Dear Council Members of the College of Medical Radiation and Imaging Technologists of Ontario, I am writing to express my serious concerns regarding the proposed increase in the annual registration fee from $470 to $643, plus HST—a total of $726.59. This sharp 37% hike raises significant questions about the College's financial management and approach to fiscal responsibility. Questioning the Logic and Approach of the Finance Committee The Finance Committee has claimed that the partial rebate of fees in 2021 created a cataclysmic financial situation from which the College has never recovered. This statement is dramatic and inaccurate. According to the 2021 financials, the College ran a $400k deficit that year. However, this deficit was covered by the $3.05M held in reserves, which is precisely what reserves are for—to manage deficits without endangering the financial stability of the organization. The College’s target is to maintain cash reserves equal to 4.5 months of annual expenses. In 2021, the College had enough reserves to cover 9 months of operating expenses, far exceeding this target. The argument that the 2021 rebate caused a long-term financial crisis is an overstatement. While I am not personally in favor of the 2021 rebate, I do believe the College should disperse excess revenue from operations back to the membership on an annual basis. Without the membership, the College has no one to protect the public against—so we are, in essence, shareholders in a common interest, not debit cards for the College to use at will. Comparative Analysis: Value Proposition and HR Costs It’s important to examine these numbers in terms of the value proposition. We know the College employs individuals focused on protecting the public. However, when we divide the total human resource (HR) costs by the membership, we see the HR expenses incurred by the College to protect the public from each individual member. Based on your proposal, the College needs to spend $325.21 per registrant in HR costs to protect the public from me (or any individual member). Let’s compare this to our friends in the Laboratory and the Nursing Colleges:
• Nurses are charged $269.39 in HR costs.
• Laboratory technologists are charged $254.46.
Is the public shield around medical radiation technologists that much larger? Am I considered more of a threat? The 14% rise in HR costs in a single year is not a result of inflation but rather mismanagement. Inflationary costs have not risen by such a large margin, and attributing this jump to inflation is misleading. I strongly suggest the Council direct management to cap HR expenses at $3.25M, aligning with the proportional HR spend of the College of Nurses, and focus on protecting the public in a reasonable and cost-effective manner. Exploring Revenue Opportunities: Lessons from Physiotherapy and Nursing Colleges When you examine the financial audited statements of the Physiotherapy and Nursing Colleges, they are performing better on the revenue side due to innovative and modern ideas. We rely on user fees and a little bit of interest (from the money I already gave you).
• The Physiotherapy College administers its own credentialing exam and has sub-leased its space to generate additional revenue.
• The Nursing College has monetized and modernized their credentialing exam process, reducing costs, increasing access, and improving timeliness to certification.
Meanwhile, our exam process feels like processing X-ray films: first you wait, then you wait some more, and eventually you get the result. If it’s not the result you wanted, you face even more delays. As an administrator at a major hospital, I would prefer to hire people when they are ready to work—not be stuck waiting for an outdated exam process to conclude. Let’s take a cue from Nursing:
• The NCLEX-RN exam can be written year-round at designated test centers. After the College of Nurses of Ontario (CNO) determines eligibility, candidates receive an Authorization to Test (ATT) and can schedule their exam at their convenience. This modern approach improves efficiency, reduces waiting times, and ensures nurses can enter the workforce faster.
The College has a narrow definition of protecting the public as seen through the RHPA. I think we do more harm to patient by having them wait for their Ultrasound, X-Ray, CT or MRI. You have an opportunity to build public trust in our profession and have decided to erode the trust of the very membership you serve. Financial Responsibility and Public Trust The College has a duty to protect the public interest, and sound financial management is central to this responsibility. The Council has failed to demonstrate adequate financial oversight. Despite growing revenues, expenses continue to rise unchecked, indicating mismanagement:
• HR costs increased by 14% in one year, from $3.43M in 2022 to $3.92M in 2023. This rapid increase raises red flags about uncontrolled spending.
• The decision to commit to a 10-year lease for office space, even though a virtual office model has been adopted, shows poor financial judgment. Maintaining high rent for underutilized office space is a significant financial drain.
Financial stability must come from sound decision-making, not by shifting the burden of mismanagement onto registrants. Rising Revenues, Yet Continued Deficits Despite increasing revenues, the College reported a deficit of $212,791 in 2023. This is not due to a lack of income, but a result of poor financial management, as evidenced by escalating HR costs and unnecessary rental expenses. The College holds over $2.6M in reserves, with $1.86M restricted for emergencies. Yet, the decision to lock away a significant portion of funds without addressing current deficits reflects poor strategic planning. I challenge the College position of reserving 4.5 months of operating expenses into reserve to protect the financial stability of the organization. If the College were exposed to extreme financial risks or had an unpredictable annual revenues, this figure would be appropriate. However, we as registrants are mandated to pay our annual fees to the College and we are properly insured and legislatively protected from litigation under the purview of the RHPA. From a corporate risk perspective, the College is a safe bet. Reducing this number to 3.0 months is more in line with similar not-for-profit corporations. Also, historically, the College has held much more in reserve, which has allowed for the unchecked expense growth to occur year over year. I Am Not Your Wallet It is unacceptable to expect registrants to cover the cost of the College's poor financial decisions. As a registrant, I refuse to act as a financial lifeline for the College’s inability to manage its resources. The current proposal lacks a transparent, detailed justification, and I cannot support an increase that stems from wasteful spending, unchecked HR growth, and maintaining unnecessary office space. The Briefing Note presented to Council from the Finance Committee is littered with biased statements and focuses on a single solution. Alternatives are noted, but not transparently presented. This document needs to be redone in a more professional manner and should be circulated to others in the College who have the skills and judgment to help the College make the right decision. If I were chair of the Council, I would be sending this back to committee for more diligence. Call for Accountability: Health Workforce Regulatory Oversight Branch I formally request that the Health Workforce Regulatory Oversight Branch investigate the College's financial practices. As the regulatory body responsible for overseeing compliance with the Regulated Health Professions Act, the Oversight Branch should ensure that CMRITO’s financial mismanagement is not placing undue strain on both registrants and the public. The financial problems are not new and yet expenses have grown at double digits year-or-year. Council and the Registrar need government support and help before this mismanagement jeopardizes the public. Offer of Assistance Given the financial challenges facing the College, I offer my assistance in conducting a thorough review of its finances and operations at no cost. With my expertise, I aim to help the College balance its budget and achieve financial stability sooner, not by 2028. This review would ensure the College is making prudent financial decisions that protect the public while supporting its registrants. Thank you for your attention to this serious matter. I look forward to your response, one that demonstrates a commitment to responsible financial governance and thoughtful leadership. Kindly forward this to Council and publish on the feedback website. I attempted this, but exceeded the word limit. You have my permission to post my name as well. Sincerely,