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

I have several questions regarding the "grandfather clauses" and a comment,

1) How does the requirement for 400  hrs of scanning in the field  in the last year, or 1200 hrs in the last 3 years accommodate sonographers  who  have had maternity leaves?  I know a sonographer who has had 2 maternity leaves in the last 3 years despite having 10 years experience and being an excellent sonographer she  won't meet the requirements.

2) how does those same requirements  make allowances for part time sonographers? I am nearing the end of my career, I work 2-3 days a week during the summer and 1-2 days a month the rest of the year, this suits myself and the Hospitals I work for just fine.  Despite having over 25 years experience at a major teaching hospital, attending education days, inservices, etc, I just barely make the required hrs. Next year I may not.

3 ) how does those same requirements accommodate the teachers in the university or college courses? it will be difficult  for those who work  full time teaching to acquire the required hours in the field scanning. 

 My comment, The push to have sonographers regulated has been going on for years!  Why now the rush to have it done by Oct 17th.  The requirements were announced in September, most of the meetings  to inform sonographers are held after the deadline for comments.    

If this was a true consultation, there would be adequate time allowed for sonographers to be informed, to respond with their  comments and suggestions, for the committee to review the comments and make adjustments and then inform sonographers of those changes. Even have sonographers vote on the requirements.  That is a true consultation process.  The proposed process is a lump it or leave it process.

Sonographers want their profession to be regulated but on terms that best serve them. Terms that reflect the sonographer community as a whole. They deserve to have adequate time for input and consultation.

there is also no mention of what the costs will be for sonographers. There is no mention of the benefits we will receive if we are registered with CMRTO.

The required registration of sonographers will give the CMRTO an infusion of cash, so they have a vested interest in passing this as quickly  and with as little fuss as possible.  

I urge the committee to slow down, allow for  consultation and input Let's get it right the first time.

CMRTO response: The Ministry of Health and Long-Term Care has directed that the regulation of sonographers begin in January 2018. See the letter here: https://www.cmrto.org/what-we-do/consultations/letter-on-the-regulation-of-dms.pdf.

This has been ignored enough. I expect an answer as to what the CMRTO is planning to do regarding the different disciplines of ultrasound. Why are all sonographers being labeled as just DMS and not being recognized for what they are trained to do. Again, all this would take is adding a few letters on the end of someone's title. ARDMS and Sonography Canada have been doing this for years. The public in Ontario should be aware and protected. We have every right to know the answer to this.

CMRTO response: Once registered with CMRTO in the specialty of diagnostic medical sonography, sonographers will be required to perform only those procedures for which they have the knowledge, skill and judgment to perform safely, effectively and ethically. Certification with an association is one method of demonstrating that a person is able to meet this requirement. This is how the regulatory framework works for all specialties of the profession. For example, MRTs in the specialty of radiography practise in other areas, such as CT, mammography, angiography, bone mineral densitometry and many other areas, provided they have the knowledge, skill and judgment to perform the procedure safely, effectively and ethically.

In addition, the proposed amendment to the regulation adds a condition on members in all five subspecialties that they practise only in the areas of the profession in which they are educated and experienced.

I understand that we only practice in areas we are trained in but why not recognize it in the sonographers title? This is the whole reason for regulation no? This is not hard to do and it would save all sonographers from spending money being certified with other associations. All I see here by the CMRTO is ignoring the simple solution of recognizing sonographer individual credentials and just collecting fees without any structure. Frankly this is unacceptable and irresponsible. 

To answer that a sonographer must belong to another association in order to prove that they are competent to work within that subsection of sonography is unacceptable. These other associations are not cheap to belong to. What is the point of regulation then? What does CMRTO do exactly? Other than accept our dues that is. Is it not YOUR responsibility to make sure someone is competent and maintaining their skills? Why should a sonographer prove through ARDMS or Sonography Canada they are capable of performing a pediatric exam vs an adult constantly? Or that they are capable in Echo or Vascular. CMRTO should be able to assess this from the sonographers current credentials at the start on registration in January and then take over for these organizations in recognizing the skills of a sonographer. That is what regulation is. Why would CMRTO not be able to determine this when they sign up and then title that sonographer accordingly? I expect an answer as to why this is not going to occur. If this is true you are just increasing the financial burden on thousands of sonographers without any benefit. 

