Thank you to everyone who logged on to the virtual Public Engagement Forum on February 2, 2022.
In December, 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 [email protected].
Question 1: Given the new practice hours requirement, what exemptions do the College plan to allow for circumstances such as maternity leave, medical leave, compassionate leaves for school and daycare closures during the pandemic, parents choosing to work part-time while raising families, leave to care for a dependent family member, or reduced hours due to working in remote locations?
I am concerned that without a clear, compassionate, and reasonable proration of required hours, much needed professionals could be forced to leave the profession. For example, a mother experiencing two maternity leaves in the same cycle and wanting to work part time to raise a young family. Or a mother on maternity leave who requires further time off to look after a medically fragile or sick infant.
Answer: Under the Health Professions Act and College Bylaws, the College’s Quality Assurance & Professional Practice Program requirements must be met as a condition of licensure. There are no exemptions from program requirements. That said, for the current pro-rated cycle for practice hours, the College did allow for exceptions where registrants who were on leave or had exceptional circumstances were able to report the 360 hours over the entire 3-year cycle rather than the July 1st, 2020, to December 31st, 2021, portion of the cycle. There were 44 exceptions approved for practice hours, none were requested for CCCs.
The required hours are set over 3 years to accommodate part time workers and those who may be away from practice for a portion of the cycle. The option of a 1-year cycle was discounted for those reasons. In most situations, even with an extended leave and working part time following the leave, the 750 hours over 3 years is achievable. In a small number of situations where it is not, cases are reviewed on a case-by-case basis. There are several options available to those registrants upon their return to practice – for example, a medical accommodation, undertaking a practice review and support.
Question 2A: When do we expect to transition to the new Regulatory College of Allied Health and Care Professionals? What changes should we expect with regard to fees, certified practices, and anything else that might be important?”
Question 2B: Do you have any additional information about what a combined allied health specialist regulatory college would look like?
Answer: Unfortunately, since the release of the Government Steering Committee report on modernization of the health profession regulatory sector in August 2020, the group of colleges targeted for amalgamation under a proposed “Regulatory College of Allied Health and Care Professionals” has received no direction from the Minister or Ministry of Health, and several requests for engagement have been either postponed or were not responded to.
The group of colleges has continued to meet to strategize, undertake preliminary assessments, and request engagement with Ministry staff; however, while the Ministry remains pre-occupied with the pandemic, opioid crisis, amendments to the College’s governing Health Professions Act, and the amalgamation of the group of oral health colleges, the College is unlikely to know more in the short term. The decision on whether to amalgamate CSHBC into a new entity remains a Cabinet decision, and all decisions regarding the design, administration, and regulatory framework on any new college would be made by the new board, CEO, and Ministry of Health. Certification requirements are set by Government.
Question 3: What is CSHBC doing to protect client and family interests in the new MCFD system? … I am concerned that clients and families will not receive regular and thorough services with the new MCFD model as with other public health services. This also has the potential for RSLPs in BC to get a bad reputation. How will CSHBC ensure that clients and families receive the same level of care and services under the new MCFD model?
Answer: The College regulates the professional and clinical standards of the registrants it licenses to practice in the public interest, regardless of clinical context – i.e., clinicians, not clinics. CSHBC has no say in the operational policies of Government ministries or Government programs.
The reputational concerns expressed in the question fall within the ambit of professional advocacy and are therefore outside the scope of the College’s regulatory mandate. The College directs registrants to the CSHBC website page in respect of Our Regulatory Role for clarification of the jurisdiction of regulators versus profession associations, and/r to express your concerns to the relevant entity(ies) – i.e., Speech Language & Audiology Canada, Speech and Hearing BC, or the Ministry of Children and Family Development.
That said, recognizing that client advocacy is a professional responsibility and therefore different than professional advocacy, the College is currently reviewing the competencies and requirements for assessing and treating those with social communication disorders such as autism spectrum disorders. The announcement of the newly proposed MCFD program is very recent, and a great deal more information is required; however, the College will continue to monitor future developments.
