CSHBC has compiled questions that registrants and applicants may have about the College’s increased and new fees that are effective December 7, 2022. In keeping with CSHBC’s commitment to fiscal and administrative transparency, the College is providing detailed answers to the questions.
1. Why is CSHBC making adjustments to fees?
The CSHBC Board, supported by recommendations from the Finance & Audit Committee (FAC), determined that fee increases and new fees are required to achieve stabilized revenue for 2023/2024 and beyond, eliminate deficits, and maintain contingency reserves. The College is a not-for-profit entity created under BC’s Health Professions Act and must operate on a cost-recovery basis to fulfill its multi-profession regulatory role. The Board approved the increased and new fees and the BC Ministry of Health authorized the changes and established the effective date of December 7, 2022.
The fee adjustments are part of a five-year period of significant organizational transformation, which began in 2017 to eliminate gaps in capacity and enable CSHBC to properly regulate and maintain the public’s trust in the growing professions of audiology, hearing instrument dispensing, and speech-language pathology.
In 2018, the CSHBC Board, after careful deliberation and in recognition of its regulatory and fiduciary responsibility to the public and government, determined that CSHBC fees were set artificially low, and had essentially been subsidized for a decade at the cost of having an adequately resourced administration and regulatory capacity for the speech and hearing professions in BC. Given the number of years past Boards had postponed any fee increases, further inaction was no longer fiscally responsible or tenable
Therefore, the decision was made to increase registration and renewal fees in 2019 – the first increases since the College’s inception in 2009. When CSHBC announced another set of fee increases in 2021, the College noted that one more similar fee adjustment may be required in the future to meet the College’s stabilized, long-term revenue target, not including smaller incremental changes to address cost of living increases and inflation over time. The fee increases and new fees now being announced represent the additional fee adjustment that was anticipated.
CSHBC did not make the decision to increase certain fees and introduce some new fees lightly. The college understands that this decision may create challenges for registrants and applicants. The Board considered all options and determined that making the fee adjustments was, on balance, the course of action the College should take.
2. Will more significant fee increases be needed in the foreseeable future?
CSHBC continues to have relatively fewer staff compared to national speech and hearing regulators, which typically regulate only one or two rather than three professions and no Ministry-mandated certification programs. But as a result of the organizational transformation, the College has vastly improved its regulatory capacity and attained a stabilized, long term revenue target. CSHBC does not anticipate more significant fee increases in the foreseeable future, aside from smaller incremental adjustments to address cost of living increases and inflation as required.
3. Why is the College increasing fees when new legislation to replace the Health Professions Act has been tabled and amalgamation of health regulatory colleges is on the horizon?
On October 19, 2022, the BC Government introduced new legislation to replace the Health Professions Act that governs health regulatory colleges in the province. According to the BC Government news release on the replacement legislation, the Health Professions and Occupations Act, it will enable a “streamlined path to reduce the number of health regulatory colleges through amalgamation.” The news release also notes that the BC Government “will continue finalizing the amalgamation of colleges from 15 to six.”
BC health regulatory colleges, including CSHBC, are in regular communication with the Ministry of Health and other BC health regulatory colleges about developments with the new legislation and amalgamation. That said, it is unknown how long it will take for the legislation to pass through the required stages before becoming law, and if the legislation becomes law, how long the high-cost transition will be to an amalgamated college that takes over regulation of health professionals currently regulated by CSHBC. Until that happens, the work of regulation must continue. Regardless of any movement toward amalgamation, the College remains a not-for-profit entity created under the Health Professions Act and must operate on a cost recovery basis to fulfill its regulatory mandate under the law.
4. Can CSHBC provide more of an explanation of the organizational transformation to increase capacity that has taken place since 2017?
During the five-year organizational transformation that began in 2017, CSHBC has incrementally and carefully evolved from being severely understaffed, to having a staffing level that is adequate for properly regulating three professions and 10 certification programs.
