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On March 31, 2023, Council of the College of Medical Radiation and Imaging Technologists of Ontario (CMRITO) met to consider consultation comments received regarding proposed amendments to the Registration Regulation made under the Medical Radiation and Imaging Technology Act, 2017 (the “Amended Proposed Regulation”).
These proposed amendments were made to comply with a new regulation made under the Regulated Health Professions Act, 1991 (RHPA) that requires all health regulatory colleges to have an emergency class of registration by August 31, 2023. This regulation must include the circumstances in which a member in the emergency class may apply for another class of registration, exempting that applicant from at least some of the registration requirements that would ordinarily apply.
In accordance with the RHPA, the Amended Proposed Regulation was circulated for 60 days to members and stakeholders for comment. Comments were received between January 26, 2023 and March 30, 2023. Council considered all comments received by the deadline, keeping in mind the CMRITO’s mandate to protect the public interest.
In light of the comments received, amendments were made to the Amended Proposed Regulation initially circulated. Specifically, Council removed the examination requirement from the list of exemptions that apply to emergency class registrants applying for a specialty certificate of registration with CMRITO.
This means that emergency class registrants would still be required to successfully complete the national certification examination to be eligible for a specialty certificate of registration. In Council’s view, this amendment was necessary to protect the public interest and ensure the safe, effective and ethical provision of medical radiation and imaging technology services to the public of Ontario.
As directed by Council, the Amended Proposed Regulation is once again being circulated to members and stakeholders for comment. Because the Amended Proposed Regulation must be filed with the Government of Ontario by May 1, 2023, Council has approved an abridgment of the circulation period to 30 days, or such other period as the Minister of Health may approve.
Therefore, depending on a decision by the Minister of Health, the consultation process may close earlier.
Click here to review the Amended Proposed Regulation, with the proposed amendments that are being circulated for comment highlighted in yellow.
If you have questions, you may wish to consider reviewing this Frequently Asked Questions document. This document was published on March 3, 2023 during the initial consultation, but has since been updated to reflect the amendments made by Council on March 31, 2023.
Please note that all comments are reviewed before they are posted to ensure that they comply with our Social Media Policy.
CMRITO Member
April 3, 2023
7.1 (1) 3. - Technologists who completed their education 5 years ago and have had no clinical experience since then, and working technologists who have been out of practice for 5 years, frequently no longer have the knowledge, skill, and judgment to safely practice. I recommend changing 5 years to 1 or 2 years at most. 7.1 (3) 2. - In practice, when supervisor is required but not specified as "direct supervision", this is achieved simply by having a senior or charge technologist being employed by the organization, without having them engage in any observation, assessment, or intervention. When practice issues occur, they are only identified once patients are harmed. I would recommend changing "supervision" to "direct supervision" to ensure that errors are identified and corrected before patients are harmed.
CMRITO Member
April 3, 2023
Remove the requirement of a degree program before applying to become a Radiographer. Go back to a 2 or 3 year program only. Our pay does not reflect a 7 year obligatory training. So many young radiographers are going back to learn ultrasound or MRI and we need MRTs now!
CMRITO Member
April 3, 2023
I am still concerned about this shortcut to a different discipline, and the quality of care my patients will receive. I like the examination, I would be interested to know that at least the examination will be the same as a new graduate in that discipline would have to write, since they don’t even have to have the token hours anymore. The wording about the examination appeared vague to me, hence the question.
CMRITO Member
April 3, 2023
I agree with the statement from the CAMRT in regards to the MRIT Emergency status. There are huge legal implications in allowing a fast track process to "Medical Radiation Technologist" procedures to anyone from an uncertified school or someone internationally trained. CMRITO has an obligation to it's current Medical Imaging Professionals and the patients we treat to not provide short cuts that will undermine our profession and the commitment of our current members.
CMRITO Member
April 3, 2023
Within the 5yrs (400hrs) the emergency applicant should be able to find the time to write the national exam.( the employer would need to recognize this requirement). We all did it, we all are required to provide proof of compliance with on going education. If the emergency applicant is granted to work then they should then be require to complete the same requirements as the current members working. Having a co-worker that can't work alone (needs supervision) isn't help for establishment that are in operation 24/7/365. It is added cost to the employer as they must have a MRT with the emergency applicant. Therefore the emergency applicant should be writing the national exam, preference within the 5yrs (400hrs). (preferably less). Throughout this pandemic , for those who didn't give up,,,,where is the recognition, instead you are giving non member a break .
CMRITO Member
April 3, 2023
Can this Emergency Class apply to technologists who have retired in the last one, two or more years?
