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The Government of Ontario is continuing its efforts to increase health human resources capacity to respond and recover from the pandemic, ensuring Ontarians have access to safe, high-quality care now and in the future.
To that end, a new regulation under the Regulated Health Professions Act, 1991 (RHPA) requires all health regulatory colleges to have an emergency class of registration by August 31, 2023 which must include:
Implementing these new requirements will require the College of Medical Radiation and Imaging Technologists of Ontario (CMRITO) to amend its Registration Regulation made under the Medical Radiation and Imaging Technology Act, 2017.
As you may recall, on June 14, 2019, Council approved a proposed Registration Regulation made under the MRIT Act for submission to the Ministry of Health (MOH). This proposed Registration Regulation, was the subject of a previous consultation.
In order to comply with the new RHPA regulation, the CMRITO’s Executive Committee, acting on behalf of Council, has approved, for the purposes of circulation and comment, amendments to the proposed Registration Regulation to establish an emergency class of registration (referred to in this consultation as “the Amended Proposed Regulation”).
In accordance with the RHPA, the Amended Proposed Regulation is being circulated for 60 days to members and stakeholders for comment. Prior to finalizing the Amended Proposed Regulation, Council will consider all comments received by the deadline, keeping in mind the CMRITO’s mandate to protect the public interest.
You are welcome to provide your comments using this form.
The deadline for receipt of comments is March 30, 2023.
Click here to review the Amended Proposed Regulation, with the proposed amendments that are being circulated for comment highlighted in yellow.
Please note that all comments are reviewed before they are posted to ensure that they comply with our Social Media Policy.
CMRITO Member
January 26, 2023
Terrible idea to be honest. There are going to be a lot of substandard and improperly educated technologists who are going to end up working in clinical settings that will be a danger to not only registered technologists but to patients as well. This will result in poor quality clinical outcomes for everyone.
CMRITO Member
January 26, 2023
yes
CMRITO Member
January 27, 2023
Hello. Is there a layman's explanation for what this legislative change refers to? I am not sure I understand what I should be expressing my opinion on. What is the government attempting to bypass here? Thank you,
Member of an Organization
January 27, 2023
None
CMRITO Member
January 27, 2023
Given the diluted state of education that we are currently seeing with "sonographers" who have been educated outside Canada (and some inside Canada), i can only fear the quality of staff who will be practising if people are rushed through the process and allowed to practise with even less screening and education. The quality of sonography in Ontario is falling, and will continue to fall as long as there is not a requirement that personnel are properly trained and as long as schools which do not adequately meet standards are allowed to graduate under-prepared "sonographers". The skill of sonography is disappearing; we are seeing picture takers. Schools such as McMaster-Mohawk, CNIH, & Anderson continue to strive to educate students to a high standard; but there are several whom we could mention in the GTA who are not teaching anywhere near to an appropriate level. However, they are allowed to exist and charge exorbitant rates for little value. But, since we are in a shortage, these schools are allowed to flourish. Standards? What standards??
CMRITO Member
January 27, 2023
This new by law / policy , is very redundant. What is the cost of this emergency class registration. Please provide a summation of your new proposal for emergency class. Please provide a clearer document showing differences between an emergency class and regular class registration ,if not provide more then 90 days for commenting as time needed to show this information to legal counsel.
CMRITO Member
January 30, 2023
I don't understand the purpose of this class of registration, what purpose does it serve? What benefits will come from it? Do we need it?
CMRITO Member
January 30, 2023
Hello, I’m looking for more clarification on the proposal https://www.cmrito.org/programs/consultations/ prior to providing feedback via the approved form.To whom will this emergency classification apply to? I have consulted with multiple members and we all interpret the intention and application differently. Is it accurate to interpret this emergency class as an expedited ability to practice for out of province and out of country trained MRT’s awaiting complete review for permanent registration? Expedite members re-instatement who have vacated the profession in good standing, expedite previous members who left not in good standing? Can/Will this apply to students who have just graduated an accredited program and are waiting to write the CAMRT exam and receive their results for full registration? Thank you for the clarification.
CMRITO Member
January 30, 2023
Emergency class designation assuming will be posted on the CMRITO public website with the expiry date and or if it has been revoked. My thought that it is best that the college monitor this as there is already a lack of compliance and reliability of current members to update their information online. Requesting more clarity with respect to scope of supervision as this does impact recruitment and potentially scheduling of staff. If there are limitations to independence, the hiring facilities need to be aware as we screen applicants resourcing the CMRITO website. For defining clinical practice hours: in Canada only or does international hours, if verified, qualify?
CMRITO Member
January 31, 2023
As many of my questions would be the same as posted by others before me, I will not repeat. However, I would like to suggest that a FAQ post be created to help better inform members for feedback that will be meaningful. Initially, I can see the benefits but greater clarification is needed around the meaning of "supervision" as well as whether the date for enacting this could be pulled forward to allow flexibility with upcoming graduates who have not yet written their CAMRT certification or are awaiting results.
CMRITO Member
January 31, 2023
what liability will the registered MRIT supervising the MRIT Emerg will have since not part of current practice and what is the criteria to be such supervisor and approval process? "The member shall practice the profession only under the supervision of a member, approved by the Registrar, who holds a specialty certificate of registration in the same area of the profession in which the member of the emergency class is educated."
