ID
2019-001

Type
Rules
Sector
All Sectors
Status
Approved by Minister
Date
Comment Due Date

FSRA Rule 2019-001 – Assessments and Fees is intended to ensure that FSRA is a self-funded agency that operates on a cost recovery basis and to enable FSRA to carry out its legislated mandate.

Based on extensive research, collaboration and engagement with stakeholders, the proposed fee rule is intended to enable FSRA to maintain continuity of FSCO and DICO operations during the transition, and to be a forward-looking, flexible, self-funded regulator capable of responding to the dynamic pace of change in marketplace, industry and public expectations.

As per the Financial Services Regulatory Authority of Ontario Act, 2016, an initial proposed fee rule 2019-001 was posted on October 5, 2018 for a 90-day public consultation. Based on input received, FSRA posted a revised rule on February 4, 2019 for further consultation.

The FSRA Board has approved the rule and delivered it to the Minister of Finance on March 8, 2019.

As per the legislation, the Minister may approve or reject the Fee Rule, or return it for further consideration. If the Minister approves the Fee Rule, the Fee Rule will come into force on the later of: (a) the 15th day following the Minister’s approval; and (b) the date on which FSRA assumes regulatory authority over the financial services sectors that it will regulate (the latter date being the Regulatory Effective Date). If the Minister does not take any action with respect to the Fee Rule by June 6, 2019, the Fee Rule will come into force on the later of: (a) June 21, 2019; and (b) the Regulatory Effective Date.

Dialogue and consultation will be at the core of FSRA's approach to its ambitious transformation and modernization plan. FSRA appreciates the input provided on this first rule, and will continue to seek stakeholder input on future directions.

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Sector Comment Date posted Sort ascending
Credit Unions and Caisses Populaires
[2019-001] Eric de Roos - Canadian Credit Union Association

February 25, 2019
Auto Insurance
[2019-001] Not Provided - Intact Insurance
Please see attached.
February 25, 2019
Home, Life and Health Insurance
[2019-001] Tracey Primmer - Travelers Canada
Please find attached the comments of Travelers Canada. Thank you.
February 25, 2019
Home, Life and Health Insurance
[2019-001] Kim Donaldson - Insurance Bureau of Canada
Please find attached our comments of the Revised FSRA Fee Rule consultation.

Thank you,

Kim
February 21, 2019
Health Care Service Sector
[2019-001] Erika Kuehnel
Ever increasing administrative fees for sole provider healthcare operations and small clinics may act as a barrier to quality, evidence informed patient care. Increased financial/administrative requirements discourage smaller providers from providing treatment to motor vehicle injury claimants, resulting in patients with established relationships with capable providers moving to providers do not know the patient's history, preferences or goals. This makes care more costly/less efficient. It offers an incentive to large/chain clinics, that may offer less personalized care, and promotes a protracted course of recovery. This is counter to current measures under the Ontario government in recent years to deliver the "right care to the right patient at the right time".
February 20, 2019
Health Care Service Sector
[2019-001] Trina Ting
Chiropractors who treat fewer than 6 MVA patients per year should be excluded from the annual fee
February 13, 2019
Credit Unions and Caisses Populaires
[2019-001] Janet Grantham - Mainstreet Credit Union
I support taking a transitional year to implement the risk weighted approach to fee assessment this is regardless of the fact that there will be a small cost to my credit union.
February 5, 2019
Pensions
[2019-001] Jim Keohane - Healthcare of Ontario Pension Plan
See attached January 4, 2019 letter submitted on behalf of Healthcare of Ontario Pension Plan.
January 4, 2019
All Sectors
[2019-001] Jim Elson - Ontario Bar Association
Please find attached a submission from the Ontario Bar Association
January 4, 2019
Credit Unions and Caisses Populaires
[2019-001] Eric de Roos - Canadian Credit Union Association

January 4, 2019
Mortgages
[2019-001] Paul Taylor - Mortgage Professionals of Canada
Please see attached for comments from Mortgage Professionals Canada. Thank you.
January 4, 2019
Home, Life and Health Insurance
[2019-001] Denis Dubois - Desjardins General Insurance Group
Please find attached DGIG’s response to your request for comment on the proposed rule regarding FSRA assessments and fees.
January 4, 2019
Mortgages
[2019-001] Eli Dadouch - Firm Capital Corporation
Myself and Firm Capital have been licensed since early 1988. The vast majority of these changes are not helpful to the industry and do not address the issue. We need a two tier system, one for Mortgage Bankers and the current system for Mortgage Brokers. The current system does not recognize the Non-Bank Mortgage Banker. These proposed changes will create a lack of capital flowing to the consumer borrower. As seen in the early 1990’s a lack of capital has a long term affect on real estate values. (1) keep the 2 year licensing cycle, no consumer benefit is achieved by changing to a 1 year cycle - only additional administration cost to the Brokerage; (2) The $200 non-qualified syndicated fee is an un-fair “penalty” for complying with the Act. The $200, 5 day payment requirement is a further “red-tape” administration problem. Do not penalize the industry for those that lacked judgement in addressing suitability for investors. A different set of rules need to be applied to a proper non-bank lending entity, such as a publicly listed MIC with an independent board of directors, not a $200 penalty for complying with the Act. Consult with those that actually cover this sector, not the general brokerage industry, who act as brokers to lenders. These changes are harmful to the consumer and educated investors and not protective in any manner.
January 4, 2019
Pensions
[2019-001] Ric Marrero - ACPM

