This consultation closed on Monday, April 3, 2023.
About this consultation
The College has proposed significant changes to the Registration Regulation under the Midwifery Act, 1991.
The Registration Regulation has been revised to meet three main objectives:
- Set requirements to register safe, competent, and ethical midwives
- Ensure fair registration practices
- Reflect modern midwifery practice.
The College proposes to revoke the current regulation and replace it with a new Registration Regulation. Both the current regulation and the proposed regulation can be read below.
In 2021, the College conducted consultations on our recommendations regarding new registrant conditions and clinical currency requirements. The College also sought feedback on practice-related questions to understand current midwifery practice, including midwifery practice outside of a midwifery practice group model. This feedback was considered in drafting the proposed Registration Regulation.
Prior to recent amendments to the Regulated Health Professions Act, 1991 (RHPA) requiring health regulatory Colleges to develop regulations creating an emergency class of registration, the Council of the College had approved the inclusion of a new Emergency Class within the proposed changes to the Registration Regulation. The College has since updated the proposed provisions for an Emergency Class to include the requirements outlined in the applicable regulation under the RHPA and is circulating the current proposal for consultation.
Now we are requesting your feedback as we launch our consultation on the proposed changes to the Registration Regulation.
It should be noted that the provisions of the proposed Registration Regulation have been drafted by legal counsel and reflect standard legal language.
It should also be noted that additional policies will be created in relation to some sections of regulation to further elaborate requirements and processes.
Your participation in this consultation will inform the proposed changes to the regulation and will help us to ensure the proposed Registration Regulation meets the College’s public interest mandate and objectives mentioned above.
Thank you in advance for your time and feedback.
Consultation request
Please review our consultation document, which compares the proposed Registration Regulation with the current one, gives a rationale for each proposed change, and discusses the anticipated impacts on clients, the public, midwives, and applicants. You are encouraged to consider the prompts in each section when preparing your feedback.
- Consultation document with comparison table
- Proposed Registration Regulation Including Emergency Class
- Current Registration Regulation
How to provide feedback
You may submit your comments on this page below.
All comments are reviewed before being posted publicly to ensure they meet the Posting Guidelines. Your name and email will not be published with your feedback, however, you will be identified as a member of the public, a midwife, or a stakeholder. Email addresses are required to ensure that individuals provide feedback only once. If you prefer to provide feedback using a different format, including email, or if you have any questions about the consultation, please contact us as cmo@cmo.on.ca.
Midwife on April 3, 2023
We would request that we keep the transitional certificate class. We have used this option to get New Registrants privileges in a timely way, due to the summer months and also it has had benefits for continuity and meeting clients well in advance to being on-call for them. Clients have really liked meeting the New Registrants as soon as possible and we think this extra time of relationship building provides safety. We believe it has allowed for a more robust integration time and it lends itself to more interactions between the new midwife and their new team member midwives as during this time they are checking in with every client and extra handover occurs. We think this class of registration has increased safety and collaboration in our practice. We would ask to please keep it as an option because it increases safety and quality of care.
Midwife on April 3, 2023
I agree with removing the number of births from the criteria to be registered to facilitate midwives working in different models of care. I would like to learn more the number of hours and other criteria to maintain competency in areas of care provided.
Midwife on March 24, 2023
The change to hours of clinical practice from births recognizes the evolving work of RMs. It would be good to have an understanding of how many hours that would be. Emergency class of registration seems essential.
Midwife on March 18, 2023
As I understand it, midwives in what is currently the inactive class cannot provide labour support or breastfeeding support as this is part of the midwifery scope of practice. This means that an inactive midwife is more limited in her actions than a member of the general public. I would like this to change with the new regulations and with the non-practising class.
I’m not sure if this is relevant to the current standard, but many midwives have expressed that they would like to be able to use the word midwife when retired and no longer practicing. I understand protecting the term “registered midwife”‘ but there should be a version of the title we are allowed to use instead of being completely forbidden from acknowledging that we are no longer practising midwives.
Midwife on March 15, 2023
I agree:
• The proposed definitions are sufficiently clear for midwives and applicants.
• The proposed definitions are sufficiently clear for clients and the public.
• The proposed definitions accurately reflect contemporary midwifery practice.
I agree:
• The new emergency class serves the people of Ontario in the public interest.
• The registration requirements for the emergency class are sufficiently clear for midwives and applicants.