CMRITO Member
January 31, 2023
I have concerns with the proposed route to registration post-emergency for those who held an Emergency Class certificate. Specifically having the option to be exempt from the need to successfully pass the certification exam. Successfully passing the national certification exam should not be an exemptible requirement of registration.
CMRITO Member
January 31, 2023
'.
CMRITO Member
February 1, 2023
I have more questions that comments, so here it goes: - After how much education can a student qualify as part of an emergency class? - They are to work under the supervision of a professional, but isn't this the case with students in clinical practice anyway? - How many members of an emergency class can there be, anyway? Would this number have any positive effect on the delivery of health care? And, now, a comment: - This seems to me like a slippery slope, as it may be prone to misuse and exploitation, not to speak about the risk at which it would put the public. - It is rather unnecessary, actually, as the students who are in clinical practice actually act as a free workforce.
CMRITO Member
February 2, 2023
I have been an Ultrasonographer for more than 20 yrs. I have seen every level pass through doors. Having sonographers or any Medical imaging specialist pushed through with out proper schooling and training only leaves patients at risk. I have seen Sonographers say they have learned through watching You Tube Videos. This is totally unacceptable. This is not fair for the people who have gone the extra mile to learn the profession and it certainly is not fair to the patient who is assuming the person doing the test meets qualifications. Due to the fact that there is a shortage and desperate need for Medical imaging staff places will get desperate to fill positions. Having unqualified Sonographers and Medical Imagers does not solve a problem it creates a much larger problem. What about all the abnormalities that will be missed due to uneducated and under qualified people saying they can do the job. In the end this will cost health care so much more. My answer is No, there are already a lot of unqualified people who have snuck through already.
CMRITO Member
February 2, 2023
What is the new regulation we are to review ?
CMRITO Member
February 2, 2023
There are so many thoughts and questions. First this is such a slippery slope and as someone who has been a patient, my sense of fear of having any procedure done increased exponentially. This college is meant to protect the public, the only one who will gain from this change is the administrators. Secondly, as a practitioner I am alarmed at the request to devalue our role in the health care system as exchangeable (do nurses and doctors have the same proposal put forth?) Our professional expertise is not exchangeable. Will a PSW get this opportunity, can a radiologist now become a surgeon (emerg)?). Thirdly, 400 hours to replace the expertise of each profession is frankly laughable and yet "... the applicant is able to safely and competently practise" is part of the dialogue. Consider the level of the impact of errors on the poor patient in a repeat procedure for e.g. a repeated nuclear medicine scan or god forbid, an error in radiation therapy treatment where the high dose of radiation cannot be ignored. What profession will the supervisor belong to and how do they make their decision about expertise?
CMRITO Member
February 9, 2023
I believe some clarification is required to know what we are commenting on with these changes. Are students that have not passed their cmrito exams allowed to work under " emergency clause" ? Are we talking about people trained in other countries? Do these emergency technologists meet our CMRITO standards upon hiring? I am unsure how this helps the few technologists remaining that have been working throughout the pandemic. We need more skilled, trained, competent technologists at the ground level. It is not helpful to have "emergency technologists" that trained technologists are still required to oversee all the time...we have enough to do as it stands. We also do not want to compromise patients care ever. However, I do see the value of the creation of "technological assistants " being added to the mix of health care professionals. This would be a person that helps with radiological transfers, changing patients, assists with positioning, portering, cleaning up the rooms, calling for patients, answering phones. This could increase the volume of radiological procedures being performed by not having technologists performing all these tasks and leaving them more available to perform patient procedures. This could be a living wage position for someone that wants to work and have a career without too much education being required.
CMRITO Member
February 12, 2023
Where is the link for the proposed changes??
CMRITO Member
February 15, 2023
I think this is great if recent graduates are able to work in the emergency class while waiting to write their exam or if by chance they are not successful when writing they can continue to work. We are in DESPERATE need of technologists so the sooner you can implement this the better.
Member of an organization
March 22, 2023
I understand the need for emergency class, and fully support the ability of new graduates to work while waiting to write or for the results of the national certification exam. However, I disagree with the exemption of writing the national exams for those in the emergency class, especially given that in the most recent emergency (Covid-19) pandemic, access to the exams remained available. If successful completion of the exams is necessary for all other classes, then it should be for emergency class as well, perhaps with a reasonable timeframe imposed on completion of such exams. Being able to move into a specialty class without having to write the exams seems to set-up a two tier requirement for practitioners that doesn't seem fair.
CMRITO Member
March 29, 2023
All the comments made here on this platform are valid. There are many concerns legislating an Emergency class. Why does the CMRITO not make it easier for retired Technologists to return to work within an appropriate time time frame after retirement. This would have to include reduced fees for annual dues and to bypass the QC requirement . Retired technologists might return to work for short intervals to alleviate staffing pressures in imaging departments.
CMRITO Member
March 29, 2023
- future potential to become fully registered technologists - define clear guideline and responsibilities - how the roles of these members differ from the regular registered technologists - resources and tools of education programs/courses to supplement skill set
Professional Association
March 24, 2023
Click here to read the letter submitted by Sonography Canada in response to CMRITO's emergency class of registration regulation consultation.
Health Profession Regulator
March 24, 2023
Click here to read the letter drafted by the College of Nurses of Ontario in response to CMRITO's emergency class of registration regulation consultation.
Professional Association
March 29, 2023
Click here to read the letter submitted by the Canadian Association of Medical Radiation Technologists (CAMRT) in response to CMRITO's emergency class of registration regulation consultation.