January 4, 2019
Home, Life and Health Insurance
[2019-001] Brendan Wycks - CAFII

January 4, 2019
Home, Life and Health Insurance
[2019-001] Brendan Wycks - CAFII

January 4, 2019
Credit Unions and Caisses Populaires
[2019-001] Rhonda Choja - Libro Credit Union
Please find attached Libro Credit Union's submission for both fee rule 001 and 001B. We thank you for the opportunity to respond and look forward to continued collaboration with regards to the fee rule and ongoing relationship between Libro and the FSRA.

Regards.
Rhonda Choja
VP Corporate and Advisory Services
Libro Credit Union
January 3, 2019
Home, Life and Health Insurance
[2019-001] Erica Kelsey - Aviva Canada

January 3, 2019
Auto Insurance
[2019-001] Not Provided - Intact Insurance

January 3, 2019
Home, Life and Health Insurance
[2019-001] Catherine Allman - Ms.
Please find attached comments from the Canadian Association of Direct Relationship Insurers (CADRI) to FSRA Proposed Rules 19-001 and 19-001B.
January 3, 2019
All Sectors
[2019-001] Peter Shena - Ontario Pension Board
Please see the attached letter.
January 2, 2019
Mortgages
[2019-001] Evan Cooperman - Foremost Financial Corporation
Please see attached for our comments.
January 2, 2019
Health Care Service Sector
[2019-001] Virginia Nsitem
There is so much time and effort into completing forms, and often documents are rejected for simple errors, causing more time and administrative hours to correct. Payments are always delayed. In addition, we have addes administrative costs associated with processing extended health coverage. Any increase in fees does not appear to be justified as there does not seem to be any benefit to the provider.
January 2, 2019
Mortgages
[2019-001] David Mandel - First Source Mortgage Corporation
See attached as it relates to Private Lending and Non-Qualified Syndicated Mortgages. The perpetuation of a big miss by regulators as proposed.
December 31, 2018
Pensions
[2019-001] Williams Jones - Canadian Federation of Pensioners
Please find attached the comments of the Canadian Federation of Pensioners to Consultation 2019-001: Assessments and Fees.

William Jones
Director, Canadian Federation of Pensioners
December 28, 2018
Pensions
[2019-001] Not Provided - Ontario Teachers' Pension Plan
Please find enclosed the Ontario Teachers' Pension Plan's comments on Proposed Financial Services Regulatory Authority of Ontario Rules 2019-001 & 2019-001B.
December 27, 2018
Credit Unions and Caisses Populaires
[2019-001] Not Provided - Your Neighbourhood Credit Union

December 21, 2018
Home, Life and Health Insurance
[2019-001] Not Provided - Independent Financial Brokers of Canada

December 21, 2018
Home, Life and Health Insurance
[2019-001] Not Provided - The Co-operators

December 21, 2018
Home, Life and Health Insurance
[2019-001] Not Provided - Canadian Association of Independent Life Brokerage Agencies

December 20, 2018
Home, Life and Health Insurance
[2019-001] Not Provided - Insurance Bureau of Canada

December 20, 2018
Pensions
[2019-001] Not Provided - CAAT Pension Plan
The CAAT Pension Plan welcomes the opportunity to comment on FSRA's Assessments and Fees consultation. Attached you may find our submission.
December 20, 2018
Home, Life and Health Insurance
[2019-001] Not Provided - Canadian Life and Health Insurance Association
Please find comments from the CLHIA attached. Thank you for the opportunity to provide input.
December 20, 2018
Pensions
[2019-001] Not Provided - OMERS _

December 14, 2018
Health Care Service Sector
[2019-001] Not Provided - Ontario Rehab Alliance
The Ontario Rehab Alliance (ORA) is very encouraged by the level of consultation, openness and transparency that FSRA has demonstrated to date. However, following consultation with our members we believe that most licensed HSPs are unable to absorb and accept the proposed fee increase without an undertaking to bring about a comparable increase to HSP rates, evaluate the demonstrable value and effectiveness (in reducing fraud) of licensing and provide more insight into licensing-related activities and costs.

