Thank you to everyone who logged on to the virtual Public Engagement Forum on December 2, 2020.
In October, registrants and members of the public were invited to submit questions in advance of the meeting. CSHBC Board members answered submitted questions during the meeting. We have published those questions and their responses below and hope you will find this useful.
Please direct any additional questions to firstname.lastname@example.org.
Question 1: Would you please explain in simple terms the changes around the number of hours needed to work to continue to hold the SLP registration with the College? I’m interested, as my 3-year period is about to finish, and I was away from work due to a life-threatening situation my daughter went through.
Answer: Practice hours ensure that registrants are current in their practice, not just in their knowledge. We’ve had a number of registrants who had not practiced their profession since graduation many years ago. Other registrants held multiple registrations but were only practicing in one profession. The practice hours provision in the Bylaws is new, as of June 29, 2020, so the hours required for the current cycle, ending December 31, 2021, are prorated. There are a number of practice activities, in addition to seeing clients, that can count as practice hours. Registrants are encouraged to check the website Notices to the Professions website posted n June 29th and July 16th for the number required number, as well as the standard of practice entitled Attaining & Maintaining Practice Competence. If, after reviewing the information, you do not think that you can meet the requirement, please contact the College directly as we deal with extenuating circumstances on a case by case basis.
Question 2: What is the College’s view, or purpose, on having SLPs determining an area of specialty? I’m trying to determine the pros and cons.
Answer: Sections 155 and 156 of the CSHBC Bylaws include provisions to describe your practice, preferred areas of practice, and to declare a specialty. This is not required, but it is an option for you to consider. You cannot call yourself a “specialist”, but you can indicate any special technique or provision of services that you provide. It may be advantageous to do this if it helps inform the public about your practice. Registrants should refer to the policy Reserved Titles & Credentials under Registrant Resources on the College website for more details on how you can list and state your qualifications. Titles such as “medical speech-language pathologist” or “pediatric audiologist” are not reserved titles and should not be used. Registrants must also be familiar with Bylaw section 152 which addresses marketing practices and prohibits registrants from engaging in advertising practices that could mislead the public about the nature of their services.
Question 3: I work in a school district and I’m wondering why the College doesn’t prescribe specific information for us that comes from the Provincial Health Officer regarding COVID-19?
Answer: COVID-19 orders relating to the pandemic are issued by the Provincial Health Officer and are supported by the BC Centre for Disease Control and WorkSafe BC. School districts receive additional guidance and information from BC’s Ministry of Education, and registrants employed by a school district must comply with the directives from their employer, the school district.
The College’s mandate is to protect the public, so it’s vitally important that we relay any new, rescinded, or amended public health orders to our registrants. However, CSHBC cannot provide legal advice or offer our own legal interpretation on the application of those orders. We also can’t add additional information the relates to specific situations or locations. We encourage you to check the College website regularly as the situation is constantly changing and is very fluid.
Question 4: Under the new, amalgamated college, will registrant fees go up, down, or stay the same?
Answer: Registrant fees under the new college will be set by the new Board once it is established.
That said, regulatory authorities, large or small, operate on a cost recovery basis. Fees are set according the revenue required to regulate properly in the public interest. As the first multi-profession regulator in BC, CSHBC would argue that while a larger registrant base may result in some positive benefits due to the economies of scale, the regulation of multiple professions can have the opposite effect. As proposed, the new college would be mandated to regulate as many as 13 professions in the public interest, requiring an expanded administration and capacity for profession-specific councils. In addition, CSHBC’s policy of one registration fee for multiple licenses to practice is unsustainable and unlikely to continue under the new college.
Question 5: I am a Registered Hearing Instrument Practitioner (RHIP) and a Registered Audiologist (RAUD). I notice that I need to have Continuing Competency Credits in both professions for this 3-year cycle. Why was this changed and is it double what I used to need?
Answer: The CSHBC Bylaws were updated at the end of June 2020. In the interest of public protection, it was determined that registrants need to be current in professional knowledge for all professions they are licensed to practice. Please check the website, in particular the standard of practice called Attaining & Maintaining Practice Competence, for more information about determining how many credits you need for each profession that you are licensed to practice. For those dually registered, it is not double the requirement, and the requirements have been prorated for the current cycle because the new Bylaws came into effect part way through the cycle. As with practice hours, you should contact the College is you have any extenuating circumstances that preclude you from meeting the CCC requirement.
Question 6: Will there be another installment plan offered at registration renewal in March 2021?
Answer: Unfortunately, no. The impacts of the COVID-19 pandemic were unprecedented. Given that a state of emergency was declared just two weeks prior to the College’s 2020/2021 registration renewal deadline, the College’s Registration Committee passed a one-time emergency resolution that same day to allow registrants to pay 2020/2021 renewal fees under an installment plan, to assist them in meeting the financial challenges of practice disruptions and the general lockdown related to COVID-19. The Committee’s one-time emergency resolution was only possible under an emergency order issued by Government. The College’s bylaws have no provision for an installment plan.
While the vast majority of registrants fulfilled their professional responsibility by paying their fees on time despite the challenges, a small but relatively significant number did not. This resulted in a significant administrative burden to the College. As a small non-profit entity with a single revenue source, the annual budget development and approval process under an installment plan is untenable.
Question 7: My certified practice certificates expire in different years, which do not match up with the 3-year cycle for CCCs and practice hours. Is there a reason why certified practice is different?
Answer: Certified practice certificates may be applied for and granted at any time. They are valid until March 31st, three years after they are granted. If your certificates were approved in different years, their expiry dates will be different. You will be notified of your expiry date when your certificate is approved. We will be adding a courtesy reminder feature to the registrant portal. It is important not to miss the expiry date and to have reported 4 CCCs per certificate prior to renewal.
