Q1: Would the College be a separate body from the Associations and require separate membership fees?

A1: Yes, a College is a regulatory body -- completely separate from an Association -- which sets their own fees and are 100% funded by the College membership.

RMTs are paying over $780 CAD per year to the College (CMTO) in order to practice massage therapy in Ontario. This College fee does not include liability insurance, business licensing, and business/entity registration with the College.

Note: Businesses attempting to register in most Self-Regulated provinces must have their business name approved by their respective College in order to be given permission to operate. This includes multi-disciplinary clinics where each self-regulatory college would give approval; for example, in a clinic with chiropractors, physiotherapists and massage therapists, all three of the regulatory colleges would have to approve the business name.

Colleges also require written and practical examinations be completed before therapists can become eligible to apply for membership. [2020 CMTO]

Practitioners from outside of Ontario must complete prior learning assessments, a written examination, and a practical competency examination (at an estimated cost over $ 2000.00 CAD).

Therapists seeking to work in Ontario (from other self-regulated provinces) must have completed their written and practical examinations (or complete the examinations in Ontario for a cost of at least $ 1200 CAD) and would also need to complete a jurisprudence exam (approx. $ 200 CAD) to reflect the differences in the massage-specific laws for each province. Once these items have been completed the candidate can then apply to the College for membership.

Self-Regulated provinces limit labour mobility by not recognizing the training or experience of those from other countries or unregulated provinces. If a therapist moves to an unregulated province without maintaining their status (active or inactive) and obligations of membership in the self-regulated province, the therapist may be considered to have 'left the industry' and would not be able to move back into a self-regulated province without hardship. Applicants attempting to move back into self-regulated provinces may be told to complete prior learning assessments, retake their written examinations, retake their practical examinations, or be instructed to completely retrain their therapy skills in a professional educational institution.

Memberships are not transferrable across Associations or Colleges.

Joining a professional association (to support and protect the therapist) is considered optional in most Canadian provinces that are self-regulated and would cost between $125-400 CAD per year.

In Nova Scotia a therapist must be registered with a Massage Therapy Association in order to practice using the title of Massage Therapist. Association membership would run between $ 125-400 CAD per year.

Massage Therapist Registrants of an Association in Nova Scotia are eligible to perform direct billing with Insurance Benefit Providers.

Q2: What is the difference between Title Protection Legislation in Nova Scotia compared to Self-Regulation of Massage in provinces such as Newfoundland, New Brunswick or Ontario?

A2: Title Protection does not create a College of Massage Therapists.

Three associations were included under the Nova Scotia Title Protection Legislation which was proclaimed as of January 01, 2020. In Nova Scotia, the title of Massage Therapist/Registered Massage Therapist (or similar names) must be approved by one of the designated associations and follow the criteria laid out in the Act. For more information on the act (also known as Bill 193) click here.

In a self-regulated province, a College is the one and only gatekeeper to the insurance companies, the only body that can grant the title of RMT or like names, and the entity that has the ability to internally investigate complaints, like sexual assault and fraud, through the use of special investigators within the College system.

The Nova Scotia Government has this to say about the differences between bill 193 (Titles Protection) and Self-Regulation

Q3: How would Self-Regulation change the existing Association(s)? CEUs? Policies?

A: MTWPAM is unlikely to continue as an association if a College forms within Nova scotia.

MTWPAM is made up completely of volunteers who maintain autonomy and have a separate voice from the other associations.

If we all have to join a College to practice there may be little reason to continue running the association if the draft proposal is accepted. In some self-regulated provinces there is only one association serving to protect the therapist and some Colleges deem membership in these associations to be optional.

Associations in self-regulated provinces still can present massage therapist concerns to the College, offer group rates on liability insurance, promote massage therapy to the public and government and attempt to help promote change within the profession.

Associations outside Self-Regulated Provinces:

• serve to represent and support the therapist
• serve as a liaison between government entities and therapists
• act as gateway to allow direct billing from insurance benefit providers
• perform investigations into the conduct of the membership
• set training standards and educational requirements for the membership
• promote the profession to the public
• direct serious matters of misconduct to legal authorities as needed

It is uncertain how the multiple associations will work together if self-regulation is proclaimed in the province.

Continuing Education Units (CEUs)

CEUs of 30 credits per cycle is pretty standard across Canada but Ontario has recently changed their continuing education program. CMTO members now complete an online self-assessment called Strive and all courses undertaken must support the therapists chosen development path (as approved by the College). As such, the College no longer pre-approves continuing education courses from other training providers. It is unclear what impacts are being felt by CEU providers or what cycle requirements exist in this new framework.

Policies in Self-Regulated Provinces

The best thing to do is look up each regulated provinces website and go through their 'Scope of Practice" or other documents to determine the differences. Each College has their own view as to what modalities are considered massage therapy.