The ORA strongly supports the philosophy underlying the proposed exemption of HSPs with few claimants annually. Namely, the retention and recruitment of licensed providers serving smaller more remote communities. However, we are surprised by the larger than anticipated size of the proposed group of HSPs with 6 or fewer claimants annually, the impact on the regulator’s fee revenues and the corresponding impact of increased fees for non-exempted HSPs. We would like to know more about the composition of the proposed exempted group to better inform our position on exemption, namely:

• The geographic distribution of exempted HSPs
• The breakdown of treating vs IE providers in this group
December 11, 2018
Health Care Service Sector
[2019-001] Patricia Fleet
Why the increase in fees to practice through HCAI (which is mandatory) when there is no increase in fees to service MVA clients? And there has been no increase in the fees to service clients since 2014?
December 10, 2018
Health Care Service Sector
[2019-001] Anjelika Alechina
The proposed fee increases of the location and claimant annual fees are unreasonable. Health Service providers with twelve (12) or fewer claimants per year should not have to pay an annual fee, averaging one claimant per month.
December 6, 2018
All Sectors
[2019-001] Shannon McGrath - ModernOT
FSCO and FSRA add a considerable cost to our operations, both financially and administratively. As a result of the current processes, we have had to add tens of thousands of dollars in costs for administrative support and electronic software to implement this heavily regulated system. As a result, we see that many specialists, psychologists, physiotherapists in Ottawa and Kingston will no longer see clients who were involved in motor vehicle accidents, and as occupational therapists we are considering the same. The professional fee guidelines have not been increased for many years, and the loss of the ability to recuperate mileage when servicing rural communities has reduced services for Ontarians outside of major city centres. The most qualified, experienced senior health care professionals will be the first to say that they no longer see car accident victims because it is too much extra paperwork, administration and with lower rate of pay.

