Please note, this consultation is now closed. Thank you to everyone who provided comments.
About this consultation
The Fees and Remuneration By-law has been reviewed by Council and the College is consulting on several proposed changes.
The goals of Council’s review of the by-law were to:
- Ensure that fees and fee practices are equitable and proportional.
- Ensure that fees reflect operational resources and to streamline fee practices and processes.
- Alignment of the by-law with other College governing documents.
Council and staff collaborated on this data-informed process to propose an updated by-law. We also reviewed the by-law through an equity lens and considered potential unintended consequences. Lastly, in reviewing the by-law, an environmental scan took place to compare fees, fee practices, and per diems with those of other regulated health Colleges.
The proposed changes to the by-law are open to a 60-day public consultation from Thursday, April 4, 2024 to Monday, June 3, 2024. Following the 60-day consultation, the Fees and Remuneration By-law will be brought to Council for final review and approval at its June 2024 meeting.
Consultation request
The comparison table outlines the current provisions in the by-law, along with proposed changes and their respective rationales.
Update: April 8, 2024.
To provide greater clarity on the proposed changes to the Fees and Remuneration By-law, we would like to highlight three substantial areas of change for consideration. Please refer to the full consultation table to learn of all proposed changes and give your feedback after reading the document.
Changing the automatic annual increase in fees:
Currently, registrant fees in all classes of registration increase 2% per year without any option for the College to raise fees by a lesser amount. The proposed by-law allows for consideration of an inflationary increase that may be up to 2% and rounded up to the nearest dollar. This would allow for the College to decide to freeze fees in a given year, as is being proposed for the 2024 renewal period.
Elimination of installment payments:
Council is proposing the removal of installment payments in article 4.8. Current practice involves allowing payment of the annual fee in two installments on specific dates. Registrants facing financial challenges will still have the option to request a modified payment plan.
Changes to administrative fees in some areas:
The College is proposing to increase administrative fees in some instances and removing administrative fees in other areas. Please review the comparison document for more information.
How to provide feedback
You may submit your comments on this page below until Monday, June 3, 2024. You may also email your comments to cmo@cmo.on.ca.
Anonymous on June 2, 2024
I agree with the freeze of fee increase and change to an increase of “up to 2%”. I don’t agree with removing the installment option. I don’t agree with any of the administrative fees being increased.
Midwife on May 31, 2024
I agree with all the reasons previously mentioned that the installment option should still exist!
Anonymous on May 27, 2024
I agree with what those have already said but wanted to reinforce that removing options for payement reduces accessibility and causes financial stress and strain during a time where folks are struggling to pay for groceries and/or mortgages.
The fees we pay conpared to other associations/colleges are high, and as said by others, doesn’t seem to fouctuate base on caseload either.
For a province/profession where there is retention issues, increasing fees and making it harder to pay them is so unhelpful.
Anonymous on May 26, 2024
The proposed changes from the CMO are seeming more and more like a path to removing equity and access for midwives being able to continue working.
Our fees are exorbitant already and removing the ability to have payment plans is an atrocious step backwards with the assumption that midwives are able to make this work easily for themselves or their families- We know this also puts marginalized midwives at an increased risk and isn’t that one of the CMO framework goals to protect and support? It is not supportive to say there “plans can be made” when there is no clear outline of what that would look like, what the rubric for approval might be, and an acknowledgement of increased burden on already overworked midwives to complete this process with the potential of being denied. The CMO clearly states ” Equity: We identify, remove, and prevent systemic inequities.”, “Transparency: Transparency
We act openly and honestly to enhance accountability.”, and “Integrity: We act with humility and respect and apply a lens of social justice to our work.” Where is the lens of social justice and prevention of systemic inequities with this proposed change? Where is the transparency in how the proposed framework to support those who will be most impacted, was there a consultation within the CMO DEIA working group? What actions were taken by the CMO prior to recommending this change to ensure equitable best practice?
