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Closed Public Consultation: Fees and Remuneration By-law

Closed Public Consultation: Fees and Remuneration By-law

Note: This public consultation is now closed.

This March, the College of Midwives of Ontario Council proposed changes to our Fees and Remuneration By-law that include a registration fee increase. If approved, this increase would bring the fees to $2150 for general class of registration and $1075 for inactive class of registration, effective for this year’s renewal. Fees would then increase by inflation, at 2% per year.  While this was not an easy decision for Council, it is necessary in order for the College to continue fulfilling its mandate of public protection and meeting the cost of regulation.

As members are aware, the College’s statutory work is mandated by our governing legislation and we do not have the option of reducing or shifting our regulatory focus. This means that while we are fully committed to prudently managing our financial resources, we cannot avoid certain expenses.

Member fees cover the work that the College does; setting standards for the profession; registering new midwives and renewing existing members; administering the quality assurance program; and handling complaints and discipline cases; among other functions.  These all work together to create a system of professional regulation, where Ontario families know that when they opt for a midwife, they are getting a professional that they can trust.

The complexity of the registration applications reviewed by the College has increased due to greater differences in the way midwifery is practised in other Canadian jurisdictions and due to alternative practice models becoming increasingly available in Ontario. While the number of complaints and discipline has not increased, we continue facing an increase in the number of complex investigations and preliminary inquiries.

The College’s work is also driven by external developments and the directives received from the Ministry of Health and Long-Term Care. Most recent examples include the work required by the Protecting Patients Act, 2017 and the Minister’s scope of practice and transparency requests.

As a member-funded organization, we are constantly examining our spending and looking for efficiencies. Last year, we embarked on a major change program to cut operational costs and to support more effective ways of working in the future. This includes streamlining our processes, reducing the number of staff where possible, and maximizing the use of available technology to create administrative efficiencies.

Through temporary expense savings we were able to hold membership fees for 2017-18. At the time, based on long term estimates, we calculated that fees would likely need to raise by a larger amount in October 2018. This year, the College has done a careful examination of the revenue and expenses of the College over the coming years and it has been determined we will need to raise general registrant fees by $200 in October 2018 followed by 2% inflationary increases each year thereafter, which is less than originally projected.

The relatively small size and slower growth of our membership mean that in order to maintain our core statutory functions, our fees do need to be higher than some other regulated health professions in the province.

A fee comparison shows that our fees are in the middle of the other midwifery colleges in Canada, as you can see below.

Province

Fee

Alberta

$2750

British Columbia

$2340

Ontario (proposed)

$2150

Manitoba

$1900

Saskatchewan

$1800

Instalment Payments

Another proposed change to the Fees & Remuneration By-law is to the way the College processes instalment payments. Currently, processing instalment payments adds about 60 hours of staff time each year. Council is proposing to add an additional administrative cost to registration fees paid in instalment.  Members experiencing financial difficultly are able to apply to the Registrar for compassionate consideration and an altered payment plan.

You can click here to see detailed information about all of the proposed changes to the by-law.

Our consultation is open until June 3rd, 2018, and all members of the public, stakeholders, and midwives are invited to share their thoughts below. Click here to review the College’s posting guidelines in advance of leaving a comment.

All Feedback

  1. Midwife

    We have not yet received a response from the HRTO regarding any adjustments that many or may not be made to the compensation that midwives receive for our work. In other professions, there is an expected increase in wages over the years that corresponds to inflation. If, in fact, midwives in Ontario are set to receive yearly increases in our compensation that follow rates of inflation, then it seems reasonable that our fees should increase accordingly. However, we have not received such pay increases in the past, and this yearly increase in college fees represents a very difficult financial burden on midwives when there is no corresponding yearly increase in compensation. This profession continues to present more and more obstacles in the way of midwives practicing in the province, and it will become less and less appealing for new midwives to enter the profession if this continues to happen.

    • Are you a: Midwife
    • Organization: Kensington Midwives
    • On behalf of: Yourself
  2. Midwife

    If the fee is increasing, we should get some subsidy, for example, the LOP fee should be waived. Our scope hasn’t changed much and with the govnt cuts, we don’t have full caseloads. MWs are unable to secure a permanent position, and jumping from practice to practice, so the cost increases for re-activation, LOP, and all the fees. I think a survey should be sent out to members regarding a fee increase rather than saying a fee increase is coming. AOM discussed how the fee increase will assist the association, I’m unsure what the College will be doing. There were many proposals for changes, however, I haven’t seen any purported.