I am concerned that the fee structures and processes that are added administratively will take the most qualified professionals away from the Ontarians who sustain serious injuries and are in need of complex care that their insurance is supposed to provide. I would like to see less administration, allowing our professional Colleges to regulate our practices as they always have, and a review of the Professional Fees Guidelines.
December 4, 2018
Health Care Service Sector
[2019-001] Samantha Glowinski
As an OT, I am regulated by COTO and FSCO, dual licensing that is not supported. COTO regulates my clinical and business practises. FSCO therefore adds a second and unnecessary level of oversight. Increasing fees for regulated health professionals is not supported and as we have not had a raise since 2014, regulatory fees should be reduced or eliminated.
December 3, 2018
Health Care Service Sector
[2019-001] Lisa McGowan
I find that the fees are already very high and tax my sole practitioner practice greatly. I passed my audit and work hard to ensure I follow all of the regulations. If the cost keeps increasing I won’t be able to continue to provide service and I live outside of a major city and there are few providers in this area.
December 3, 2018
Health Care Service Sector
[2019-001] Marie Hren - Neuro-Rehab Services Inc.
I disagree with the increase of fees to clinics, wherein clinics must bear the financial burden for sole providers. Speaking from experience, I don't believe that clinics have a higher profit margin that do sole providers - because of overhead costs, many clinics likely have far lower profits than do sole providers.
December 3, 2018
Health Care Service Sector
[2019-001] Moira Hunter-Kenyon
I do not feel that it is reasonable to consider ANY increase in fees of any type when health care providers have not had so much as a cost of living increase in 6 years. Occupational Therapists who typically work in clients home have also seen an elimination of a mileage allowance. Working in a rural environment this resulted in a 10% reduction in my revenues overall as I have lots of country driving. My revenues and income have declined over 20% in the last 5 years and I simply cannot accept that FSCO needs more money from me without any consideration of an annual cost of living allowance for health care providers and reinstating the mileage allowance for OTs
November 16, 2018
Health Care Service Sector
[2019-001] JR Nieuwland
We have not had a fee increase for years yet you want to increase the fees charged to us. Our costs are going up. That’s not fair. No providers should be exempt.
November 16, 2018
Health Care Service Sector
[2019-001] Alison Birkett
It is unreasonable to increase regulatory fees when health professionals have not had a fee raise since 2002. Regulated health professionals are doubly regulated since FSCO introduced this. Other issues related to payment should be addressed first, such as hourly rate parity and inclusion of all professionals, as those not listed in the PSG continue to benefit from a free market.
November 15, 2018
Health Care Service Sector
[2019-001] John Brooksbank - Chiropractic Health Care Centre
Recommendations are reasonable and supportive of small private clinics. I highly endorse the proposals provided for review.
November 6, 2018
Mortgages
[2019-001] Dan DeLuca
First off, I completely disagree with the fsra having to regulate what in essence is a bill payment. As a provider I do not provide any insurance or financial advice or service. If the fsra believe that to be the case then every single user of a credit card pos terminal in ever my single business should also be regulated. It's a money grab plain and simple and the fsra know it, but I can't do anything about that.
As to the matter of the fee increases, a bad idea.
Please ask for some clarity, I would be happy to indulge you.
November 6, 2018
Health Care Service Sector
[2019-001] Reena Pathak - Dr. Reena Pathak
I am liking that the fees have not increased much, but I am also liking the fact that if there are 6 or less auto cases, the AIR must be completed, but no annual fee will be charged. I am a small office and this is a good thing, since it will allow me to register and still assess and treat patients accordingly should they come with a necessity for treatment for an auto accident.
November 6, 2018
Health Care Service Sector
[2019-001] Sherri Flegel - Sherri Flegel, RMT
One time registration fee is still cost prohibitive as sole practitioner RMT, who only takes on MVA for existing clients or their referrals. I will not be able to make back the $337 to make it even worth my while to treat MVAs. I am happy to see no annual fee for 6 or less claimants, but I still won't use the FSRA/FSC0 due to registration fees.
November 5, 2018
Health Care Service Sector
[2019-001] MARK BLAU
The Insurance companies requested this additional regulation, they should be the ones who pay for the full costs not the providers. The insurance companies set and raise their own fees each year yet we have little say as to our fee schedule. We have not had a raise in fees in years why should our fees go up?
November 5, 2018
Health Care Service Sector
[2019-001] Kelli Blunt
I can appreciate there are yearly increases to providing hcai. As a service provider in my small community, I believe I am one of the few providers left serving patients in this profile. It is already a costly endeavor to service patients with the paperwork requirements, billing procedure, compliance protocols and staff training and then the delay in collecting accounts receivable due to awaiting EHC and insurer payments. Therefore any further increases continues to question my decision to participate. I have continued as when my own patients suffer impairment as a result of an auto injury I don’t know where they can receive care in my community without significant travel.
November 4, 2018
Health Care Service Sector
[2019-001] Keshena Malik
Unreasonable to increase fees when hourly provider rates are not increasing to reflect this change.
November 3, 2018
Health Care Service Sector
[2019-001] Joanne Hubley - Liva health
I have always found these fees a cash grab and disagree entirely with being responsible for paying AIR. Persons caring for the injured should not be penalized for using a system to help them navigate a confusing insurance model. Rather these fees should be paid by the insurer from collected premiums. The cost of doing business for Healthcare providers shouldn't come at more costs to the providers period!
October 31, 2018
Health Care Service Sector
[2019-001] Sean Batte - Sean Batte Chiropractic Professional Corporation
At present the online portal of HCAI remains complex and time intensive. Given the fees that are assessed to providers to register and maintain their registration with the FSRA, the HCAI portal should be simplified and made considerably more user friendly. Further, courses should be made available for its use.
October 31, 2018
Health Care Service Sector
[2019-001] Dr. Scott Wilson - Physiomed
As a clinic owner and practitioner, how are these fees directly providing value to me and my patients, and what is the reason to raise the rates. In the Extended Health and WSIB sector, we are able to invoice directly to the insurers via TELUS without a fee, not sure why this isn't the case with HCAI especially when the remuneration amounts are dictated by FSCO as well.
October 31, 2018
Health Care Service Sector
[2019-001] Dean Love - Dean Love
I, along with a number of other providers, opted out of treating MVA victims due to the cost and hyper-regulated intrusiveness of this program. One result has been to create challenges for patients in underserviced rural areas who have to travel much farther to get care when injured in an MVA.
October 31, 2018
Health Care Service Sector
[2019-001] Peter Bassit
I am not a fan of the fees to begin with. I don't believe that health providers should have to pay HCAi fees to be registered, as its primary purpose is to prevent insurance fraud and organize the MVA sector. All of which is the insurance companies responsibility. I believe the insurance companies should be paying for this as it primarily benefits them. Any increase in fee's in my opinion is ludicrous. Why do we have to pay per claimant, its ridiculous and clearly a money grab.
October 31, 2018
Health Care Service Sector
[2019-001] Kim Lamont - Kim Lamont & Associates
