Thank you, Mr. Chairman.
I have provided to the committee clerk a memo on this subject, which I understand has been distributed to members. I'll just speak briefly from that.
The Constitution Act, 1867, in sections 91, 92, and 93, divides legislative powers between the federal and the provincial levels. With respect to the foreign qualification process and foreign credential recognition program, three areas of legislative powers are affected: immigration, labour, and education.
Immigration was assigned to the federal government under subsection 91(25)—naturalization and aliens—and education was assigned to provincial governments under section 93 of the Constitution Act, 1867.
Labour has not been clearly assigned to either level. Although the Constitution Act, 1867, does not formally mention labour or employment, it has been interpreted to fall under subsection 92(13), “Property and Civil Rights”, or as a matter of a “merely local or private Nature in the Province”, under subsection 92(16), and therefore subject to provincial--not federal--jurisdiction.
Most of the legislative powers assigned under the Constitution Act,1867, are exclusive to either level of government. Neither level can legislate in an area assigned to the other. There can be exceptions, however, where the legislated provisions are necessarily incidental to an assigned area of jurisdiction. Labour legislation related to activities otherwise within federal jurisdiction--for example, federal crown corporations, banks, airlines, Indian reserves, telecommunications, and interprovincial transportation--is a valid exercise of federal legislative powers as “necessarily incidental” to the assigned areas of federal legislative jurisdiction.
Federal initiatives on foreign qualification recognition seem to be constitutionally legitimate, as they apply to immigration. In other words, their objective is to help immigrants who arrive in Canada with qualifications recognized by a foreign authority.
There is only one restriction on those initiatives: they must not interfere with matters that come under provincial constitutional jurisdiction, such as education or labour, unless, in the latter case, those initiatives are “necessarily incidental“ to federal immigration jurisdiction.
That's most of what I have to say, Mr. Chair.
I am available to answer any questions.
Thank you, Mr. Walsh, for coming this afternoon.
I am certainly a lawyer by profession, but I'm nowhere close to being an expert on constitutional matters. Being a first-generation newcomer, I was a law graduate from India when I came to Canada, and I did have to live with it for a few years. It's very complicated, as you said. Jurisdictional issues are complicated and very hard to understand as well, especially for a new Canadian.
We all know that on a skilled worker basis, we have all kinds of professionals coming to Canada. Unfortunately, due to these complications, most of them have to go through very rough and tough times. Also, quite a few of them basically are unable to achieve their profession after coming to Canada. When we talk about jurisdiction, it is clear that education is under provincial jurisdiction. At the same time, I was curious to hear your views on whether the federal government has any jurisdiction to make changes to the credential recognition process.
With reference to this particular program, my understanding is that it's an attempt by the federal government to, as it were, facilitate the process: to help the provinces and territories find common ground regarding what accreditation you need to be a doctor or a mechanic, or whatever the area or the field might be.
What more can the feds do than play maître d' to an ongoing discussion about this? I suppose in some areas—and, again, government officials can more capably address these questions for you—they could try to establish standards, and they could even establish their own accreditation system. They could say they recognize this fellow to be suitably qualified as an engineer, let's say, but they can't force the provincial governments to accept that. If the provincial regulatory agency set up by the provincial government doesn't find the person to have the appropriate qualifications, that's the end of the matter.
So if the federal government, for some reason or other, thought it might be helpful if they were to set up their own accreditation regime and make judgments and assessments and give certificates of one kind or another along those lines, if that would help, they might do that, I suppose, but they can't impose those accreditations on the provinces, and they can't, by virtue of those accreditations, in my view, give the individual the ability to carry on the practice of an engineer or a doctor in a province. The individual has to get provincial regulatory approval.
Yes, I would. I think the option available to the federal government is to do as you suggest, exercising what you call moral suasion, that is, trying to convince the provincial authorities that it's in their interest as much as in the federal government's interest to assist these immigrants to gain the appropriate qualifications.
But don't forget, I think you recognize that there may be some jurisdictions where persons are recognized as being qualified, whereas the local professional regulatory group don't think they are qualified. In some cases, that may be a sound judgment. In other cases, some might characterize it as job protection. In either case, the immigrant is unable to work.
Some of this I guess is unavoidable; it's in the nature of immigration. You could go to another country and not be able to work for other reasons--you can't speak the language or something. So there are hardships for everyone, there's no question about it. I understand that members of Parliament often are asked by constituents who are immigrants or second-generation immigrants, and they're trying to deal with that problem.
