Consultation – Feedback Summaries

The following is feedback relating to all CASLPO consultations as of July 4, 2017. This includes input from the public, members and other stakeholders.

Changes to Fees By-Law Feedback

The following is the feedback received regarding CASLPO’s proposed by-law changes to membership fees in the following areas:

Application fees
2Initial Practice Registrant (IPR) fees
Annual fees for General, Academic, Initial and Non-Practising members
Proration of Annual fees
Payment of fees
Schedule of fees and penalties

The College solicited feedback by way of survey. An e-blast was sent to all members on March 28, 2017 and we posted an announcement with links to the survey on our website landing page.

In total, CASLPO received 1,222 responses (30% of the total membership). Of the 1,222 responses, 623 (51%) provided comments within the survey tool comments section. Additionally, 74 members emailed a letter to the professional members of Council. The College responded in detail on May 10, 2017.

In keeping with the College’s consultation protocols and to meet the need for open and transparent communication with the public, members and stakeholders, attached are the detailed results which are organized in the following manner:

survey sent to members, aggregate response data and verbatim comments
analysis of survey results considered by Council
original letter received from 74 members
response letter sent to 74 members

Feedback Summary

Application Fees

86% understood the reasons for the change
59% agreed that the proposed change was reasonable
Of the 1,222 respondents, 28 made comments that centred on two matters:
- The application fee should vary based on the complexity of the applications.
- Canadian applicants should pay a lower fee than international applicants who require more work to process their applications.

Initial Practice Registrant (IPR) Fees

86% understood the reasons for the change
42% agreed that the proposed change was reasonable
Of the 1,222 respondents, 101 made comments that centred on three matters:
- Fees should not increase for IPRs. They are already burdened with student loans, difficulty finding consistent work, and a lower pay scale when work is found.
- Why is more money being directed to mentorship and what are the new tools/resources being added with the additional funds?
- This increase could further reduce applications and negatively affect the membership population.

Annual Fees for General, Academic, Initial and Non-Practising Members

85% understood the reasons for the change
24% agreed that the proposed change was reasonable
Of the 1,222 respondents, 623 made comments that centred on seven areas:

i. Fee to salary ratio

Members do not receive annual increases in their salary to keep pace with inflation or any other factor.
Members in the public sector have not received any regular increases in their salary over the last 5-10 years.
SLPs are earning less due to the difficulty in finding jobs and are working more casual and part-time hours. This makes it difficult to pay the current fee.
CASLPO members pay a larger fee as a percentage of their salary compared to other professions.

ii.Cut Costs

Rather than increasing fees, CASLPO should look at cost cutting measures.
In the current environment, SLPs are doing more with less. CASLPO should do the same.
More burden is being placed on members through a fee increase when membership growth is already an issue. CASLPO should bear the burden by cutting costs.
CASLPO offices should move outside of Toronto to a location with lower rent, and away from Yonge and Bloor.

iii. Rising costs of Complaints, Reports and Discipline

Why have costs for complaints, reports and discipline risen so significantly?
What evidence does CASLPO have to substantiate that these costs will continue to rise?
CASLPO needs to find efficiencies in the process rather than passing on the costs for complaints, reports and discipline to its members.
There appears to be very few cases mentioned in the Annual report. How can these processes cost so much money?
$315,000 spent on 2 discipline cases is excessive.

iv. CASLPO fees are higher than other Colleges

CASLPO fees are higher than other provinces.
CASLPO fees are higher than other professions.
CASLPO fees are higher than other rehab and mental health professions and the risk of harm is significantly lower.

v.Why are fees increasing by 2%

Instituting a 2% increase each year when inflation isn’t known and the external job environment is precarious is not reasonable.
Fees have increased by significantly more than inflation over the years.
A fee increase shouldn’t be needed because there should be a surge in membership with the new McMaster program and increased enrollment at other Universities.
Without knowing how the College spends members’ money it is difficult to support a fee increase.

vi.College Services

CASLPO does nothing to benefit its members.
Compliance activities (i.e. SAT and peer assessment) are excessive and are not warranted.
CASLPO should do more to protect SLP and AUD jobs rather than simply offer title protection.
CASLPO takes a passive role with respect to legislative changes with regard to SLP and AUD professions and is out of touch with members.

vii.Public Awareness

CASLPO is currently spending too much on public awareness.
The current public awareness campaign is ineffective.
Rather than spending money on informing the public on how to make a complaint, CASLPO should spend the money on educating members on how to avoid having a complaint brought against them.
Members pay OSLA to inform the public. CASLPO should not take on this responsibility.
CASLPO should reduce the use of pamphlets and brochures and concentrate on social media.

Proration of Annual Fees

91% understood the reasons for the change
72% agreed that the proposed change was reasonable
Of the 1,222 respondents, 6 made comments that centred on one matter:
- Prorating membership fees quarterly rather than monthly means that individuals are paying for months during which they received none of the services or advantages associated with being a CASLPO member

Payment of Fees

92% understood the reasons for the change
73% agreed that the proposed change was reasonable
Of the 1,222 respondents, 21 made comments that centred on two matters:
- General support for the proposed change except members feel it is unfair to charge a penalty or fee to a member without providing notice.
- Why suspend a member if the fee is being added to their annual renewal.