I am a Registered Occupational Therapist, and therefore am already regulated (both in my interactions with the public and in my business practices) by COTO. I willingly pay a large fee each year for this, because it protects my profession. I do not gain any benefit from the duplication of regulation of practice by FSCO, now FSRA, nor does my profession. I believe that Regulated Health Professionals in good standing should not be required to be licensed under FSRA. Further, I cannot understand the justification for a regulatory fee increase when the rates paid to Health Care Providers has not increased in 5 years.
October 30, 2018
Health Care Service Sector
[2019-001] Alicia McDougall
As regulated health care professionals, we already pay annual regulatory fees to our respective colleges. Additionally, our practices as healthcare providers and from a business perspective are regulated by our respective colleges. Therefore, FSCO adds a second and unnecessary level of oversight. Further to this, increasing fees for regulated health professionals with no associated increase in pay scale is not supported. If any changes should be made, there should be a decrease in fees and an increase in pay scale to accommodate inflation in our economy.
October 30, 2018
Health Care Service Sector
[2019-001] Stephen Konkle
I am a Health Service Provider who currently treats less than six MVC patients (claimaints) per year, as I have for the last 5 years. I would welcome the new fees for service providers, as it would allow me to direct bill for these claimants, whereas I currently do not. However, I do worry about additional fees for having a clinic audited, etc.
October 30, 2018
Health Care Service Sector
[2019-001] Reza Nejad - healthcare management group
Dear reader,
The fees are in excess. The insurance companies spearheaded HCAI and they should be the one to pay the cost of running it not the providers that are forced in using it without an alternative mode of the submission made available to them.
Best regards,
October 30, 2018
Health Care Service Sector
[2019-001] Bob Maitland
The purpose of treating individuals involved in MVAs is to return them to pre-accident status. Not only is this a demanding task, but the additional regulation of healthcare providers by an entity that is neither a regulated health profession governing body, nor an arbiter of evidence-based medicine is neither sound nor warranted and makes for an even more adversarial environment between insurers, claimants and providers. Furthermore, the lack of quinquennial SABS review, which are customary in the past, since September 2010, along with the absence of yearly service provider fee increases in line with inflation, are indicative of the partial nature of the newly formed FRSA. I hope that this decision is reconsidered for the benefit of all invested parties.
October 30, 2018
Health Care Service Sector
[2019-001] Lisa McGowan - Private Practice
As a Registered Occupational Therapist I am already regulated by my college, COTO, whose annual fee is much higher than some other colleges. The purpose of the college is to protect the consumer, which would included the insurance industry. The duplication of fees should be eliminated, and certainly fees for the duplication should not increase. It adds insult to injury that a fee increase is contemplated when RHPs have gone without an increase in hourly fees for 5-6 years along with loss of ability to invoice for incurred mileage. I have contemplated stepping out of this area of practice as a result
October 30, 2018
Health Care Service Sector
[2019-001] Janine Holleran
I don't think it is fair to make us pay a registration fee since we already paid one for FSCO. It should be waived to all providers who have already paid a registration fee.
October 30, 2018
Health Care Service Sector
[2019-001] Pam Kreps - Kreps Chiropractic Centre
I do like the change to no annual fees for providers seeing less than 6 per year. I live in small town and have 2 offices 35 min apart as a sole practioner. I do this for my patients in the area. The annual fee is alot for what I see but do it for patients so they have a prationer in this area that tkes MVA cases. I am apposed to any increase for second office.
Dr Harald Kreps DC
October 30, 2018
Health Care Service Sector
[2019-001] Maathavan Thillai
Im a small practice unable to help MVA patients because of the cost of maintaining a FSCO license. I like the six or fewer claimants per year will pay NO annual fee suggested change.
October 30, 2018
Health Care Service Sector
[2019-001] Sumon Chakrabarti
I do not agree with raising the rates as proposed. Healthcare providers have not had an increase in hourly rates for years, nor has FSCO raised the funds available for MIG ($3500) to reflect inflation. If our costs continue to increase, it does not make sense to raise the costs for renewal.
October 30, 2018
Mortgages
[2019-001] Lance Humphries
Once every two years is quite sufficient. Excessive regulation/oversight hurts freedom and ultimately, the economy.
October 29, 2018
Health Care Service Sector
[2019-001] Kathleen Morris - Kathleen Morris, RMT
I do not agree with the proposed increase in charges. It is difficult for RMT's to have a large fee to pay in order to receive payment when auto insurers do not pay the full rate. We are offered a fraction of what we could make and we have an increased work load. There is extra paperwork with MVA clients; we need to spend more time creating invoices, submitting subsequent treatment plans when clients have not improved enough within the initial blocks. I personally have had to turn away new clients or lengthen treatment plans for non-MVA clients due to the inability to book them because my schedule is full because of the number of MVA treatments booked into each week. Without these MVA clients, I could see the other people and get paid my full rate. With MVA's I am still doing the same amount of laundry, booking, cleaning, and massage therapy. Would you do your job as well if you knew you were being paid $20 less per hour?
October 29, 2018
Health Care Service Sector
[2019-001] Sarah Good - Sarah Good
I think that it is a great idea to have providers with less than 6 claimants not pay an annual fee. I have less than six claimants most years and was considering ending my licence so that I can avoid the fee. However, if I don't have to pay an annual fee, I will remain open to seeing clients trough SABS.
October 29, 2018
Health Care Service Sector
[2019-001] Maria Paulsson
As a Registered Occupational Therapist I am already regulated by my college, COTO. OTs pay significant sums of money to be regulated by COTO, the purpose of which is to protect the consumer, which would included the insurance industry. There is duplication of oversight that is entirely unnecessary. The duplication should be eliminated, and certainly fees for the duplication should not increase. It adds insult to injury that a regulatory fee increase is contemplated when RHPs have gone without an increase in remuneration for 5-6 years along with loss of ability to invoice for incurred mileage.
October 29, 2018
Health Care Service Sector
[2019-001] Nir Tamir
In 2006 fees were established in this sector. Most of us took a significant reduction in fees since 2014 there has been no increase in fee and they remain lower than they were 12 years ago. Insurance rates went up and up. It’s simply unfair to increase cost and for a duplicate license. In fact the insurers requested HCAI so they need to pay for it.
October 29, 2018
Health Care Service Sector
[2019-001] Susan Cook
As a therapist who has been working in this sector for many years I find it interesting that an increase in our auto sector regulatory fees is felt to be needed while at the same time freezing our professional fee guidelines for the last five years. We already pay regulatory fees to our College. Additional regulatory fees should not increase. I also agree with other comments that should a facility pass their site visit, if anything, their fees should decrease.
October 29, 2018
Health Care Service Sector
[2019-001] Wendy Nieuwland - Skill Builders Physiotherapy & Rehab Centre
I feel that it very unnecessary to regulate service providers who are already regulated. Our licensing bodies who we have to pay a fee to for this regulation ensures that we follow all rules and if we didn't, we would lose our license. This extends to finances, our record keeping and how we conduct our business practices. There is no need to waste your resources on this double regulation both of which are government run. I would highly agree with regulating those who wish to bill for claimants through HCAI who are not regulated health practitioners. And I do not agree with a fee increase since we have not had a fee increase in several years for our services yet our costs of doing business are going up just like yours. I respectfully hope you will take this into consideration.