I think the resources available to the federal government, arguably, are more than moral suasion; they may have fiscal suasion. Then they will tend to advance their view and perhaps bring the provinces. But you see, even if you have one province on side, they've got to get all the rest on side to get the mobility aspect addressed. I would think it's a very complex matter. As urgent and as pressing and as worthy as the goal may be, it seems to me it's a very difficult area to deal with, although some progress has been made in the past because of the mobility rights under the Charter.
Nonetheless, Canadians want to be satisfied that when someone presents themselves as being qualified to do X, they are in fact qualified to do whatever it is they're being paid to do. So the regulatory authorities have to be careful that they maintain their standards appropriately.
Yes and no. There are complications with it.
Let's take my own field as a lawyer. Lawyers are provincially regulated. There is no federal bar that would approve my standing as a lawyer. The federal government hires lawyers, and they require the lawyers to be recognized and registered as lawyers in one of the provincial jurisdictions. If it were to decide it would have its own standards and certify an individual as being a lawyer for its purposes, but that individual had no recognition by any of the regulatory officials, that lawyer might not be terribly useful to them.
So it's a bit of an artificial question, because the individual has to work in a larger economic field than just the federal field. While it may theoretically be possible in some fields for the federal government to decide that this individual is going to work for us and only for us, so we'll decide whether he's qualified to fly a plane or not and don't need provincial authorities to tell us, there may nonetheless be other reasons why some recognition outside of the federal level should be obtained.
Going to that particular example of pilots—and I don't know for sure whether I'm right in saying this, so I again qualify what I'm saying, but I'm curious now and will double-check to see whether this is the case—it seems to me that if the airlines are federally regulated and provinces have no jurisdiction in regulating airlines, then yes, the federal government would have the ability to decide whether someone is qualified to fly a plane. So with some caveat, that makes sense to me, but I'd want to double-check to see whether the feds are actually doing this or have chosen to accept provincial control of that area too.
Mr. Walsh, it's always a pleasure to have you sit in on a committee. The committee always benefits from your counsel.
Let me get further elaboration concerning what our chair posed on federal-provincial jurisdiction and responsibility. I'll respect your vast expertise on the broad range.
Maybe I can set it up with a hypothetical case.
If, for example, somebody wanted to tow a ship that they wanted to salvage through Canadian waters and the federal government was responsible for processing the application, granting the permits, granting the licence, securing the bond, so it monitors it during the towing process, but it cuts loose at sea and ends up on the shore of an unfortunate province—this is just a hypothetical situation—and then the federal government washes its hands of it, what—I'll use Mr. Butt's comment—would a premier of this hypothetical province have besides moral suasion to make his federal partner play a role is disposing of this, let's say, 243-metre wreck?
Thank you once again, Mr. Chair.
Mr. Walsh, I would agree that specifically in our profession I have seen the change, and I'll answer some of my colleague's concerns also.
For a few years I had been trying to get into different universities in different provinces, and there were different standards. That obviously has changed now. As a lawyer you can virtually go to any province, and for a certain period you don't have to go through any requirements. You simply put your name in and you can pursue your profession, as far as the lawyers are concerned.
From all this discussion today, I want you to reconfirm my understanding that as far as recognition of foreign qualifications or evaluation is concerned, the federal government can take the leadership role by facilitating or assisting or encouraging the provinces and territories to get onboard and work together to recognize the foreign qualifications, but nothing more than that. They cannot force any province, any regulatory body, to follow suit, to recognize qualifications in any specific manner.
Is that my correct understanding?
I really want to try to understand this on a very practical level. I'm just looking at our witness list for the next hour. We have the Canadian Society for Medical Laboratory Science, the Royal Architectural Institute of Canada, and the Canadian Association of Medical Radiation Technologists.
Each area of a profession, in large part, not all—even in some distinct labour categories—generally has an association that represents them nationally; often they have an association that represents them provincially. What I'm hearing is that the federal government has little constitutional or separation of powers ability to influence significantly the outcomes for these immigrants as they come here. They are often more controlled by their professional association, be it engineers, doctors, bricklayers, construction workers--whomever.