Schedule of Fees and Penalties

93% understood the reasons for the change
85% agreed that the proposed change was reasonable
Of the 1,222 respondents, none made comments on this proposal

Conclusions

After taking into consideration the feedback from members and balancing that with the need for the College to be resourced appropriately, Council made several changes to its original proposals for fee changes, which can be summarized as follows:

The proposed increase in Annual fees of 2% for the 2017-18 membership year be reduced to 1%.
The proposed increase in Annual fees of 2% for the 2021-22 membership year be eliminated.
The proposed increase for Initial Practice Registrant (IPR) fees be deferred for one year (from October 1, 2017 to October 1, 2018) to provide IPRs and applicants with ample notice of the increase.

Click the Items Below to Review:

Transparency By-Laws Feedback

The following is the feedback received regarding CASLPO’s proposed by-law changes that would allow the College to post the following information on the Public Register:

Registration-related information regarding:

Criminal charges, convictions and bail conditions; and
Information from other regulators.

ICRC-related information regarding the following types of orders:

Oral (in-person) cautions; and
Specified continuing education or remediation programs (“SCERPS”).

Discipline-related information:

Notice of Hearing; and
Status of hearing.

The College solicited feedback by way of survey, email, fax and mail. An e-blast was sent to all members (July 14 and September 8, 2015) and we posted an announcement with links to the survey, email and fax on our website landing page. In addition, we contacted several patient-specific organizations, two of whom agreed to post our solicitation for feedback (Ontario Brain Injury Association and Ontario Association for Families with Children with Communication Disorders).

We received 326 survey responses through our e-blast (presumably all members) and 8 direct emails. Below are the trends identified. Attached are the detailed results, which are organized such that you will see each survey question followed by the aggregate responses for the first 12 questions, followed by the verbatim comments for each of the last 3 questions regarding the 3 broad areas of proposed by-law changes. The email responses follow the survey responses.

Trends

The aggregate data for all the proposed by-law changes indicated that the majority of respondents think the information should be made public and posting the additional information is in keeping with the College’s mandate of protecting the public. The total percentage of respondents who either “strongly agreed” or “agreed” in response to all questions was between 52% and 79% across all proposed by-law changes.
The strongest agreement was seen regarding posting criminal convictions (74% agreed that the information should be made public; 79% agreed this was in keeping with the College mandate of protecting the public).
Weakest agreement was seen regarding posting oral cautions (52% agreed that this information should be made public).

Criminal Charges, Convictions and Bail Conditions

Criminal findings/convictions:
- 74% agreed it should be made public
- 79% agreed the change is in keeping with the College mandate of protecting the public
Criminal Charges and bail conditions:
- 63% agreed it should be made public
- 66% agreed the change is in keeping with the College mandate of protecting the public
Information from other regulators:
- 71% agreed it should be made public
- 70% agreed the change is in keeping with the College mandate of protecting the public
Of the 326 respondents, 62 made comments about posting additional information concerning criminal charges, convictions and bail conditions; and information from other regulators (19%). Some of the emerging themes include:
- Concern about how the College would exercise its discretion when posting the information
- Misunderstanding of what would be posted (e.g. date of birth, results of mentorships)
- Would like more information about which charges, convictions and bail conditions would be relevant
- Concerns about “innocent until proven guilty” principle being lost
- Many comments of agreement

ICRC Orders

Oral cautions:

52% agreed it should be made public
56% agreed the change is in keeping with the College mandate of protecting the public

SCERPs

53% agreed it should be made public
58% agreed the change is in keeping with the College mandate of protecting the public
Of the 326 respondents, 57 made comments about posting information related to ICRC outcomes (oral cautions and specified continuing education or remediation programs (17%). Some of the emerging themes include:
- Too punitive for something that is meant to be a learning experience
- Misunderstanding of what these outcomes mean
- Confusion between allegations and outcomes (Note: We would be posting outcomes, not allegations)
- Many comments of agreement

Discipline Hearings

Discipline hearing information:

53% agreed it should be made public
56% agreed the change is in keeping with the College mandate of protecting the public

Of the 326 respondents, 50 made comments about posting additional information regarding the Discipline hearings and decisions (15%). The overwhelming trend here was that it was unclear to respondents that the posting of allegations already occurs, as does a summary of the decisions and reasons.

Conclusions

Overall, there seemed to be agreement that the additional information should be made public and that it is in keeping with the College mandate. However, many individuals commented on their concern about:

how the College would exercise discretion with regard to determining “relevancy to one’s practice”
the permanency of web-based information
other parties, such as insurance companies, banks, etc. making use of the information
the length of time charges take to be resolved, which extends the time this information would be posted
The College is presently reviewing these concerns.

Click Here To Review: Summary and Verbatim Feedback