Study of Registration Practices of the
COLLEGE OF OPTICIANS OF ONTARIO, 2007
ISBN 978-1-4249-6468-0 [HTML English version]
The Office of the Fairness Commissioner (OFC) undertook a study of registration practices of Ontario's regulated professions during the fall and winter of 2007–2008. The purpose of the study was to understand each regulated profession's 2007 registration practices and to establish baseline data and information to enable the OFC to measure progress as it fulfills its mandate under the Fair Access to Regulated Professions Act, 2006.
This report reflects the registration practices of the College of Opticians of Ontario as of December 31, 2007. Information in this report was gathered from:
face-to-face meetings with registration staff of the regulatory body
additional documentation provided by the regulatory body
relevant websites
career maps for the profession posted on the Ministry of Citizenship and Immigration's website (where applicable).
The College of Opticians of Ontario also provided registration information and statistics for 2005, 2006 and 2007 through a standard spreadsheet designed by the OFC.
An analysis and summary of the findings for all of the regulated professions is contained in the OFC's Ontario’s Regulated Professions: Report on the 2007 Study of Registration Practices.
The practice of opticianry in Ontario is governed under the Regulated Health Professions Act 1991 and the Opticianry Act 1991.
The protected title regulated by the College of Opticians of Ontario (COO) is “optician.”
Opticians are health professionals trained to supply, prepare and dispense optical appliances; interpret prescriptions prepared by ophthalmologists and optometrists; and fit, adjust and adapt optical appliances. In some jurisdictions in Canada, opticians are also known as ophthalmic dispensers.
As of November 2007, almost all graduates are employed and there is a need in the province for more opticians. Approximately 98 per cent of the graduates from Georgian College are finding placements in the field. Less than 1 per cent of graduates are not practising.
Sixty-one per cent of opticians in Ontario are over 40 years of age and 50 per cent are over 50.
The market for eye care has increased due to a larger aging population needing glasses and contact lenses. Since the fall of 2007, members of the college have been allowed to perform refractions (measuring focal anomalies of the eye). This requires additional training that opticians can take through Georgian College and Seneca College in Ontario or through the Northern Alberta Institute of Technology.
Another new development is that laser surgery centres are now hiring opticians to perform pre- and post-surgery care.
The staff of the college consists of nine full-time employees, one part-time and one contract employee. There are four staff – the Registrar, the Director of Professional Programs and two registration coordinators – involved in the registration process.
Certificates of registration are issued for the following registration classes:
Opticians
Intern Opticians
Student Opticians
Registered opticians are authorized to dispense, fit and adjust eyeglasses, contact lenses or subnormal-vision devices based on the prescription of an optometrist, ophthalmologist or medical doctor. Ontario does not have separate licensing for eyeglasses and contact lenses.
Registered intern opticians and registered student opticians are authorized to dispense eyeglasses, contact lenses or subnormal-vision devices only under the supervision or direction of a registered optician, optometrist or ophthalmologist who is physically present during the dispensing.
Every person practising in Ontario as an optician, student optician or intern optician must be registered with the College of Opticians of Ontario. Failure to register is a significant offence and can result in disciplinary action or prosecution. Penalties can include fines of up to $25,000, in addition to a range of other remedies available to the court.
All applicants for registration must:
Provide details of any conviction for a criminal offence or an offence related to the practice of opticianry, a finding or a current proceeding for professional misconduct, incompetence or incapacity in Ontario or any other jurisdiction
Have Canadian citizenship, permanent resident status, or authorization to work under the Immigration and Refugee Protection Act
Be able to speak and write English or French with reasonable fluency
Pay the required registration fee
In addition, an applicant must meet the following non-exemptible registration requirements for a certificate of registration as an optician:
successful completion and graduation from one of the recognized opticianry programs, or from a program that is deemed equivalent
or
the ability to satisfy the Registration Committee (by undergoing an assessment of prior learning and experience) that he or she has a level of knowledge and skill in the practice of opticianry that is equivalent to that acquired by graduates of recognized opticianry programs and
successful completion of the registration examinations approved by the Council of the College of Opticians and
successful completion of at least 1,000 hours of verified dispensing experience.
To obtain and keep a certificate of registration, a student optician must be enrolled in an approved Ontario opticianry program or be in the process of completing additional training as ordered by the Registration Committee.