Am I correct in thinking—I'm asking you to verify that I understand this conceptually—that all we can really do at the federal level is to assist these types of associations, which we're going to be asking questions of, as well as other groups, to get their house in order, get their regulatory schemes in order, so they can apply to a broader range of provinces, or perhaps the whole country, if they so undertake to do so?
Am I correct in thinking that way, or do they individually have to have agreements with the provinces as well to be part of that regulatory framework?
Prior to that role, I handled our certification and prior learning assessment portfolio, and integration of internationally educated medical laboratory technologists, or IEMlTs, continues to be my commitment and passion.
The CSMLS is the national professional association for over 14,000 medical laboratory professionals in Canada. We are also the national certification body that establishes the entry-to-practice requirements in consultation with the provinces and territories. We also offer the only national prior learning assessment program for our profession that is used in all jurisdictions, with the exception of Quebec. We have always done some form of recognition, however, and in 1999 the program became more robust, with the goal of providing fair, open, and transparent assessments of credentials, education, work experience, professional development, and language proficiency.
Since 1999, we have assessed over 2,000 files and certified more than 1,000 international medical laboratory technologists. Our program is unique in that each jurisdiction relies on the assessment and certification for entrance into the labour market. Our program has been reviewed and celebrated by agencies such as the Ontario Fairness Commissioner, the Manitoba Fairness Commission, HRSDC through the pan-Canadian framework for the assessment and recognition of foreign qualifications, and the Ontario Health Professions Appeal and Review Board.
The CSMLS thanks the Government of Canada for its sustained interest in investing in immigration to build on Canada's prosperity. Citizenship and Immigration Canada has a great responsibility in the recruitment and selection of newcomers to Canada, and HRSDC is there to help in the transition, whether it is offshore or in Canada. Programs like the FCRO and the pan-Canadian framework are important to the successful integration of newcomers.
The CSMLS has been fortunate enough to have had nine research and pilot projects supported from the HRSDC FCR program, and they have undoubtedly helped us create a program that is reliable, fair, and transparent, valued by regulators, fairness commissioners, and our profession.
Our HRSDC projects include:
• overview of best practices, identification of barriers for the clients and creation of a standardized assessment process;
• plain language review of all documents related to certification and prior learning assessment to ensure clarity in English and French;
• the business case for creating and sustaining bridging programs;
• loan libraries to remove access issues and costs for internationally educated technologists;
• the creation of a resource guide for IEMLTs to help address the gaps in experience and education in relation to the Canadian context of practice;
• the creation of an online self-assessment tool, also available offshore;
• the feasibility of creating a peer support network;
• investigation of factors enabling or impeding integration of five groups of internationally educated health professionals, two to seven years post-licensure and certification;
• and our newest project, the CSMLS self-directed bridging program.
We have also had language projects funded provincially, through MCI Ontario bridge funding:
• investigation of language assessment tools and benchmarks necessary for the success for internationally educated medical technologists;
• language proficiency testing for IEMLTs, validating cut scores and a new testing tool.
Each of these projects has facilitated the development and validation of a fair, open, and transparent prior learning assessment program. These projects have undoubtedly helped contribute to the CSMLS vision of creating a process that is evidence-informed, allowing for the best possible outcomes for the technologist, the profession, and the public. Like any robust research program, the CSMLS has several areas of further interest and eagerly awaits the outcomes of the peer support network and the five professions integration project, as there will undoubtedly be a list of recommendations that will further enhance the outcomes of our internationally educated technologists. We are also hoping to engage in another multi-profession project addressing common challenges.
We would like to applaud the HRSDC for their willingness to collaborate and negotiate new projects that will be of benefit to the CSMLS, the IEMLT, and, ultimately, the Canadian public. The application process is relatively seamless, and improvements have recently been made, allowing for the more timely sharing of documents for both HRSDC and the recipient.
We are fortunate to have a single point of contact for FCR applications at HRSDC and have appreciated the effort HRSDC has taken to better understand the complexity of my profession and the issues we face.
We meet annually with our HRSDC contact to discuss current and future projects. In fact, they seem to understand projects, challenges, and opportunities as well as I do. This leads to productive discussions that are dynamic, future-focused, and centred on improvement.
