Proposed changes to registration regulation to register sonographers (Consultation Closed)

Consultation on proposed regulation to regulate diagnostic medical sonographers with CMRTO

CMRTO’s President, Wendy Rabbie, received a letter from Denise Cole, Assistant Deputy Minister, Health Workforce Planning and Regulatory Affairs Division, Ministry of Health and Long-Term Care, dated August 1, 2017 directing the CMRTO to regulate diagnostic medical sonographers under the CMRTO. CMRTO also received direction to begin the registration of diagnostic medical sonographers by January 2018. (Click here to view the letter.)

We are delighted the government has decided to regulate diagnostic medical sonographers under the Regulated Health Professions Act (RHPA) and within the CMRTO. The CMRTO has been working for many years to assist the Ontario Ministry of Health and Long-Term Care in completing the public protection framework for medical radiation technology by regulating diagnostic medical sonographers (DMSs) with MRTs.

The CMRTO Council has approved, for circulation and comment, a regulation to amend the registration regulation made under the Medical Radiation Technology Act, 1991 (MRT Act). The amending regulation will enable the CMRTO to regulate diagnostic medical sonographers as a fifth specialty. It also sets out the registration requirements for an applicant to be issued a certificate of registration in the new specialty. If the regulation is enacted, it will come into effect at the beginning of 2018. By the end of the one-year grandparenting period at the end of 2018, all individuals practising as a DMS will be required to be registered as a member of the CMRTO in order to be authorized to practise diagnostic medical sonography in Ontario.

In accordance with the RHPA, the proposed changes are being circulated for 60 days to members and stakeholders for comment. Prior to finalizing the proposed changes, Council will consider all comments, keeping in mind the CMRTO's mandate to protect the public interest.

You are welcome to review these proposed changes and provide comment on the consultation section of the CMRTO website at www.cmrto.org. Please let your sonography colleagues and other interested individuals know about the consultation.

The deadline for receipt of comments on the proposed changes is October 17, 2017.

Summary of the Proposed Regulation amending the Registration Regulation made under the Medical Radiation Technology Act, 1991

Following is a summary of the proposed changes to the CMRTO registration regulation in order to regulate diagnostic medical sonographers with CMRTO as a fifth specialty. Click here to see the proposed regulation and here to see the consolidation of the registration regulation made under the MRT Act as if the proposed amendments have been made.

1. Registration requirements during grandparenting period

Initially, there will be a one-year grandparenting period starting in January 2018. The purpose of this provision is to permit those individuals working competently in diagnostic medical sonography currently or within the last three years to apply for registration as a DMS. These individuals may not have completed an approved educational program or an approved examination. Under the grandparenting provision an applicant must be, or must have been, engaged in practice in Canada within the scope of practice:

• on the day the regulation comes into force, or
• for at least 400 hours in the prior year, or
• for at least 1200 hours in the prior three years.

The applicant must also provide satisfactory evidence of their competence to practise in diagnostic medical sonography. All applicants must pay the application fee and the fee for registration required by the CMRTO by-law.

The scope of practice is the use of soundwaves for diagnostic ultrasound for the purpose of diagnostic procedures, the evaluation of images and data relating to the procedures and the assessment of an individual before, during and after the procedures.

2. Ongoing registration requirements

After the grandparenting period, the following registration requirements will apply to all individuals wishing to practise diagnostic medical sonography in Ontario:

1. An applicant must have successfully completed an approved program in the specialty of diagnostic medical sonography or a program considered by the Council to be equivalent. The approved programs are set out in Schedule 1.3 of the proposed regulation and consist of the programs currently accredited by the Canadian Medical Association Conjoint Accreditation Services Committee.
2. An applicant must have successfully completed one or more of the examinations approved by the Council.
3. An applicant must have engaged in clinical practice, or completed the approved program, within the last five years.
4. An applicant must meet all of the above requirements in the same area of practice within the specialty (ie. general sonography, cardiac sonography or vascular sonography).