The CMO needs to look hard at their own overhead fees and decide whether the downtown rent and high costs could perhaps be reduced. It is concerning that we saw that the CMO was able to run very well remotely during lockdown and yet we are paying the cost for the office space and looking at an increase? We could much more effectively manage these costs with reductions rather than continuous increases.
It’s exceptionally challenging to feel supported in registering with the CMO when we are paying so much money and we receive such little support when required. The amount of times I have received the “you’ll hear back from us within 2 business days” that require excessive follow up contacts and still receive no information is abysmal. If we are looking to increase overhead costs, increase barriers to financial payment and stability, please make the plans and contacts accessible! While I understand the CMO is there to “protect” the public, it’s still a provincial licensing body that is making it harder and harder to want to stay registered.
Midwife on May 21, 2024
Adding a message to say my thoughts reflect the same as others..don’t increase fees, reduce your overhead, move to monthly payments. Also a thought – why is our college not working to try to combine with the CNO or CPSO, similar to BC? It would help to reduce our overhead registration fees and provide us with the option of a MUCH cheaper health plan. Our fees are absolutely insane and the overall increase of midwives does not seem to be helping to reduce these fees at all. Big changes need to happen.
Midwife on May 21, 2024
I do not understand the rationale for eliminating payment of fees/dues in instalments. If “Registrants facing financial challenges will still have the option to request a modified payment plan”, this seems like it will just be an added layer of bureaucracy for midwives to indicate or demonstrate their need. Why not just retain the instalment option?
Midwife on May 21, 2024
Being able to pay the fees in installments is vital. Evan as a senior midwife, having to pay the fee in full will potentially cause undue financial strain.
Midwife on May 21, 2024
Is midwifery not supposed to be about accessibility, equity and holistics of the individual. The lack of equity and consideration of individual midwives situations displayed by the exorbitant fees is appalling enough. But now to force midwives to pay the exorbitant fees in a way that may cost midwives accessibility and feasibility to provide midwifery care or to tend to other vital financial responsibilities is disgusting. We work too hard with too little compensation, recognition and consideration from our officials and interprofessional colleagues for this profession to continue to stay afloat long term if things continue on this trajectory.
Midwife on May 13, 2024
I would love to see the CMO consider the different ways midwives work (and hope to work in the pursuit of sustainability in midwifery) when making changes to the Fees and Renumeration by-law. As a midwife who has recently returned to clinical practice part-time, after an extended period of time as an inactive member, I am discouraged by how prohibitive annual fees are for midwives to continue in the profession if they are not working full-time or close to full-time. For a midwife billing 20 BCC’s a year, the percentage of income that goes to annual fees is exhorbitant. In consideration of options that would enable me to stay in the midwifery profession while I have young children, I can’t even consider what could be described in other fields as casual part-time, as I couldn’t afford the fees. Is there not a way to modify fees based on workload? I can imagine that this is difficult to implement, but without this type of solution, I think midwives will continue to get pushed out of the profession.
I would also like to suggest that there not be an increase in the annual corporation renewal fee. CPSO charges $175 for an annual renewal and we currently pay $250. As part of the renewal, we also need to purchase a corporate profile report, which now costs approximately $80. I don’t understand how submitting a renewal application once a year warrants a $50 increase above $250, which already feels high.
Anonymous on May 11, 2024
I do not agree with these changes. As many others have said, our fees are already prohibitively high and we are yet to benefit from the JCS.
Midwife on May 10, 2024
We already pay inequitably exorbitant fees (CMO and AOM) as midwives at a time when my colleagues are dropping like flies. Taking away the option to have. Monthly payments, but making people jump through hoops if they want to pay that way, is another example of how out of touch our college is. It is time for our college and our association to start becoming more aware of the body of people who work under their purview. It is also time for them to become more fiscally conservative and accountable.
Midwife on May 8, 2024
I work both in Ontario and another province. I am considering resigning my registration in Ontario because the AOM and CMO fees do not make much financial sense to even switch to inactive when I can work elsewhere in the country for a small fraction of the cost and make more money overall (even without including the savings in fees). Literally less than 2% of the combined Ontario fees.