    • Are you a: Midwife
    • On behalf of: Organization
  3. Midwife

    As a midwife, I can not abide by this fee increase. As other’s have mentioned, midwives have seen very minimal increase in pay while fees continue to rise. The CMO has one of the highest staff to member ratios of the self-regulated professions in Ontario, and occupies expensive downtown real estate, that no midwifery practice group could afford. Our overhead fees to run our practice groups has seen no appreciable increase, yet we are able to make do and continue to provide our services effectively with less and less resources to do so. The CMO can too!

    • Are you a: Midwife
    • On behalf of: Yourself
  4. Member of the public

    The continued increases in professional fees is (one of many) contributing (factors) to my decision to leave the profession. It is becoming too expensive to work.

    • Are you a: Member of the public
    • On behalf of: Organization
  5. Midwife

    I think it is misleading to provide quotes of what midwives in other Canada jurisdictions pay for College fees without also pointing out how FEW midwives they have in comparison to Ontario. Their respective websites state that there are 110 Active midwives in Alberta, and 274 Active midwives in B.C. Indeed, should are fees not decrease as our membership has increased. Let’s look at what OTHER professions are paying and compare. My mother-in-law is a nurse and is astounded by our fees.

    I echo what many others have already stated. I disagree with a fee increase. It’s unbelievable the increase in my scope of practice (and hours consequent that I work) since I started midwifery over a decade ago and yet minimal pay increase. I am happy to hear the CMO has looked at and implemented ways to “streamline” work and cut costs….but look harder. Yes, maybe move out of the GTA and find affordable rent?? Or tell the powers-that-be that your membership cannot afford the cost of a functional College and advocate for government assistance. I don’t know the answer, but I know it is not to charge underpaid midwives even more to work.

    • Are you a: Midwife
    • On behalf of: Yourself
  6. Midwife

    We are paying too much in relation to other healthcare professionals.. we were told that as the profession, and the numbers increased, our fees would go down.

    • Are you a: Midwife
    • On behalf of: Yourself
  7. Midwife

    I’m curious to know what the college fees are for physicians and NP’s. And what this equates to as a percentage of their income?
    The fees seem extremely high to me even without the increase. But it’s difficult to make an informed decision without comparators. Can the CMO provide these comparisons?

    • Are you a: Midwife
    • On behalf of: Yourself
      1. Midwife

        I would like to see a column added with the average income of each category of professional.

        • Are you a: Midwife
        • On behalf of: Yourself
  8. Midwife

    As many comments before mine have rightly stated, College fees should be pro-rated to a midwife’s income, with reductions for NR midwives and for those practicing part time. I practice full time and I still find the fees difficult to swallow, but I would support paying more if my colleagues with lower income could pay less.

    • Are you a: Midwife
    • On behalf of: Yourself
  9. Midwife

    I disagree with the fee increase across the board.
    I would instead support equitable fees, so that NR’s pay significantly less, and those working full time pay more than those working part time. Inactive midwives should be required to pay only a very small fee. When midwives work part time for different reasons (some not by choice), maybe to not burn out and/or contribute in other ways to the profession (hospital work etc.) we work an entire month or two to pay our professional fees. That is far too much money. Part time members are taking care of less of the “public” so it makes sense to prorate the fees based on caseload. (that being said I know that would be perhaps difficult to confirm). Until we get a significant pay increase, I do not support a fee hike, and if that means less work that can be done by the CMO then that is acceptable to me.

    • Are you a: Midwife
    • On behalf of: Yourself
  10. Midwife

    one way to save money would be to be move out of beautiful downtown Toronto to a location where the rental cost is a good deal less

    I am opposed to this raise in our fees at this time. If and when Ontario Midwives are paid fairly I would change my opinion about this matter.

    • Are you a: Midwife
    • On behalf of: Organization
  11. Midwife

    Thank you for providing the opportunity to give feedback for this consultation. I respect the CMO work and role. However, are you guys doing any calculations on how much does it cost to be a registered midwife? With the expenses that we have: the AOM membership, CMO licence, hospital privileges, certifications like NRP, emergencies skills, fetal surveillance, CPR, any conference that we need to attend to keep ourselves current, any updates and even any research we need to perform to provide ICDs, (do you know that if we do not have access to a library, some articles, journals, papers, guidelines, thesis or studies we need to review, we have to pay to have access to view them?), sogc membership (optional), student loans, and adding into consideration that some practices can not provide full caseload, the NR, midwives that are new moms that are not working full time, midwives that are at the end of their midwfiery journeys and decreasing workload, some of us are already living for working insted having any work life ballance.
    There are more and more expectations, responsibilities and scope being added to our daily practice. I sure you understand that some of us are getting burnout. If you lose midwifery membership, you will have less and less public to protect.
    I do not support any more fee increases until our pay increases above the inflation rate.

