Fees and Budget: FAQs
The College of Naturopaths of Ontario is receiving a number of inquiries about the fees being charged to the profession by the College, the budget that has been developed by the College and the Council’s reasons for approving the budget. The following are the answers to the many of the questions being posed.
Index of Questions
Elected Council Members
Why are the College fees high, especially compared to the BDDT-N’s fees?
The Board of Directors of Drugless Therapy – Naturopathy (BDDT-N) charged active members $900 annually while the College of Naturopaths of Ontario is charging members $1,495 annually. There are several important factors to behind this difference in fees.
First, the number of regulatory programs that are required under the Regulated Health Professions Act, 1991 are greater than those required under the old Drugless Practitioners Act. The BDDT-N was not required to run a Quality Assurance Program, a Patient Relations Program or an Inspection Program. All of these require funds to be able to operate both in terms of the volunteer and staff resources needed as well as the procedures by which we interact with members of the profession.
Second, the regulatory programs that the College runs that are similar to those of the BDDT-N are far more robust. The RHPA carries significant due process requirements to protect both members and the public and these impose costs. In addition, the complaints process under the BDDT-N was far different from that under the College as was the process by which discipline is handled. Our budgets need to account for these procedural and process improvements.
Third, the College is significantly larger in terms of its governance structure. The BDDT-N was a Board of five individuals while the College has a Council of 13 individuals. This means that the costs of compensating these individuals for their time away from practise are higher as are the expenses that they are due to be paid for their participation. These financial costs are increased when you consider that the BDDT-N had three committees while the College has 11 committees, of which 9 are mandated in the RHPA or the Regulations made under the Naturopathy Act, 2007.
Finally, the College’s legal obligations surrounding confidentiality and security of information; accessibility; safety and security of volunteers, staff and the public are much greater than those in place at the time the BDDT-N first established its office.
Why did the College increase its fees this year?
In 2015, members paid the BDDT-N $900 and the College $575 for a total of $1,475. In 2016, those fees were increased by 1.3% in accordance with the Consumer Price Index, as mandated in the College’s by-laws. This added $20.00 to a member who holds a General Class certificate of registration.
Unfortunately, the College has also had to register for HST now that proclamation has occurred which has added an additional tax burden on members. The College recommends that members speak to their accounting professionals regarding how they might be able to adjust their practices to this cost.
Why is the College charging HST?
The College has been examining for some time the question of whether it was required to charged the Harmonized Sales Tax to members. At the conclusion of our review, it was clear that the College should be registered for HST and collecting that tax on behalf of the federal government. Members of the profession should seek the advice of an accounting professional to determine whether they should register and to understand the costs/benefit of doing so.
In addition, by registering for HST, the College becomes eligible to reduce its overall expense burden. Prior to being registered for HST, the College had to absorb all taxes it paid on supplies and services. Now that it is registered for HST, the College can offset the tax paid against the tax collected when paying the Government. This results in a significant savings on the expenses incurred by the College.
If the College were not registered for HST, the HST paid by the College would remain as expenses. This would mean that the fees of the profession would have to be increased. By charging HST, some members may be able to benefit by claiming the tax paid against the tax collected when paying the Government.
The College recommends that members speak to their accounting professionals regarding how they might be able to adjust their practices to this cost.
Is the College aware that some members of the profession are struggling?
The College has heard from some members of the profession that they are struggling to sustain their practises and make ends meet. For our part, the College will always carefully consider the fees that it is charging ensuring that we only collect the level of fees that we require.
The costs being encountered by the profession are not solely at the hands of the College. Members must also purchase professional liability insurance and most members belong to both of the professional associations.
The College also encourages all organizations relating to the practise of the profession to consider their fees and opportunity to work collaboratively to first, using an evidence-based approach quantify the degree to which the profession is encountering financial sustainability issues and second, to examine their own fee structures and revenue opportunities to alter the costs being borne by the profession.
With such high fees and people leaving the profession, won’t fees be driven even higher?
Some members are concerned that the fees being charged will drive individuals out of practise and result in those who remain to pay higher fees. Unfortunately, given the limited sources of revenue available to the College, this might be true; however, we encourage all members to seek out appropriate ways of organizing their practices in order to ensure their long-term sustainability. For members of the profession, there are steps you can take to help ensure the College fees do not need to increase significantly in the future, which will be discussed below.