My non-midwife professional colleagues were complaining about their high registration fees of $1000, which they can apply for these to be fully reimbursed by working, for some portion of the year, in a rural or remote area. My colleagues were aghast at hearing the fees we pay. They wondered if our pay was higher and I had to assure them that sadly that is not the case. I have worked in rural areas my entire career, without full caseload generally because of the burden of travelling long distances, caring for more complex clients, and I have never received any incentives for doing so. Because the pay was less, proportionally more of my income went to being registered while being paid less and there is no recognition of this at all.
I appreciate that the CMO is looking to increase the fees less than the previously mandatory 2% but it is frankly not sufficient and insulting.
Midwife on May 8, 2024
I have always been appalled by the extortionate fees required for the privilege of being a midwife. As a part time midwife, it basically means you work 2 months with no income as that money goes towards fees. Removing the option for instalments adds injury to insult. Surely in this day and age, it can’t be that logistically difficult for us to have our money automatically removed from our accounts on a quarterly basis?
Midwife on May 8, 2024
The vast majority of these proposed changes are inappropriate and out of touch with the realities of being a midwife. To take away the option of paying in instalments on such a large fee is a terrible idea. Given that the AOM can manage monthly instalment payments for the same number of people it seems a completely reasonable expectation that the CMO should be able to offer the same option. When fees are due in October this is also incredibly challenging for new midwives who now have to pay almost $3000 in a lump sum given most have not yet discharged any clients and may not have started to earn any income. It is completely unreasonable. To say that this is an overwhelming logistical challenge when so many other organizations can offer it would suggest that the CMO does not have competent administration.
The fee to return from a leave is also completely unreasonable. Given that midwives have to pay such high fees while inactive it does not make sense to require an additional fee on top of this to return to active status. Surely the large fee for inactive status can be used to cover the administrative work to move a midwife from inactive to active status. If the CMO wants to charge a fee to change from inactive to active status then they should not be charging inactive midwives anything during the time they are inactive.
Midwife on May 8, 2024
One of the reasons our fees are so high is economies of scale – as both the RNAO and CPSO have so many members, the cost per individual is significantly less especially as the liability burden on obstetrical care providers is so high. However, I think the fees for inactive are disproportionally high. It discourages midwives who need time away from the profession from staying with that status, and makes it doubly difficult to return once you have completely resigned.
Midwife on May 3, 2024
Increased fees are unacceptable. It is the responsibility of the College to manage within their financial means, and not pass costs on to midwives, who are already leaving the profession in droves. Increasing fees will only introduce more barriers and disincentivize remaining a midwife.
Anonymous on April 20, 2024
The CMO needs to look at drastically reducing costs and therefore fees, not increasing fees. I disagree with any increase in fees. We need incentives to remain active and inactive members. The fee for inactive status needs to be drastically reduced, and at least a cap on the active fees.
Anonymous on April 14, 2024
I agree with many of other comments here I do not support these fee increases, they are proportionally difficult to afford. I am also concerned about the removal of the instalment fees. There should be a move to monthly rather than taking away instalments. This disadvantages midwives who are struggling financially and new registrants who have high upfront costs, student loans.
Midwife on April 11, 2024
I am really upset about our exorbitant CMO fees. this recent increase up to 2706 is roughly a thousand dollars over where our fees were.
So the CMO has decided to charge midwives a FULL COURSE OF CARE, just to have a job!!! A full time midwife carrying 40 clients, a part time midwife carrying 20+ clients? has to send an ENTIRE course of care to the CMO just so she can have a job. between our CMO and AOM fees and continuing education/recertifications, midwives basically provide care for 3 clients FOR FREE every year just so we can work!!
our CPSO colleagues pay $1795 yearly.
