Note: This public consultation is now closed.
The College of Midwives of Ontario’s Council has proposed changing the Fees and Remuneration By-law to raise membership fees from $2193 to $2550 for all classes of registration other than Inactive. This represents a $357 increase effective October 2019 registration renewal. The Inactive class of registration will not be affected by these changes, and will increase at 2%, as per the existing by-law.
The College’s Council has approved a deficit budget for 2019-2020 and projects two additional deficit budget years before our revenue equals our expenses. A combination of increased membership fees, operational expense cuts, and the use of the College’s existing net assets will allow us to achieve financial sustainability. The College will continue to ensure that midwifery care in Ontario is provided safely, by skilled and qualified midwives.
We invite midwives, stakeholders, and members of the public to comment on the proposed changes to the Fees and Remuneration By-law below. Council will consider your feedback and make a final decision at its June 26, 2019 meeting.
Our consultation is open until Thursday, May 30, 2019 and all members of the public, stakeholders, and midwives are invited to share their thoughts below.
Questions and answers:
The College of Midwives is the regulator of midwives in the province of Ontario. We regulate midwives practising in Ontario by ensuring that midwives meet high standards and acting when risks are identified. All midwives follow the same professional principles and standards of practice. We provide guidance to help them do so. Our purpose is to serve the public and the public interest.
No. Changes to our operational funding from the Ministry will not impact the public. The College will continue to regulate midwifery in the public interest and ensure that midwives in Ontario are qualified, skilled, and competent to practise. Ontarians can be confident that the College makes decisions in their best interest.
The College has no role in increasing numbers of midwives in the province. The Ministry of Health and Long-term Care sets the number of midwives able to practise in Ontario each year, and the number of baccalaureate midwifery education program positions are determined by the Ministry of Training, Colleges, and Universities.
No. Despite our small numbers, the College has been working steadily toward financial independence. The College submitted two different plans to the Ministry which detailed possible paths to financial independence – one in 2014 and one in 2016. While these plans were not implemented by the Ministry, the College has continued to work toward financial independence.
The College is financially independent as of April 1, 2019. The College projects deficit budgets for three years and will use net assets to cover the projected deficits. The College anticipates revenue will equal expenses in the fiscal year 2022-2023.
Historically, fees for members who were registered in the Inactive class were set at 50% of the General membership fee. The College’s Council considered previous member feedback that raising Inactive class fees would disproportionality affect non-practising members as they were not earning a midwifery income. Council proposed maintaining the Inactive fees with a 2% increase annually, as outlined in the current By-laws. This makes the fee for Inactive members for October 2019 $1097.
Most midwifery regulatory authorities and Colleges throughout Canada continue to receive funding from their provincial Ministries, so their membership fees are subsidized. The fees in other financially independent Colleges are comparable to ours: Practising midwives in British Columbia paid $2340 in 2018; and practising midwives in Alberta paid $2750 in 2018.
How do Ontario midwives’ fees compare to other regulated health professions in Ontario?
The College does not have the option to reduce costs by eliminating programs because all College programs are mandated by governing legislation.
The College made every effort to reduce costs in all spending areas. Some examples are listed below.
- Cuts to Council expenses:
- The president stipend has been eliminated, and the president will be paid on a per diem basis only
- Committees and panels will meet electronically whenever possible, resulting in reduced travel and accommodation costs
- One Council training day was eliminated, resulting in reduced travel and accommodation costs
- Cuts to operational expenses:
- There will be no merit increases for staff for the next two years
- There will be cuts to the staff benefits package for the next two years
- There will be an indefinite hiring freeze and only existing positions will be replaced
No. Council has proposed a plan that places the College in a stable and sustainable position and expects to hold fees to what is proposed in the By-laws.
Yes. Members continue to have the option to pay annual registration fees by cheque in two instalments. Initial registration fees continue to be pro-rated based on the months of practice before registration renewal in October. Members who have extenuating circumstances can continue to apply to the Registrar for consideration of alternate payment plans or reduced fees.
Midwife on May 29, 2019
An increase in fees is a solution that will increase attrition and burnout in midwifery. Working part time seems to be the only way to manage practicing and creating any work life balance. Since part time midwifery is the only way I can work without negatively impacting my mental health, the increase in fees also increases my chance of leaving the profession. It is becoming too expensive and/or too stressful to be a midwife.
