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Fees & Remuneration By-law Public Consultation

July 22, 2019

Note: This article was originally published in our Summer 2019 edition of our On Call newsletter, and has not been updated.

The College held a public consultation for the Fees & Remuneration By-law in May and June.

The College held a public consultation in May and June for the Fees & Remuneration By-law to address the proposed increase in membership fees for 2019-2020.

During the consultation, the College received responses from 39 members which represents a total of 4% of all members.

You can see the general feedback we received and the College’s response below:

General Disappointment & Frustration

A few members responded positively to the proposed change, expressing that they anticipated the fee increase to be even higher due to the unexpected loss of Ministry funding. The majority of responses, however, expressed disappointment with the proposed fee increase. Many members stated that they are underpaid and undervalued, and any fee increase adds to the stress of their work. Many expressed frustrations that, despite winning their case with the Human Rights Tribunal of Ontario regarding pay discrimination based on gender, they haven’t seen a pay increase and the proposed College fee increase exacerbates this issue.

The College is concerned that a small profession, especially one whose membership numbers and compensation are controlled by the government, is burdened with the total costs of regulation. The College has no role to play in increasing numbers of midwives in the province as a means to increase revenue nor in negotiating midwives’ compensation levels. The Ministry of Health and Long-Term Care sets the number of midwives able to practise in Ontario each year, and the number of baccalaureate midwifery education program positions are determined by the Ministry of Training, Colleges, and Universities. The Ministry of Health is also responsible for setting midwives’ compensation rates. The College can, however, continue to work to further reduce costs while still meeting its mandate to regulate in the public interest and provide organizational stability. The College hopes that once revenue exceeds expenses and there are sufficient net assets to draw from for unexpected risks, that fees could be re-examined in the future.

Recommend moving the College out of downtown Toronto

This was a common theme, appearing in 9 of the 39 comments, and has been raised in previous consultations as well. Staff and Council members meet regularly with stakeholders including the Ministry, other health regulatory colleges, the Association of Ontario Midwives, the Office of the Fairness Commissioner, Midwifery Education Programs and the International Midwifery Pre-registration Program. The College benefits from being able to share resources with other Colleges which are located in Toronto. The College is located in mid-Toronto, where rent is more affordable than the downtown core, yet still provides easy access along the Yonge subway line for all staff, Council members, and stakeholders. A move outside of Toronto would mean a sudden loss of all staff which would greatly interrupt services and put the College’s operations and deliverables at significant risk. While the College’s budget for rent and utilities is not significant, when the College’s lease expires in August 2022, we will explore all options to limit expenses in this area.

Recommend lower fees for some, including new registrants, inactive members, and part-time midwives, and increase payment plan options.

The feedback in this area was valuable and will be noted to inform future discussion around fees. The College presently offers an Inactive Class with a 50% reduced membership fee. Initial registration fees continue to be pro-rated based on the months of practice before registration renewal in October. The College cannot meet its budgetary requirements and offer lesser fees for new registrants and those working less than full time or further reduce Inactive class fees at this time. The College commits to look at this alternative and/or additional reduction of fees once the College’s revenue exceeds expenses and there are sufficient net assets to mitigate unexpected risks.

2019-2020 Registration Fees

The College is pleased to announce that Council has approved a $50 reduction in the proposed membership fee increase for the General class. This adjustment comes after meeting with Council to present and discuss feedback from our Fees & Remuneration By-law public consultation and having more success than anticipated with reduced spending in 2018-2019.

The Inactive class of registration will not be affected by these changes, and will increase at 2%, per the existing by-law.

Increasing membership fees is a difficult decision for Council and the College to make. However, in order for the College to fulfill its mandate of public protection and meet the cost of regulation, this increase in membership fees was necessary.

Going forward, the College will continue to evaluate its spending year over year to ensure it is operating as efficiently as possible while still delivering on its mandate. The College will address other recommendations from the consultation feedback in future years.

The College thanks all members for their feedback during this consultation. You can read all the submissions here.