present, there is no clear process for these PSWs to refresh skills. We must provide opportunities for PSWs to undertake enhancement training (within the scope of the role). PEPA strongly supports the establishment of enhancement programs with outcomes that are standardized. 6