Proposed changes to CMRITO fees

The fee increase is too much at once. I understand there hasn't been an increase in a while but that decision shouldn't be imposed on the technologists. There seems to be other areas in the cmrito budget where savings could be made (i.e. building lease, staff pay, etc.). Other professions like nursing and lab do not have such fees. We should be on par with these health professions, or at least in reason.

May 26, 2025

Ms. Pree Tyagi
CEO & Registrar
College of Medical Radiation & Imaging Technologists of Ontario (CMRITO)

Re: CMRITO registration fees

Dear Pree:

Thank you for inviting further consultation on the CMRITO’s proposed registration fee increases. The Ontario Association of Medical Radiation Sciences (OAMRS) values its collaborative relationship with the CMRITO and the opportunity to share concerns and comments from OAMRS members and offer suggestions.

We would like to reiterate that we believe the proposed increases are excessive, especially during a major health human resource (HHR) crisis and well documented shortages of MRTs and DMSs in our province. This is a time when we should be supporting MRTs and DMSs and promoting more MRTs and DMSs in the workforce, consistent with many Ontario government initiatives. Increasing your fees to the levels you are suggesting is counterproductive to the Ontario government’s HHR plans to address shortages, increase capacity and improve services. We are again, requesting council reconsider these fee increases.

Through your consultations, CMRITO has posted documents to justify the fee increase such as “Fact Sheet: Understanding the Proposed By-law Amendments to CMRITO’s Fees”. The points in the document are valid, however, the information is not comprehensive and lacks the complete picture. As an example, the college makes a good point that the number of registrants has grown from 6,700 to 12,100 since 2011 and workload has therefore increased accordingly, but no mention of the additional revenues received by all those additional registrants paying the fees. The registration fees have more than doubled your revenues and those revenues are not addressed.

Unintentionally, your announcement of the fee increase last fall has prompted our members to take a closer look at your financial statements and annual reports that subsequently have led to many concerns and questions about your operations to justify the proposed fee increase. In our previous letter, dated September 27th, 2024, we asked some important questions that would help justify and provide clarity for Ontario MRTs and DMSs to better understand and comprehend the fee increases. Your response to our letter was one of thanks and that you were reviewing all the feedback from the open consultation and reassessing.

MRTs and DMSs are questioning the integrity of CMRITO’s operations and would like to see evidence that their fees are being managed effectively and within the mandate of the college. In the spirit of transparency, please provide clarification and elaboration on the following points to Ontario MRTs and DMSs:

1. Can you explain the justification for increasing fees, particularly after the addition of over 4,000 Sonographers to the CMRITO in 2018? This represents more than a third of your total registrants and an increase of over $2 million in revenue.

2. Please clarify what is meant by the statement that the fee increase "will allow CMRITO to reach its financial goals by 2028 and secure the long-term financial stability of the College"? What specific financial objectives are being targeted?

3. A more detailed accounting on specific aspects of your financial statements, particularly rent, staff salaries, operational expenses, and meeting costs would be appreciated to achieve a better understanding of the College’s expenses and operations.

4. You mentioned prior to the proposal to increase fees that there was a robust exercise to review the College's finances by the Finance and Audit Committee, Executive Committee, and your independent auditors. Could you share some of these details to provide members with a better understanding for the increase?

5. Would CMRITO be open to holding an open town hall meeting with its registrants to discuss the financial statements and the rationale for the fee increase in more detail?

6. It has been noticed that CMRITO has been sponsoring and sending multiple staff and council members to attend trade shows at National Association conferences such as in Vancouver and Alberta. Our members are confused as to why an Ontario regulator with no business development would be spending tens of thousands of dollars to sponsor and attend National conferences in other provinces. Please explain your role at these conferences.

7. It has been noticed that while CMRITO supports out of province education events, it does not support Ontario education events. Why does CMRITO sponsor and support out of province MRT and DMS events but not Ontario where your registrants practice?

8. It is well known that CMRITO uses the two National Associations to administer the entry to practice certification exams for MRTs and DMSs. What is the oversight CMRITO provides for these exams and does the CMRITO approve the fees for these exams?

Our members are questioning the integrity of the CMRITO in meeting its mission for public protection and cost-effective operations of the college. We suggest that an operations and governance review by an independent third party would be a positive step forward in restoring confidence in the college. Is this something the CMRITO would consider doing? We also understand there may have been a town hall meeting organized recently to discuss the issues, but our members were not made aware. Please clarify if there was a meeting. OAMRS would be happy to assist you in the engagement process with Ontario MRTs and DMSs pertaining to any future meetings. If future meetings are planned, perhaps it could be possible to address our questions and concerns at the meeting.

We look forward to your timely response and are also open to having a meeting to discuss further.

Kindest regards,

Greg Toffner, MHS, RTR, PhD(c)
President and CEO
Ontario Association of Medical Radiation Sciences (OAMRS)

Cc: CMRITO Council
OAMRS Board
Ontario Minister of Health

I strongly disagree with the proposed changes to the fees structure for the following reasons. 1) Having the annual fee increases mirroring the Ontario consumer price index without limit does not reflect the economic reality of CMRITO members whose raises can be below that the Ontario CPI. Those running our regulatory college should not be collecting fees in a manner that outstrips the raises of those practicing in the profession. 2) The 2025 annual fees of comparable registered health professionals shows that the proposed fee of $545 (under Summary of Fee Models) is significantly higher than the $340 collected by the College of Laboratory Technologists of Ontario or the $354 collected by the College of Nurses of Ontario. And that annual due will balloon to $669 by 2029. While CMRITO compared our fee to that of psychotherapists, physiotherapists and dental surgeons, I would ask our college to provide evidence that our regulatory requirements and costs can be aptly compared to such vastly different professions and earnings. 3) Given the CMRITO stated goal of operating without a budget deficit, and the College`s ongoing annual deficit despite increased revenues from a growing collegiate body, an independent audit of the College`s expense prior to any fee increase is the minimum responsibility the College should take to ensure the public is well served by the fees CMRITO collects.