In 2017, the entire CSHBC staff complement consisted of two full-time employees, including the Registrar & CEO and another staff person, plus one part-time consultant. This equaled 2.6 Full-Time Equivalents (FTEs). This staffing level compared to audiology and speech-language pathology counterparts with far more staff resources in Ontario (18.0 FTEs) and Quebec (22.0 FTEs). This was a completely inadequate and unsustainable number of administrative personnel for managing what was then a registrant base of 1,800 practitioners, three professions, and ten certification programs across an entire province.
Since then, the College’s staff complement has increased to the current number of 12.8 FTEs to manage the College’s growing registrant base of more than 2,000 and core operational areas – including, but not limited to, finance and administration, registration and certification, quality assurance and professional practice, and complaints and investigations.
As a result, CSHBC is much better positioned to manage core functions of the College, including but not limited to:
- Administering applications for registration in three professions, initial registration of applicants who have met requirements, and renewal of registration.
- Administering the CSHBC Hearing Instrument Dispensing Practical Examination.
- Administering application for and renewal of certificates in 10 Certified Practice certification programs.
- Maintaining four Quality Assurance & Professional Practice Program modules: Practice Reviews, Practice Hours, Continuing Competency Credits (CCCs), and Professional Practice Information.
- Offering the services of CSHBC Professional Practice Advisors (PPAs), who provide professional practice information and guidance to registrants to ensure adherence to regulatory requirements. There has been a high demand for this service.
- Administering four online learning courses.
- Managing a complaints and investigations caseload that has significantly increased. In the last year alone, the number of new investigations increased from 17 (2020/2021) to 31 (2021/2022).
- Communicating regularly to registrants, applicants, and other stakeholders. In its first decade, CSHBC issued a total of approximately nine news stories, an average of one per year. In 2021/2022, CSHBC issued 37 news stories and 24 notices to the professions.
5. Why is the Hearing Instrument Dispensing (HID) Practical Examination fee increasing from $650 to $950?
CSHBC administers the newly revised HID Practical Examination, one of two required exams that applicants to become a Registered Hearing Instrument Practitioner (RHIP) must pass. A cost analysis of administering the HID Practice Exam twice annually shows that the cost to the College per candidate is approximately double the increased fee. Costs include staff resources, contracting invigilators and examiners, and booking the exam site for multiple days. Therefore, CSHBC continues to significantly subsidize the exam. The fee increase is needed for CSHBC to recoup a reasonable proportion of the College’s investment in the exam that is in line with the actual administration costs.
6. Why has CSHBC introduced new fees for applying and registering for multiple registrations?
CSHBC registrants may apply and register for (when meeting the requirements) a “first”, “second”, and up to a “third” registration as a Registered Audiologist (RAUD), Registered Hearing Instrument Practitioner (RHIP), and/or Registered Speech-Language Pathologist (RSLP). In the past, there was one application fee, registration fee, and registration renewal fee for registrants with multiple registrations, regardless of the number of registrations held. That fee structure did not reflect the true cost to the College of administering applicants and registrants with up to three registrations. As set by the BC Ministry of Health, each of the three professions regulated by CSHBC has an individual scope of practice and restricted activities under the Speech and Hearing Health Professionals Regulation, as well as unique application and registration requirements that must be thoroughly vetted. The College is introducing new fees for multiple registrations to more accurately recover costs involved with being a multi-profession regulator.
7. The application and renewal fee for a Certified Practice certificate remains $100 per certificate, however, there will no longer be a $200 maximum fee regardless of the number of certificates applied for or renewed. The fee for each certificate applied for or renewed will be $100, with no cap if multiple certificates are applied for or renewed. Why has this change been made?