Midwife on May 29, 2019
Hello,
While I appreciate the difficulty, we are having financially due to gov’t w/drawal of funds — I am not in agreement with increasing our fees. I do feel the burden of fee increases is being put on the backs of midwives who have not had a pay increase in a significant amount of time. If this was the first increase, I could be more sympathetic, but it is not. We have faced significant increases over the past decade without a pay increase. I worry the impact this will have on part-time midwives who are already working a significant portion of their income towards professional fees. At some point I think the CMO needs to find ways to meet the legislation for self regulation and not have such onerous methods of evaluation.
Inactive midwives — fees are too high. If lower, would the CMO actually have more midwives who choose to keep inactive status versus resign fully?
Retired midwives — there needs to be an option here as well ….
Lastly – there needs to be payment plan option. It is unacceptable that midwives are expected to cover such a large registration fee without a payment plan option.
Midwife on May 27, 2019
While I agree with the proposed changes, and I appreciate the work the College is doing in these difficult political times, I agree with the comments other midwives have made below. Specifically, the burden of the increase is going to fall on practicing midwives, when they are also struggling with very high AOM fees. I am concerned about the attrition rates and the many comments I hear and read about newer midwives finding it unsustainable to work in this model. I fear we may end up losing many more midwives if changes aren’t made to give them increased support to work happily and sustainably. This would include decreased professional fees when possible, better remuneration for countless volunteer hours, and an expanded, more flexible model, especially for senior midwives, and those with young children. As one of the pre-regulation midwives who has worked for the profession since 1982, it saddens me, and I fear for the future of midwifery in Canada..
Midwife on May 26, 2019
Last year because of health I was only able to do 7 births. This year I will do 10, just enough to keep my licencse, but have to share some of that fee with other midwives and mileage. Given that last year, then, 2/7 of my gross income went to AOM and CMO charges, more than 30% of my income went to those fees.
I would like to have a gradation based on the number of births done, and thus the income of the midwife.
But I agree with what has been said: since we have to raise fees because of being treated poorly by our government, move the central office to the east side of Belleville and charge part-timers of 15 and fewer births less.
.
Midwife on May 26, 2019
I will now work for more than 48 hrs just to pay my College fees. It is unsustainable for me. If I am unable to work at a full time capacity I am unlikely to be able to afford to cut back my practice. We have one of the highest fees in the province and we were told as membership increased our fees would go down. This hasn’t happened. You are forcing older Midwives who want to cut back in caseload to leave the profession instead, because they can’t afford to pay all their fees. Don’t you want to maintain the wisdom and experience of these Midwives within the profession?
This economic hit to Midwives continues to push them to work at an increased caseload level in order to make enough money to live. This is in contrast to the guidelines the CMO provides to promotes healthy work life balance. Those recommendations for healthy practice culture and self care don’t really have any weight when contrasted with the economic reality Midwives face. We can’t do it all- but that’s what you are asking.
Midwife on May 25, 2019
Like a few others, I was worried the increase would be higher than it currently is, and I appreciate the effort the College is putting it to keeping that increase as low as possible. However, I too am frustrated by the very high inactive fees and the lack of part time fees. I also echo the concerns about NR fees – how can an NR be expected to pay such high fees while having to potentially wait months to make any sort of income? I would like the CMO to address these concerns that have very real impact on the mental health and well-being of midwives, and by extension, real impact on the quality of care we provide to the public.
Midwife on May 25, 2019
I feel it is necessary to retain non-active and retired midwives in the College in a substantive way as community knowledge base and collective memory. I would like to propose a category for retired midwives that is affordable, nominal in amount , that midwives in this category would be likely to sign up for. As we become a larger active group, this other category of non practicing membership would also grow, and small as the membership fee would be, would over time be like an alumni category and a source of College revenue. But primarily, acknowledgement of the increasingly larger group of retired midwives will continue to help us keep perspective on the many contours midwifery is undergoing.
Midwife on May 25, 2019
This is a very good point & good suggestion!
The CMO doesn’t need to be located in Toronto necessarily, and this would decrease costs significantly.