CMRITO Member
April 3, 2023
In my opinion , all imaging technologists should comply with CMRITO regulations and have proper licence .
CMRITO Member
April 4, 2023
I am looking for clarification regarding the Emergency Class, how would this affect someone that has retired but may want to return to the profession to assist during a pandemic or staffing crisis? Would they need to rewrite the certification examinations again?
CMRITO Member
April 4, 2023
In my opinion all people how works at imaging should comply with CMRITO regulations and have a license , pay fees and dues what is required.
CMRITO Member
April 4, 2023
I think this is a dangerous president to set. It is not necessary . There should be greater effort to increase student positions in clinical settings to be trained under proper supervision following strict guidelines. When you cut corners ( for emergency use) it is difficult to then go back to strict liscencing guidelines . The public deserves quality and fully properly registered technologist performing their procedures .
CMRITO Member
April 5, 2023
I agree with the comments and concerns that have been submitted by members of CMRITO. As a sonographer I have seen firsthand that just because you can write and pass an exam does not mean that you are able to competently perform an ultrasound. This will come at a price to the patient's health. Is CMRITO willing to risk a patient's life just to be able to fill vacancies? I think this comes as an insult to all technologists that have worked so hard to make their profession what they are today.
CMRITO Member
April 6, 2023
It's totally unfair to allow anyone to work without writing a proper exam and a proper registration. MRTs are the least respected members in the medical field. This makes the whole profession appear unimportant and secondary considering the amount of education you need to become one. MRT's are already getting underpaid by IHF, this will open doors to exploitation by recent rich immigrants who are constantly buying IHF without any knowledge of how to properly regulate anything in the medical field.
Organization
April 14, 2023
Click here to read the letter from the Competition Bureau in response to CMRITO's revised emergency class of registration regulation consultation.
Organization
April 18, 2023
Click here to read the letter from the Canadian Association of Medical Radiation Technologists in response to CMRITO's revised emergency class of registration regulation consultation.
CMRITO Member
May 11, 2023
I agree that a training period of 2 or 3 years is ideal.
CMRITO Member
May 11, 2023
I have been a sonographer for more than 25 years and previously a radiographer with some overlap of both specialties. I resigned from being a radiographer more than 5 years ago but I still work as a sonographer. I believe that retired or resigned former members would still be competent to perform general x-rays and should be given a chance to be reinstated perhaps with limitations if necessary. For example, perform chest or extremity x-rays only or submit a log book of supervised exams performed prior to working independently. However, in the sonography specialty, the scan is so operator dependent that pathology could be easily missed if not provided on the images submitted to the radiologist. I am not sure how this happens but I have already seen members who have passed the exams but cannot scan because their hands on scanning experience was lacking. Priority one is protecting the public but I would be happy to be recognized as a radiographer once again since I am still an active member of CMRITO
CMRITO Member
May 11, 2023
I dont think any short cuts or exemptions should be considered at all...techs should have to be fully trained and certified in Canada
CMRITO Member
May 11, 2023
7.1.2 should read: "The applicant must have successfully completed a medical radiation and imaging technology program in a specialty approved by Council." It is inappropriate to have the Registration Committee act in the role of verifying approved programs. When the Registrar has concerns about an applicants fitness to practice, the Registration Committee acts as a independent double check. By having the Registration Committee involved in the approval of non-Canada courses/programs, you are removing the independence from the process. 7.1.3.6.i: The mandate of the Council is to make sure that all medical radiation and imaging technologists provide safe, effective and ethical medical radiation and imaging technology services to the public of Ontario, and meet or exceed accepted standards of practice. The Council is not equipped to determine or assess the ending of an emergency circumstance. The declaration of an emergency is a function of the Government of Ontario. This portion should be removed. On the whole, government should signal how the emergency registration class will be activated and deactivated across all regulated health disciplines. It is feasible to see that this will be geographically specific and very fluid. 