Abstract

Introduction This article provides a comparative analysis of recent reform to the health profession regulatory frameworks in three jurisdictions: Australia, the United Kingdom, and Ontario, Canada. Aims The goal of this study was to present case studies on the reform in each jurisdiction and provide cross-case comparisons and analysis. Method A comparative multiple case study analysis was conducted to identify the factors influencing reform and underlying aspects to current reform proposals. Policy documents and legislation were analyzed using qualitative content and thematic analyses. Results In Australia, the desire for national uniformity needed to be balanced against achieving adequate accountability. In the United Kingdom, the primary struggle was between balancing appropriate autonomy and flexibility for the health profession regulators with legislated consistency. In Ontario, the government has been increasingly willing to step into areas traditionally within the self-regulatory ambit. Common themes existed across the reforms: a shift in each jurisdiction towards a more overt primacy of the public interest over professional interests, greater independence of regulation from the professions, a push towards collaboration and consistency between professional regulators, and a focus on articulating principles to aid in assessing regulatory quality. Conclusion These findings allow regulators and policymakers to understand the factors and forces that influenced these divergent reforms and the common underlying themes contributing to reform proposals internationally.

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