Midwife on May 24, 2019
I think it is important that any penalties are to cover administrative fees, and not for punitive reasons, unless there is an unreasonable delay from a member, and that reasonable grace periods are allowed.
While I didn’t see this addressed per se in the by-law, penalty fees for parts of registration renewal that may be missed, incorrectly entered, or otherwise not in order, but that have been forward in good faith by members, should be minimal and only cover administrative costs. We should not be penalizing members acting in good faith, and should not depend on penalty fees to supplement CMO income.
Inactive on May 24, 2019
Now that midwifery has gained the credibility it was seeking, by having high profile executive type offices for the AOM and the CMO, it should no longer be necessary, especially since our goal should be to have a small carbon footprint. Less money should be spent on legal cases that target specific midwives subjected to Complaints, Discipline and Quality Assurance audits, often without evidence based information, subjecting excellent midwives to financial demise trying to defend themselves against false accusations, and rumours. Part-time, Retired and Inactive Midwives should retain membership at reduced rates. The founding members should be given a lifetime membership and be invited to continue contributing to the profession we built!
Midwife on May 24, 2019
If we received increases to account for inflation I would not be opposed to the 2% increase, however an increase of 2% year over year equates to exponentially less money in midwives pockets.
The penalty fees of 15% are exorbitant.
It is very disheartening to essentially provide 1 course of care for free, earning just enough to cover the yearly College fee.
The financial burden on NRs is very heavy. I vividly recall the hardship that fees placed on me as a NR. I think we should have more options for how NRs pay fees (ie. increase the number of installments, have NRs pay a nominal fee to start working with the bulk of their fees due once they have an income).
I am curious as to the rationale behind the $50 administrative fee in addition to the membership fees. Is there a reason that it is charged as a separate fee as opposed to increasing the membership fee by the additional $50?
Midwife on May 24, 2019
I want to comment on a matter that is likely part of a different set of regulations and standards – I am guessing Registration?
The CMO should strongly consider implementing a category for Retired midwives. The Inactive fee is not sustainable for the years we all hope to have after retirement, and currently, midwives who have worked long and hard and made important contributions cannot call themselves midwives any longer. In my view, this is a loss to Midwifery as well as personally to those who have given and taught so much.
I hope it will be possible to consider a new title that retired midwives can use in perpetuity after retirement, for a much lower fee. I suggest a one-time exit fee of $500 or so. The public register could have a final entry made to indicate their retirement date, and a brief statement could say they are no longer registered to practice midwifery but were, and the years they worked.
Thanks for your consideration.
Midwife on May 24, 2019
I was expecting this increase in our already onerous fees, thus am not surprised by them. I do believe that it is the responsibility of the college to further reduce their costs especially by moving out of Toronto (as I believe the AOM should as well!) and I hope the College seriously considers this recommendation.
Midwife on May 23, 2019
I’m really concerned we cannot comment anonymously. I do not agree with any fee increases to midwives fees before other cost saving measures are in place. I’m sure rent of office space is much cheaper outside of Toronto.
Midwife on May 23, 2019
I believe there are other ways to raise the necessary funds besides increasing fees for midwives. Midwives are already struggling with other increase fees due to the lawsuit and issues with job locations due to hospital caps. They already pay far more then other health care providers for their college fees. I strongly believe relocating the CMO office would be a benefit, the rent in Toronto is outrageous and it is not necessary to keep paying those rates. There are plenty of locations with less expensive rent and this would take the pressure off having to raise fees. For Midwives trying to work part time, raising fees makes it even more difficult. Why isn’t there a reduced rate for part time midwives?? One more obstacle for midwives trying to keep a work/life balance. Even the inactive fees are way way too high. For a profession with a high burn out rate, you would think the college would encourage midwives on inactive leave to take their time to achieve mental and physical wellness again before re-entering practice, however the high cost of inactive fees force midwives to make a choice and return to work prematurely (often resulting in permanent burn out or unsafe client care) or to resign permanently before they are ready to make that choice. What a midwife pays in 1 year of inactive fees is equal to what other similar professions would pay in 7-8 years of inactivity. In short, I do NOT support raising fees in anyway, even the annual 2% should be discontinued!