    • Are you a: Midwife
    • On behalf of: Yourself
  12. Midwife

    Like many other posters, I strongly advocate for:
    – sliding scale of fees based on RM’s level of pay (increase the fee as our income increases, giving a bit more breathing room to cash-strapped NRs)
    – FIGURE OUT HOW TO LET PEOPLE PAY IN MONTHLY INSTALLMENTS. The AOM has managed to sort this out, and it makes such a gigantic difference.

    • Are you a: Midwife
    • On behalf of: Organization
  13. Midwife

    I cannot imagine this will be a popular decision. Ontario midwives are feeling the pinch as our association and college fees rise but we do not see a change in income. I have a been a midwife for 7 years and although I have had some increases due to the years of work, I actually have more expenses every year. I value what the College does but I think that many midwives struggle to shoulder the cost and currently raising our fees is quite hard to digest. The association offers monthly equal payments and this does help budget instead of a large sum of money once a year. I would suggest that the College consider options for paying monthly (without charging additional fees!) if there is no way to restrict spending.

    • Are you a: Midwife
    • On behalf of: Yourself
  14. Member of the public

    Wow! Good News! 7% increased rate. This is calculated with 1000 members at least 110000 $ from our pocket. How about we do not pay them 7% extra per year and they will work harder on our money.
    “Currently, processing instalment payments adds about 60 hours of staff time each year.”
    cc 110000$ for 60 h= $ 1833/h
    This is $ 100 for 18 people. Nice team!

    • Are you a: Member of the public
    • On behalf of: Yourself
  15. Midwife

    It is increasingly becoming difficult for NRs to be able to pay for our fees and student debt and rent and food and car and gas and still bring home any money for bills and living. Taking into consideration that some NRs do not get full caseload and do not have savings, I do not feel this fee increase is in good taste. I feel like
    – decreasing the amount a NR has to pay, or
    – decreasing the amount for midwives that have been practicing for less than 3 years, for example, or
    – scaling CMO fees according to pay scale
    would be beneficial/more fair for new midwives to be able to maintain somewhat of a healthy income. I definitely do not agree with charging more for installment payments — this is how paying for these exorbitant fees for our college, our association, our hospital, etc is possible. Adding a fee to make paying for a more expensive fees easier seems a bit ludicrous to me. I feel like the time of this proposal is inappropriate, especially for new midwives and even moreso for NRs, seeing as the AOM fees have recently increased remarkably, Considering that midwives do not get an inflation increase in our pay I do not feel a 2% inflation increase on our fees would be fair.

    • Are you a: Midwife
    • On behalf of: Yourself
  16. Midwife

    We have one of the highest College Fees in the province, when compared to other health care providers. We were told our fees were so high in the 1990’s because there were so few Midwives. Our numbers have grown, but there has been no reduction in fees. This will be a hardship for Midwives who have not seen appropriate increases in their income.

    • Are you a: Midwife
    • On behalf of: Organization
  17. Midwife

    I am writing to provide feedback on the CMO proposal to raise college fees.
    As a New Registrant Midwife in my first few months of practice, I struggle to pay the current fees, (not to mention other concurrent AOM fees). I’m sure I am not alone in my experience of being a new graduate with huge debt from my degree program, currently being a midwife at the lowest pay scale, and after SEVEN MONTHS of full time work, still WITHOUT my first paycheck (as I was first hired with a practice without a caseload for me, then started with a new practice and am waiting for my first billings to be processed). Furthermore, NRs already pay huge fees for the CMRE exam, the new Jurisprudence exam fee, and sometimes have to pay out of pocket for NR equipment while awaiting reimbursement.
    May I suggest the CMO consider reducing college fees for NRs who are in the lowest pay scale, often work reduced caseloads, often had to move, are in student debt and often don’t have savings.
    The CMO fees should be scaled to the RM pay scale – proportional college fees to the income earned.

    • Are you a: Midwife
    • On behalf of: Yourself
  18. Midwife

    I do not agree with the increase. This job is already so demanding on our lives and families in so many ways, we don’t need financial burden to be another issue. Between the AOM fees and CMO fees, many midwives are working an entire month each year (or more depending on caseload ) just to pay fees in order to work! That is ridiculous! An entire month of essentially free work. I don’t know of any other career that this is the case. If I understand the inflation of 2% correctly this means that a midwife that is currently 30 years old and plans to work until 50 years old will be paying close to $3200 in CMO fees by the time they retire. If this is the case, I think it will become impossible for midwives to sustain midwifery as a long term career choice.