Will CMRTO allow private clinics and hospitals to cross train (on the job training) their general  sonographers in other specialties like echocardiography , vascular ...etc ?

I am an International Medical Graduate (MBBS). I got got my Medical Degree/ Diploma assessed by ICAS Canada. I underwent one year ultrasound training at a teaching hospital and worked full time as paid ultrasonographer before coming to Canada. I hold RDMS, RDCS, RVT and RPVI Certifications from ARDMS. I am employed as Lead Cardiovascular Accredited Diploma Course Instructor at an Government Accredited and Sonoraphy approved Private College in Ontario. My two Cohorts have already graduated successfully and I am teaching two Cohorts currently. Our curriculum include both Didactic and practical Lab hours and I teach both. I am also working at a Diagnostic Lab but part time only.

I was wondering if my didactic and lab teaching experience of around 3 years will be good enough to be eligible for registration with CMRT considering specially the fact that I am teaching a Canadian  Government Accredited and Sonography Canada approved Cardiac and Vascular Ultrasonography Program.

I will appreciate if CMRTO can furnish its position/view on the subject.

I am a mammographer  just starting my training to perform Breast Ultrasound  as many mammographers do at "Breast Clinics/ Womens Clinics.  Will this even be permitted by this new registration process?  I have completed correspondance courses and will be training at my hosptial.  I will clearly not be eligible for grandfathering, nor will I have completed the entire General Sonography Program. Will mammographers from this point forward not be able  to train for just Breast US?

I am an MRT and registered sonographer with sonography Canada.  I too applaud the regulation of this profession.  Some of my concerns or comments are as follows:

1.  Remove MRT from the suggested abbreviation as a prefix to DMS.  Not only is this confusing, but as an MRT who is proud of my credential, I don't feel a  sonographer should be entitled to use it.

2.  Grandfathering. I see the details are still being discussed, but to ptotect the competency and integrity of qualified registered technologists currently employed, I strongly support upholding current requirements and exams in place with sonography Canada. Simply "working in the field", or having a supervisor write a note stating competency is far too lenient.  

3.  As so many comments previously, subspecialities need to be recognized. Employers take advantage of general sonographers often tasking them with different areas (echo, breast, msk, vascular) with little training or support in the clinical setting. Without the CMRTO recognizing the vast differences in skills for certain exams, how can we expect an employer to understand?  Not to mention sonographers with added specialities should be compensated financially for their extra skill sets. This could be better argued through the collective bargaining process if additional credentials were recognized.

Thank you for the opportunity to share my comments!

It is about time that sonographers become Regulated. We still have people coming into the sonography profession and taking short cuts around education. Many educated people can, and have written  the ARDMS exams, and pass and hold credentials from the ARDMS. That does not make them compentent sonographers. An ARDMS credential shows they are compentent in exam writing. Having a credential doesn't prove competence in scanning. Sonography is the most operator dependent of all the imaging modalities. I personally know many sonographers that hold multiple ARDMS credentials, as I do. When I wrote my ARDMS exams it was common for most sonographers to  write the echocardiography exam. Some of these sonographers have never performed echocardiography in over 20 years. Does having a credential make someone competent? If you haven't performed an echocardiography exam in >20 years do you have the knowledge, skills and judgement to do an echo examination now? I wouldn't want that sonographer doing my echo exam. Please don't get hung up on a credential. It is important, but I don't think it is that important. Being in a Regulated College, will ensure that we are all self reflecting, and saying do I have the knowlege, skills and judgement to do this examination. If we don't  have the knowledge, skills and judgement we shouldn't be doing that examination. Sonography Canada's credentials are the credentials most employees are looking for now; and Sonography Canada should be applauded for all the work they have done in ensuring competence in scanning is involved in passing their examinations, but remember not too long ago Sonography Canada grandfathered in ARDMS registrants as well. If you take the time to study the history of  the Regulated Health Colleges you will find that all of the Regulated Colleges initially grandfathered practioners in. You have to start somewhere, and the CMRTO will ensure they will know everyones background. It is the duty of the Regulated Health Colleges to protect the public. As a health professional I will be honoured to be in a Regulated College; knowing that the entire Regulated sonography community is bound to protect the public and uphold to the highest standards, and ensure safety to all people having ultrasound examinations. Our current un-regulated environment allows the incompentent practioner to work and to tell patients they are sonographers. Regulation will ensure only Regulated Sonographers can hold the title. (What ever that title may be). Regulation also means that if someone is fired because they are incompetent, that there will be mandatory reporting of this person to the CMRTO, and that individual will not be able to work again, until they have proven their competence. Isn't this what you want if you are a professional? Don't we want the incompetent to be Regulated out?  It is called Self Regulation for a reason, we the professionals are funding it; and Regulation ensures patient protection. Thanks CMRTO for ensuring that all sonographers are striving to continously learn, and improve, and protect the public. 

