TC Formal Consultations Draft Regulations for Homeopathy
Last Updated on Friday, 07 October 2011 12:26
Written by Ontario Homeopath
Friday, 07 October 2011 09:01
Transitional Council of the College of Homeopaths of Ontario
Formal Consultations Draft Reguations for Homeopathy
The transitional Council has reached an important juncture in its work to develop the three statutory regulations required under the Homeopathy Act, 2007, in order that the Act may be fully proclaimed and the College may begin operations. The Registration, Quality Assurance and Professional Misconduct Regulations are now ready for consideration by stakeholders during a 60-day statutory period, beginning August 15 and ending October 18. During this period, the transitional Council is requesting written submissions and comments from all interested parties.
To read the complete draft regulations log into the Council's website at http://www.collegeofhomeopaths.on.ca/index.html
Or click on the following links:
Quality Assurance: http://www.collegeofhomeopaths.on.ca/docs/Quality%20Assurance%20Regulation%20Consultation.pdf
Professional Misconduct: http://www.collegeofhomeopaths.on.ca/docs/Professional%20Misconduct%20regulation%20for%20Consullation.pdf
OHA Board of Directors' Response
Your Board of Directors has spent considerable time and effort pouring over the documents and drafting a response. Below is a sample of our response which highlights the three main areas we feel need to be addressed.
We appreciate the opportunity to respond to the draft regulations proposed by the transitional Council of the College of Homeopaths of Ontario. The Ontario Homeopathic Association (OHA) represents approximately 200 highly qualified members.
OHA supports the transitional Council’s mission statement: ‘The Mission of the transitional Council of the College of Homeopaths of Ontario is to protect the public interest through self-regulation of the practice of homeopathic medicine by setting high standards for competency and ethical practice’. We look forward to recognition and practice of homeopathy to its full potential through clear and adequate regulations that will set the stage for excellence of the homeopathic profession in Ontario.
As an initial comment, we note that the draft documents mention prerequisite basic chemistry and biology courses for entry to practice. However they do not specify basic medical science courses as part of the qualifications. Perhaps this will be addressed in the competency guidelines that are currently being developed. We feel strongly that fluency in basic medical sciences is essential to all professions under the RHPA. This is an important component in understanding and discussing health concerns with our patients, who are generally well informed and for competent referral and collaboration with other health care providers involved in our patients’ care.
That said, in reviewing the draft documents we have identified a number of problematic areas with suggested amendments. Of these, we would like to highlight two of the issues - one that would significantly reflect on competence and the other relating to clarity of professional designation.
Registration Regulation 2.(1) 10.ll – We suggest the number of hours of professional practice required for registration, be changed from 750 hours within three previous years, to a total of 1400 hours. We specify the hours be divided between a minimum of 300 practice hours during the last three years, and 1100 hours of supervised clinical internship with face to face patient management, any time in the past. We propose that the clinical internship is necessary to develop competence and confidence for professional practice. These clinical internship hours, combined with three hundred hours of professional practice in the preceding three years will allow new applicants time to build their practice.
Registration regulations 3 (1) 10 - We find the issue of ‘title, professional designation’ to be particularly problematic. The term ‘Homeopath’ is well and clearly understood by both the profession and the public. Further, within the provision of the Homeopathy Act, 2007, ‘Homeopath’ is a protected title, thus negating the need for a qualifier such as ‘registered’. The Transitional Council’s draft proposed abbreviations such as RH or RHP will have the effect of clouding the identity of the profession and its members, with possible erroneous interpretations such as ‘registered herbalist’ or ‘registered holistic practitioner’ among others. We propose that the professional designation be ‘Homeopath’ with no abbreviation at this time.
To read the OHA's full response please sign on to our Members' Login at www.ontariohomeopath.com. Under the 'Membership Menu' choose 'Proposed Regulation Response' to view the complete document the OHA will be sending to the Transitional Council prior to October 18th. In this section we have also provided you with a sample response letter that we ask you to send to the Health Minister and Transitional Council ASAP with any additional personal comments. We need our voices heard! We graciously ask that OHA members please take a few minutes to defend our profession by sending your own personal response and/or support for the OHA's position by forwarding the sample response letter.
We look forward to hearing your comments regarding these documents. If you wish to send comments to the transitional Council, please consider sending OHA a copy via 'cc' in your email.
If you wish to send comments to OHA regarding our proposed response, email the OHA at
and list 'TC draft Regulations' in the subject line.
If you wish to send comments to the transitional Council, please find their official response template document at http://www.collegeofhomeopaths.on.ca/docs/Feedback%20Form%20Final%20fillable.pdf
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