October 29, 2018
Health Care Service Sector
[2019-001] Gina Matesic
I am curious how you can request an increase in fees, when our own fees have not increased in several years? This seems to be quite contradictory. I also am curious WHAT the increased fees are related to? I am grateful for my role as a health care professional, with the ability to work with injured persons to help them be healthier and achieve a greater quality of life. There are times in this industry that the "health care" concept seems to get lost, and that there is not a respect for the true care and compassion that we have for our clients. We are responsible to them, and thus continue our education, ensure we are treating from an evidence-based practice and adding value...that should be worth something, shouldn't it?
October 29, 2018
Health Care Service Sector
[2019-001] Nevena Moylan - Nevena Moylan
Service provider rates have not gone up since 2010, yet fees are increasing. Why?
October 29, 2018
Health Care Service Sector
[2019-001] Katie Wolk
I like that the annual fee will be eliminated for facilities like my own with fewer than 6 claimants per year. I would like to see an increase in support for claimants needing massage therapy, who only receive $58.19 per hour of treatment, while the cost of massage across Ontario is $85 to $100 per hour on average. I hope that my one-time fee I have already paid to FSCO remains a one-time fee and that I do not have to pay another one-time fee to the FSRA. If I need to pay $337 again, the service will be too prohibitive to me and I won't be renewing my facility licence.
October 26, 2018
Health Care Service Sector
[2019-001] Heather McKechnie - Heather McKechnie
I did not renew my license this year because I did not have any MVA clients and did not want to pay for the right to bill online in the event that I had another MVA client. The proposed changes to eliminate fees for a health care provider to drop fees unless they provide service to more than 6 people would have made a difference to me. I have heard so many complaints from other social workers about Insurance companies quibbling over fees is a real deterrent. I hope you do make these changes as proposed asap.
October 26, 2018
Health Care Service Sector
[2019-001] Jacquelyn Bonneville
As a regulated health professional, I already pay College fees that review my business, insurance fees, and FSCO licensing fees. I feel like an increase in these fees is unnecessary and a duplication of fees I already pay.
October 22, 2018
Health Care Service Sector
[2019-001] KAREN RUCAS - Life care planning consultants
Historically, health service providers were not in favour of being regulated TWICE in Ontario. Our respective Colleges not only regulate us from a clinical perspective, but also review our business practices within Ontario Regulation 95/07, Section (1)18 to 26. We pay hefty annual fees to our respective Colleges and, since 2014, large fees for FSCO licensing. Consequently, we do not wish to see licensing fees go up, particularly for those of us who have been deemed compliant during FSCO audits. We would like to see profession specific data related to audit findings and fees must go down. Alternatively, the government might re-consider this duplicative regulation and remove it entirely.
October 21, 2018
Health Care Service Sector
[2019-001] Nicholas Livadas
Most Canadians seem to be enjoying pay hikes, from people earning minimum wage, those earning annual pay hikes, and other professionals increasing their fees as per market forces. My allowable billable rate is fixed and stagnant, life got very expensive, and now fees are going up. Please give me a break is some form.
October 21, 2018
Health Care Service Sector
[2019-001] Leslie Birkett
As an OT, I am regulated by COTO and FSCO, dual licensing that is not supported. COTO regulates my clinical and business practises. FSCO therefore adds a second and unnecessary level of oversight. Increasing fees for regulated health professionals is not supported and as we have not had a raise since 2012, regulatory fees should be reduced or eliminated.
October 21, 2018
Health Care Service Sector
[2019-001] Donna Barrett
Regulated health professionals are already regulated by their professional Colleges. This level of oversight is duplication and is co-occurring with our respective Colleges charging us fees to provide the same types of regulation. These fees are excessive and should be reduced and not increased. Our professional fees have been capped and stymied by FRSA for the past 5 years with no increase, despite the cost of inflation. In addition we have had the ability to charge mileage expenses removed from us. In effect, FRSA regulations have reduced our income (loss of mileage costs, despite the rampant increase in fuel costs that we incur to service the insured in their home environment), frozen our wages for the past 5 years with no respect or acknowledgement of the increase in cost of living, and now you have not only added, but are increasing fees for a regulation that is already provided by our Colleges. We respectfully ask you to reconsider either removing these fees altogether or reducing them to reflect a more reasonable cost given the loss of income we continue to incur in this industry as health care professionals.
October 21, 2018
Mortgages
[2019-001] Stephen Lidsky - PMC Funding
The new proposed fee rules require mortgage brokerages to pay a fee of $200 for non-qualified syndicated mortgage investments within 5 days of a potential investor receiving the disclosure documents. Often deals are delayed or even canceled; fees should instead be due within 5 days of the closing date of the transaction.
October 17, 2018
Mortgages
[2019-001] Stephen Lidsky - PMC Funding
I don't think this is the appropriate forum to voice opinions on the definition of "non-qualified syndicated mortgage investments", however perhaps you can forward to the proper channel. A syndicated mortgage on a commercial or industrial property should not be considered "non-qualified" due to the asset class. A first mortgage for 50% of an industrial property's value almost always contains less risk than a high ratio second mortgage on a residential property, yet the latter is not subject to the same disclosure requirements. "Non"-qualified syndicated mortgage investments should be restricted to development deals, which require a greater degree of sophistication and understanding by an investor. Simple commercial/industrial properties and single family home construction do not warrant being labeled as "non-qualified".
October 17, 2018
Mortgages
[2019-001] Igor Tsemokh - Mortgage Accomplished
Annual Fee must be the same as Mortgage Professionals paid under FSCO. Brokerage fee may vary depends of the numbers of Brokers/Agents. Membership Fee already increased last Year. it is not important : every Year or every 2 years. Please do not increase Membership payment.
October 12, 2018
Mortgages
[2019-001] JERRY ROSE - VERICO ALLENDALE MORTGAGE SERVICES LTD.
Do not change the licensing term from two years to one yearit will only increase administration costs without serving any useful purpose.All mortgage brokerage firms and their employees have E & O E insurance so a one year term is meaningless.Make sure all syndicated mortgages are registered on the secured property in the % of each lender and you solve the problem no need for a $200.00 fee .You should also run these changes by the Ford Admin. before implementing.
October 10, 2018
Mortgages
[2019-001] Amrut Rathod - Reliable Financial Group Inc
1. All brokers registered under mortgage brokers act and also lenders. I have faced some lenders have their own reservation and do not allow to submit the deals. Why difference? They shall entertain all brokers registered with FSCO.
2. Some agents/brokers registered with brokerage they leave in the middle or on renewal and join another brokerage FSCO or registration authority never contact to brokerage for their consent/comment.
3. All restriction to broker and brokerage but lenders and borrowers do not have to comply or their responsibility.
4. There shall be some check before mortgage application initiated by other lender or brokerage, because borrowers are shopping from one to another and earlier or beginner lender/brokerage loose the business. Meaning lender or brokerage working after earlier brokerage shall inquire first brokerage or lender or get consent.
October 10, 2018
All Sectors
[2019-001] Richard Austin - Self-employed

