Currency Consultation 2023 Submission Form

This is the online submission form for the Registration Policy 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 policy 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. REGISTRATION POLICY CONSULTATION

Please select all the sections in the proposed Registration Policy 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;

This section is proposed to be amended for additional clarity and to better reflect subsection 6(1) of the Registration Regulation with respect to the three-year cycle being a continuous one. Rather than noting the number of practise hours a Registrant may practise over “any” three-year cycle, it would instead note “each” three-year cycle. Additionally, information regarding outcomes for Registrants who have not met their currency hours has been proposed to be moved from this section to a new section titled “Currency Hours Not Met” for added clarity.

This section is proposed to be amended for additional clarity and to better reflect subsection 6(1) of the Registration Regulation with respect to when currency is audited, with the following proposed addition:


  • Except for a new General class Registrant who has not completed their initial three-year cycle, currency is audited annually for each preceding three-year period.


Amendments are also being proposed to stipulate that Registrants who are inactive (by class or by suspension) and returning to the General class will be audited for their first reporting year back in the General class and the two years preceding their date of inactivity.

This section is proposed to be amended to stipulate that Registrants in the General class must accrue a minimum of 750 hours of direct patient care over each three-year period and clarifies those activities in which direct patient care hours can be acquired, i.e.:


  • Patient interactions, and any administrative activities (e.g., billing or charting) or patient case-specific research conducted in the course thereof.
  • Supervision of patient interactions.

This proposed new section provides an onboarding timeline for implementation of the new requirement around minimum hours for direct patient care and sets out the date by which the College would begin auditing Registrants in the General class on specific direct patient care minimums.

This section proposes amendments to the acceptable evidence that may be used by Registrants in the General class (without a non-clinical Term, Condition or Limitation) to substantiate their practise hours/direct patient care hours. The following evidence is being proposed to be removed:


  • Confirmation that the duties and responsibilities outlined in a job description were performed.
  • Clinical research articles.
  • Clinical education plan.

This section is proposed to be amended for additional clarity and be inclusive of the proposed new direct patient care requirements, with the following proposed changes:


  • Setting out that currency is met by meeting the requirements set out in the Registration Policy
  • Noting that the cost of the peer and practise assessment is set in accordance with Schedule 3 of the by-laws.
  • Setting out that individuals who elect to change class or enter into a non-clinical Term, Condition or Limitation (TCL) by virtue of having practised 0 hours or 0 direct patient care hours will be required to undergo a review by the Registration Committee at point of seeking to resume direct patient care with a class change or request to remove the TCL.

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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