Question 4: How will CSHBC improve communication with members in the future, for example raising rates, practice hours confusion, and notice when the portal was ready?
Answer: For clarification, CSHBC registrants are not “members” of the College. The College’s constituents are members of the general public. The College regulates its three professions as mandated by the Ministry of Health, to ensure the public’s trust in the professions of audiology, hearing instrument dispensing, and speech-language pathology is maintained. Notice of the most recent applicant and registrant fee increases, approved by the Ministry of Health, were communicated in a manner fully compliant with notice provisions as prescribed by the Health Professions Act.
With respect to your question about communications, both generally and about practice hours reporting specifically, while the volume of website communications has increased dramatically since the transition to the new website and database platform in 2019 …
College website publications (news stories, notices to the professions, FAQs):
- 2010 ~ 2019: 9 in total
- 2019 ~ 2021: 105 in total*
*Not including newsletters and bulk emails – an increase from less than 1 publication annually to more than 50.
… the College regrets the confusion surrounding the practice hours reporting function within the registrant portal. The reasons for this were twofold:
- first, due to the pandemic, a Ministry-imposed moratorium on all college bylaw amendments extended far beyond what was initially anticipated. This meant that the bylaws requiring practice hours for all licenses held could not be brought into force as anticipated.
- second, completion of the College’s portal change requests, submitted to our portal development vendor in 2020, were delayed by almost a year. In addition, on two occasions, the vendor inadvertently launched the practice hours reporting function before the development work, and proper user testing, had been completed.
Again, the College sincerely regrets these ongoing issues and the confusion and inconvenience caused to registrants.
Question 5: What are the College’s investments as listed in the financial statements?
Answer: Historically, the College has always invested its contingency reserves in low-risk, short- and long-term deposits. That said, the College is currently pursuing two changes in this regard:
- first, the College’s investment policy is currently being amended to allow for greater flexibility – i.e., the retention of an investment manager to explore the potential for improved investment yields via a socially-responsible and risk-managed investment portfolio.
- second, a number of colleges targeted for amalgamation, including CSHBC, are exploring the possibility of aggregating their respective reserves into a larger, collective portfolio, potentially resulting in greater income yields while simultaneously reducing the cost of management service fees.
Question 6: Will vaccinations for RSLPs be enforced/tracked by CHSBC and if so, how will this be done and within what time frame?
Answer: For clarification, regulatory colleges do not have the statutory authority to create such policies – i.e., orders mandating vaccinations for regulated health professionals as a condition of licensure. That authority falls within the jurisdiction of the Office of the Provincial Health Officer (PHO) under BC’s Public Health Act.
Part 5 of the Public Health Act confers emergency powers on the PHO. Significantly, Part 5 of the Act reflects that, during an emergency, a PHO order overrides other legislation such as the Health Professions Act, CSHBC’s governing legislation, as well as the bylaws of health profession regulatory colleges, including CSHBC. Further, the Act’s emergency powers provide that the PHO may, in an emergency, order a person to take preventive measures, including ordering a person to be treated or vaccinated.
Where the PHO enacts an order, colleges, and the registrants they regulate in the public interest, are required at law to comply. To date, no such order has been issued by the PHO.
The College encourages registrants with additional questions or concerns regarding mandatory vaccination policy to direct those concerns to the Office of the PHO and/or BC’s Minister of Health.
Question 7: My concern/question is the rapid increase in college fees from 2020 to 2021 and now again going into 2022 and possibly again in 2023. We are a small membership, so saying it is in line with other colleges’ fees doesn’t add up for me and many colleagues I talk to. Please explain the math you used.
Answer: Your questions are fully addressed in the College’s website News story, and comprehensive FAQ document, published on November 2, 2021 – we encourage you to visit the website to learn more about the history of CSHBC fee increases since 2010.
CSHBC understands and is sensitive to the fact that fee increases are challenging for registrants. The decision to raise fees is never taken lightly and is the result of careful consideration. A majority of CSHBC Board members are also registrants and are thus also affected by the fee increases.