October 9, 2018
Date posted Sector Question and response
Health Care Service Sector

Question: I am very disappointed that the commission has decided to revert back to status quo fees and will not be providing an exemption or at least a graduated fee structure. eg 1 to 6 patients so much , 7 to 15 so much and full fee structure for 16 plus. I would be interested in seeing the comments that opposed this potential change.

FSRA response:

The decision to maintain the status quo fees currently charged by FSCO was in response to comments received on the originally Proposed Fee Rule posted on October 5, 2018. All of the Comments received can be reviewed the FSRA website here and the responses to Questions here. Additionally, the summary of comments received and FSRA responses for all sectors, including HSPs is included in the Notice and Request for Further Comment on Proposed Fee Rule 2019-001, available on FSRA’s website here.

Health Care Service Sector

Question: I may see no more than 2 or 3 auto claims per year. Charging a fee would be onerous on such a small volume....and this is over and above the costs for obtaining a FSCO billing number?

FSRA response:

Beginning in spring 2019, responsibility for the regulation of Health Service Providers (HSPs) who support auto claims will transfer from the Financial Services Commission of Ontario (FSCO) to the newly created Financial Services Regulatory Authority (FSRA). Proposed fees charged by FSRA will replace those charged previously by FSCO.

The fee structure currently proposed by FSRA responds to earlier industry feedback and mirrors the status quo used today by FSCO with no new increases to the fee levels previously charged by FSCO.

  • An annual per location fee of $128 remains unchanged
  • A per claimant fee of $15 remains unchanged.
  • Also unchanged from the status quo is that new applicants will pay a service provider licence application fee of $337.00. New applicants who apply for a service provider licence will also pay a pro-rated per location fee and per claimant fee based on the number of whole and partial calendar months remaining in the fiscal year, as outlined in Section 4.3 Fees (Service Providers)of the Fee Rule.

For additional clarity, existing FSCO licence holders will not have to pay a licence application fee to obtain a new licence from FSRA.