If an applicant has not successfully completed an approved program or equivalent (for example, an internationally educated applicant), the applicant must satisfy the CMRTO Registration Committee that their educational program is substantially similar to an approved program and that the applicant is competent to practise diagnostic medical sonography. The requirements in the above paragraphs b, c and d also apply.

All applicants must pay the application fee and the fee for registration required by the CMRTO by-law.

3. Specialty Certificate

The proposed regulation provides that there will be one specialty certificate for diagnostic medical sonography. Applicants must meet all of the requirements for registration in the same area of practice within diagnostic medical sonography (general sonography, cardiac sonography or vascular sonography each being considered an area of practice) in order to be registered in the specialty of diagnostic medical sonography.

4. Title

The title assures the public that the regulated professional is legally authorized to practise the profession in Ontario.

The proposed regulation provides that a member who is registered in the specialty of diagnostic medical sonography may use the title “medical radiation technologist – diagnostic medical sonographer” or “diagnostic medical sonographer” and the associated abbreviations, MRT(DMS) or DMS.

There is one title for all the areas of practice of diagnostic medical sonography, whether the individual has met the registration requirements in general, cardiac, and/or vascular sonography.

5. Conditions of registration

The current registration regulation requires all MRTs to engage in competent practice within every five year period in at least one of the specialties in which the member holds a certificate of registration. This provision will also apply to DMSs.

A new condition is proposed which would apply to all CMRTO members: the member shall practise only in the areas in which the member is educated and experienced.

Consultation and next steps

We wish to hear your comments on the proposed changes. Please add your comments and thoughts by using the form below, or by email here. The CMRTO Council will carefully review all comments before making any decisions regarding the proposed amendments. If the proposed amendments are approved by Council, notification and the finalized by-law will be posted to the CMRTO website.

The CMRTO will keep all MRTs informed of the proposed changes to the public register through its website, social media and Insights.

View the comments made to date below:

This is an excellent step toward better public protection and a long time coming.

I have been in the Diagnostic Services portfolio for over 30 years. Sonographers I felt have aways been part of the Diagnostic Services world as they work side by side with MRT's and perform diagnostic examination on patients. 

I am very happy that sonographers will become regulated finally and with a College that has such a great track record of caring for their members while ensuring they protect the public.  

I have read all the proposed changes to the regulations you have posted. I feel they are fair and inclusive. 

Thank you for allowing me to comment. 

This will be great to ensure that the public is safe and that standards for practice are in place. Welcome Sonographers!

  I was wondering if the name of  the society should be changed to better reflect the nature of imaging. Sonography is not a radiation tool.  Maybe the society should be known as a medical imaging society rather than focusing on the medical radiation part and to better include sonographers

I am currently a member of the CMRTO and practice radiography as well as diagnostic sonography

I held ARDMS certification previously and now hold solely Sonography Canada Certification as the Canadian standard for Sonography

Will I need to pay an additional fee to practice sonography or will my current fee paid as an MRT R cover this cost? An additional fee will be monetarily difficult for me as a single parent

CMRTO response: No, you will not need to pay an additional annual registration fee. You will be required to add the specialty of sonography to your registration, but there is only one annual fee regardless of how many specialties you are authorized to practice. When you apply to be registered in sonography, you will be required to pay the one-time application fee ($100.00 + HST, total $113.00).  

The regulations is another hurdle to block international graduates to join the profession just like IMGs are forced out of the medical profession. According to these regulations, International graduates , education and experience from back home has 0 acknowledgement. Either stop taking  immigrants in Canada or make it easy for them to work in their field of profession. Absolutely unfair to the immigrants.You need to make different provisions for immigrants, why would they spend the money and waste their time to study the same courses that they already did. 

Registering requirements for grand parenting period are not fair. If a sonographer is unemployed and has not worked for a year and did not work for 1200 hrs in previous five years , he is out of the profession ?? How fair is this ? 

CMRTO response: Initially, there will be a one-year grandparenting period starting in January 2018. The purpose of this provision is to permit individuals working competently in diagnostic medical sonography currently or within the last three years to apply for registration as a DMS. If you are not eligible to apply under the grandparenting provision, you may be eligible to apply if you have completed an approved educational program, and an approved examination.