$2706 per active midwife per year is ridiculous. no fee installments is ridiculous.
midwives are already unpaid for a myriad of work we provide.(eg first trimester losses) because our fee schedule with the government doesn’t allow for us to receive ANY funding for care less than 12 weeks and/or midwife attended birth. I and my midwife colleagues have provide care to countless women in clinic and over the phone and at their homes following first trimester losses and don’t get paid for that work. and yet we’re charged an entire client by our college so that we can work and provide that unpaid care
I am just outraged at the cost of our college fees and I don’t understand where all this money we pay to the CMO actually goes. ridiculous.
Midwife on April 11, 2024
I am not in favour of an increase in fees this significant. Yes, costs rise with inflation, but CMO overhead should not be managed by midwife members. We’ve worked hard – and paid through the nose – to see our compensation increase and now that little extra is going to be consumed by the CMO?
I’ll have to pay a lump sum fee for the year on return from a maternity leave when over a quarter of my mat leave income was consumed by benefits payments? I have to pay $100 just to return to active status? That seems punitive to parents. A classic misogynistic move. Punish women for having families.
I know the CMO exists to protect the midwifery consumers and not midwives, but Ontario midwifery will cease to exist if attrition continues at the rate we’re seeing. Practicing in Ontario is already so expensive. Support midwives, do not carry out these prohibitive fee increases and schedules.
Midwife on April 11, 2024
The AOM has found a way to allow monthly installments. The College must do the same, or at the very LEAST allow the fees to be paid in two payments like it has been done until now. Talk to the people at AOM and find out how they do it. You cannot bring up the excuse of a hugs drain on the resources twice per year when the Association does it 12 times. You must find a way to at least keep it as it has been.
Member of the public on April 10, 2024
As a midwifery student these proposed changes are terrifying and out of touch. I completely agree with the other points made by others commenters. Though I would also add that as a previously registered health care professional in Ontario my regulatory college did not charge annual fees as steep as this and yet they were still able to protect the public. Please listen to your members and reassess.
Member of the public on April 10, 2024
These fee increases are going to hurt the public. Burdening under supported healthcare workers with significant steep increases de-incentivizes knowledgeable , skilled, talented and compassionate midwives from remaining in the field. As the purpose of the college is to act in the best interest of the public and protect us, this can best be accomplished by supporting midwives. These increases are out of line with cost of living pay increases of your staff members putting further behind every month. The public is served and protected by supporting incentivizing talented individual practices. If the college requires an increase in finances starting by looking at ways to minimize waste and downsize expenses of the college and advocating for appropriate subsidies from the government
Midwife on April 10, 2024
I echo the sentiment of the rest of the profession it seems. Why anyone needs offices since Covid is beyond me. Home was good enough during the pandemic and probably a great deal cheaper than Toronto real estate. I do not agree with any fee increase. Fees continue to rise and yet very little (if anything) is given in return. We continue to fight for equal pay and basically have to work 1-3 bcc for some to simply pay for the fees to have the privilege to work (AOM included) How is the increase more than inflation? I honestly thought NMC was expensive when it moved from 75 to £125 a year . Maybe the CMO could take note of the other midwifery governing bodies whom also manage the same job for next to nothing in comparison to CMO fees. It certainly feels like we are fighting a loosing battle as a profession. Increased workload without any financial gain, lump some payment (even the AOM are stopping monthly paying adding tot the financial burden) benefit cost increase whilst the cover is getting worse.
As for inactive fees… what is this even paying for. Who pays NOT to work? Could they simply not be put ok hold during the leave.
I hope in future someone stands up for the midwives who continue to work on the front line and advocates for us as fiercely as we do our clients.
Midwife on April 10, 2024
Here to echo what countless other midwives have already said. please figure your overhead out, work diligently on reducing spending, for goodness sake move to more affordable office space, allow us to pay in monthly installments. our fees are so high as is. your model is not sustainable as it is and college members are paying the price for it. please fix it.