I agree:
• The titles of the four classes of registration (General, Supervised, Emergency and Non-Practicing) are sufficiently clear.
• The elimination of the transitional class is in the public interest.
• The addition of the emergency class is in the public interest and helps to serve Ontarians.
• Renaming the “inactive” class to “non-practicing” is a more transparent title to reflect that midwifery care cannot be provided by those registered in this class.
I agree: SUGGEST THAT A RANGE OF AN EXAMPLE OF THE RANGE OF “HOURS” REQUIRED FOR CURRENCY COULD BE ADDED HERE. (e.g. 500-1000 hours or whatever you imagine it to be for a locum/hourly paid/salaried clinical educator/Alternative practice/part-time)
• The reporting requirements for applicants applying to any class of registration are sufficiently clear.
• The application requirements allow the College to gain a clearer picture into the applicant’s suitability to practice and accordingly make decisions in the public’s
interest.
• The reporting requirements are sufficiently clear for midwives.
• The broadened terms, conditions, and limitations sufficiently cover all circumstances that pertain to the professional conduct of a midwife that the College would need to know about for determining the midwife’s suitability to practice.
I agree:
• The requirements applicants must meet to be registered in the general class of registration at the College are sufficiently clear.
• Recognizing Canada-wide degrees in this section reduces barriers for applicants to register with the College
• The proposed regulation reflects the evolving practice of midwifery and sufficiently ensures midwives maintain clinical competency in the areas in which they practice.
I agree:
• The requirements that out of province certificate holders must meet to be registered in the general class of registration are sufficiently clear.
• These provisions facilitate labour mobility and serve the public interest.
• The proposed terms and conditions on supervised certificates are sufficiently clear.
• The requirements to have an approved supervisor and to be actively pursuing meeting the supervised requirements serve the public interest while providing some flexibility for midwives.
• The timeframes for holding a supervised certificate of registration and extensions are sufficiently clear.
• The proposed expiry provisions serve the public interest.
• The requirements for moving from a supervised to a general certificate of registration are sufficiently clear and reasonable for midwives.
I agree:
• The labour mobility requirements for out of province supervised or equivalent certificate holders are sufficiently clear for midwives and applicants.
• These provisions facilitate labour mobility and serve the public interest.
I agree:
• The new emergency class serves the people of Ontario in the public interest.
• The registration requirements for the emergency class are sufficiently clear for midwives and applicants. Such a clause would make it easier to deploy midwives to meet the increased needs for MRPs during an emergency; such as the next pandemic, natural disaster, etc..
• The terms, conditions, and limitations on an emergency class certificate of registration are sufficiently clear.
• It is in the interest of clients and the public to have midwives practise under supervision while registered in the emergency class.
• It is in the interest of clients and the public to have midwives identify that they belong to the emergency class
• The time periods associated with the expiry/revocation of an emergency class certificate of registration and possible extension are sufficiently clear.
• The circumstances associated with the expiry/revocation of an emergency class certificate of registration serve the public interest of the people of Ontario.
• The 90 days provided prior to the expiry/revocation of an emergency class certificate of registration following notice from Council that the emergency circumstances have ended serves the public interest by providing sufficient time to coordinate and transition care
• The requirements to move from an emergency certificate to a general certificate are sufficiently clear.
• Recognizing the requirements for entry into the emergency class and the births attended while in the emergency class serve to help the people of Ontario in the public interest.
I agree: WITH RESERVATION?
• The registration requirements for issuing a non-practicing certificate of registration are sufficiently clear.
HAVE YOU CONSIDERED THE IMPLICATIONS FOR CLINICAL EDUCATORS WHO PRACTICE IN ALTERNATIVE PRACTICE AGREEMENTS, WHO ARE NOT BILLING THE MOH THROUGH A TPA, OR WHO MAY PRACTICE IN A UNIVERSITY-BASED CLINIC ASSOCIATED WITH A TENURE. PRACTICE MAY ONLY BE RECORDED AS PART OF CLINICAL TEACHING ACTIVITIES WHERE CARE IS DELIVERED TO CLIENTS WITHOUT ANY ADDITIONAL COMPENSATION OTHER THAN FACULTY SALARY? HOW CAN THE REGULATION SPEAK TO FACULTY-BASED PRACTICE? PRACTICE CAN AND DOES OCCUR OUTSIDE OF MOH FUNDING.