7.1.3.6.ii: The Registration committee has no role in revoking a registration. This is a function of the Fitness to Practice committee. Again, this adds new powers to the Registration Committee that conflict with its core mandate and degrades its function of being an independent assessor on an applicant meeting didactic requirements. Each member should be respected and a fair, equitable and transparent process applied if their registration class is revoked. I am upset to see an ill defined and parallel process for this needed and important class of registration and want to see the Registration Committee removed from here. On the matter of the national exam. I am supportive of the national exam being a requirement for practice, but need to see modernization in the exam process. As a Senior Director in one of the largest and busiest facilities in the Country, I cannot fathom why the examination process is held twice a year and why it takes 3-weeks to understand if one passes. I think we should include language in the legislation that mandates expedition of the process. I question the effectiveness of this legislative change if we do not change the frequency of exams. I would like to better understand the relationship with the CAMRT as the exam issuing authority and suggest that it is in the publics best interest to have exams available at any time and for the results of these exams to be immediately available. It really is time to modernize our processes to ensure the public has timely access to qualified and dedicated imaging professionals. Thank you
Member of an Organization
May 11, 2023
Very happy to see the update to make the national exam non-exemptible. I have only one suggested edit and that is the use pronouns. Suggest changing he/she etc to their/them
CMRITO Member
May 11, 2023
I trained hard as a student, placement student and then for the CAMRT exam. We all worked hard for our designations, and we are proud. Relaxing regulatory standards is not the answer. Supporting and funding Public Healthcare and individual regulatory bodies, i.e. Health Professionals, should be way. I, along with many, have strong concerns over this. A small blurb, I could fill 500 pages with reservations. Work closely with ER staff including RNs & RPNs, who order under ER medical directives. MRT's, in our facility, are continually finding instances where the medical directive is not followed, too many unnecessary x-rays are ordered. These designations do not have enough skeletal knowledge. If you do not have a clear understanding of the anatomy, and what each specific view is intended to demonstrate, you should not be ordering x-rays. The comments received, including ER Drs, is that x-ray is no big deal. They are not concerned with nursing staff over ordering, or incorrectly ordering exams. Often these same patients are sent back for additional by the ER Dr, as the anatomy ordered under the medical directive, was not what was needed. It may be okay for one ER visit, but how old is this person? How often do they visit the ER? How many CT, xray's, nuc med scans have they had in the past? Is there consideration of stochastic effects resulting from medical history? How about latent? Another huge concern is digital imaging, it has such a wide window for acceptable images that had way too much exposure. They do not have the knowledge, skills, or judgement to adjust parameters to optimal exposure. This results in too much radiation in too many patients. It's hard enough with young Ontario grads entering the field. I am truly concerned, this is frightening. We need to look forward, this is a jump backwards. Thank you very much
CMRITO Member
May 11, 2023
Certification exams and registration to the CMRITO regulatory college is an essential component in safeguarding public safety. If we begin to consider taking away these gold standards due to political and labour demands, we then are lowering our standards as a profession and may be allowing individuals who may not have passed their certification exams to provide direct and unsafe patient care. Many people pass clinical placements (very difficult to fail people during clinical assessments) when they should not and this is further confirmed by formal assessments such as certification. As an educator I do not advocate for promoting this practice even for emergency situations. We need to maintain our high standards of professional practice by ensuring all employed MRTs are mandated to write their certification exams and are registered with CMRITO.
CMRITO Member
May 11, 2023
Allowing the proposed amendment to the Act is a massive mistake. Barriers are purposely put in place to allow the provincial regulating bodies to properly vet new applicants. Fast tracking the application process degrades the profession, CMRITO registered technologists and the image of the College in the public's eye. There is absolutely no reason why our high standards should be LOWERED to increase staffing rates. If this Act passes, and we know it will, EVERY SINGLE CMRITO technologist should receive a FULL refund of their fees and exemption from yearly CME requirements until the Act expires. Let's be fair...if the new applicants can be admitted with lower standards, then lower the bar for the rest of us. We should not be penalized for the short comings of the Ford Government.
CMRITO Member
May 11, 2023
What is meant by an emergency class of registration?
CMRITO Member
May 11, 2023
Many of the highly qualified and experienced technologists are retiring or leaving the profession, since the pandemic, due to stress and burnout. This is the main reason for staffing shortages. For the dedicated and qualified that remain, you are adding to an already difficult situation. Under qualified emergency technologists will require more supervision and individual time to train. Can you afford to lose more qualified staff due to burnout, because you will, and then what??