To obtain a certificate of registration as an intern optician, the applicant must have successfully completed and graduated from an approved opticianry program or have completed any additional training as ordered by the Registration Committee. A registered intern optician is eligible to sit the National Registration Examinations.
Applicants seeking registration as opticians in Ontario who have been educated and/or licensed outside of Canada must first submit a written request to the college. An application package will be provided requesting that applicants submit the following information:
information about their professional background
information about any successfully completed licensing examination that allowed them to practise in their home country (if applicable)
information about dispensing experience and number of fittings
an assessment of academic credentials and a comparison to Ontario educational standards from World Education Services (WES) or University of Toronto, Comparative Education Service (CES). A course-by-course evaluation is required. (The cost of the assessment is the responsibility of the applicant.)
copies of any documents submitted to WES or CES and detailed descriptions of the program of study (total number of lecture hours, course objective and format, method of evaluation, etc.)
information about proficiency in English or French. If the applicant’s primary language is not English or French, and if the applicant graduated from a school/university where the language of instruction was not English or French, the applicant must demonstrate reasonable fluency by achieving an acceptable score on a test of language proficiency (see 3.g below).
The Registrar refers completed applications to the Registration Committee, which considers applicants’:
international education
professional experience
license to practise in their home country
licensing examination that enabled them to practise in their home country
continuing education
other pertinent information relating to registration as an optician in Ontario
After consideration of all submitted materials, the committee will make one of the following four decisions:
Request that the applicant undergo an assessment of prior learning and experience. This is done by way of assessment testing, which verifies that the applicant’s current level of knowledge and skill in the practice of opticianry is comparable to that of applicants educated in Ontario. Should the applicant be successful at the assessment test, he or she can write the National Registration Examinations. Upon successful completion of these examinations, the applicant is eligible to apply for a certificate of registration as an optician.
Advise an unsuccessful assessment test candidate to undertake additional training and to apply for a certificate of registration as a student optician.
Direct the applicant to write the National Registration Examinations. This decision allows the applicant to apply for a certificate of registration as an intern optician. Upon successful completion of the examinations, the applicant is eligible to apply for a certificate of registration as an optician.
Refuse to issue a certificate of registration to the applicant.
Successful completion of the National Registration Exams (National Eyeglasses Exam and National Contact Lens Exam) is mandatory for all internationally trained opticians who wish to practise as opticians in Ontario.
At the time of registration, the applicant must be a Canadian citizen or landed immigrant or must hold a valid employment authorization.
Internationally trained applicants must make every effort to submit the necessary documents to prove their academic credentials and professional experience. If the documents are not available/destroyed, the applicants may submit a signed undertaking or declaration.
The COO uses World Education Services (WES) and the University of Toronto Comparative Education Service (CES) to evaluate and authenticate the credentials of internationally educated opticians. The National Association of Canadian Optician Regulators (NACOR), an interprovincial association that monitors and investigates common issues related to accreditation and mobility of opticians, does not currently provide any type of credential assessment, but it is developing an accreditation process for Canadian opticianry educational institutions.
Applicants seeking registration as opticians in Ontario must have a diploma in opticianry from an educational institution that is recognized by the College of Opticians of Ontario.
After graduating, applicants must pass the National Registration Exams (National Eyeglasses Exam and National Contact Lens Exam) before being eligible to register with the College of Opticians of Ontario and call themselves registered opticians.
To obtain a certificate of registration as an optician, the applicant must be registered as an intern optician and have completed both of the following requirements:
250 eyeglasses fittings, including 100 multifocal fittings and 25 high myopic or hyperopic fittings under the supervision or direction of a registered optician, an optometrist or an ophthalmologist
and
20 contact lens fittings, including at least five rigid gas-permeable contact lens fittings under the supervision or direction of a registered optician who is a certified contact lens fitter or a contact lens mentor (for rigid or soft contact lens fittings), or an optometrist or ophthalmologist.
In November 2003, the College of Opticians of Ontario deemed the National Registration Examinations (combined National Eyeglasses Exam and National Contact Lens Exam), administered by the National Association of Canadian Optician Regulators (NACOR), to be equivalent to the COO’s Registration Examination. NACOR developed the national eyeglass and contact lens exams as a way of measuring the competencies of persons seeking entry to practise as opticians. The objective was to develop an examination that would be accepted across Canada.