I disagree:
• The terms, conditions, and limitations on a non-practicing certificate of registration are sufficiently clear to midwives.
• The terms, conditions, and limitations are sufficiently clear to members of the public.
I agree:
• The resignation process is sufficiently clear for midwives.
• The consequences for failing to provide information as required under the by-laws are sufficiently clear.
• Notice of an intention to suspend or suspension adequately reflects the level of risk involved to clients and the public when midwives do not provide required
information.
• The process for a suspension being lifted in relation to failing to provide required information is sufficiently clear.
• The consequences of failing to maintain professional liability insurance are sufficiently clear to midwives.
• The process for a suspension being lifted once professional liability insurance has been obtained is sufficiently clear.
• This section sufficiently protects clients seeking compensation as a result of malpractice or negligence
• The requirements for a suspension being lifted once a fee or penalty has been paid are sufficiently clear.
Midwife on March 5, 2023
I have no issues with any of the proposed registration regulation changes. The written registration changes seem pretty clear. I am happy to see the removal of active birth numbers required to maintain competency as the outlined numbers do not reflect competency. I do agree with the emergency class of registration.
I did find the process of reviewing the proposed regulation changes quite difficult. It took a lot of time to read through and compare with current regulations and for the average midwife it is hard to tease out if small changes in wording would affect regulations on how I practice midwifery or might want to in the future as well as how that affects how the practice of midwifery works in general.
Midwife on February 23, 2023
1. Processes undertaken by hospitals and other entities that may credential and appoint midwives to their staff may be missing from the lists of information midwives should provide to the College. I am thinking of disciplinary processes – where have these gone? Why? I think this is an important area to continue to consider.
2. Intrapartum surveillance for fetal well-being is not covered sufficiently in any of the required competency courses (NRP, ESW, CPR) to reflect the huge responsibility it entails and the risk it represents. The CMO should add fetal surveillance certification to the list of required courses.
3. The changes to active practice and maintenance of competency are great. Why is the CMO not applying the same logic and direction of these changes to the initial registration period? The focus on caseload-type practice here risks increasing the hardship of entry to practice, where new midwives may be held to working conditions that other CMO members are not. Why not reflect the new approach to competency maintenance from the start?
Community Midwives of Halton on February 16, 2023
We understand the rationale for removing transitional certificates from registration options. However, some clinics and new registrants have relied on using the transitional certificates for initiating the hospital privilege process in the spring in order to get through credentials prior to when MAC breaks for summer holidays. At our hospitals there are no meetings held in July or Aug for credentialing new staff, so if new midwives miss the June meeting, then they cannot get privileges/attend hospital births until late September or October. This proposal would significantly impact services in our community if adopted before the upcoming cohort of graduates are registered. Should the CMO proceed with this regulation change, please consider delaying the effective date by some months to give all midwifery clinics a chance to adapt and adjust the timing of caseload for future new registrants.
Midwife on February 8, 2023
I agree with the removal of minimum birth requirements. I would like further clarity that there is no minimum requirement for births or “midwifery work” in or out of hospital.
Insurance requirements should be more flexible to allow midwives to work more independently and flexibly.
Midwife on February 7, 2023
it is interesting that in order to become registered in Ontario as a midwife, one needs to have done 30 births with continuity and 10 out of hospital. I wonder how reflective this is of organized midwifery in other countries.
And then to remove any requirement to do births to be registered in Ontario.
What percentage of ontario midwives are not doing intrapartum care and should the whole system change just because of that?
Midwife on February 5, 2023
I strongly agree with the removal of minimum birth number requirements after initial registration – this will allow midwives to work in alternate practice arrangements providing a broader scope of care not limited to intrapartum care. I’d like to see more specific details about the number of hours required and I question whether this is overly prescriptive – if a midwife meets clinical competency, why is the number of hours in practice relevant?
Midwife on February 4, 2023
I am happy to see that the new regulations deemphasize the numbers of births needed to maintain competency. With the various new models of being a midwife in ontario, we need to allow midwives to practice in alternative ways. I understand the logic that midwives need to be insured to be registered, but there are situations this is impossible due to the funding situation. The way our insurance is funded currently, if you move practices (and say have a month or 2 in between), your insurance may be given to another midwife, and you may be uninsured (but also not practicing), but need to remain registered. The suspension of your registration, should have a different title, and no fee attached to reinstating it.