Introduction

The Chief Executive Officer of the College is initiating a consultation relating to proposed changes to the College’s by-laws. The reasons for these proposed changes are set out below and in the attached compendium document.

This matter is under active consideration; however, no decisions have been made at this time. The College is seeking the feedback of its Registrants, system partners and the public.

This discussion paper is a part of the College’s augmented Consultation Program through which the College will actively engage stakeholders, system partners, and Registrants on topics where future changes are being contemplated or presently being proposed.

Proposal

In March 2023, the Council of the College approved proposed amendments to the Registration Regulation, Ontario Regulation 168/15. These proposed amendments established a new class of registration, the Emergency Class and enabled the Minister of Health or the Council of the College to open this class for registration. After detailed discussions with the Ministry of Health, the proposed amending regulation was sealed in August 2023.

To accommodate the new certificate of registration in the emergency class, certain by-law amendments are required that have been set out in the compendium document.

Additionally, whenever amendments are being considered for the by-laws, a thorough review of the full set of by-laws is undertaken in order to avoid later changes. This full review has also resulted in additional changes.  The following are the categories of changes being proposed that the reader will see in the compendium document:

EC	Proposed changes identified with the category EC are intended to accommodate the new Emergency Class Certificate of Registration. The kinds of changes identified are including individuals holding this certificate of registration on the public register and detailing the   information that is to be displayed.
H	Proposed changes identified with category H are housekeeping changes. Housekeeping changes typically involve typographical or grammatical changes that have not previously been found. These changes have no significant policy considerations.
PA	Proposed changes identified with category PA are intended to align the by-laws with Council policies. Council can and does amend its policies on a more frequent basis than by-laws and these policies can include policy elements that extend policies set out in the by-laws. These amendments align the by-laws with the added details that may currently appear only in policy. For example, eligibility criteria for appointments to by-laws may refer to not being the subject of a suspension due to non-payment of fees; however, policies refer to administrative suspensions that consider both non-payment of fees and failure to return information to the College. Aligning the by-laws to the policies is important for both clarity and consistency.
Fees	Finally, there are proposed changes to the Fee Schedule, which is Schedule 3 of the by-laws. This is necessary both to enable the Emergency Class; however, there are also changes to align the approach to Registration Fees for Registrants and Professional Corporations and to consider increases in fees that have not changed in the eight years since proclamation of the Naturopathy Act, 2007.

Current Information

The current by-laws of the College may be found on the College website for reference. The compendium document provided sets out only the provisions of the by-laws where changes are being proposed. Sections of the by-laws not included in the compendium document are not being considered for change and are therefore not a part of this consultation.

Impact on Registrants

Most of the changes being proposed would impact individuals seeking to register with the College under the new Emergency Class Certificate of Registration. Several proposed changes impact all Registrants. For example, requirements regarding CPR are not incorporated into the by-laws whereas previously they were set out only in the standards of practice. Thus, the requirement itself has not changed.

Financial Impact on College

Most Registrants of the College will not be impacted financially by the proposed changes, including the proposed fee changes. Those who are impacted are individuals taking examinations, where a small fee increase is proposed and those who have professional corporations where fees are proposed to be adjusted to match the overall fee increases that have been applied to certificates of registration for registrants.

Feedback

The College is seeking feedback from all stakeholders, including Registrants, the public, naturopathic organizations and other regulatory bodies. Feedback must be provided in writing by way of written correspondence (letter or email) or through the College’s online submission form (see below for more details).

All feedback will be published by the College on the College’s website. Feedback from organizations will be published such that a reader can identify the individual; however, feedback from individuals within the profession or members of the public will be published without naming the individual.

Regardless, all feedback must include the name of the individual submitting the feedback for validity purposes. Anonymous submissions will not be considered and will not be retained by the College.

Feedback can be provided to the following :

Written correspondence by mail:	College of Naturopaths of Ontario 10 King Street East, Suite 1001 Toronto, ON M5C 1C3
Written correspondence by facsimile:	(416) 583-6011
Written correspondence by e-mail:	general@collegeofnaturopaths.on.ca
On-line form:	By-law Consultation 2023 Submission Form

Instructions for Using the Online Submission Form

The on-line submission form for the College’s proposed by-law changes is an interactive and intuitive form. Before using this form, it is highly recommended that you review the proposed changes and make note of the areas where you wish to provide feedback. This will make the online submission process easier to use. The key questions are as follows:

Identification	You will be required to provide your full name and email address, as well as the name of any organization you may be representing. Providing your telephone number is optional.
Sections	You will be asked to identify all of the sections on which you wish to provide feedback. This will alter the online form to allow feedback on those sections only. If you do not identify a specific section for feedback, the opportunity to speak to that section will not be included in the form.
Submission Copy	At the completion of the feedback form, you can request that the online system provide you with a copy of your submission by checking a box at the end. It is recommended that you check this box so you can recall the feedback that you have provided.
Published Summary	A summary of all of your feedback will be published on the College’s website. All information provided will be published as submitted. The College does not edit submissions prior to publication. Names, emails, and other identifying information will be redacted from the materials prior to publication unless you have identified that your submission is provided on behalf of an organization.

Timeframe

The College will be providing the opportunity for feedback that exceeds the mandatory 60-day timeframe set out in the Regulated Health Professions Act, 1991. Consultation will begin on or before September 8, 2023, and will conclude on or about November 10, 2023.

Information Sessions

The College will be conducting one or more information sessions on the proposed by-law changes. This session will enable attendees to hear the key elements of rationale for the proposed changes; however, it will not be a session to provide feedback. Feedback may only be provided in writing as noted above. To facilitate these sessions, an opportunity to submit questions is being provided using this online form.

Watch the Events Listing on the College’s home page for the dates and times of upcoming information sessions.