Midwife on April 10, 2024
I do not agree with or support any increase in fees. Midwives already pay one of the highest college membership fees out there in the healthcare industry. Especially the inactive fee. Asking someone who’s not currently practising to pay over $1000 a year just for the possibility of returning to work when they are able, is ridiculous. It should be cut in half at least. Increasing the inactive fee will cause many more midwives who are currently on leave to simply resign instead of maintaining the possibility of returning. We already have a horrifying attrition rate. Let’s not make it worse. Let the inactive midwives remain inactive for less, and perhaps some of them will return to work when they are ready. Once they resign it’s so much more difficult and more unlikely they will ever return. I know that’s the case for myself and many of my Midwife colleagues. And active Midwives who are trying to practice part time already struggle to pay the enormous membership fees. Midwives in Ontario are dealing with a lot right now. The college should support them not charge them more. The college needs to find other ways to reduce their costs. Perhaps finding less expensive rent for their office or look at salary cuts.
Do not increase membership fees active or inactive.
Anonymous on April 9, 2024
I agree with other comments. Fees continue to increase with more restrictive access to services and despite the fact that fees were supposed to decrease with the growth of the profession. It costs money to go inactive when someone is usually going inactive due to a leave of some sort which often results in significantly less income to pay for the fees the CMO is charging to go inactive. Why is the inactive fee so high, what exactly are we paying for when we are not working????? Seems like we are paying to be penalized for a leave. This is ridiculous, punitive and I agree makes it more and more difficult for people to remain in the profession. Then when you want/need to become active again you have to pay more fees plus the full amount of the active membership fee when you have not been working and therefore likely do not have the money to pay these fees. Plus when you have gone inactive for ANY reason you are scrutinized very closely, and often restricted in your ability to work when the CMO FINALLY decides you can work again as the process to become active again has become a very lengthy one over the last few years and has caused many delays in people being able to return to work. This process further penalizes people when they are already often in a vulnerable financial position.
I have also thought for a VERY long time (as I have been in the profession for more than 20 years now) that we should have the option to pay the CMO fees monthly as the AOM does. Why has the AOM been able to figure out this option but the CMO has not and is in fact now making it MORE difficult to pay fees we have no choice but to pay if we want to continue in the profession. I understand the role of the CMO is to protect the public but this should not come at the expense or determent to its members, the midwives who are providing care to the public.
As for hybrid work I agree with others in that it’s not my problem your overhead is high. If you are paying for office space then paying for people to work from home it seems you would be paying more to accommodate this model of work. Plus I presume you are paying double for services such as phones, internet and other office expenses as the CMO would be paying for all of this in the physical office in Toronto plus in peoples homes. If the AOM is also working in a hybrid model why not have one office space for both CMO and AOM if you have to continue with any physical office space at all.
Midwife on April 8, 2024
I echo other comments that fee increases are unmanageable for midwives; we are STILL struggling for pay equity and grossly underpaid. I understand that fees will not be increasing in 2024; however, that is small compensation. We were assured that as the profession grew, the fees would decrease. When will this happen? I also understand the CMO is already doing a hybrid model, with some staff working from home; therefore decreased overhead costs will have to come from moving away from Toronto real estate. As for the Inactive class fee, this should be reduced even further. $1,187 + $50 admin fee is a hefty amt. to ask someone to pay when they have no midwifery income. If we want to encourage midwives to stay involved with the CMO then I recommend fees be changed to 25% of the Active class fee, instead of 50%.
Anonymous on April 7, 2024
I understand the increasing costs of life currently and wanting to reenumerate staff accordingly, however I am not in agreeable with a fee increase. At a time when attrition rates are high and recruitment is difficult the fee increase is prohibitive and restrictive for midwives. The astronomical amounts that we pay in fees for AOM and CMO make it challenging to go part time.
I feel that the college needs to look at other creative ways of lowing overhead costs. Hybrid work from home models? Why do we need an office downtown Toronto with high rent costs etc?
Anonymous on April 6, 2024
Years ago we were told that once midwifery grew as a profession our fees would finally decrease. Now instead we are being asked to pay $2,700 a year. Worse we are being asked to pay in one lump sum. Most of the comments say the changes are to reflect inflation and align with other Colleges. Are you saying other professional members are actually paying that much?