Sages-Femmes Rouge Valley midwives on May 23, 2019
I agree with proposed changes and appreciate the creative plan given how suddenly the CMO had to put it together
Midwife on May 23, 2019
Crazy fee we pay compared to my physicians friends. It feels unfair. I would have liked to see bigger cuts in admit. Move head office out of Toronto for expensive, or in cheaper location. Midwives already pay enough fees. I work part time and this seems ridiculous. I need to work a full month to pay my fees alone. I feel beaten up.
From a midwife who loves her work
Midwife on May 23, 2019
I commend the College for managing an impossible situation that the current government has placed on them. No midwife will like the increase in fees and it is obvious that the College is trying to make this manageable. However, as other midwives have mentioned this is not our first increase and midwives are feeling the burden of these costs. I make less money as a full time midwife than I did a few years ago and it is due to ever increasing fees from CMO/AOM/hospital etc….
As a suggestion, I would encourage the College to reconsider payment options for these unfortunately highly expensive fees. The AOM has sorted a way to bill midwives monthly instalments and although those fees are also incredibly expensive, it really does make a difference to not have to pay the lump sums.
Midwife on May 23, 2019
It is hard to believe that in my 12 years of practice, fees are increasing again with no pay rise since I personally hit level six – 7-8 years ago.
As a new parent (18 months ago) and having to pay extortionate fees to be inactive for a year (which in my opinion should be close to $0), receiving very little in terms of parental leave payment ($2000 per month – not sure how anyone can live off that), I felt it was impossible to continue an extended leave, and I felt forced to return in a full time capacity, as I am the sole income support for my family. I was even considering returning sooner and giving up breastfeeding because it was becoming so difficult to afford to live (1.5 months parental leave payments = CMO fees).
Returning full time was extremely difficult to balance work and new family life, but returning part time to enable more time spent with my family and taking care of my child was impossible because childcare is expensive, living costs have increased significantly, our pay has stayed the same and of course now we have the already extortionate added expense of being a midwife in Ontario. I cannot even imagine being able to have another child to complete our family because going on leave again is near impossible. Parental leave should not require any midwife feel they need to become homeless and live off boxed Mac n cheese.
As for active fees & other fees required to be a midwife, it really is disappointing we have the added stress of coming up with a month (or more) pay just be a midwife & do the job we love.
Midwife on May 23, 2019
Stop any increase to our fees beyond the 2%…we have had no increases…
Midwife on May 23, 2019
My college fees will now be more than $500 more than I currently get paid for a BCC. My previous experience as a midwife outside of Canada doesn’t count towards my fee level in Canada (midwife for over 10 years). With the government dictating how many BCCs a midwife can bill per year, how are we expected to be able to financially maintain extraordinary fee levels from both the college and the aom with reduced caseloads?
I understand we are a small profession therefore our fees will be higher, but with the rest of the political and gender discrimination of midwifery, I seriously dont see myself remaining in the profession much longer. It’s a sad truth, but I’m unprepared to be treated with so little worth in a job I love and am good at. It’s all i have known since i was 19. But the fighting for recognition is tiring.
Midwife on May 23, 2019
To be honest, I was expecting a much larger increase in our fees when the Ford Government announced the funding cuts, so I am pleasantly surprised. It is unfortunate… but it is manageable. Thank you for all the work you have done and continue to do to advocate for us!
-Isabelle
Midwife on May 23, 2019
I believe that the CMO is placing the majority of the burden of the cessation of government funding into the midwives. It should be possible to reduce budget costs more severely for the CMO. Midwives pay extreme fees.
Midwife on May 23, 2019
I strongly support not increasing fees for new registrants or those not working full time. These fees are astronomical.
Midwife on May 23, 2019
I really can’t quite believe this is even being called into question…raising fees again???!! Our fees to the CMO are significant, in fact, they are extreme and prohibited and increasing them really does impacts Midwives across the entire province. We already work absurd hours underpaid and undervalued. We face scrutiny from other health care workers working along side us. The pay equity ruling confirms our devaluation even at the government level ~ this is another slap in the face.
As many have already addressed, the CMO is located in prime estate in Downtown Toronto. Moving this location to somewhere less expensive would make good fiscal sense ~ especially when expecting all midwives across the province to ‘foot the bill.’