I am an MRT(R) who does mammography and am registered with the ARDMS as an RDMS in the specialty of breast ultrasound. My training for breast ultrasound involved taking the Burwin Sonography Principles and Instrumentation and Breast Ultrasound courses, 1 year clinical training under the supervision of a radiologist, and the ARDMS registry exam.  Will this new regulation require MRT's who practice mammography to complete a full sonography program as listed in Schedule 1.3 to be able to be trained and perform breast ultrasound? Will the CMRTO accept the education and exam as prescribed by the ARDMS to practice breast ultrasound as an MRT in Ontario? 

The grandfathering practice should be simply proof of registration with ARDMS and/or Sonography Canada. As a paying member of both these organizations currently, I should not have to again prove myself capable of performing my job that I have done for over 13 years. We have educational requirements with both these governing bodies that require CME submissions every three years. and the three year dates for a lot of techs do not fall exactly the same. So it is a lot of course juggling to make sure your CMEs are beneficial to both organizations. and now a third organization to add to this? Seems like a lot of red tape to perform our profession. this would be very discouraging for future techs. And I am also an x-ray tech. So I seem to pay endless dues for my profession, and this will add another fee. I feel this does not benefit patients or the community. Sounds unfair and unnecessary

I have been a registered Sonographer for nearly 20 years, working only in Ontario.  I applaud that the field of Ultrasound will be recognized and regulated in this province.

What is a bit unclear to me at this point is what will be expected from a fee responsibility.  What specifically will our fees be to become registered with CMRTO and is our registration still required to be upheld with Sonography Canada and ARDMS? 

And, I have a specific question related to my current professional situation.  I have been seconded to another project within the hospital for a minimum of 2 years and am currently not practicing in ultrasound.  What will this mean for me personally during this process?

Last year I paid $531.10 to the CMRTO for my MRT registration.  Will Sonographer's be paying the same CMRTO dues as MRT's?

CMRTO response: Yes, members in all specialties will be paying the same fees.

The annual fee for registration with the CMRTO is set out in the by-laws of the College. Each member is required to pay an annual fee of $470.00 + HST ($531.10). There is only one annual fee regardless of how many specialties a member is authorized to practise.

When someone applies to be registered in a new specialty, they are required to pay a one-time application fee of $100.00 + HST ($113.00).

I have a question regarding grandfathering and required hours worked.  I have had three children in the last five years, and therefore do not meet the required hours for grandfathering.  Are there any provisions in place for this type of circumstance?

A question for CMRTO regarding CME's.

As both an MRT(R) and a sonographer, I'd like to know what the yearly educational requirements will be for technologists who hold both certifications. 

As a sonographer, I already perform other delegated tasks approved by my employer (institution) such as IV insertion and injection of contrast media.  As some of my colleagues have either hid behind the excuse that they wouldn't be 'covered' in the event something went wrong and they were to get sued, or not allowed to perform such tasks due to union involvement from competing professions, is there somewhere in the 'scope of practice' with this regulation that states sonographers are allowed and encouraged to perform these tasks many are already doing anyways, and will in fact be protected by the CMRTO should an adverse event occur?

Thanks in advance for your response.

CMRTO response: You can find out about the controlled acts that MRTs are authorized to perform in the CMRTO Standards of Practice on www.cmrto.org.