Hello

I think it is important to recognize the different sonography sub-specialties: cardiac, vascular, general. Please consider adding something to the DMS credentials. For example, DMCS DMVS DMGS. If someone has two or more credentials, they can proudly show them all and be recognized for them. Employers do request for subspecialties. Having these in the credentials, makes them easily identifiable.  

I don't understand the 5 year period of competent practice. Could you please clarify? 

Thank you very much

CMRTO response: Registration with CMRTO will provide sonographers with the legal authority to practise diagnostic medical sonography in Ontario. Employers can still require certification in the sub-specialty areas. It is a condition of a specialty certificate of registration that, within every five-year period after issuance of the certificate, the CMRTO member must engage in competent practice in at least one of the specialties in which they hold a certificate of registration. This means that if you hold a certificate of registration in two specialties - for example, radiography and diagnostic medical sonography - then you will be able to maintain both specialties on your certificate of registration provided that you are engaged in competent practice in at least one of the specialties within the five-year period.

CMRTO members attest to meeting this condition every year at the time of the annual renewal of their certificate of registration.

1) What's the difference of registration process/practice limitation between: a) techs with full Sonography program training (with or without specialty certificate) vs. b) techs with only limited/specialty scanning certificates? Re: Section 4.2 subsection (1) and (2)

2) The designation/abbreviation can be shortened: consider MRT(S) (S for sonography) or MRT(U) (U for ultrasound) rather than MRT(DMS). As all the other disciplines have simpler abbreviations, ultrasound could follow as well. Re: Section 8(2)

How the council will  determine the satisfactory evidence of the competence to practice in diagnostic medical sonography? If somebody is already employed then why to check the competence.

CMRTO response: As part of its public protection role, CMRTO must ensure that all its members are competent to practice. During the grandparenting period, the CMRTO will likely be relying on the applicant's clinical supervisor to attest to the person's competence to practice diagnostic medical sonography.

I note clause 4.2(1)2: "The applicant must have successfully completed one or more of the examinations set or approved by the Council in the specialty."

I am hopeful that ARDMS will be one of these examinations because I and many new sonographers who have graduated from the same Ontario college have been working under this license.

A requirement for additional testing, and in turn fees and time, in exchange for no noticeable change to our profession, would be obstructive to both our professional and family lives.

CMRTO response: If the ARDMS examination is not one of the examinations approved by the CMRTO Council for diagnostic medical sonography, you will be able to apply for registration under the grandparenting provision. This provision will enable sonographers who are practising competently in diagnostic medical sonography currently, or within the last three years, to apply for registration, without the need for additional testing.

I note clause 4.2(1)2: "The applicant must have successfully completed one or more of the examinations set or approved by the Council in the specialty."

I am hopeful that ARDMS will be one of these examinations because I and many new sonographers who have graduated from the same Ontario college have been working under this license.

A requirement for additional testing, and in turn fees and time, in exchange for no noticeable change to our profession, would be obstructive to both our professional and family lives.

I note clause 4.2(1)2: "The applicant must have successfully completed one or more of the examinations set or approved by the Council in the specialty."

I am hopeful that ARDMS will be one of these examinations because I and many new sonographers who have graduated from the same Ontario college have been working under this license.

A requirement for additional testing, and in turn fees and time, in exchange for no noticeable change to our profession, would be obstructive to both our professional and family lives.

As a cardiac and vascular Sonographer with a background in nursing it feels strange to me to be part of a college that has an obvious basis in radiation technology and I feel a change in the name of the society representing ultrasound should better reflect its new diversity.  I also want to express my appreciation for all the work undertaken to recognize sonographers as the professionals they are.  Having worked in this field and nursing for the past 31 years I have met some wonderful mentors that have helped me become the Sonographer I have aspired to be and who have made me appreciate the professions I am a part of. As such, I feel that to paint ultrasound as simply imaging is understating the complexities involved (especially in echocardiography).  I know standards must be established and maintained to protect the public. And I applaud your society for stepping up to the plate to take on this new challenge but I wonder what will be in it for us other than another fee to pay.