Our fees are already prohibitive for NR’s and any midwives wants to work part time.
This proposition of yet another fee raise is absurd – one year membership is even higher than 1 BCC for a level 6 midwife! Fees have continued to increase despite more midwifery graduates across the province. Extreme fees and poor compensation will only serve to burn out midwives quicker and drive them out of this profession…then who will pay these increases?? Step up CMO, fiscal responsibility not fee increase
Midwife on May 23, 2019
I don’t support the increase in fees. As I locum and working part time, I pay the same amount of fees as someone making twice as much as me. There is already enough of a penalty to those unable to work full time. Currently I am paying for the college to “manage” work that I am not doing for half the year. IF the college would prorate fees depending on how much you worked, then I would support an increase. Until then, I don’t.
Midwife on May 11, 2019
I am very disturbed by the fact that our fees keep increasing at a tremendous rate. I have been practicing for 5 years and I have seen the fees increasing no stopping, for one thing or another. This profession is demanding enough to be worried about more financial burnouts. CMO states that doesn’t want to impact the care provided to clients. However, Midwives, human force, already facing this difficulties for sure will impact the care provided to clients. For instance, continuity of care will become challenging if a midwives wants ti get as many clients as possible to have enough income. Midwives will start quitting because part time is not doable, which will affect our demand. I agree with the idea of moving to a less expensive place. Moreover, agree with the comment of at least wait to hear from the government to increase our already low payments before considering any fee increase.
Midwife on May 10, 2019
I agree with the concerns raised here. As a current NR I have already found the registration and association fees to be prohibitive. I already feel anxiety at the thought of another cost increase. I understand that budgets need to be balanced and the CMO is integral in regulating our profession. But as our work is already vastly undervalued and underpaid, this feels like yet another blow that, when compiled, makes me want to reconsider being a midwife.
Midwife on May 10, 2019
Our fees to CMO are significant, and increasing that really impacts Midwives across the province. We already work underpaid and undervalued. The pay equity ruling confirms this. It’s quite challenging and unfair, honestly. I fully value the work the College does and will continue to do, but these fees for midwives are unattainable and difficult for most, including myself.
It is a lot to ask for a midwife to pay this either in a 1 time fee or split in two. If the College is going forward with this increase, offering different payment options should be evaluated and offered for Midwives.
Midwife on May 10, 2019
These fees are astronomical. With our pay held steady and the increased load of our AOM Levy, it is not financially beneficial to be a midwife in Ontario. For myself, I currently have no other training or options, but I know at least a half dozen midwives close tp retirement or on the fence about staying in this stressful job with less and less financial stability and these fees may be the lasts straw for them- which may increase the remainder of us MORE. I know this is not news to anyone, but I feel I need to voice it. When I started this job 9 years ago, I was making significantlt more money than my husband. He has also stayed in the same job all these years and now makes significantly more than me, which I find SIGNIFICANTLY unfair. As does he, as he KNOWS the stress, responsibility and hours I put in surpass his….this is just my own situation but most of out there are in the same boat. No raise in pay + increased living expenses+ increased professional fees= I bring home less and less money every year
Member of the public on April 15, 2019
Reading through the comments, it makes a lot of sense to reconsider the location of the College. This is something I think should be assessed. Significant cost savings could be achieved by moving out of Toronto.
As a former midwifery student and current registered nurse, I am amazed at how difficult the system is for midwives. I support the CMO, however the membership fees are shocking – $2550 for just the CMO. Other provinces are paying midwives better and are still subsidizing portions of their college fees; I worry that this will cause a loss of midwives for Ontario.
New Registrants and midwives who work PT will be particularly affected by these fee increases. In the case of those who work PT, this could mean less midwives in rural/remote areas. It could also impact if/when midwives decide to return to work following certain leaves (maternity/parental/sick).
It seems like everyone is well aware of how challenging it is to become/practice as a midwife. Six years ago while in the MEP, I remember learning the burnout stats and writing papers on the challenges of being a midwife. It blows my mind that nothing has changed, and if anything, the system is continuing to make things harder for midwives.