    • Are you a: Midwife
    • On behalf of: Organization
  19. Midwife

    2% inflation increase each year forever when as midwives we dont even get any type of inflation increase in our pay? What are registration fees for other professions such as Nurse Practitionners and doctors? And does that take into consideration that not only do we pay 2000+ dollars for the CMO and 3000+$ for the AOM? Do all other midwives in canada have 2 associations to pay? Thats 5000$ of professonial fees, is this similar to other professions?

    I am very against the the inflation fees (even if i fully understand why and where the money is needed). One time increase then reevaluate in a few years a possibility?

    • Are you a: Midwife
    • On behalf of: Yourself
  20. Midwife

    We don’t have any increase in our pay, but our fees are going up, I don’t agree with that, maybe we should pay until our payment goes up

    • Are you a: Midwife
    • On behalf of: Organization
  21. Midwife

    I do not support this increase in fees. I am in my 4th year of practice and still significantly in debt due to the high cost of training and then the additional costs required to be a midwife (college fees, association fees, hospital fees, car, gas, equipment costs beyond funding coverage) I am even more against the penalizing of midwives paying by installment when in most cases those paying by installment due so bc of financial difficulties in the first place.
    The analysis of midwifery pay already shows we are not adequately compensated for the work we do, to increase fees like this just adds insult to that injury.

    • Are you a: Midwife
    • On behalf of: Yourself
  22. Midwife

    Not in favour of either of those proposals, but *if* the fees go up then it seems doubly unfair to charge extra to pay in installments. As responses already show, it’s a huge cost, and to then be expected to pay all up front to avoid extra fees is extremely inconsiderate.

    • Are you a: Midwife
    • On behalf of: Yourself
  23. Midwife

    Being a new midwife and new mother, I am finding all the fees for being a midwife quite financially consuming.
    I went back to work part time at 7 months postpartum because I couldn’t afford to stay off longer.
    For newer midwives and midwives supporting young or growing families (maternity leaves), inflation of fees is becoming crippling. Until we see proper pay and inflation of our own pay, I don’t think it is fair to demand more of an already (typically) struggling profession.

    • Are you a: Midwife
    • On behalf of: Yourself
  24. Midwife

    I agree with other comments that the timing of this is less than ideal. We as midwives have had huge fees over the past years to the AOM covering our legal costs (which I fully realize we agreed to), but that doesn’t make it easy. As a midwife currently on maternity leave, it would then still cost me over $2000, between AOM and CMO, to be inactive for the year. This seems crazy!

    • Are you a: Midwife
    • On behalf of: Yourself
  25. Midwife

    I am not in favour of the proposed increase. As a midwife in my 3rd year of practice, I pay $2400/month on the student loans that I incurred in order to become a midwife. This, combined with the AOM fees, combined with the fact that our clinic has difficulty maintaining full caseload for midwives, means that I rarely feel that I’ve turned a profit on this profession. AOM fees have recently increased exhorbitantly, therefore I feel the timing of this proposed increase is inappropriate.

    • Are you a: Midwife
    • On behalf of: Yourself
  26. Midwife

    As a new registrant, who works in a model of “fee for service” type payment the fees are a struggle to pay. I began work in October, with no cash, debts and essentially working for free until I could start billing a caseload of 1 bcc a month for the first 4 months. I had to pay all fees, my car, my rent, my livin, food etc with no cash flow. It meant borrowing money off my parents which I am still paying back.
    Reducing the initial fees for NRs and increasing already high fees in 2nd year would make a big difference to those who are starting out.

    • Are you a: Midwife
    • On behalf of: Organization
  27. Midwife

    As a new registrant with a reduced caseload, I had to take out a loan in order to pay my college fees this year. The fees are astronomical and I’m not sure my family can sustain any more. Going forward, would you consider reduced fees for new registrants? New registrants typically relocate (which can be expensive), are on the lowest pay scale, and often have a reduced caseload in their first months, right when fees are due. Between college fees and AOM fees the entirety of three months of pay went only to fees for me and I know I’m not the only one.

    • Are you a: Midwife
    • Organization: Born Midwives
    • On behalf of: Yourself
  28. Midwife

    Fees should not go up until midwives pay goes up! In that same vein…raising rates yearly to reflect inflation while knowing that midwives have not a pay raise to match inflation in a decade is ridiculous.

    • Are you a: Midwife
    • Organization: Ms
    • On behalf of: Organization

Comments are closed.