The option to attempt the College of Opticians Registration Examination still exists for the students who enrolled in the opticianry program at either Seneca College or Georgian College prior to the Fall 2004 academic year. Students enrolled for the first time since the Fall 2004 academic year are permitted to attempt only the National Registration Examinations upon graduation. Once all currently eligible students have been through the examination process (including any required supplemental attempts), the College of Opticians Registration Examination will cease to be offered.
A candidate is entitled to attempt the national exams a maximum of three times within a three-year period. After the third attempt, the candidate must complete an upgrading program approved by the Registration Committee of the College of Opticians of Ontario before any further attempt of the examination will be permitted.
For candidates who wish to be registered in Ontario, the COO determines the eligibility to attempt the national exams. Candidates from other provinces who want to attempt the national exams in Ontario may do so, but they must seek permission from their home province and meet its eligibility requirements. Out-of-province candidates who successfully complete these examinations in Ontario can apply for registration in their home province.
In order to become eligible to attempt the National Registration Examinations, a recent graduate of an opticianry program in Ontario (Georgian College and Seneca College) must:
ensure that the College of Opticians has received written confirmation from the teaching institution that all of the requirements for graduation have been met
and
be a current registered intern optician and have completed 1,000 hours of verified dispensing experience.
The COO will confirm eligibility to attempt the exams only after it has received this information.
When the COO receives verification from NACOR that an applicant has passed both the National Eyeglass Examination and National Contact Lens Examination, it sends the applicant a letter and an application form for a Certificate of Registration as an Optician. The letter states the fees the applicant must pay to register and lists the documents that must be provided.
If their opticianry education was not completed in English and English is not their primary language, internationally educated applicants must pass one of the following proficiency exams:[1]
Test of English as a Foreign Language (TOEFL) with a minimum score of 550 on the paper-based test and of 220 on the computer-based test, and the Test of Spoken English with a minimum score of 50
Canadian Language Benchmarks with a minimum score of 7
Michigan English Language Assessment Battery with a minimum score of 85 and 50 on TSE
International English Testing System with a minimum score of 7.
| Type of fee | Amount (including GST) |
|---|---|
|
Registration – Student Opticians and Intern Opticians[2] |
$110.24 |
|
Renewal – Student and Intern Optician[3] |
$109.18 |
|
Registration and renewal – Optician [4] |
$745.18 |
|
Duplicate Certificate of Registration |
$53.00 |
|
Duplicate photographic identification badge |
$53.00 |
|
Replacement Registration Certificate decal |
$10.60 |
|
Replacement photographic identification badge decal |
$10.60 |
|
Duplicate tax receipt |
$5.30 |
|
Letter of Good Standing |
$10.60 |
|
Declined credit card |
$42.40 |
|
NSF cheque |
$42.20 |
|
Incomplete registration applications/renewal forms |
$26.50 |
|
Duplicate Certified Contact Lens Fitter Certificate |
$53.00 |
|
Continuing Education certificates (per certificate) |
$0.27 |
|
Quality Assurance Committee review of continuing education activity |
$14.79 |
|
Quality Assurance Committee "Rush" review of continuing education activity (requests for review received less than 45 days prior to the activity date) |
$147.87 |
|
Late fee – Student/Intern Opticians |
$53.00 |
|
Late fee - Optician |
$132.50 |
|
Assessment test [5] |
$318.00 |
|
File review by the Registration Committee of applications referred by the Registrar |
$530.00 |
Fees to write the National Eyeglasses Examination and the National Contact Lens Examination are $600 per exam. The College of Opticians does not collect these fees; all payments are made directly to NACOR.
| Name of Third Party | Relationship to Regulatory Body |
|---|---|
|
National Association of Canadian Optician Regulators (NACOR) |
Administers the National Eyeglasses Examination and the National Contact Lens Examination |
|
U of T Comparative Education Services (CES) |
Assesses international credentials |
|
World Education Services (WES) |
Assesses international credentials |
How long the registration process takes depends on whether an application contains all the necessary information and documentation. The Registration Committee meets once a month and complete applications are reviewed at the next scheduled Registration Committee meeting. In the event that a meeting will not occur within six weeks of an application being completed, the committee may hold a special meeting strictly for the purpose of reviewing the application. It can take two or three meetings before the application review is completed if more information is required. After registration is approved, it takes up to five business days to notify the applicant of the committee’s decision.