Midwife on April 3, 2019
It is very upsetting to hear that the CMO fees are increasing so substantially especially considering how high the fees are already. These fees will make it very difficult, if not impossible, for part time midwives to stay in the profession. Another burden for already over worked, grossly underpaid, and undervalued midwives whose workload and scope keep expanding!. For many it may be time to consider another career. This profession is in dire straits!
Midwife on April 1, 2019
I also would like to add my voice to the concern of higher fees and how we can afford to pay for them. Our clinic doesn’t have enough clients for the midwifes who want to, to work full time, so this increase will be felt. We pay so many fees! Some of us also have student loans.
How many employees does the CMO have? Can one job be cut? I love the suggestion of moving the College out of Toronto. Hamilton would be a cheaper location, and close to Mcmaster University.
I just finished my new registrant year and it was very difficult to pay the fees when I wasn’t making money yet….and that contributed to a loan that is getting paid off. Please give NRs a break!
Midwife on March 30, 2019
I am a General Resident and I believe that New Registrants, like those in Inactive Practice, would also be disproportionately affected by a rise in college fees. I would prefer to see no increase for NRs and that GRs shoulder the balance of this burden.
Midwife on March 30, 2019
I am extremely disappointed and discouraged at the thought of any increase to our already expensive fees. I was informed in 1994 that our then fees that were so much higher than our RN fees would decrease as our members increased!! I have yet to see a decrease.
I am so disappointed that any fees are increased to our already overpriced fees: COM, AOM, legal fees, parking fees, continuing education fees, benefits fees (in arrears for those midwives working part time)
It has come to a point where midwives will not be able to afford working part time.
This is yet another slap to the face of already over worked and undervalued midwives
Midwife on March 30, 2019
I feel any increase for membership fees needs to be delayed until midwives receive their appropriate pay increase. Our membership fees continue to increase, while our income appears be at a stalemate. I recall being told that our membership fees would decrease (after complaining that our College fees were so munch more than RN fees) when number of members increased!! It makes it difficult to continue to afford working as a midwife with the COM fees, AOM fees, parking, continuing education requirement costs, benefit costs not completely covered when working part-time (yet expected to be payed in arrears)
We are already paying so much more than most of us can afford, with the added legal expenses.
I am extremely disappointed! And if my vote counts for anything I most definitely vote AGAINST this fee increase!
Midwife on March 29, 2019
One area in which the College could significantly reduce cost is to move. The CMO is located in prime downtown Toronto real estate – moving the CMO into a more economical space could help to mitigate the costs that are being passed onto members.
There is plenty of class “B” office space available that would have enough space to house the college. The priority here should be functionality – not showmanship.
Midwife on March 29, 2019
I am deeply disappointed that the Ministry has placed the CMO in the position of having to increase fees for Registered Midwives effective October 2019. While it is appreciated that the CMO has made every effort to reduce expenses, the impact this will have on already underpaid, under appreciated midwives can NOT be under-estimated. Death by a thousand cuts…. It’s hard to imagine this won’t potentially eventually have an impact on the quality of care we provide at the front line. It’s hard to maintain a high level of excellence despite our commitment to high quality care and to our clients, when we are constantly undermined.
Midwife on March 29, 2019
I wanted to sent a note of appreciation for the clarity of questions and answers. It’s an unfortunate situation, and appears that you have made a thoughtful approach.
My only concern is the disproportionate affect on New Registrants starting their careers who need to register in order to work – but will often not be paid for their work for months. Thanks for your thoughtfulness towards inactive members.
Midwife on March 29, 2019
I thank the CMO for the work that has been done this year. I would like to be a voice for the New Registrants. I believe they should be exempt from this increase. There aren’t many of them, and I think the General Registrants can easily carry the slightly additional increase this would create. Starting a career in midwifery is incredibly difficult financially, per our pay structure. I propose us GRs cover the increases for these 90 NRs, or at least offer NRs delayed payment of this increase.
Midwife on March 29, 2019
Our College fees are already so high. With the pay equity ruling confirming that there has been systemic and sustained gender based pay equity discrimination against midwives, and no response from government regarding this ruling, it is difficult to imagine paying even more to maintain our registrations at this time. I deeply value the work the College does, but these fees for individual midwives are unsustainable.