Proposed Amendments: Fee for Applications to Modify or Remove the Terms, Conditions or Limitations imposed on a Certificate of Registration (Consultation Closed)
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The College is seeking feedback on draft amendments to the Fees and Remuneration By-Law that, if passed, would add a fee for any member who applies to modify the terms, conditions or limitations of his or her restricted certificate of registration imposed by the Registration Committee.
Background and Proposed By-Law Changes
Section 1 of the College’s current Fees and Remuneration By-Law indicates that the College can charge for application fees. However, the College does not currently charge application fees when members have requested a modification to terms, conditions, or limitations imposed on their certificate by the College’s Registration Committee.
The Registration Committee has reviewed an increasing number of such applications from members. In 2013, the Committee reviewed more than 450 applications from physicians for amendments to their certificates of registration.
A review of the College’s registration resources has identified that:
- The College’s registration function costs well exceed its revenue from registration fees
- Applications to modify terms, conditions or limitations previously imposed by the Registration Committee consume resources. Some applicants make more than one such application. Other such applications are complex applications and consume significant Committee resources. This cost is not reflected in the current model by which no fee has been payable for an application to modify terms, conditions or limitations previously imposed by the Registration Committee.
Calculating the Fee
Like the fee for an application for a new certificate of registration, the proposed fee to modify a term, condition or limitation previously imposed by the Committee is expressed as a percentage of the annual fee payable by a member of the College.
Council is proposing for these types of applications that members be charged a fee in the amount of 25% of the annual fee specified in section 4(a) of the Fees and Remuneration By-Law. This would be half the fee that is payable for an application for a new certificate of registration. Based on current figures, the fee at this time would amount to $392.50. This proposal reflects the fact that in order to process an application to modify terms, conditions or limitations previously imposed by the Committee requires on average approximately half the staff time and resources, compared to that taken in processing a new application for a certificate of registration.
The proposed fee change would affect less than 1% of the membership.
If approved, the fee will take effect at the start of the next membership year commencing June 1, 2015.
The proposed amendment to this by-law is underlined below.
We value your feedback and thank you for participating in the policy review process.
Proposed Amendments to Fees and Remuneration By-Law No. 2
Section 1 of By-Law No. 2 (Fees and Remuneration By-Law) which currently reads as:
A person who submits an application for a certificate of registration or authorization shall pay an application fee. The application fees are as follows:
(a) For a certificate of registration authorizing postgraduate education, 10% of the annual fee specified in section 4(a);
(b) For a certificate of registration authorizing supervised practice of a short duration, 20% of the annual fee specified in Section 4(a);
(c) For an application for reinstatement of a certificate of registration, 60% of the annual fee specified in s. 4(a);
(d) For any other certificate of registration, 50% of the annual fee specified in Section 4(a);
(e) An additional fee of:
(i) $5 to offset costs of audits, reports and reviews of registration practices required by provincial legislation will be applied to every application for a certificate of registration; and
(ii) $15 to offset the cost of a criminal record check will be applied to every application for a certificate of registration that is not accompanied by the results of a criminal record check from an acceptable source.
(f) For a certificate of authorization, $350.00.
Would be amended by adding the following new sub-section:
g) For an application to the Registration Committee for an order directing the Registrar to modify or remove terms, conditions or limitations imposed on the member’s certificate of registration as a result of a registration proceeding, 25% of the annual fee specified in section 4(a).
The College’s Executive Committee and Council will carefully consider your comments before making any decisions about the proposed by-law changes. The College will consider the extent to which your suggestions or comments represent the expectations of the profession, and are consistent with our public interest mandate. If, after consultation, the by-law is passed by Council, notification and a copy of the finalized by-law will be posted on the College’s website.