That said, the economics underpinning the administration of health profession colleges is relative straightforward. As not-for-profit entities with essentially a single revenue source, colleges are mandated at law to operate on a cost recovery basis and are therefore fettered in their ability to implement other profit-generating tools. The College’s duties and responsibilities are also non-discretionary and ultimately revenue must meet expenditures.
Since 2017, after a decade of neglect, the College has vastly improved its regulatory capacity, and while a protracted period of significant organizational transformation is nearing an end, some work remains to be done.
As the first multi-profession college created in BC in 2010, CSHBC faces the twin challenges of regulating multiple professions over a very small revenue base. The new fee schedule, approved by the College Board and the Ministry of Health, brings the College closer to its required revenue target, and more accurately reflects the true cost of proper regulatory oversight to protect its constituents, the public, for whom the College is mandated to protect – i.e., by enforcing professional and clinical standards across three professions, not one. The recent decision was based on an assessment of the College’s true business operating costs and revenue required to ensure the College’s short- and long-term financial viability, protect its contingency reserves, and eliminate the risk of future deficit positions.
Question 8: I’ve been having some discussions with other school RSLPs in the last year or two about interpretation of College professional guidelines within school district settings. RSLPs in educational settings have quite a difference scope of practice, particularly in tiered service delivery models in which RSLPs are also supporting school teams/staff at a general level (e.g., at school-based teams, presentations to staff and in-services, classroom consultations etc.).
Part of our service provision involves student assessment and intervention, but not all of it is direct in nature. In Ontario, CASLPO has ‘addendum’ standards of practice guidance documents for those of us employed in schools. Could CSHBC provide school district RSLPs with similar reference documentation to help clarify our compliance guidelines for common situations we find ourselves in the school settings (especially compliance regarding consent and sharing of information)?
Answer: The College’s scope of practice for the speech-language pathology profession, established by the Ministry of Health, is the same regardless of the practice setting and is governed by the Health Professions Act and the College’s standards of practice. The roles vary from setting to setting – for example, private clinic, schools, hospitals, agencies etc. CSHBC standards are carefully drafted so that they can apply in any practice context and for any clinical population – the new College standard on clinical definitions is a good example as it includes consultative services. The other consideration is that even though some registrants are working in an education setting, they remain regulated health professionals practising under the Health Professions Act.
Tiered service delivery models also exist in contexts other than schools, and it is important to make sure that the standards apply broadly. If a registrant is unsure how to interpret a standard, they can access the College’s Practice Support & Consultation service for assistance.
CSHBC has deliberately eliminated referring to client services as direct (or not) because service delivery models vary and there is confusion about what “direct” actually means — for example, is virtual care direct or not? The College’s preference is to refer to ‘client’ or, in this case, ‘student services’ whether the client/student is present or not.
As regulated health professionals, CSHBC registrants are bound by provincial legislation that prescribes the rules around consent for sharing information and consent for clinical services. Consequently, registrants must adhere to those requirements regardless of where they work. It is for the safety of the clients/students, as well as registrants, that these safeguards are in place.
Question 9: Given the severe shortage of RSLPs, why are registrant standards so stringent for out of country applicants? It has become prohibitive to hire from out of Canada, and difficult to hire from out of province.
Answer: It would be inaccurate to characterize CSHBC registration requirements for internationally educated applicants as more “stringent” than for domestic applicants. The international academic and accreditation landscape for each profession is unique, each presenting different challenges. The College’s registration requirements are consistent with other speech and hearing regulators nationally, as well as other health profession regulators in BC as mandated under the College’s governing legislation, BC’s Health Professions Act. That legislation is designed to ensure regulators have the necessary tools to properly assess substantial equivalency across academic programs worldwide, often with significant variation in program curricula, and it is the College’s responsibility to protect the public by ensuring that international applicants meet the same standards of knowledge, skills, and ability, and entry-to-practice competence, as domestic applicants, not to lower its standards to accommodate labour market concerns, which is well outside its jurisdiction and mandate.
