Notice to Membership
Further to concerns raised by the Chinese Medicine and Acupuncture Association of Canada (CMAAC) in a presentation made at the October 3, 2016 Council meeting of the College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario (CTCMPAO) and in a subsequent letter, the College feels it is important that all Members have the facts provided in our response.
The purpose of this Notice is to address CMAAC’s concerns but most importantly, to clarify both the facts and CTCMPAO’s position.
1) Language Fluency
CTCMPAO is currently reviewing its language fluency requirements and the assessment tools to determine if applicants are reasonably fluent in English or French. If CTCMPAO were to establish a new benchmark for language fluency, it would only be applied to "New" applicants.
If a new benchmark is established, the existing membership, in both Grand-parented and General classes will not be reassessed or required to demonstrate that they have met the new requirements.
Please note that, to date, CTCMPAO has not committed to a new benchmark. CTCMPAO is consulting with other jurisdictions, the Office of the Fairness Commissioner to determine if a new benchmark would be compliant with the Agreement on Internal Trade (AIT). If the CTCMPAO Council were to propose a new language fluency benchmark with new defined criteria, a full consultation process will occur.
2) The Doctor Title
The next "Doctor Title Working Group" meeting is currently being scheduled to discuss the next steps in developing a regulation for the doctor class. At the previous meeting, there was discussion about hiring a consultant to draft the regulations. However, after careful consideration, CTCMPAO is not in a position where it is ready to draft a regulation. There is much work to be completed before CTCMPAO would be in the position to propose a regulation for the doctor class; such steps include determining the appropriate competencies; the requirements to enter in to this class; appropriate level of education, and a proper method for assessment, such as an examination.
Most importantly, CTCMPAO needs to build a solid case demonstrating how and where the doctor class would benefit the public. CTCMPAO welcomes any evidence-based recommendations from the profession to support a claim that the public would benefit from a doctor title class.
To further build the case for the doctor class, it would be prudent for more Grandparented members to take and pass PLAR and transfer to the General class. The membership needs to demonstrate that the majority of them are competent practitioners at an entry level.
To date, more than half of the entire Grand-parented membership has yet to attempt PLAR with less than a year to the July 2017 deadline. The current focus should be encouraging members to go through this entry to practice competence assessment, before making a request to initiate a new advanced registration class.
3) Professional Member Representation
The Council’s current complement is seven (7) professional members and eight (8) public members, which is well within the allotment as described in the TCM Act.
Members of Council regardless if they are a professional or public are to serve in the interest of the public. Because regulatory Colleges are not "member-service" organizations, ‘self regulation’ is not jeopardized with representation of more public members over professional members. It does not take away the expertise and knowledge of those who sit on Council and Committees.
In fact, CTCMPAO’s public members often defer to the professional member’s knowledge when subjects related to standards, best practices and training are discussed. Decisions are often based on their recommendations keeping in mind that their judgements are in the public interest.
Although there are vacancies on the Council, CTCMPAO has had an ongoing and open invitation to members to participate on Committees as non-statutory Committee members. CTCMPAO welcomes anyone that would be interested in applying to serve as a non-Council Committee member.
CTCMPAO established criteria that only General Class members may sit on Council because only these individuals have demonstrated to date that they are competent practitioners.
Additionally, there are terms for certain districts that extend to the end of 2019. The Grand-parented class expires in April 2018. Should a Grandparented Council member not transfer to the General Class by the deadline, their position on Council would also expire, which is another reason it was decided that it is required for Council members to be a General Class member to ensure the Council maintains its professional compliment following the April 2018 deadline.
4) Financial Matters
CTCMPAO releases audited statements which are included in the Annual report. The 2016-2017 Annual report will provide more details on how membership fees are allocated which will be available in the coming weeks.
In regards to the annual membership fee increases, this was approved by Council in 2014, The fees were increased to address legal matters from court challenges, pursuing unauthorized practitioners, offset costs for electronic credit card transactions and building a surplus to ensure the CTCMPAO is sustainable.
Council decided to freeze the fee increase for the 2015-2016 membership renewal year to encourage members to go through the PLAR process. In 2016-2017, CTCMPAO is proceeding with decisions that had previously been approved and stated in the College By-Laws.
CTCMPAO has a healthy surplus and is reviewing its investments. However, there is uncertainty with the membership size moving forward because of hesitation from Grand-parented members to take PLAR and transfer to the General Class. To ensure sustainability, CTCMPAO has planned to ensure that it continues to operate should there be a significant reduction in membership in April 2018 when the Grand-parented Class expires.
Looking ahead, CTCMPAO has numerous activities, including a long list of discipline matters, pursuing unauthorized practitioners, plans for professional development opportunities, the doctor title class and the recent activity and recommendations from the Ministry of Health and Long Term Care in regards to how sexual abuse matters are treated by regulatory health Colleges. These are just some of the key initiatives to ensure that CTCMPAO can continue to protect the public, all of which will require significant financial resources.
Should you have any questions related to the facts set out in the Notice, please contact the Registrar Allan Mak, at firstname.lastname@example.org