One of the biggest limitations we all face with grants funded by HRSDC is the lack of sustainability of the projects, as this is beyond the mandate of HRSDC. We encourage the Government of Canada to find a logical place for sustainability of these projects. We believe that HRSDC might benefit from the implementation of a post-project process that looks at sustainability. While the CSMLS does not enter into funding agreements for programs or processes that we cannot sustain, the failure of several regional bridging programs for internationally educated medical laboratory technologists suggests that this might help, as it would force grant applicants to have collaborative agreements in place long before a project ends, to ensure that a project will be sustainable.
Further, the CSMLS encourages the Government of Canada to consider credential evaluation or PLA as part of the immigration process, not something an immigrant tries to navigate once they arrive. We are excited about the outcomes of the CIIP projects in India, China, and the Philippines, and look forward to its expansion to the U.K.
We've seen the challenges of a process that allows a newcomer to self-declare their occupation with no actual validation of the claim. Verification would assist the government in determining fit, especially related to the professions on the preferred list for the foreign skilled workers, and allow the immigrant to better plan for their journey to Canada. It will allow them to make an informed choice in coming to Canada, determine the order of events they will undertake when they get here, and possibly alter their expectations on arrival.
We thank the government for their interest and action in the assessment and integration of immigrants to Canada. We sincerely hope investments continue to be made in this area, as the financial burden on associations and internationally educated professionals would be insurmountable were it not for the commitment of the Government of Canada.
My name is Jim McKee. I'm the executive director of Architecture Canada.
With me is Jill McCaw, project manager for the broadly experienced foreign architect project.
I'd like to mention that Saskatchewan architect Dave Edwards, chair of the broadly experienced foreign architect task force, would very much like to have been here today but couldn't be, as the meeting was held on fairly tight notice.
I'd like to thank the committee for the opportunity to report on the progress of our project, which is labelled BEFA for short. It's a project made possible by the foreign credential recognition program and one conceived to put in place an innovative new system for assessing the credentials of foreign-trained architects in a manner that is timely, fair, transparent, pan-Canadian, and rigorous in ensuring that Canadian standards for architectural practice are upheld.
The project is proceeding with the full backing of the Canadian architectural profession. Our partners, the provincial and territorial members of the Canadian architectural licensing authorities, CALA, share a commitment to put in place a new process for assessing the credentials of foreign-trained architects to be administered by the Canadian Architectural Certification Board. The project is currently in the pilot phase. Our target date to go operational is September 2012.
Under the current system, foreign-trained architects seeking to qualify for practise in Canada must be able to demonstrate educational qualifications equivalent to those specified by the Canadian educational standard. They have to find work with an architectural practice and accumulate 5,600 hours as an intern architect, and they have to write the Canadian qualification exam.
Three, four, or more years are required to complete this process. It can be unattractive to an architect already holding a broad range of experience who is well advanced in their career in their home country.
The reality is that we currently have a prescriptive certification system predicated on the vast majority of candidates entering the profession coming from accredited Canadian schools of architecture.
Moreover, the reality is that Canada needs more architects, not less. Like many professions, its membership is aging. Within ten years, 58% of Canadian architects will be above the age of 50. As this group transitions to retirement, one study has projected that we will face a shortfall of between 100 and 200 architects a year.
Our fundamental objective, then, is to develop and put in place an assessment system and interview process that results in more internationally trained architects being integrated into the system without in any way diluting or lowering Canadian standards of admission to the profession, the regulation of which exists to protect the public interest, notably public safety.
We are now well advanced in the development of this new system. It will include an online self-assessment component that will enable foreign-trained architects to begin the process of assessing their credentials vis-à-vis Canadian standards of practice while still in their home country.
To be clear, foreign-trained architects will still need to provide evidence of an architectural education, proof of licensure or its equivalent in their jurisdiction, as well as proof of broad experience, at least seven years, as a practising architect in their home country.
The fundamental focus of the new system, however, will be on testing for essential competencies required to perform as a qualified Canadian architect. These competencies have been identified after extensive work with assessment consultants and with practising architects.
The competencies have then been mapped out in a comprehensive matrix, which underlies the online self-assessment questionnaire that will be the starting point for any foreign-trained architect seeking to be certified and referred to the licensing authorities.
Once they've completed their self-assessment and uploaded supporting documentation, their file will be reviewed by a team of assessors. They will then be scheduled for a face-to-face interview, which we use to verify their competencies. This evaluation will be carried out by three Canadian architects trained as assessors.
