Much has happened in the past few weeks with regard to our regulatory activities.
In April the BC government released a report by Harry Cayton, entitled “An Inquiry into the Performance of the College of Dental Surgeons of British Columbia and the Health Professions Act” (Full report). At the time the Cayton report was released, our work with the government assisting in the development of the scope of practice regulations for Radiation Therapy was essentially completed, and we were waiting to hear when the draft regulations would be posted for public consultation. This work is now currently on hold as the BC government considers the recommendations made in the report.
The most significant recommendations for MRTs made in the report are contained within Part 2 (starting on p. 69). Within this part of the report, Cayton makes many recommendations as to how the current Health Professions Act in BC could be significantly reformed. In addition, he makes numerous recommendations about the general framework for regulation of healthcare professionals in BC. Below are a few of the highlights from the report that are of particular interest to the CAMRT-BC and the other three disciplines that are currently seeking self-regulation.
- Note 9.30 on p. 75 regarding the amalgamation of colleges: Part 2.01 of the HPA sets out arrangements for the amalgamation of colleges. The Ministry of Health should actively encourage and facilitate mergers, especially of the smaller less well-resourced colleges. The joining together of the three nursing colleges is an example to others. I do not think that mandating mergers at the present time would be good for public protection as the colleges vary so greatly in size and competence. The result might be to damage a smaller college which performs well by merging them with larger college which performs badly. Fewer, larger colleges with resources adequate to do their job should be the objective. This should also reduce fees to registrants.
- Note 9.32 on p. 76 regarding a moratorium on new colleges: The Ministry of Health should as a matter of policy place a moratorium on creating any new colleges and should consult on how any occupations currently under consideration for regulation could be registered with an existing College.
- Note 10.2 on p. 85 regarding the way healthcare regulatory bodies have been set up in the past: In numerous jurisdictions self-regulation of the liberal professions has shown itself slow to adapt to the expectations of consumers. In healthcare in particular it has struggled to adapt to the changing needs and expectations of patients, to new technologies and to new business and delivery models. Regulation based on the supposed uniqueness of individual occupations runs counter to contemporary practice through effective team-based inter-professional collaboration. It also protects existing occupational boundaries against new roles and ways of working, putting up barriers to desirable developments in the expansion of the health workforce.
- Note 10.21 on p. 89 regarding a moratorium on new colleges: In order to make progress on reform of the professional regulatory framework there should be a policy commitment that no new colleges are created. There should be active encouragement existing colleges to follow the lead of the nursing colleges and to seek partners for amalgamation. The smaller colleges are a priority and are likely to benefit most from the economies of scale and increased capacity arising from mergers.
- Note 10.22 on p. 89 regarding a assessing the need for a college based on risk: An evidence based occupational risk assessment process should be developed and implemented to identify the potential risks of harm from occupations within the health sector and to consider the appropriate mitigations. Only if statutory regulation is necessary should it be proposed. Other levels of assurance may be sufficient to manage the risks. The new oversight office should make recommendations to the Minister including as to which college new occupations should be allocated.
- Conclusions of Section 2 (p. 92) 11.1 There are many amendments and improvements that could be made to the Health Professionals Act to make it fairer to both registrants and complainants, clearer and easier to operate for Colleges and more transparent to the public. I have suggested some of the improvements that could be made in this report. 11.2 If the HPA is to be amended a full consultation on changes and a careful consideration of how they would actually work out on practice will be needed. Right-touch regulation warns us of the importance of considering the unintended consequences of regulatory changes as well as their benefits. 11.3 It is my conclusion, however, that changes to the HPA alone will be insufficient to create the flexible, public focussed, team-based and efficient regulatory system needed to support the delivery of safe healthcare in the future. 11.4 A complete overhaul of the way health professional regulation is conceived and delivered is required. I have set out a new structure to improve governance, performance, fairness, efficiency and cost effectiveness. I hope that the Ministry of Health, with the support of the colleges and, importantly, the health professions themselves, will seize the opportunity created by this review to work together to shape reform in the interests of the citizens of British Columbia.
CAMRT-BC Advocacy on the Regulatory College (July 2019)
As you can see there are recommendations that could impact the implementation process for self regulation of Radiation Therapists in BC. Right from the release of this report, CAMRT-BC has been working internally with our partners, volunteers and stakeholders to assess and formulate a response to this report.
- On May 5, the CAMRT-BC sent CAMRT-BC_Response to Cayton Report to the Minister of Health and other government officials, outlining our concerns about where this report might leave our regulatory status. Our regulatory partners, the BC Society of Laboratory Science, the BC Society of Respiratory Therapists and the BC Society of Clinical Perfusion have also responded to the government.
- Following notification on May 11, of a public consultation on Part Two of the report by the government, CAMRT-BC began working with partners and other stakeholders to respond to the Cayton report in detail. This feedback was submitted on June 12, 2019. The committee is chaired by the Honorable Adrian Dix, Health Minister, Mr. Norm Letnick, health critic for the official Opposition and Ms. Sonia Furstenau, health critic and house leader for the BC Green Party caucus. Members of the public and health system stakeholders were also invited to provide written comments on Part Two of the report, see the CAMRT response here.
- The CAMRT-BC is meeting regularly with our regulatory partners to discuss next steps. When more information is available, we will be circulating it to the membership.