Georgian College in Barrie, Ontario (two-year full-time program) and Seneca College in Toronto, Ontario (four-year part-time program) offer opticianry programs that are recognized by the College of Opticians of Ontario and approved by the Ontario Ministry of Training, Colleges and Universities.
These programs comply with the COO’s entry-to-practice competencies and professional standards.
Upon the Registrar’s referral, the Registration Committee reviews and assesses the qualifications to practise opticianry in Ontario of applicants from around the world and across Canada who do not fulfill the requirements to be issued a certificate of registration. The Registration Committee can make an order directing the Registrar to do one of the following:
Issue a certificate of registration
Issue a certificate of registration if the applicant successfully completes additional training or examinations
Impose specified terms, conditions and limitations on a certificate of registration
Refuse to issue a certificate of registration.
The committee is also responsible for assessment testing and for requests for a review of failed sections of the College of Opticians Registration Examinations. Requests for a review of failed sections of the National Eyeglasses or Contact Lens exams are handled by NACOR.
The Registration Committee is composed of at least two members of the Council who are members of the college (optician members) and at least one member of the Council appointed to the Council by the Lieutenant Governor in Council (public member). In 2007, the Registration Committee had three optician Council members and two public members.
Applicants who are dissatisfied with the Registration Committee's decision to deny or attach terms, conditions or limitations to a certificate of registration can request that the committee review the file once again. If they are not satisfied with the results of this second review, they can appeal for either a review or for a hearing before the Heath Professions Appeal and Review Board (HPARB). This board will review, in private, the decision and the documents considered by the Registration Committee.
The applicant does not appear at the HPARB review, and no representation is made on his or her behalf. The HPARB hearing, however, is a quasi-judicial process and the applicant can attend and make representations before the panel, as can representatives of the Registration Committee.
The HPARB has the power to rule in one or more of the following ways:
It can confirm the decision of the Registration Committee.
It can require the Registration Committee to make an order directing the Registrar to issue a certificate of registration to the applicant if the applicant passes an examination specified by the Registration Committee or successfully completes any additional training specified by the committee.
It can require the Registration Committee to make an order directing the registrar to issue a certificate of registration to the applicant subject to any terms, conditions or limitations the Board considers appropriate.
It can require the Registration Committee to give further consideration to the application in light of any recommendations that the board might make.
There are no formal bridging programs for internationally trained opticians. Seneca College and Georgian College have informal programs that can be tailored to individual needs at the request of the Registration Committee.
The COO’s partnerships with opticianry regulators across Canada have led to the development of a mutual recognition agreement to allow more labour mobility for opticians who meet specific criteria. Nine of the ten provincial authorities have now signed the agreement: British Columbia, Alberta, Saskatchewan, Manitoba, Ontario, New Brunswick, Nova Scotia, Prince Edward Island, and Newfoundland and Labrador.
Under the agreement, an applicant for a certificate of registration as an optician who at the time of applying is licensed or registered, and in good standing, in another province or territory of Canada to dispense both eyeglasses and contact lenses will be accepted for registration, provided he or she meets the general registration requirements.
An applicant for a certificate of registration as an optician who, at the time of applying, is licensed or registered, and in good standing, in another province or territory of Canada to dispense eyeglasses but not contact lenses, will be issued a certificate of registration as a student optician upon enrolling in the Northern Alberta Institute of Technology’s (NAIT) contact lens program[6] or in the required contact lens courses at Georgian College or Seneca College. Neither Seneca College nor Georgian College offers a separate contact lens program, but both institutions will tailor a contact lens program for candidates at the request of the Registration Committee. Upon successful completion of a contact lens program, the applicant is eligible for a certificate of registration as an intern optician, after which he or she can write the National Contact Lens Examination. If the applicant is successful on the exams, he or she is eligible to apply for a certificate of registration as an optician.
There is frequent contact with applicants, usually by e-mail or by telephone.
There is no backlog in the registration process at this time.
The COO attempts to address any complaints regarding the registration process in an informal and friendly manner. All applicants first speak with the Coordinator of Registration. If there is a complaint that the co-coordinator cannot handle, the person gets transferred to the Director of Professional Programs and the Director will deal with the issue. If the Director can’t help, the applicant may contact the Registrar, or the Deputy Registrar should the Registrar be away. The COO has never had a complaint regarding the registration practices that they were not able to handle at one of these levels.