In some self-regulated provinces you can be removed from the profession for treating your spouse or partner as these activities are listed on the College websites as "sexual assault" offenses. Some Colleges consider the treatment of friends and family members as a 'conflict of interest' and require immediate discharge and referral to other practitioners.

In some self-regulated provinces certain modalities such as cupping and aromatherapy are forbidden to be performed by Massage Therapists.

Q4: Will there have to be consensus of a majority of therapists in all the associations before the legislature would consider passing a bill for Self-Regulation?

A: Yes and No.

MTWPAM would request an actual vote from all therapists in the province but it does not mean the government would have to grant this request.

Note: There is an opportunity for all members of the public or profession to attend legislature to comment or speak to the passing of any bill.

The government can institute any form of regulation as long as they can substantiate that the government is acting in the best interests of the public.

It is the duty of all Massage Therapists to be informed of the nuances of self-regulation legislation in order to understand impacts and to ensure informed consent.

Q5: The Canadian Red Cross provides health equipment to people who are referred by a registered health provider like physiotherapists, OTs, RNs, LPNs and Doctors who fill out a recommendation form -- will we be able to do this?

A: Likely the answer is No (as has been the case in self-regulated provinces for a hundred years).

The Red Cross loans equipment based on an assessment or recommendation from certain health care providers/professionals. As much as we know what we can do, and are capable of, our education program is still a private career college program and not a university degree.

It is understandable that many RMTs want to be seen as on par with other health care providers but self-regulation in other provinces has not accomplished this in over a hundred years (CMTO).

Q6: WSIB and Compensation Claims -- If Self-Regulated will we be able to process WSIB/ Compensation Claims?

A: No.

RMTs in self-regulated provinces are not able to sign off on their own WSIB cases.

"Payment for massage therapy will be considered when it is recommended by the workers’ primary health professional (i.e. physician, chiropractor, Registered Nurse (EC) or physiotherapist)." -WSIB

Q7: Would therapists that have already graduated from a 2200-hour program be grandfathered in without taking an additional exam?

A: Uncertain.

Therapists would likely be 'grandfathered' in (accepted) but the final decision on the policy would be up to the government.

We cannot guarantee that 'grandfathering' will happen.

In the current framework of Self-Regulatory Colleges, and what was proposed by MTANS/NHPC, new graduates will be faced with written and practical examinations before they can may be eligible for membership and to be able to practise in the province.

Q8: Would there be a document outlining the terms of regulation available for our membership to read before voting on this issue?

A: No.

You can research other provinces websites and compare but there would not be a sample of the policies.

Associations can initiate the request for self-regulation -- or input into terms -- but the policies will be created and set by the government.

Q9: Do terms vary from province to province and who is it that makes up the regulating body?

A: There are slight variations province to province.

Every College board is made up of massage therapists and government-appointed members of the public.

There are also paid administration staff, private investigators, peer assessors, legal staff et cetera who serve within the College.

Q10: Would this affect the kind of insurance that we need to carry?

A: No. Our insurance requirements are the same as in self-regulated provinces.

Q11: As it is now, Massage Therapists in British Columbia are trained differently than those trained in Nova Scotia, for example. Would this self-regulating body determine that the education that all massage therapists receive all be similar?

A: There is a lot of confusion about standards for training with various groups doing different things.

This is what is happening in self-regulated provinces:

https://www.cmto.com/about-theprofession/interjurisdictional-practice-competencies-and-performance-indicators/

The Nova Scotia Massage Therapist Titles Protection Bill sets 2200 hours as the minimum level of education for Nova Scotia. 2200 hours has been the accepted minimum across the country (and is the minimum the insurance industry will accept for billing privileges).

British Columbia is an exception with a requirement of 3000 hours of training. BC is also a member of FOMTRAC and follows a competency-based model.

In Quebec, and the United States of America, therapists may practice with as little as 500 hours of training from a private career college while some countries like New Zealand have university-level training programs.

Q12: If the association becomes regulated will I, as a member who has been grandfathered in, still be able to be a member of the association?

A: I think this question was referring to the new Title Protection Act. Yes, as far as we can see right now.

Under Title Protection all of our equivalent members should be accepted or 'grandfathered' in. It seems reasonable that all members would be eligible to join a College as well although we have no guarantee. The decision would be made by the government.

Q13: Will Self-Regulation mean we'll be Recognized as a Health Professional or Health Care Provider?

A: We would be governed by the Regulated Health Professions Network. There would be no change to our employment/payment structures and becoming a regulated health profession has not made massage therapy covered by the public health system anywhere in Canada.

There were some limited coverages in Ontario and BC but to the best of our knowledge they are discontinued and not likely to return.

