Manitoba Association of Health Care Professionals v Shared Health
Kristin L. Gibson, Arbitrator — April 14, 2026

Does an internationally trained health professional’s additional education entitle them to an academic allowance under the collective agreement, or does that education simply represent what was required to qualify for the position in the first place? In Manitoba Association of Health Care Professionals v Shared Health, 2026 CanLII 41505 (MB LA), Arbitrator Kristin L. Gibson dismissed the grievance, finding the additional credentials had not been shown to exceed what was needed to qualify.

Background

The grievor was an internationally trained Occupational Therapist who obtained her diploma in Nigeria and her bachelor’s degree in Occupational Therapy in India. To practise in Manitoba, her credentials were assessed by the Association of Canadian Occupational Therapy Regulatory Organizations (ACOTRO) through its Substantially Equivalent Assessment System (SEAS), which found them substantially equivalent to a Canadian degree but required some additional “gap-filling” education.

Schedule B of the collective agreement provides an academic allowance for qualifications that meet three conditions: (1) from an accredited institution, (2) relevant to the position, and (3) NOT a “qualification for the position.” The first two conditions were conceded. The dispute focused entirely on the third: whether the grievor’s master’s degree and additional qualifications exceeded what was required to qualify as an OT in Manitoba.

The Decision

Arbitrator Gibson distinguished the case from a 2015 decision (by the same arbitrator) involving Canadian-trained Occupational Therapists who held post-entry master’s degrees clearly beyond what was needed to qualify. In that case, the additional degree was plainly above and beyond the entry-to-practise standard.

Here, the grievor’s path to qualification as an OT in Manitoba necessarily included additional education to bridge the gap identified by ACOTRO. The arbitrator found the grievor had not demonstrated that her additional credentials exceeded what was required for her to qualify for the position in Manitoba. In other words, the extra education was the price of admission—not a bonus beyond it. The grievance was dismissed.

Key Takeaway

Collective agreement language must be read carefully in the context of internationally trained professionals whose path to qualification is different from domestic graduates. Academic allowance provisions that exclude “qualifications for the position” will capture the additional education internationally trained workers need to meet Canadian equivalency standards. Employers and unions dealing with internationally trained health professionals should be clear about where the line falls between qualifying credentials and genuinely supplementary academic achievements.