The outcome of this process will be a decision that a candidate either qualifies directly for admission into the profession and will be directed to the designated provincial/territorial licensing body, or requires skill upgrading in certain areas in order to qualify for licensure, or does not have competencies required for licensure in Canada and should pursue alternative career paths.
Candidates who do meet the competency standards for practice in Canada have the potential to be licensed as an architect within a Canadian jurisdiction several years sooner than currently is the case. From the moment they finalize their self-assessment, candidates should be scheduled for a face-to-face interview and be advised of their results within one calendar year. A candidate licensed in any jurisdiction in Canada through this process will be able to pursue practice anywhere in the country.
With respect to required skills upgrading, I should add that the financial support provided by Human Resources and Skills Development Canada is also being committed to the development of online distance learning courses that will be offered through the RAIC Centre for Architecture at Athabasca University.
As was mentioned earlier, the new assessment system is in the pilot stage. The first pilot took place in Vancouver in March 2011, and two more are scheduled for January and March of 2012, including one pilot focusing on French language candidates. The system will be refined through these pilots prior to receiving final endorsement from provincial and territorial regulators. Again, our objective is to launch the system operationally in September 2012.
As we move forward, one issue that our provincial and territorial colleagues will be addressing with their governments is amendments, where required, to adapt the legislative framework for this new approach.
Much of the work remains ahead of us, but we have made significant progress to date, thanks in no small part to the strong support being provided to this project by all of the provincial and territorial regulatory bodies, the volunteer commitment of the BEFA task force membership, and the Canadian Architectural Certification Board.
We welcome the opportunity to provide you with additional information in the question and answer session.
Thank you very much, Mr. Komarnicki.
I am Chuck Shields. I am the CEO of the Canadian Association of Medical Radiation Technologists. With me is Giulia Nastase, the special projects manager in our office, who is looking after our work in the area related to internationally educated medical radiation technologists or, as you'll hear me referring to them, IEMRTs.
I will speak in English, but it would be our pleasure to answer any questions in French as well.
We are pleased to be working with HRSDC and Health Canada and have been working with them for several years to work with IMRTs, to help them be successful with the certification process and to enter practice in Canada.
I'd like to start by saying a little about us, as an association. We were founded in 1942. We are governed by a board of 14 members from across the country, representing every province and all disciplines.
The mission of the association is to serve and support members and to provide patients with the highest quality of medical imaging and radiation therapy care. CAMRT ensures that all medical radiation technologists are certified as having the knowledge, skills, and judgment to enter practice through the development of services and tools that help MRTs to continue to practise safely and effectively in a rapidly evolving field.
As the national voice for the profession, CAMRT is engaged internationally and promotes the effective contribution of MRTs in the Canadian health system discussions and decisions.
We have 12,000 members, of about 17,000 practitioners in the country. These are divided among four disciplines. This is important because our work involves MRTs from all four disciplines. One is radiographers, which includes CT technologists, mammographers, intervention radiographers, and those conducting general X-ray; radiation therapists, who are involved with cancer treatment; nuclear medicine technologists; and magnetic resonance imaging technologists.
MRTs are highly trained professionals who perform medical imaging and radiation-based therapy procedures. They work closely with radiologists and nuclear medicine physicians, who interpret the results of procedures, and with radiation oncologists, who direct radiation-based cancer treatment.
We have two primary roles as an association. First, we are the national certifying body. This we share with the Canadian Society for Medical Laboratory Science. Second, we are a professional association. As a certifying body, we develop the national entry-to-practice competency profiles, which are core to much of what we do. They are the basis for the examinations. They are the basis for the education programs for the profession. We also develop the certification exams, and we work closely with the provincial regulatory bodies.
As a professional association, we have an extensive continuing professional development program. We work on advancing professional practice and we have an advocacy program.
It was in our role as a certifying body that we noticed and became involved in working with internationally educated medical radiation technologists. Over the years, as we've worked with them, we've developed a conceptual framework that sees the task as a continuum—working with the IMRTs in their native countries as they are first considering emigration, from their point of view, all the way through the assessment preparation and the certification process to their successful integration into the Canadian health system.
We've been fortunate to have a series of projects funded by HRSDC. The first one was completed in 2006 and was titled “A Situational Analysis and Recommendations for Internationally Educated Medical Radiation Technologists”. In that project we collected supply and demand information for the profession related to the profession overall and IMRTs. We evaluated the assessment and certification processes and identified challenges and barriers. There were 22 recommendations that were published in that report, and to date we have acted on and implemented 19 of them.