Because certified practice certificates are acquired at different times, and not every registrant holds a certified practice certificate, they cannot align with the general CCC and practice hours requirements, which apply to every registrant.
Question 8: Am I able to provide service virtually to a client if they leave British Columbia?
Answer: If your client is out-of-province for a short period of time with intention to return, such as a vacation, you may continue to provide services virtually, assuming that the services provided are amenable to virtual care. Registrants who provide virtual care should be familiar with the College’s standard of practice on virtual care.
If your client moves and establishes themselves more permanently outside of British Columbia, you must determine whether you need to be registered in that region to provide your professional services. If so, you must register yourself prior to providing virtual care. For example, if a client moves to Alberta, you may be required to register with ACSLPA in order to continue providing services to that client. Registration requirements and categories vary from place to place so you need to check with that jurisdiction directly.
Question 9: What is the difference between the roles of CSHBC, SAC, and Speech & Hearing BC?
Answer: Health profession regulators in BC are accountable to the general public and the Minister of Health, whereas professional associations are accountable to their members. Under the Speech and Hearing Health Professionals Regulation, CSHBC is mandated by government to protect the public by regulating its three prescribed professions.
CSHBC must remain impartial in the public interest and is not permitted to advocate for, or on behalf of, the professions or registrants it regulates. Unlike a professional association, it would be inappropriate for a regulatory authority to negotiate regulatory policy with the registrants it regulates on behalf of the public.
Speech-Language & Audiology Canada (SAC) is the national professional association for the professions of audiology and speech-language pathology, Speech and Hearing BC is the provincial association, membership for both is voluntary. Both associations advocate for their professions, on behalf of their members. Neither association has any regulatory jurisdiction over CHSBC registrants. For more information about this, please check the Our Regulatory Role page on the CSHBC website.
Question 10: I would like to ask a question to the board about the new requirements for additional practice hours and additional continuing competency hours for those who hold dual certification. Specifically, for audiologists, where the HIP scope of practice is a subset of the AUD scope of practice, with the single exception of the word “dispensing” in front of ‘fitting hearing aids’. Why is this new requirement being applied across the board for dual registrants instead of applying it only where there are substantial differences in the scope of practice? It may be logical to require additional evidence of competence where the scope of practice is very different as between and SLP and a HIP or between an SLP and AUD. The majority of audiologists are dual registered, so this new requirement is disproportionately impacting audiologists requirement for 1/3 more practice and continuing education hours.
Will the board take the opportunity of the upcoming changes with merged allied health college structure to review and recommend to the BC Ministry of Health amendments the regulations to correct the omission of ‘dispense’ from the scope of practice of an audiologist. Adding this single word would bring the scope of practice of audiologists in line with the other Canadian Provinces and clarify the two categories of AUD and HIP to be similar to complementary professions such as Optometrists/Opticians in BC.
Answer: By way of background, prior to the formation of the College, the Minister of Health determined that the professions of audiology and hearing instrument dispensing should be regulated separately. Under the Speech & Hearing Health Professionals Regulation, as set by Government, those seeking multiple licenses to practice are required to obtain separate registrations. CSHBC had no say in this matter.
There are several differences between the scopes of practice for audiology and hearing instrument dispensing. The ‘dispensing’ distinction is only one. Other differences in scope include: audiologists can diagnose, have different certified practice certificates available to them, can assess and manage children of all ages for a variety of hearing needs, and can delegate a broader range of clinical activities to support personnel (i.e., communication health assistants).
You are correct that a majority of RAUDs registered with the College are dually registered. There are also several who are registered as either ‘RAUD, RSLP’ or hold all three licenses to practice. That said, we are aware of numerous cases where dually registered RAUD, RHIPs have not dispensed in many years, if ever, since graduation, and this is not in the interest of public protection.
Similarly, CSHBC’s registrant base includes RAUDs who have retained their RHIP licence but are no longer dispensing in their current role and are not keeping current in knowledge (CCCs) or in the practice of dispensing (practice hours). Another variable we are required to consider, is the high variability in dispensing training that is provided by audiology programs across Canada and internationally. The College receives applications for registration from graduates of domestic and international programs with inconsistent curricula.
There are enough differences between the two professions to warrant CCC and practice hour requirements for both. The research, technology, and management strategies are constantly changing in both professions, and it is in the public best interest that a registrant be current for all professions they are licensed to practice. However, because of the scope overlap and courses which could apply to any profession, we set the required number of CCCs and practice hours low, and did not double them or triple them, for those holding multiple registrations. This helps accommodate those who work part time or are not practising for part of a cycle. We also broadened the CCC and practice hours categories, beyond client care only, to again make the requirements more manageable. Some credits or hours could apply to any profession (e.g. our online learning course on client consent). For this cycle ending Dec 31, 2021, for CCCs you would require 45 in Audiology and 5 additional CCCs in dispensing (if you choose Audiology as your primary license).
In the College’s view, advocating for changes to a scope of practice falls under the ambit of a professional association, not a regulator. In the past, other Canadian jurisdictions have signalled their interest in the BC model. And while the Ministry of Health has indicated that they are not considering changes to existing scopes of practice at this time, registrants and/or professional associations may wish to express their views to the Ministry directly.
Question 11: I’m a non-practising registrant. Am I still eligible to participate on a College committee?
Answer: Absolutely. All Full, Non-practising, and Retired registrants are eligible to sit on a College committee. The College is always actively seeking qualified professional members for its regulatory and advisory committees.
Expressions of interest are first reviewed by the Governance Advisory Committee, and any recommendations for appointment are then submitted for Board approval. We encourage registrants to check the CSHBC Opportunities page on the College website for current committee vacancies.