The Ministry of Citizenship and Immigration conducted a survey in 2005 to collect information about occupational regulatory bodies in Ontario. A new development since that time is that the college now offers assistance to applicants upon request, including a detailed explanation of the registration process, help reviewing documents for completeness, and help filling out the application forms. Applicants can also make appointments to meet directly with Registration Coordinator or Director of Professional Programs.
If the COO identifies gaps in an applicant’s program, it works with the colleges offering opticianry to provide specifically tailored programs.
The college does not have a career map, but its website contains flowcharts of the registration process.
On September 25, 2007, the Council of the COO voted in favour of a motion to adopt a Standard of Practice for Refraction for Opticians in Ontario. This decision came after a draft of the standard was circulated among stakeholders for their comments. The Standard of Practice reflects a strongly collaborative model of practice in that opticians who perform refraction must work with practitioners who are authorized to prescribe eyewear.
The standards approved by Council set out specific mandatory criteria, including but not limited to education and continuing education. A package of materials including an application form will be mailed out to all Ontario opticians in the near future. It is important to note that the publication of the Standard of Practice approved by Council and receipt of this package in themselves do not permit opticians in Ontario to refract. Opticians who wish to refract in accordance with the Standard of Practice must apply to the college and satisfy all the requirements before they perform refraction.
Definitions used in these tables:
Alternative class of licence: a class of licence that enables its holder to practise with limitations; additional registration requirements must be met in order to be fully licensed. Alternative classes of licence granted by the College of Opticians of Ontario are specified under the tables below.
Applicant: an individual who has applied to start the process for entry to the profession.
Applicant actively pursuing licensing: an applicant who had some contact with the College of Opticians of Ontario within the year specified.
Inactive applicant: an applicant who had no contact with the College of Opticians of Ontario within the year specified.
Member: an individual who is currently able to use the protected title or professional designation of “optician.”
| Language | 2005 | 2006 | 2007 |
|---|---|---|---|
| English |
Yes |
Yes |
Yes |
| French1 |
Yes |
Yes |
Yes |
| Other(s)2 |
|
|
|
1 French materials available on request only.
2 Assistance may be available to applicants from Serbia, Croatia, Bosnia and Macedonia, etc. on request.
| Applications received | 2005 | 2006 | 2007 |
|---|---|---|---|
| Largest number |
Iran |
Iran |
United Kingdom |
| Second-largest number |
India |
India |
South Africa |
| Third-largest number |
Philippines |
United States |
Netherlands |
| Fourth-largest number |
Colombia |
United Kingdom |
|
| Fifth-largest number |
Germany |
South Africa |
|
| Number of staff | 2005 | 2006 | 2007 |
|---|---|---|---|
| Involved in registration process1 |
3 |
3 |
4 |
| Involved in appeals process |
1 |
1 |
1 |
1 The Director is involved in both the registration and the appeals process.
| Members | Ontario | Other Canadian Provinces | USA | Other International | TOTAL |
|---|---|---|---|---|---|
| Total members |
2,505 |
129 |
2 |
23 |
2,659 |
| Non-practising members1 |
8 |
2 |
0 |
2 |
12 |
1 A non-practising member can change status to practising member at any time.
|
|
Jurisdiction where members were initially trained in opticianry (before they were granted use of the protected title or professional designation in Ontario) | ||||
|---|---|---|---|---|---|
| In 2005 (Jan. 1 to Dec. 31) | Ontario | Other Canadian Provinces | USA | Other International | TOTAL |
| New applications received |
193 |
15 |
1 |
12 |
221 |
| Applicants actively pursuing licensing |
191 |
14 |
1 |
6 |
212 |
| Inactive applicants |
2 |
1 |
0 |
6 |
9 |
| Applicants who met all requirements and were authorized to become members but did not become members |
0 |
0 |
0 |
0 |
0 |
| Applicants who became members1 |
90 |
13 |
1 |
0 |
104 |
| Applicants who were authorized to receive an alternative class of licence2 but were not issued a licence |
0 |
0 |
0 |
0 |
0 |
| Applicants who were issued an alternative class of licence2 |
101 |
1 |
0 |
3 |
105 |
1 Some of these members initiated their applications in earlier years.
2 Alternative classes are student optician (enrolled in an opticianry program; can dispense under direct supervision of a registered optician, optometrist or physician) and intern optician (graduated from an opticianry program and preparing to write the National Registration Examinations; can dispense under direct supervision of a registered optician, optometrist or physician).
