By-law Consultation 2023 Submission Form

This is the online submission form for the By-law Consultation being undertaken by the College of Naturopaths of Ontario. It is recommended that before completing this form you review the overview provided on the College's website and the compendium document which sets out in detail the specific by-law changes being proposed.


While summary information of the proposed changes is provided in this form, it is not as detailed and does not provide the full rationale that you will find in the compendium to the call for consultations.


To be valid and considered by the College, all submissions must include the name of the person providing the feedback and, where applicable, the name of any organization that you are representing.


All feedback will be published by the College as part of the consultation program. Submissions from individuals will not be identified; however, those submitted on behalf of an organization will include the name of the organization and the name of the person submitting the feedback.

1. ABOUT YOU

Please provide your given (first) name.

Please provide your family (last) name.

Please provide an email address to which the College may send you communication or information.

Please provide a telephone number where the College can reach you during regular business hours. To adjust the country, please use the arrow key to select the correct flag.

Phone
Are you a Registrant with the College of Naturopaths of Ontario*

Please enter your four-digit College registration number.

Organizational Representation*

Are you making a submission on behalf of an organization?

Please state the full name of the organization you are representing.

2. BY-LAW CONSULTATION FEEDBACK

Please select all the sections in the proposed by-law changes on which you will be providing feedback. Only those sections you select will be provided on the form below.

This section proposed to add the following definition:


"Patient Interaction" means a patient encounter that includes an assessment and/or diagnosis, treatment and/or monitoring of a patient or patient’s condition in accordance with the standards of practice of the profession;


Grammatically, this section has been revised to move "the Registrant" to the opening paragraph and remove it from each individual requirement. Additionally, the following changes are also proposed:

  • (i) limits the ability of a person holding an emergency class certificate from election to Council.
  • (ii) is clarification but not a policy change.
  • (vi) adds the failure to return information to the College as an ineligibility criteria.
  • (xiii) is clarification that the definition of conflict of interest is as defined in the by-laws and that the CEO is the arbiter of matter
  • (xvi) is a new provision requiring a clean social media history.
  • (xvii) is a new provision and does not permit a person who has filed a lawsuit against the College to run for office.

This section is proposed to be amended for grammatical purposes and clarity. Rather than referring to a Registrant who does not practice, it would now refer to a person who holds an Inactive Class of Registration.

Two related changes are proposed. The first is to remove section 10.34 and combine it with 10.33. The second is to remove the mandatory requirement for a bi-election to be held instead allowing the Council to determine whether this is the best approach in the public interest.

This section is amended to add "video conference" specifically to the provision which is the current approach of the Council.

This provision sets out the eligibility requirements for appointment of a Registrant to a Committee. These changes are intended to align with those set out for election to Council. As such, this section is proposed to make the following changes. First, to move "the Registrant" to the opening paragraph and remove it from each individual requirement. Additionally, the following changes are also proposed:

  • (v) adds the failure to return information to the College as an ineligibility criteria.
  • (xiii) is a new provision requiring appropriate social media history.
  • (xiv) add conflict of interest and notes that the definition is as defined in the by-laws and that the CEO is the arbiter of matter.
  • (xv) is a new provision and does not permit a person who has filed a lawsuit against the College to run for office.

This section applies to members of the public who wish to participate in a College Committee. The changes made relate to the removal of having declared bankruptcy in the past 7 years, an antiquated requirement and to limit the applicability of Provincial Offences to limit participation to those offences that relate to suitability to serve on the Committee.

This section applies to volunteers of the College and limits their ability to apply for staff positions unless they first resign their position. Staff positions include certain in-field roles such as assessors, inspectors, examiners. The College does not consider these positions as staff or employment positions and proposes to remove this specific limitation.


A new provision, 16.11.01 is proposed to place a limitation on in-field volunteers such that they cannot be appointed to a committee that is responsible for the program for which they are in-field volunteers.


This section requires that all Registrants and Professional Corporations pay an annual registration fee. It also notes that Registrants must pay their fee by March 31st of the prior Registration year, as is the current practice.


New here is the proposal that any fee ordered by a College Committee that is not paid or is not subject to a payment plan and in good standing, will be added to the Annual Registration Fee.

The proposed change is to remove the requirement for payment of the registration fee by the end of March as it is moved to section 18.01.01.

The change here is grammatical to cite the actual section of Schedule 3 where the applicable fees may be found. NOTE: There is no intention of removing the automatic increase.

This section is clarified to apply to only those seeking to be registered in the General Class are eligible for a proration of fees. Applicants to the new Emergency Class are not eligible as their fees are proposed to be very low.

This section sets out additional information about Registrants that is placed on the Public Register. The following changes are proposed:

  • (xii) to include expired as Emergency Class certificates may expire.
  • (xiv) setting out the requirements on the register for Emergency Class certificate holders.

This section addresses the information that the College may request from Registrants, pursuant to the Code. The following changes are proposed:

  • (viii) to include practice supervisor along with preceptor for those who do so in their practice.
  • (x) to update the information required relating to currency hours based on the College's recent experience.
  • (xv) to include proof of CPR which exists in a standard but is now added to the by-laws.
  • (xvi) for emergency class certificate holders, to provide names of supervisors, hours of practice and number of patient interactions.
  • (xvii) for General Class certificate holders who supervise another Registrant (in any class), to provide names of supervisees, locations, controlled acts performed, number of patient interactions and hours of practice.

This section applies to all Registrants. The proposed change is to reduce the timeframe for these reports from 30 to 14 days, which is in keeping with the shift from mail to email and on-line forms being used. Additionally, for emergency class certificate holders, they must inform the College of any change in a supervisor within two days.

This is a new provision that would see the costs associated with professional corporations indexed against the Consumer Price Index as has been the case for Annual Registration Fees for registrants.

The change proposed is to allow the CEO to approve Life Registrant status for those individuals who meet the criteria set out in the by-laws. This will reduce the workload of the Registration Committee, expedite the change in status for some Registrants and align the process to the application for registration process.

This new provision proposes that for those applicants for Life Registrant status who the CEO believes do not meet the criteria or who the CEO would propose to deny the request be referred to the Registration Committee for review. This is consistent with the application for registration process set out in the Regulations.

There are eight changes to the fee schedule as follows:

  1. Fee for clinical practice exams increased by $20 to $370.
  2. Retake of any one part of clinical exam increased by $20 to $170.
  3. Application to change class, emergency to general when the person has been in emergency more than 2 years - $275.
  4. Application to change class, emergency to general when the person has been in emergency less than 2 years - $100.
  5. Annual Registration Fee for Emergency Class - $100.
  6. Application fee for Professional Corporations increased by $85 to $485.
  7. Issuance fee for Professional Corporations increased by $55 to $305.
  8. Renewal fee for Professional Corporations increased by $50 to $250.


Other changes include the removal of the replacement certificates and ID cards and removal of any fees for duplicate receipts if the person obtains them directly from the portal.

3. DECLARATION AND SIGNATURE

Declaration*

I declare that the information that I have submitted is true and represents my own personal opinion or that of the organization that I am submitting on behalf of.

Signature


By checking the box below, you are affixing a signature to this form and indicating that this form and the information contained herein is bound directly to you.


4. COPY OF SUBMISSION

Below is a check box to enable you to receive a copy of your submission. It is highly recommended that you check this box and enter your e-mail address. This will enable the on-line system to send you a copy of the information that you have provided to the College.

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