The College also believes that this period of dramatic change will end and as the profession becomes accustomed to the new model and the costs associated with it, adjustments to practises, pricing and patient loads will be made to restore balance.
Does the College have any options available to it to lower fees?
Unfortunately, as noted above, the College’s limited sources of revenue mean that the College has few options to lower fees at this time.
For the immediate term, the College is examining its operations to try to ensure that further fee increases are not necessary. In the longer term, both the College and the members of the profession need to take steps to ensure that fees do not need to be increased. Both the Council and the staff will be examining this closely in the future.
Why are the fees charged by other health regulatory Colleges lower?
It is very difficult to compare the fees charged by other Colleges to those of the College of Naturopaths of Ontario. Not every College is required to run the same programs, for example, only four Colleges including this one have an inspection program. Not every profession has the same scope of practice meaning that the regulatory framework will differ dramatically between Colleges.
A great deal of emphasis has been placed on the lower fees charged by the College of Homeopaths of Ontario. the naturopathic profession is very small in numbers, it has a very broad scope of practice and has been authorized to perform a large number (seven) controlled acts. This means that our regulatory framework is larger, the number of complaints and investigations to be carried out are more numerous and more complicated and the number of referrals to discipline can be expected to be higher. Homeopaths by comparison, have a considerably smaller scope of practice and have not been authorized to perform any controlled acts.
What can members do to keep fees as low as possible?
The College, like any other health regulatory College, is a business and it takes an infrastructure and people to run it. There are a number of steps member can take to help us keep our fees as low as possible. Here are a few of those:
– paying your registration fees on-time and on-line requires less human intervention which allows us to keep our staff resources lower. When a member misses a fee deadline, we are required under the legislation to issue formal legal notices, which also takes time and resources.
– when completing your annual Information Return to the College, complete it on time, take your time, be accurate and provide everything needed. Members who do not complete the Information Return on time have to be given formal legal notices as do those who provide inaccurate or incomplete information. This requires considerable time and effort by College staff and this increases our costs.
Read before you Write
– In reality, the staff of the College enjoys their interactions with the members of the profession. Overall, the members are kind, very polite and all want to do things correctly the first time. These positive interactions are great, however, it is important to read all of the information we provide before you write us an e-mail or call us. When the registration processes noted above are under way, we have scant resources much of which is taken up by answering questions about things we have already anticipated and answered in our handbooks and tools.
Avoid unnecessary complaints and investigations
– Whenever humans interact, their will be unavoidable conflict, often based on misunderstanding and miscommunication. These kinds of complaints and investigations can take a huge human resource and financial toll on the College, which places pressure to add more resources. Being cautious and professional in your interactions with your patients, colleagues and other health professionals can go a long way to avoiding potential complaints against you.
Practise within the legislative framework
– The College has a number of regulations, standards of practise and by-laws that it is required to enforce. Members who intentionally or otherwise practice outside of the legislative framework run the risk of a complaint being filed against them or of the College initiating an investigation of them based on information being brought to our attention. If a member practises outside of the legislative framework, the College is required to act as a part of our public interest and public protection mandate. This may result in complaints against members or investigations of members and it will also likely result in costly discipline cases. Some examples that we have already seen in the short time since proclamation on July 1, 2015 include:
- Performing IVIT without having met the standards of practice necessary to do so;
- Administering substances by injection without having met the standard of practice to do so;
- Administering a substance by injection that is not authorized to the profession;
- Prescribing, dispensing, compounding or selling a drug without having met the standard of practice necessary to do so;
- Prescribing, dispensing, compounding or selling a drug that is not authorized to the profession or doing so beyond the limitations set out in the regulation;
- Drawing blood for a test not authorized to the profession;
- Performing a laboratory test or ordering a laboratory test not authorized to the profession;
- Advertising (usually on a website) in a manner that is not in keeping with the Advertising standard of practise.
The costs being borne by the profession are a concern to the College and all of its stakeholders. We implore the profession to do their best to help keep the College fees as low as possible by practising within the legislative framework, doing their best to read the materials provided by the College, and completing information accurately and on-time. We also implore all organizations related to the profession to re-examine their fees and sources of revenue to assist in providing relief to the profession.
What value do I get from being a member of the College?
The College has received questions about the value that members get from the College. We can identify a number of benefits of membership in the College of Naturopaths of Ontario.