CMRITO Member
May 11, 2023
I am totally agree with the amendment that national certification certification should be mandatory for safe practice of emergency class technologist and to ensure public safety
CMRITO Member
May 11, 2023
In general, I think this is a bad idea. If we're so short on MRTs, we need to have open and honest discussions with appropriate stakeholders about why so many are leaving the profession. We have a huge number of graduates, and at the same time, our center has never had turnover like we've had in the last 4-5 years. This is a systemic issue that throwing in emergency registrants will not fix; in fact, having hospitals filled with emergency registrants will only amplify the existing issues in our already broken system. I'm afraid that CMRITO cannot solve this problem; it's provincial mandates and individual hospital policy that can make the changes. Regarding "clinical practice in the specialty within the five years immediately," - I would like to see a more specific definition of 'clinical practice.' From my experience, we have individuals who are technically still in 'clinical practice' but who are in research or education roles and haven't treated, planned, or simulated a patient in a number of years and who struggle with those skills when they are asked to do so. Regarding "The member shall practise only in the areas of the profession in which the member is educated." - if they are to have successfully completed a medical radiation and imaging technology program in a specialty in Canada approved by Council or in a jurisdiction approved by Council or the Registration Committee - then what areas do you think they would NOT be educated in? Canadian education is extremely comprehensive and this wording feels like there's a grey area not being disclosed. If they are not competent enough to work alongside another emergency class person, then that's dangerous. If you're requiring members (some of whom are technically new grads with <1 year experience) to be the 'supervisor' of emergency class registrants, you're asking too much of the non-emergency people - especially if we're also teaching students. Spread people too thin and errors will happen. Human factors is the weakest link in quality. "The member shall practise only while identifying himself or herself as a member of the emergency class." - your language is binary; not all therapists identify as him/her, there's no reason not to use "themselves" as inclusive language.
CMRITO Member
May 11, 2023
Nil.
CMRITO Member
May 11, 2023
There should be NO practice within any discipline unless the person is fully qualified and has passed the appropriate exams. No exceptions. This demeans the professionalism of the current registered members and is a potential threat to the public. I think this highlights how little the MOH understands the complexity of the various disciplines, it is not as simple as changing one’s shirt or borrowing a pen because you don’t have one !
CMRITO Member
May 11, 2023
In Paragraph/section 7.1 Emergency Certificate of Registration Section 4, point 2. The supervisor of the MRIT (emerge) needs to have the power to halt the practice of said MRIT (emerge) if they are concerned that the practitioner does not have the requisite Knowledge, skills and judgement to complete the task safely and appropriately, pending a review of the emergency practitioner's skill set.
CMRITO Member
May 11, 2023
Will these new regulations even further degrade the abilities required by 'sonographers'. There is an incredible number of practising, registered, sonographers who fail to show a reasonable ability in their scanning skills (skills is a very loosely applied term here). Many of these unskilled people obtained CMRITO status after the grandfathering allowance in 2018-2019, meaning that regulation is not weeding out those who have not obtained adequate training. They study from the exam prep books, manage to pass, but fail to hold the transducer in the correct orientation when faced with a scan test at an interview. I feel sorry for the general public if standards fall even further.
CMRITO Member
May 12, 2023
Everyone should be properly trained under supervision with good scanning techniques and anatomy knowledge
CMRITO Member
May 12, 2023
In case of emergency registration the continuing education should be “limited” to the mandatory continuing education required by the employer.
CMRITO Member
May 12, 2023
What is the Emergency class of registration? How will this issue affect your paying members? How is it deemed compliance with a new regulation under an act that has been in place for the past 32 years? How will the consultations work? When you were consulting to bring sonographers under the oversight of the CMRTO, I engaged in the alleged consultative process and absolutely NONE of my questions were answered - is this the arrangement in place this time as well? Please consider these Qs part of the consultations being offered and undergone. Awaiting your answer
Member of an Organization
May 12, 2023
Sonography Canada appreciates the opportunity to comment further on the proposed changes to the regulation, as revised and presented. Thank you to the CMRITO for taking our original comments and recommendation into consideration and making the DMS certification examination a non-exemptible requirement for full specialty registration. We feel this is critical for ongoing patient safety in the province of Ontario and for protection of the public. We broadly support the latest amended regulations and would like to add one remaining concern that was also addressed by the Canadian Association of Medical Radiation Technologists....namely that emergency class registration should not be available to those who have already failed the Sonography Canada certification examinations multiple times. We agree with CAMRT in that this will allow emergency class registration to those who have already attempted the national certification examinations and failed several times. We echo CAMRT....Sonography Canada recommends inclusion of conditions that would remove eligibility for these individuals.
CMRITO Member
May 12, 2023
I disagree with the emergency class of registration. Having a registration does not imply that this person would be competent to obtain diagnostic images. They should have to pass the exam like everyone else in order to obtain a registration. Healthcare may be crumbling in Canada, and this doesn't mean that our profession must do so as well.
CMRITO Member
May 13, 2023
My plan to visit Canada and complete the requirements is by April - May/2023, unfortunately the Country of Sudan have been invaded by Repel forces (RSF) which has occupied and destroyed the whole country which includes the ports of departures, so I need an exception period to arrive to Canada however we have no internet services and when it comes it comes with very low speed.
CMRITO Member
May 13, 2023
This is a very dangerous proposal. It should not be allowed to happen. Also all technologists believe your lack of concern over bill 60 is disappointing.
CMRITO Member
May 15, 2023
Council to consider reduced Dues for Part-Timers.