NS Department of Health and Wellness clarification

"Currently, Nova Scotia does not have its own Regulated Health Professions Act. All self-regulated health professions in Nova Scotia are regulated under their own separate and distinct Acts and Regulations and are all members of the Regulated Health Professions Network (RHPN).

The differences between the current legislation (Title Protection) and full self-regulation is as follows:

1. The purpose of title protection is to ensure that each person using the professional title has the credentials to do so; title protection sets out the minimum criteria required to represent oneself under the specific professional title (i.e. Massage Therapist).
2. The purpose of self-regulation in health professions is protection of the public. Self-regulation is founded upon the principle that members of the profession are best able to regulate themselves given their knowledge of the profession and of services provided, and the value of peer review and peer oversight.

Self-Regulation Standard Regulatory Activities include:

• registration and licensing of the profession 
• registration appeal procedures;
• investigation of complaints, including powers of the investigation committee and complaint disposition;
• the professional conduct review process including professional conduct hearings, and publication of decisions; and
• preparing and tendering settlement agreements."

Q14: Will Self-Regulation (the government) help us stand up to the insurance companies who want to get rid of massage therapy as a health benefit?

A: No. The role of the Colleges of Massage Therapy in regulated provinces is to protect the public from massage therapists. It does not advocate for the profession. Associations would need to work with the insurance companies to educate them on their policies with regard to the membership.

Q15: How long is legislation going to take?

A: The Title Protection Act should come into effect fairly soon.

If we were to pursue a College/Self Regulation it could take a few years to work out the policies or be done quickly, there is no way to predict a timeline.

Q16: Will being Regulated make massage therapy HST exempt in Nova Scotia?

A: No.

HST exemption is a federal matter and must be applied for on a national level. Colleges are provincial and have no ability to change federal statutes.

A request has been made to the federal government by several entities. If that application is successful all provinces would become HST exempt regardless of regulation.

More info here: https://www.rmtact.ca/

No self-regulated provinces are currently HST exempt. Clients can claim massage therapy as a medical expense.

Q17: Do Colleges set prices on massage therapy services?

A: No, they can have a suggested fee schedule but RMTs can continue to set their own rates in any province. Remember that the insurance benefit providers continue to set their own rates in regard to what maximum fees they will cover per client.

Q18: Does being self-regulated mean that untrained people can no longer offer massage?

A: No, massage therapy is NOT a controlled act in Canada. Please see the section at the top of this page for information on controlled acts.

Anyone in any province can provide or sell massage services.

Even if there was a College and someone had their RMT designation 'taken away' they can still obtain liability insurance and perform massage therapy. They just cannot call it massage therapy or any variation of that designation.

The Nova Scotia Titles Protection Act provides an immediate solution to ensure safety to the public in regard to untrained therapists. The public may reach out to law enforcement at any time (and without expense to any Association or College) to report suspected violations of the act.

Self-regulated Colleges must investigate any improper use of names/titles (at expense to the College) and present their investigation results to law enforcement for further action.

Q19: What has MTWPAM been doing in regard to providing information and awareness for Self-Regulation in Nova Scotia? 

A: The MTWPAM Board has been involved in discussions on and off for many years as it does get brought up by other associations and interested parties.

The MTWPAM Board met with other massage therapy associations beginning in 2018 to discuss communication and collaboration efforts to promote the profession. In the summer of 2018 MTANS indicated that it would be moving forward with a proposal for self-regulation and began sharing information on what that proposal might look like. In the spring of 2019 MTANS requested final comments on their proposal and that members of the committee sign as non-disclosure agreement to proceed further.

MTWPAM declined to sign any NDA believing that the process should be transparent and open to all invested parties. MTWPAM cited that they would reach out to their membership to provide awareness and to seek input from the membership.

A series of five information sessions were held in-person, between May and November of 2019, to discuss the term self-regulation and what that could mean for massage therapists within the province of Nova Scotia if a proposal were brought forward.

These informational 3 hour sessions included the slideshow provided by two other associations who had submitted a proposal for self-regulation to the province. Questions and concerns were discussed by members and the board representatives in an informal format.

A survey was distributed electronically in August of 2019 after the AGM (June) which included all the information and comments provided during the first three sessions so that informed members could decide if they wanted to move forward with self-regulation legislation. A good deal of time was also allowed at the AGM for members to discuss self-regulation within the province.

Members were encouraged to attend the MTANS virtual symposium in October of 2019 to see what MTANS had presented to the Department of Health and Wellness. A member from the department was present at this symposium.

Additional sessions were held in the fall and a vote was distributed to members for their review and completion in November -- with any questions, comments or concerns -- the results of which were delivered to all registrants of the association and the department of health and wellness. The results were shared electronically with all members of the association and were presented at the 2019 and 2020 AGM.

If you would like to know more, please reach out.