In the absence of an international accreditation regime, CSHBC does not recognize any international education programs for the three professions it regulates. For the professions of audiology and speech-language pathology, the College utilizes the National Academic Equivalency Framework (AEF) to assess equivalency against domestic programs such as UBC, which are endorsed by a national accreditation body. Currently, there is no national accreditation body overseeing domestic hearing instrument dispensing programs; however, the College is currently developing a hearing instrument dispensing AEF based on the national model develop for audiology and speech-language pathology – this will allow the College to eliminate a barrier for internationally educated applicants seeking licensure as hearing instrument practitioners, as well as graduates of international audiology programs seeking dual registration.
The same as domestic applicants, internationally educated audiology and speech-language pathology applicants seeking licensure in BC who have met CSHBC’s entry-to-practice requirements are granted Full registration after passing the entry-to-practice examination, or Conditional registration if they have not yet passed that examination.
Question 10: Why is there no part-time registration category? SAC and ASHA allow for this. Practice hours are no guarantee of competency.
Answer: Speech-Language & Audiology Canada (SAC) and the American Speech-Language Hearing Association (ASHA) are both professional associations that advocate for their members and professions, a completely different mandate to a regulatory authority with a legal mandate to license and enforce standards in the public interest. Membership in a professional association is voluntary, with no regulatory consequences for non-compliance or allegations of professional or clinical incompetence or misconduct. In addition, licensure is based on ensuring clinical and professional competency throughout an entire registration cycle, not hours worked. The purpose of SAC and ASHA as association membership is completely different. Further, registrants often have more than one part time position and change positions frequently – it would not be possible to track that level of detail. Ultimately — unlike BCCNM for example, with a registrant base of 60,000 — CSHBC does not possess the resources or infrastructure required to enforce a part-time registration category.
As for guarantees of competency, practice competency is defined as “a combination of knowledge, skills, abilities, and judgments that are necessary to practice a profession, within a defined scope of practice”. Practice competence is based on the core competencies of the profession and the application of the competencies is transferable across diverse practice settings and for various clinical populations.
This means that competency over time is dependent on multiple factors including being current in knowledge (CCCs), having recent practice (practice hours), and performance that complies with standards (practice reviews). It is accurate to say that practice hours alone or in isolation do not guarantee competence; however, practice hours are but one element of the College’s Quality Assurance & Professional Practice Program designed to ensure registrants maintain their competencies over the lifespan of their entire professional career.
Question 11: Why impose the 750-hour minimum on areas of practice such as articulation and language, especially for retirees? These do not require specialized training (such as in swallowing) where new techniques might arise. The CCCs would still be required.
RSLPs are in such short demand that imposing a 750-hour minimum limit on practice hours is shutting out most retirees from working as an SLP. Many of them have expertise that is valuable, and they may have time to help in a crunch. The years it took to become an RSLP, the exam that had to be written, and the yearly CCCs become meaningless in retirement if the minimum practice hours are not met. The RSLP then, by the College rules, ceases to become an RSLP and cannot practice in BC. This is truly a real loss of valuable RSLPs who might fill in for a short time or help ease an overburdened caseload. Please reconsider those practice hours for retirees, for new moms, for those on medical leave, and other extenuating circumstances.
Answer: For clarification, there is no such limitation on practice hours.
Practice is constantly changing, regardless of the service, and retirees who are still practicing have the same responsibilities to clients as other Full registrants. Practice hours look at recency of practice where CCCs are a measure of being current in professional knowledge. This is similar to registrants who choose to work part time – broken down, 750 hours over a 3-year cycle is approximately 20 hours per month, which is a very low part time allotment, and which could also be attained in locum /seasonal work. The College’s requirement accepts practice hours for professional work that is not client specific care, and there are several practice hour categories that include activities such as planning, consultation, and education, that can also be counted towards practice hours.