|
|
Jurisdiction where members were initially trained in opticianry (before they were granted use of the protected title or professional designation in Ontario) | ||||
|---|---|---|---|---|---|
| In 2006 (Jan. 1 to Dec. 31) | Ontario | Other Canadian Provinces | USA | Other International | TOTAL |
| New applications received |
189 |
44 |
1 |
17 |
251 |
| Applicants actively pursuing licensing |
187 |
41 |
1 |
11 |
240 |
| Inactive applicants |
2 |
3 |
0 |
6 |
11 |
| Applicants who met all requirements and were authorized to become members but did not become members |
0 |
0 |
0 |
0 |
0 |
| Applicants who became members1 |
95 |
29 |
0 |
6 |
130 |
| Applicants who were authorized to receive an alternative class of licence2 but were not issued a licence |
0 |
0 |
0 |
0 |
0 |
| Applicants who were issued an alternative class of licence2 |
92 |
12 |
1 |
3 |
108 |
1 Some of these members initiated their applications in earlier years.
2 Alternative classes are student optician (enrolled in an opticianry program; can dispense under direct supervision of a registered optician, optometrist or physician) and intern optician (graduated from an opticianry program and preparing to write the National Registration Examinations; can dispense under direct supervision of a registered optician, optometrist or physician).
|
|
Jurisdiction where members were initially trained in opticianry (before they were granted use of the protected title or professional designation in Ontario) | ||||
|---|---|---|---|---|---|
| In 2007 (Jan. 1 to Dec. 31) | Ontario | Other Canadian Provinces | USA | Other International | TOTAL |
| New applications received |
205 |
63 |
0 |
7 |
275 |
| Applicants actively pursuing licensing |
199 |
58 |
0 |
5 |
262 |
| Inactive applicants |
6 |
5 |
0 |
2 |
13 |
| Applicants who met all requirements and were authorized to become members but did not become members |
0 |
0 |
0 |
0 |
0 |
| Applicants who became members1 |
73 |
47 |
0 |
1 |
121 |
| Applicants who were authorized to receive an alternative class of licence2 but were not issued a licence |
0 |
0 |
0 |
0 |
0 |
| Applicants who were issued an alternative class of licence2 |
126 |
11 |
0 |
2 |
139 |
1 Some of these members initiated their applications in earlier years.
2 Alternative classes are student optician (enrolled in an opticianry program; can dispense under direct supervision of a registered optician, optometrist or physician) and intern optician (graduated from an opticianry program and preparing to write the National Registration Examinations; can dispense under direct supervision of a registered optician, optometrist or physician).
College of Opticians of Ontario website. http://www.coptont.org/. Last accessed: February 25, 2008.
National Association of Canadian Optician Regulators (NACOR) website. http://www.nacor.ca/. Last accessed: February 14, 2008.
Northern Alberta Institute of Technology (NAIT) website. http://www.nait.ca/. Last accessed: February 2008.
Representatives of the College of Opticians of Ontario met with staff of the Office of the Fairness Commissioner on January 21, 2008, to provide further information for this study.
[1] The college’s current language proficiency policy does not specify an exam to test a candidate’s proficiency in French. The Registration Committee is planning to amend this policy in the near future.
[2] Renewal as a Student Optician or Intern Optician is from September 1 to September 1 of each year.
[3] Applications for renewal for Student Opticians and Intern Opticians are mailed by July 1 of each year to the member’s last known address.
[4]The Optician registration period runs from January 1 to December 31. Registrants are required to renew their certificates of registration on an annual basis. Registrants will normally receive their annual registration renewal application in the mail on or before October 31. Registrants must submit a completed renewal form along with supporting documentation and payment.
[5] This fee applies to the assessment of internationally trained applicants by the Registration Committee.
[6] The contact lens program is a two-year independent study program offered through continuing education, and distance and online learning. In addition to the two years of theory, a further four levels of practicum are required. Practicum consists of on-the-job training, similar in nature to an apprenticeship, and is necessary as part of the clinical component of the program. Five hundred hours of practicum performed under direct supervision are required.