First, because of their membership in this College, members can use the term “Naturopathic Doctor” or “Naturopath” and the abbreviation “ND” following their name. Individuals who are not registered with the College in Ontario cannot use that title nor the abbreviation in Ontario. Completion of the educational program does not permit individuals to use this title in Ontario.
Second, members can also use the term “Doctor” or “Dr.” in front of their name (provided they also use ND following their name). In every day conversations, your friends and colleagues can refer to you as Doctor, which although it had been quite commonly used before proclamation of the Naturopathy Act, it only became legally accessible on July 1, 2015.
Third, members can see patients in Ontario, using these titles. Without membership in the College, an individual seeing patients and referring to themselves as a Naturopath or Naturopathic Doctor would be subject to prosecution by the College for holding themselves out as naturopaths.
Fourth, members of the College are legally authorized to perform the seven controlled acts authorized to the profession in the Naturopathy Act, 2007. Any individual who performs any of the controlled acts must be authorized under Ontario legislation to perform these controlled acts. Performing them without being a member of a health regulatory College would result in prosecution under the RHPA. Access to these controlled acts is a critical element of the scope of practice of the profession and not all health professionals can perform them.
Fifth, members of the College are now legally able to perform certain blood draws and order specific laboratory testing in Ontario. Again, while a great deal of this may have been done prior to proclamation, it is only because of the changes that these tests can be done by a naturopath without counter signatures and support of the health professions.
Sixth, and perhaps most importantly, as a member of a regulated health professional, members are seen by the public differently and usually given a higher stature and a great deal of respect and deference. It is estimated that there are less than 300,000 health professionals in the province of Ontario, which has a population of more than 5 million people. With position, however, come responsibilities.
The primary responsibility of the College is to protect the public. We do this by holding members of the profession accountable for their conduct and by ensuring members are safe, competent and ethical. Some programming, such as the Quality Assurance Program, is designed to be supportive of the profession and will be seen by members as adding value. However, for the most part, the value you get from the College is by keeping unqualified individuals from entering the profession or practising the profession and ensuring that everyone who practises is a member of the College.
The College’s job is to ensure that when Ontarians access a Naturopathic Doctor, regardless of who that ND is and where they are practising, Ontarians can be confident that the ND has the knowledge, skill and judgment to practise safely, competently and ethically.
Why doesn’t the College offer a lower fee for Part-time NDs?
The answer to this question has two parts. First, the classes of registration and fees set in the by-laws and second, the assessment of risk.
The College operates on the basis of the classes of registration available in the Registration Regulation. Annual registration fees are set out in the by-laws and are assigned based on the registration classes. Part-time is not a class of registration. Any part-time ND must hold a general class of registration in order to qualify to see patients. The College can only charge the fees as they are established in the by-laws.
The Registration Regulation established the classes of registration based on the level of risk associated with that class. A member who holds an Inactive class of registration is not authorized to see patients in Ontario and therefore represents a lower regulatory risk than a member who holds a general class certificate of registration and who can or does see patients regularly. A part-time ND still sees patients and still presents a potential risk of harm to the public, which is the fundamental underlying principle of regulation.
Why doesn’t the College offer a lower fee for members who are recent graduates?
The answer to this question is very much the same as the answer to part-time NDs. Newer members, NDs who are renewing their registration fees for the first, second or even third time, believe that they should be paying lower fees because their practises are not as well developed. From a regulatory perspective, the risk of harm to the public is the same for a new registrant as it is for a member who has been practising for many, many years. To some degree, the nature of the risks might change over time but overall, the fact that members are seeing patients is where the regulatory structure identifies risk and regulates to mitigate that risk.
Why doesn’t the College offer refunds if I change class or resign?
Once again, the by-laws of the College outline the fees that may be charged. The by-laws set put that fees for an initial certificate of registration may be prorated but no other exceptions are made surrounding any fees. Fees are due on the date they are required and they are payable at the level set out in the by-laws.
Members typically see the College in the same way they see their fees for a professional association; however, they are not the same. In the case of the association, you typically pay to obtain services or benefits. In the case of the College, you pay to be able to practise and use titles legally. The College does not provide services to the members but rather, it provides a benefit to the public.
Many members of the College change their class of registration. Some will do so several times throughout the year. If the College were adjusting fees based on these changes, a large part of our resources would be taken up by the process which would reduce our ability to fulfill our regulatory mandate.