Phase two built on the first project and was titled “Leading The Way: Ensuring an assessment and certification process that is fair, efficient, and valid for international applicants”. In that project we developed preparation guides and practice exams for all four disciplines. They are available online and have been accessed by over 1,700 IMRTs to date.
We also conducted research regarding the exam performances of IMRTs to identify areas where they had difficulty, and we worked with stakeholders from around the country to identify national guidelines for bridging programs.
The work on that project led to a third one, which we are now in the process of wrapping up. It started in 2009 and goes to the end of this year. One component of it is entitled “National Guidelines for the Assessment of Credentials of IMRTs”, and the second is “Education Upgrading and Exam Preparation Courses”. In the national guidelines, we have worked with regulators at the provincial level and provinces to develop credential assessment guidelines that address language proficiency, education programs, and work experience. In the education upgrading area, we focused and used the research we had done in the previous project to identify and develop three online courses, which are nearing completion, that get at 70% of the content area where IMRTs have difficulty.
Once these are in place and available online, it should be noted that these will be available to be taken by the IMRTs when they are in their home country, even before they move to Canada, should they decide to do that.
We also have a project in the proposal stage entitled “Education upgrading and exam preparation courses: Delivery and testing of online exam preparation courses”. This will use those three courses, offer them free of charge for three years, gather information, and analyse how effective they are in helping IMRTs.
We will also develop a competency-based exam module, because our exams are competency-based and that often is difficult for IMRTs who aren't trained in that way. We will also be developing a module to assist IMRTs in entering employment in Canada.
We've also been fortunate to receive support from Health Canada. One of these was a project that is very near to ending completion at the end of this month. That is called “Online Readiness Self-Assessment tools”. You will hear some commonalities between our different organizations. This one is providing an overview of life and practice in the profession in Canada. It provides the IMRT with more information to make an educated decision about immigration and whether to apply for certification in Canada.
I'd like to move now to talk briefly about our experience with the foreign credential review program funding. In a couple of words, I'd say it's been a very positive experience. We find that the process has been straightforward. The application, templates, and forms are available and easy to use. They also provide support in working with our staff in proposal development and review. We find the staff is knowledgeable and involved. They're able to advise, provide support to us, and they're flexible in managing the scope of the project. We also find that the reporting requirements are clear.
As far as the impact of the funding, as a small organization, we would not have been able to do the work we've been able to do had we not received the support from HRSDC and the funding from Health Canada. It is crucial. It helps us provide programs that get to the needs of IMRTs. It assists IMRTs, but also there is an overflow impact and benefit for Canadians. Employers are assisted by having IMRTs who can move into employment situations more easily. The general public and patients are assisted by enhancing and ensuring that the IMRTs are able to practise safely. Canadian-educated medical radiation technologists have been able to use many of the same tools to great benefit. We've been finding them to be quite positive.
That's a great question. There are very few professions that asses on a national level. That's where we run into some challenges, especially related to the agreement on internal trade. And we run into licensing barriers. In the past, one has been licensed in one jurisdiction and not accepted in another.
In our opinion, the ideal model is something that was given to the Canadian society by its provincial partners years ago. Because of the size, no single province had the capacity to do the assessments alone. Quebec still looks after its own, but everyone else entrusted the national organization, which is my society, to do this work for them.
We're under contract. We have agreements. They've all set the standards in consultation and collaboration. So we literally have a process that allows everyone to be assessed in Canada, whether they're arriving in New Brunswick or Ontario. And each of the regulators agreed to the standard. So when they've been assessed by my agency and they've been certified by my agency, it's carte blanche for them to work anywhere in Canada, with the exception of Quebec.
It was partially answered with that.
First, it was very good to hear you speak well about how you've got to where you are today with these programs and how the federal government has assisted you in getting there. But there's always politics involved here, and you've obviously dealt with different provinces having different requirements and different mandates. As well, I would think there's probably some politics within the profession itself, with some people receptive to this approach and others who would say, well, no, we've got to be a little more protective of our space here.
Could you share any insights, having gone through the process so far?
I might just put my thoughts to this. If you can get, as Christine's association has, a national buy-in from right across the country, it seems to me to be a highly efficient way to go. It would be self-governing really, without the government being involved at all or only involved on a very minor basis.