As required by the BC Ministry of Health, before performing specific speech and hearing health services that have been identified as involving high-risk practices, CSHBC registrants must apply for one or more Certified Practice certificates. Registrants who wish to hold Certified Practice certificates on an ongoing basis must renew them yearly. As required by the Ministry under the provisions of the Speech and Hearing Health Professionals Regulation, CSHBC’s current certification mandate includes administration of 10 Certified Practice certificates.
It has long been the case that the cost of administering application and renewal of Certificate Practice certificates has been heavily subsidized by fees from registrants who don’t hold certificates. Each Certified Practice certificate application and renewal costs the College a significant amount to process – more than six times the $100 fee to be charged for applying for and renewing a certificate. This is due, in part, to the labour-intensive work required to review applications and renewals, which must be thoroughly vetted given the high-risk practices that the certificates authorize. In addition, there are additional costs incurred for maintaining CSHBC’s online registrant system, reviewing and updating certification program content, investigating cases of clinical incompetence or unlawful practice, and other Certified Practice-related matters.
CSHBC must operate on a cost recovery, not-for-profit basis, and must also consider principles of equity and probity when determining the level of subsidy that it can reasonably accommodate via other areas of operations. Therefore, the removal of the cap on fees for application and renewal of multiple Certified Practice certificates is necessary to recoup a reasonable proportion of the College’s costs in administering the Certified Practice certificate program.
8. Are the increased and new fees helping to cover ongoing costs of the College’s office at the BC Regulatory Hub in downtown Vancouver?
In November 2019, CSHBC relocated to office space in the BC Regulatory Hub in downtown Vancouver, along with 10 other health regulatory colleges. This was a necessary move to accommodate additional staff and benefit from both economies of scale and increased collaboration with our regulatory partners.
The cost of leasing office space in the BC Regulatory Hub is not a significant driver of CSHBC’s fiscal status and the decision to adjust fees. The College has been able to reduce its office footprint, as 50% of staff work remotely in various BC locations. CSHBC also benefits from a number of operational cost savings that have resulted from being based at the Hub. These include access to shared services such as IT and reception, and access to meeting spaces for board, committee, and staff meetings. As well, there has been substantially increased collaboration between the health regulatory colleges based at the Hub, and with other colleges in BC Health Regulators, which is administered at the Hub.
9. How was the timing of announcing the increased and new fees determined?
CSHBC appreciates that registrants and applicants would like as much notice as possible about adjusted fees. The approval process for fee adjustments can take as long as a year, and the College must adhere to government, BC Ministry of Health, and fiscal timetables. On September 9, 2022, the CSHBC Board approved the current fee changes, and on September 21, 2022, the BC Ministry of Health authorized the fee adjustments, assigning an effective date of December 7, 2022. CSHBC scheduled communications on the increased and new fees around these parameters.
10. Can registrants pay their fees through installments or a payment plan?
Unfortunately, no. As not-for-profits under the Health Professions Act, health regulatory colleges cannot operate effectively based on a revenue stream that might be forthcoming over the fiscal year. In addition, CSHBC cannot offer what would essentially be a credit scheme for payment of a professional license to practice fee. Accordingly, this means that the College cannot offer registrants anything akin to a payment plan option for their licenses to practice throughout the registration cycle.
11. Can fee increases be prorated for registrants who work part-time or for only a proportion of the year?
Unfortunately, no. As a small regulatory college, the College cannot operate effectively based on an aggregate revenue stream that might be forthcoming over the fiscal year. The College budgets for activities to effectively regulate its three professions and ten certification programs based on registrant competency. This is impacted by the number of registrants on the Public Register and number of certificates held, not the number of days each registrant works.
12. How can registrants send comments about the increase and new fees to the CSHBC Board?
Any comments about the fee increases may be sent to the CSHBC Board of Directors by email, in care of the Registrar & CEO at [email protected], or in a letter, addressed to the College of Speech and Hearing Health Professionals of BC, Board of Directors, sent to the College’s mailing address. All emails and letters received from applicants and registrants regarding fee increases will be submitted to the Board.