Why doesn’t the College offer lower fees for maternity or parental leave?
While the College does not have a class of registration for maternity or parental leave, it does have the Inactive class. Members who are seeking a maternity leave may want to consider moving to the Inactive Class; however, the lower fees only apply if you are going to be inactive throughout the entire membership year. Shorter leaves will result in having to pay the full year General Class registration fee. This is simply because during the year, you will see patients and members who see patients represent a higher risk than those who do not.
Why is the College paying so much in rent?
It is impossible for the College to debate with the profession every line item in a budget of the size and scope of the College’s. The Council has retained expert staff who have knowledge of the requirements to run a regulatory College and the Council has confidence in the operational decisions being made.
Factors at issue in selecting space include:
Why can’t the College move somewhere less expensive?
- Legislative requirements to secure highly confidential information about patients and members;
- Legislative requirements to ensure the safety and security of staff, members of Council and visitors to the College;
- Legislative requirements surrounding accessibility of the College by the public;
- Access to sufficient meeting space for a) the Council; b) its committees; c) hearings held by the College;
- Sufficient space for the College to operate its programs effectively, both in terms of costs and productivity;
- Proximity to a) the people served by the College, the public of Ontario, b) other health regulatory Colleges, c) the Ontario Government and d) the members of the profession.
Moving the College outside of the City of Toronto and the Greater Toronto Area, which would be the only meaningful way to substantially reduce costs, would impact the accessibility of the College by the public, members and limit our access to important resources such as other Colleges and the Government.
The College’s current location, while accessible generally, is already located away from the main subway lines and away from most Colleges that are in the Bloor Street and University Avenue corridor. This selection was made to reduce costs from the highest type of building while meeting the other needs of the College.
As part of the cost/benefit analysis of the space available at the time it was needed, the College obtained a better than market rate on renting its current space by signing a long-term lease. As a result, a move is not possible, without incurring significant penalties, before 2023.
Why does the College have so much meeting space?
The College generally has four main committee meetings each month and a full Council meeting each quarter. In addition, we anticipate having Discipline Committee meetings three time per year, some as short as one day, others as long as 8-10 days.
Without the space to accommodate these meetings, the College would be required to rent meeting space in a local hotel for these meeting. This would mean not only renting the meeting space, which is priced higher when none or only a few hotel bedrooms are also rented, but also purchasing food from the hotels, which is extremely costly.
Why are members of the profession responsible for making up any College deficits?
The question about why members of the profession are responsible for making up any deficits of the College is a good one. The College of Naturopaths of Ontario has a very limited number of revenue opportunities. These include: registration fees, application fees (for registration), examination fees (entry-to-practice), inspection fees and administrative fees (for notices). All of these fees have in common the fact that they come from members of the profession.
Many of the health regulatory Colleges in Ontario have examined other sources of revenue. These include education and training fees from courses and adverting fees from suppliers to the profession, and from insurance. In each instance, the College has moved away from these revenue sources as they place the College in a conflict of interest with their public interest mandate.
The role of the College is to protect the public from harm and serve the public interest. This mandate is compromised if the College is seeking revenue from organizations attempting to seek influence over the profession.
The College is required to exist under the law and is expected to be independent (politically and financially) from the Ontario Government. As a result, it cannot operate with on-going deficits and remain sustainable in the long term, nor can it turn to government to seek financial support.
Aren’t the costs of salaries too high?
The College retains the services of employees who are experienced in the area of health regulation and non-profit management and administration. These are highly specialized skills. In order to attract quality professionals, the College has to provide compensation that is appropriate for the knowledge and skills employees bring to the table. Compensation levels have to be at the same level that other health regulatory College’s would pay in order to attract and retain good employees.
The College has compared its salaries and benefit packages to those of other Colleges in several ways. First, we have participated in and received the results of compensation surveys of a) other groups of Colleges of a similar size and scope and b) of non-profit associations who specialize in this type of comparative data, such as the Canadian Society of Association Executives (CSAE). The College is confident that the compensation benefits offered to its employees is at a fair market value and will allow it to recruit and retain quality employees.
Shouldn’t the staff receive salaries and benefits comparable to NDs?
