Currency Hours & Practising the Profession
Posted On: May 4, 2023
Following our initial audit of currency hours in early April of this year, the College has received some inquiries regarding what constitutes practising the profession, what happens if currency hours are not met and what options are available for individuals who practise in a role related to naturopathy but don’t provide direct patient care.
It’s important to understand the requirement and its intent.
Section 6.(1) of Registration Regulation made under the Naturopathy Act, 2007 requires that every Registrant in the General Class practice the profession for a minimum of 750 hours over each three-year period, meaning that each year the College looks at a Registrant’s practise hours for the preceding three year period. The intent of this provision in the Regulation is to ensure that Ontarians have access to safe, competent, ethical care from Ontario’s Naturopathic Doctors, the primary mandate of the College. It accomplishes this by ensuring that Registrants practice naturopathy for a minimum amount of time to maintain the necessary clinical competencies, knowledge, skill, and judgment for providing patient care. As such, Registrants in the General class are expected to be actively practising the profession in the capacity of a clinical practitioner, i.e., providing direct patient care.
Inactive Class
For those Registrants who are practising in a role related to naturopathy but are no longer seeing patients, there is an Inactive class of registration which allows Registrants to work within the naturopathic profession, without providing patient care, and continue to use the ND title provided the qualifier “(Inactive)” directly follows it. Inactive class Registrants are exempt from currency hour requirements and those related to the Quality Assurance (QA) program (e.g., continuing education).
Non-Clinical TCL
While not a class of registration, an additional option is available to Registrants who are no longer seeing patients, but who are required to maintain a General Class certificate of registration as a condition of their employment. This is the application of a Non-Clinical Term, Condition or Limitation (TCL). A Non-Clinical TCL is an agreement between the Registrant and the College outlining that the Registrant can stay in the General Class but cannot see patients and sets out any conditions that would need to be met by the Registrant if seeking to have the TCL removed. Individuals holding a Non-Clinical TCL are required to continue to meet all requirements of a General Class certificate holder, including currency hours (within their non-clinical naturopathic practise role) and the QA program. The application of a Non-Clinical TCL also requires use of the qualifier “(Non-Clinical)” after their professional title or its abbreviation to signal to the public that despite their General class certificate, they are not able to practise the profession in the capacity of a clinical practitioner, i.e., they cannot provide direct patient care.
Currency Audits & Outcomes
In 2021, the College began notifying Registrants that currency audits would begin in 2023 (looking at the period 2020-2022). Thanks to changes to the database management system employed by the College which now allows for more effective reporting on collected data. Yearly audits will continue to review a General class Registrant’s declared practise hours for the preceding three-year period.
Registrants who do not meet currency requirements, including the provision of direct patient care will not have their certificate of registration revoked, but rather will be notified in writing and provided the following options for addressing any currency hour deficiencies:
a) complete a refresher program approved by the Registration Committee. This involves self-assessing your knowledge, skill and judgment using tools provided by the College, against the standards, core competencies and controlled acts authorized to the profession, and then proposing a plan for remediating any potential areas where skill or knowledge may have atrophied for review and approval by the Registration Committee.
b) change to the Inactive class.
c) enter into an undertaking with the College for the application of a Non-Clinical TCL.
If a Registrant opts for none of the above options to remedy the identified currency deficiencies, the CEO is required, as a part of the Registration Regulation, to refer the Registrant to the Quality Assurance Committee for a Peer & Practice Assessment, in accordance with 6.(2) of the Registration Regulation, at their own cost.
If you have received a notice of audit regarding your currency hours, first, please don’t panic. Secondly, if you have questions, please contact Registration staff (registration@collegeofnaturopaths.on.ca ) rather than seeking answers through Facebook groups or other indirect sources. Finally, before responding to the notice, please give some consideration to how you practise the profession (i.e., whether you see patients or not). When choosing an option for addressing currency hour deficiencies, keep in mind that audits will continue annually and that the three-year period continuously rolls (e.g., in the first year of the audit the College looked at hours and activities reported between January 1, 2020 – December 31, 2022, next year the College will look at hours and activities reporting between January 1, 2021 -December 31, 2023, and so on).
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