The Health Professions Appeal and Review Board has confirmed the refusal of a certificate of registration for an internationally educated respiratory therapist applicant who failed to demonstrate entry-to-practice competency during a clinical skills assessment.
The applicant, who holds a Bachelor of Science in Anesthesia Technology from Islamic Azad University in Iran, applied to the College of Respiratory Therapists of Ontario in August 2023. Because her program was not accredited by the College, she was required to complete the College’s Entry-to-Practice Assessment to demonstrate equivalent knowledge and skills.
The assessment consisted of three components: an educational review, a structured interview, and a clinical skills assessment. While the applicant passed the first two stages, she scored below the minimum standard on five out of 12 competency areas during the clinical skills assessment completed in July 2024.
The Registration Committee refused to issue a certificate of registration in July 2024. The board confirmed that decision on Nov. 14, 2025.
Critical errors identified
According to the ruling, assessors identified three critical errors during the clinical skills assessment that “if performed on real patients, would have posed a significant risk of harm to patients.” The errors involved performing arterial, venous or capillary samples, managing artificial airway devices, and providing optimal invasive and non-invasive mechanical ventilation support.
The applicant failed to demonstrate entry-to-practice performance levels in five competency areas: analysis and problem solving, bronchopulmonary hygiene, airway management, invasive vascular procedures, and ventilation management.
The Committee determined “the gaps identified during the CSA are not only numerous but are in areas that would require a great deal of foundational knowledge and practice to overcome,” according to the ruling.
Applicant challenges assessment methodology
The applicant submitted to the board that simulation-based assessment may not fully reflect clinical competence for professionals with hands-on experience in real healthcare settings.
“While simulation is widely used in credentialing, I respectfully submit that it may not fully reflect clinical competence — especially for professionals with significant hands-on experience in real healthcare settings,” the applicant wrote in her submissions. “I respectfully submit that my actual clinical performance in these settings better represents my competency than the outcomes of a simulated assessment.”
The applicant argued the identified gaps were task-specific procedural issues that could be remedied through structured learning and supervised practice. She noted that some gaps appeared to align with courses identified in the College’s own remediation documentation.
She requested a graduate certificate of registration with conditions that would allow her to demonstrate competency through supervised clinical practice.
Non-exemptible requirements
The board noted that under section 55(2) of Ontario Regulation 596/94, applicants who completed programs outside Canada must demonstrate through an assessment process that they have “knowledge, skills, and judgement equivalent to those of a person who has successfully completed” an accredited Canadian program.
This requirement is non-exemptible, meaning the College cannot waive it under any circumstances.
The board found that even a graduate certificate of registration — a conditional or supervised pathway — cannot be issued unless an applicant first meets these non-exemptible equivalency requirements under the regulation.
“The Board notes, however, that with the exception of the OPIQ courses, the Applicant’s education, certifications and professional experience were all before the Committee and considered in its decision,” the ruling stated.
Work history and credentials
At the time of application, the applicant was employed at Toronto Western Hospital as an administrative assistant in the neurology outpatient clinic and at St. Michael’s Hospital as a clerical assistant in the cancer care outpatient clinic.
From 2013 to 2023, she worked in Tehran, Iran, first as an anaesthesia assistant and later as a medical officer manager.
The applicant held valid Basic Life Support and Advanced Cardiovascular Life Support certificates from Heart and Stroke, and had completed two courses from L’Ordre professionnel des inhalothérapeutes du Québec: Advanced Airway Management in Adults, and The RT in the ICU.
Assessment process details
The educational review, conducted in September 2023, found the applicant’s academic qualifications partially comparable to Canadian standards. Gaps were identified in foundation sciences including chemistry, biochemistry, physics, and pharmacological principles, as well as in assessing patients’ cardiorespiratory status.
During the structured interview in December 2023, assessors found the applicant appeared to meet the clinical and core competencies assessed during that stage based on her ability to recall and describe her experience.
The clinical skills assessment in July 2024 used standardized evaluation rubrics to score performance in simulated clinical scenarios designed to evaluate competencies at an entry-to-practice level.
Board’s analysis
The board noted the applicant provided detailed personal review and analysis of parts of the assessment but “provided no information to demonstrate that there were any issues with the conduct of the assessment and did not identify any issues with the assessment process that was carried out.”
The ruling also noted the applicant did not appeal the clinical skills assessment results when she received them, despite having 30 days to do so.
“The Board further notes that the Applicant provided no insight into the three critical errors identified in the CSA, which were identified as impacting patient safety,” the ruling stated.
The board concluded the applicant had not demonstrated she has knowledge, skills and judgment equivalent to a graduate of an approved or accredited respiratory therapy program in Canada.
The Committee had recommended the applicant enrol in and complete an approved respiratory therapy program to fulfill the College’s registration requirements.
For more information, see Zaebakhsh v College of Respiratory Therapists of Ontario, 2025 CanLII 116842 (ON HPARB).