In short, no. NDs have a very specialized knowledge and skill based on their education and training. Staff of the College have a different knowledge-base and set of skills and experience. Both staff and NDs should be compensated at an appropriate value based on the market. The College presumes that when a ND sets her or his rates, they are doing so based on their knowledge, skills and experience and what the market is prepared to pay for those services. NDs can adjust their compensation, to some degree, based on the hours they are prepared to work and the number of patients they see. Staff are required to be present in the office each day for a set timeframe and must be present five days a week (excluding vacation and holidays). They also have an exclusivity clause in their contracts which means that they are not permitted to earn an income elsewhere.
Why are meal, travel and accommodation costs so high?
The College relies on professional members, some of which are elected to the Council and subsequently appointed to committees, others of which volunteer to help it fulfill its regulatory mandate through Committees. These individuals take time away from their practises to work with the College. In exchange, these members of the profession are provided with the following:
- A per diem of $150 for each day they prepare for and attend meetings at the College;
- Reimbursement of their train, subway or air fare, or if they drive, mileage for their travel;
- A set amount for meals that they must pay for while working with the College;
- Costs for accommodations if they are required to stay overnight in Toronto.
These rates are based on the same levels that the Ontario Government provides to public members appointed by the Lieutenant Governor in Council and do not reflect the true value of the time given to the College.
What steps has Council taken to address the projected financial shortfall?
The Council has taken a number of important steps to reduce the overall deficit that has been projected for the next three years. These include:
- Registering for HST to benefit from the input tax credits as a means of reducing expenses;
- Eliminating activities that are not absolutely necessary in the coming one to two years;
- Exploring options to increase examination revenues (a consultation will be started shortly);
- Consideration of altering the way in which Inspection Program fees are collected to reduce fluctuations over the period;
- Keeping Committees to the minimum size requirements to reduce expenses;
- Cancelling unnecessary meetings.
Much of what we budget for is a “road map” and we might find that matters do not unfold the way in which we first projected. For example, the number of complaints may not continue at the pace seen by the former regulator and discipline cases may not materialize. As we proceed through this next fiscal year, the Executive Committee and Council will have a better idea of what steps may be necessary to achieve long-term sustainability.
Will the College release its full budget to the profession?
The College’s budget is the result of a complex set of calculations for each program or functional area of the College. It is created on a month-by-month basis projecting work requirements over the next three fiscal years and incorporating these into a large spreadsheet. These complex calculations are not suitable for release as no context is provided. A key principle of transparency is to provide information in context to allow the reader (Members and the Public) to understand the materials.
Although the detailed materials are not suitable for release, at the bottom of this Q&A page, the College is releasing several documents that summarize the budget for the coming fiscal year. The documents include:
- A summary of revenue and expenses, broken out by department or program area of the College;
- A consolidated report of all line item revenues and expenses;
- Notes to the budget providing a description of each item.
It is important to note that the activities that have been included in the budget are all statutory obligations placed on the College through the Regulated Health Professions Act, 1991, the Naturopathy Act, 2007 and the regulations made under these statutes. Estimates of work have been made based on information available to the College; however, actual results will vary against the budget.
In all of its day-to-day operations, the College endeavours to ensure that funds are spent only on an as-needed basis. The intent is to ensure savings at each and every opportunity available to the College.
How did individual Council members vote on the recent decisions?
Voting by the Council is primarily done using a show of hands for those present and the manner in which an individual has voted is not recorded in the minutes, unless a request by a Council Member is made to do so. Only then would the Council minutes show whether a Council member has opposed or abstained from voting on a particular motion.
The Council has open and honest debates and discussions. These are open to the public, unless there is a legislative reason to exclude the public, such as discussing personnel matters. The outcome of a vote is determined by a majority of Council (50% +1 of those present at the meeting). Once a decision is made, the decision becomes one that has been made by the entire Council.
All members of the Council have agreed to abide by this important governance principle and they all support the decisions made by the entire Council. How any individual members of Council voted is irrelevant after a decision is made.
Why isn’t my member of Council responsive to my needs, I elected them after all?
Members of the Council do not represent their constituents.
When elections are held, they are held on the principle that the members are electing the individual whom they believe can see and protect the public interest. The election is not an opportunity to elect an individual whom the profession believes can best meet their needs. The role of Council members, as it is enshrined in the legislation, is not the same as your local Member of Parliament or Member of Provincial Parliament. This important principle is enshrined throughout the Regulated Health Professions Act, 1991.