Consultation – By-law 18: Fees – Feedback Requested by August 18, 2023

Introduction

At the meeting of the Council of the College of Psychologists held on June 16, 2023, a motion was passed to circulate proposed amendments to By-Law 18: Fees. According to the Health Professions Procedural Code under the Regulated Health Professions Act, 1991, amendments to this By-law must be circulated to members 60 days before it is approved by Council [94(1)(s), 94(2)]. If you wish to comment on the following proposal, we would appreciate hearing from you by August 18, 2023.

After careful consideration by the Finance and Audit Committee, Executive Committee, and Council, an increase in membership fees is proposed. Annual membership fees for Autonomous Practice Certificates and Interim Autonomous Practice Certificate will increase to $1200, Academic Certificates to $600, and all other membership fees by 25% effective June 1, 2024. The proposed fee increases are required to maintain adequate financial resources for the College to fulfill its public protection mandate

Fee	Current Fee	New Fee
Autonomous Practice Certificate	$795	$1,200
Interim Autonomous Practice Certificate	$795	$1,200
Supervised Practice Certificate	$550	$687.50
Academic Certificate	$397.50	$600
Inactive Certificate	$238.50	$298
Retired Certificate	$50	$62.50
Limited Interim Autonomous Practice Certificate	$240	$300

In addition, the penalty for any member who fails to pay their annual fee on or before the day on which it is due will increase to 20% of the annual fee.

FAQS

WHY DO HEALTH REGULATORY COLLEGES EXIST?

The mandate of the College is to serve and protect the public interest, and it delivers programs and services to fulfill that mandate. The College needs to ensure it has adequate resources to deliver the programs and services necessary to meet the public interest mandate.

WHY DO PSYCHOLOGISTS AND PSYCHOLOGICAL ASSOCIATES PAY ANNUAL FEES?

Regulated Health Colleges in Ontario are required to be financially self-sustainable and do not rely on ongoing government funding to fulfill their self-regulatory mandate. Annual fees account for the vast majority of College revenue, approximately 90% of College income[1]. College revenue funds the operations required to fulfill its public protection mandate: Registration, Professional Affairs (including Quality Assurance and Practice Advice), Investigations, and Hearings. Registrants of the College of Psychologists of Ontario pay annual fees to sustain psychology’s self-regulation, to protect the public, and to maintain trust in the profession. Note that the current financial situation is independent of ABA which will also be a self-funded profession.

WHY WOULD THE COLLEGE OF PSYCHOLOGISTS OF ONTARIO INCREASE ANNUAL FEES?

The College takes the decision to increase fees seriously and is only doing so in order to stabilize the College’s financial position after several years of annual deficits (audited financial statements are available on the College’s website).

WHAT ARE THE ANNUAL FEES OF OTHER PSYCHOLOGY REGULATORS IN CANADA?

In comparison to the other Canadian provinces, Ontario has the second lowest fees which is inconsistent with the volume and complexity of operations that the College must manage (the College has the second most members). As presented in Exhibit 1, psychology regulators charge their members up to $1,200 for their annual membership fee.

WHAT ARE THE ANNUAL FEES OF OTHER HEALTH COLLEGES IN ONTARIO?

Within Ontario, there are a number of Colleges that have higher membership fees than Psychology. The profession of psychology in Ontario is marked by autonomy in practice in highly sensitive contexts. After controlling for the size of each College (per 1,000 registrants), the College of Psychologists of Ontario has the second most complaints against registrants[2]. Regulated health professionals with similar levels of autonomy, such as Homeopathy, Traditional Chinese Medicine, Chiropody, Denturism, and Naturopathy charge annual fees ranging from $1,200 to over $2,000 (Exhibit 2).

WHAT ARE THE NEW ANNUAL FEES?

Over a twenty-one-year horizon (since the last fee change) and accounting for only a 2% inflation rate, a highly conservative estimate of today’s membership fee would be slightly more than $1,200. This is not accounting for the real inflation rate over the last several years, nor is it representative of the operational pressures of the College due to the high number of received complaints. In order not to disproportionately impact members who have other certificates of registration, the Academic certificate will be half of the autonomous fee ($600), and all other certificates will increase in cost by 25%.

View a tracked changes of By-Law 18: Fees here.

IS THE COLLEGE DOING ANYTHING ELSE TO IMPROVE THE FINANCIAL SITUATION?

Yes! The College will be reviewing all operational processes with the intent to improve efficiencies wherever possible, including the adoption of Right Touch Regulation principles (such as improvements to Alternate Dispute Resolution) and LEAN management/Continuous Quality Improvement processes.  The College is committed to ensuring that their operations are as optimally functioning as possible. The College will also continue to investigate trends in complaints, as the College has the second most complaints of any other health profession regulator (per 1,000 registrants), which has resulted in significant financial pressure.

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[1] The primary source of revenue for the College is member Registration Fees; this includes both autonomous practice, supervised practice, academic, inactive, and retired. Together with Application Fees this accounts for approximately 90% of the College Revenues. The remaining 10% is received from Incorporation Applications and Renewal Fees, Examination Fees, Net Investment Income, Quality Assurance Penalties and Discipline Cost Recovery.

[2]Pivotal Research (January 2023). Complaint Management Performance Across Ontario Profession Regulators: Benchmarking Study-Commissioned by the College of Dental Hygienists of Ontario