Anonymous on April 6, 2024
I am also in agreement with other comments that reviewing operational costs- downtown site-should be considered. Midwives are forced to pay the extra downtown costs to provide care within our catchment area- however this is not needed by our College. In addition- the cost savings for the College with regards to instalment payments vs lump sums: does not reflect in our fees. If this is costing the college extra to have the instalment payments- but you are eliminating- where does this reflect in our “the applicant” savings?
Midwife on April 5, 2024
I don’t agree with these changes. Reduce costs, as opposed to passing those costs onto us. I get it…inflation is a thing. But now my minimal pay increase (which I’m thankful for) is going to be gobbled up in increased fees. I agree with others…the fees of doing this job make it prohibitive to want to continue.
Midwife on April 5, 2024
Absolutely not surprised that fees are increasing to match inflation and cover overheads of running the college while the registrants who have to pay the CMO for the privilege of working (or not in the case of inactive members). As many in the comments here have expressed, reducing overheads is the responsibility of the College. I suggest financial transparency to assist the registrants understanding the need for increases and to ensure the College is accountable for reducing their financial burden for the sake of the environment, the public and most importantly, the registrants who leave the profession due to the seemingly limitless barriers to practice.
Anonymous on April 5, 2024
I am rather disheartened by the increases suggested. I as many have suggested this before but the CMO has to seriously consider reducing their large overhead expenditures such as eliminating Downtown Toronto office and moving to hybrid work situation so people at CMO can work from home and reduce rent costs and not insist on midwives to continuously have fee increases that affect our earnings. This comment feels like a broken record as every fee increase we see, we ask for this model of increasing fees be examined and find cost savings yet the fees go up. It is also rather harsh to expect midwives to pay fees of this size once a year. I think as a bare minimum this needs to be reevaluated as the AOM has found ways to manage a monthly fee system. Although it doesn’t fix the increase, it at a minimum allows midwives to balance their expenses in relation to their earnings.
Anonymous on April 5, 2024
I think the increase should be 2-3%, as the rest of us have the same increase. We have a costly job. This job costs us our health, finances, and many other aspects of our lives. As an experienced midwife, I think I will work less, but at the same time, I have to pay at least 7-8 thousand dollars to be eligible to work. Maybe CMO and AOM will consider moving to another location with lower rent at least.
Anonymous on April 5, 2024
I would agree, the cost of fees for being a midwife is prohibitive and may discourage midwives working part time. Without a viable option to work part time, many more midwives will be leaving the profession. I believe the College should be looking aggressively at ways to reduce costs.
Midwife on April 4, 2024
Asking an already inactive member (likely on some kind of leave with a reduced income) to pay $100 to change their membership status seems steep, and presents another barrier in addition to the many expenses of taking and returning from a leave.
Midwife on April 4, 2024
both AOM and CMO pay rent in expensive places of Toronto, so now is the time to think of bringing costs lower, rather than working almost 3 caseloads to pay for the membership of CMO and AOM, plus when it gets to benefits, as a midwife I have to pay a lot more for medical and dental expenses for myself and my family ,…
Midwife on April 4, 2024
Agreeable with proposed amendments
Midwife on April 4, 2024
These increases are basically horrifying given midwifery salaries do not increase to “reflect inflation”. Our pay is increase 3% this year. You could increase everything by 3% and take away any gains we are achieving with our pay. Instead, you are increasing our (already completely outrageous fees) by 8%. I suggest matching increases in midwifery pay if you have to increase at all.
Between the CMO and the AOM, it costs us over 8000$ to be midwives every year. These proposed changes make me want to cry. At least the AOM allows us to pay monthly to reduce the financial burden, particularly on those of us who do not have a second income in our families or new midwives who are starting lower on the pay scale/etc. I propose you allow the choice of monthly payments. Or have the first half remain as a lump sum and the second half as monthly payments. Something to be kind as we all face lives that “reflect inflation”.
It is getting harder and harder to justify the costs of being a midwife and I worry that the decisions of the college, including these changes, are contributing to attrition rates within midwifery.