Aaron Johnston

Comments: The document is challenging to read in the absence of reading the references and the listed companion document. My obligations as a regulated member regarding the 3 listed areas are not completely clear to me having read the document. Although I am familiar with the CPD requirements I am not familiar with the general assessment and competency assessment requirements and not sure if these are regular annual obligations as a member or if these are areas focused on members with an identified difficulty? Members are advised that "Details on how to fulfill the requirements below can be found in the Continuing Competence Program Manual." This Continuing Competence Manual seems to be a key companion document but I am unable to find this on the CPSA website. If it is a part of the standard it will need to be easily available to regulated members as an issue of knowing and following the standard. It is challenging to review this standard without reference to this companion document and I suggest linking it in the request for comments. In general I do not favour reference to secondary documents in standards of practice. There is a well established and publicized process for regulated members to be aware of any changes to the standards of practice, but a secondary document could be changed or updated, changing the obligations of members, without members being aware. Although this would allow the college to be more nimble, for example requiring CPD on a specific and important emerging topic the risk of inadvertent member non-compliance is, in my opinion, too great. (I also think that the recent use of linking an activity to the permit renewal likely means that this is not required.) Reference is also made to the CFPC Mainpro requirements document. A weakness of this CFPC document is the very vague way that it addresses leaves of absence from practice on an individual and ad hoc basis (contact the CFPC to discuss). I think that this can disadvantage individuals who are already potentially vulnerable and would prefer to see the interface of CPD and leave of absence (e.g. parental leave, illness and caregiver leave) explicitly addressed in the CPSA document. These comments are intended to be constructive and to assist the CPSA in the creation of a robust and easy to understand standard of practice.

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