Health Care Service Sector

Question: The ORA strongly supports the philosophy underlying the proposed exemption of HSPs with few claimants annually. Namely, the retention and recruitment of licensed providers serving smaller more remote communities. However, we are surprised by the larger than anticipated size of the proposed group of HSPs with 6 or fewer claimants annually, the impact on the regulator’s fee revenues and the corresponding impact of increased fees for non-exempted HSPs. We would like to know more about the composition of the proposed exempted group to better inform our position on exemption, namely:

• The geographic distribution of exempted HSPs
• The breakdown of treating vs IE providers in this group

FSRA response:

FSRA’s proposed fee rule for HSPs indicated that providers with 6 or fewer Statutory Accident Benefits Schedule (SABS) claimants will be exempt from paying an annual fee. Below we provide some data on the composition of the proposed exempted group in terms of geographic distribution and Treatment versus Insurer Examination (IE) providers.

Figures are provided based on the data used for the 2017 service providers’ Annual Information Return (AIR) results summary report, which includes AIR responses for 4,366 service providers who were licensed at December 31, 2017 and had filed by August 7, 2018. All data is self-reported by licensees.

Of the 4,366 service providers, 1,668 service providers or 38% reported zero to six (0-6) SABS claimants. 1,422 or approximately one-third reported one to six (1-6) SABS claimants.

When considering the geographical composition of exempt HSPS:

  • Among HSPs with 0 – 6 SABS Claimants, the majority of exempt HSPs are geographically located in the City of Toronto (22%), Suburban Toronto (20%), and Central Ontario (24%).
  • Similarly, among HSPs with 1-6 SABS Claimants, the majority of exempt HSPs are geographically located in the City of Toronto (21%), Suburban Toronto (19%), and Central Ontario (25%).

Within each region, the percentage of HSPs that are exempt varies:

  • For those HSPs with 0 – 6 SABS Claimants, percentages of exempt HSPs range from a low of 36% (Suburban Toronto) to a high of 44% (Northern Ontario).
  • For those HSPs with 1-6 SABS Claimants, percentages of exempt HSPs range from 29% (Suburban Toronto) to 37% (Central Ontario).

When considering service type composition within this group of exempt HSPs:

  • Among those HSPs with 0 – 6 SABS Claimants, 71% provide Treatment only, while 22% provide Treatment and IE.
  • Similarly, among those HSPs with 1 – 6 SABS Claimants, 71% provide Treatment only, while 24% provide Treatment and IE.

FSRA Full Response

Home, Life and Health Insurance

Question: Proposed FSRA Rule 2019-001 highlights at p. 3, 5. Future Focus, that FSRA is proposing NOT to do a reconciliation between budgeted and actual expenses (implement a refund/credit mechanism) for the go forward.

Am I to understand FSRA Rule 2019-001B (interim) will continue the practice of reconciliation between budgeted and actual expenses in the short term?

FSRA response:

That is correct. With the proposed FSRA Rule 2019-001, FSRA is NOT planning to do a reconciliation between budgeted and actual expenses.

The interim rule (FSRA Rule 2019-001B) will continue the practice of reconciliation between budgeted and actual expenses in the short term. Per the Interim Fee Rule:

  • “As part of the transition of FSCO’s and DICO’s regulatory mandate to FSRA, FSRA developed an initial fee rule to obtain funding from the financial services sectors it regulates” (2019-001B, p.1). This new fee rule is described in proposed FSRA Rule 2019-001 – Assessments and Fees (the Proposed Fee Rule).
  • “If the Proposed Fee Rule cannot be adopted prior to the spring 2019 launch date, FSRA expects it will adopt an Interim Fee Rule, on a transitional basis, which is substantially similar to FSCO’s existing assessment regulations and fee schedules” (2019-001B, p.1).
  • The Interim Fee Rule is based on “…assessment provisions established by regulation under the FSCO Act (Ontario Regulation 11/01, Assessment of Expenses and Expenditures (Ontario Regulation 11/01)). The assessment provisions under this regulation involve an annual reconciliation of invoiced amounts versus actual costs incurred by FSCO” (2019-001B, p.2).
  • “The Interim Fee Rule takes substantially the same assessment approach as the approach currently used by FSCO, but differs from the approach currently used by DICO. More detail with respect to the Interim Fee Rule, and a comparison of the fee and assessment changes from FSCO’s and DICO’s approach, is set out...” elsewhere in the Interim Fee Rule (2019-001B, p.2).

Mortgages

Question: Pay $200 every time we fill out an investor disclosure form? Do I understand that right?

FSRA response:

The draft fee rule states:

The fee payable pursuant to subsection 6.3(3) shall be paid within 5 days following the date on which any prescribed disclosure documentation was first provided by or on behalf of the brokerage to the first potential or actual lender or investor in a non-qualified syndicated mortgage and shall be accompanied by a copy of the syndicated mortgage disclosure form provided to such first potential or actual lender or investor in respect of that non-qualified syndicated mortgage.

Based on this, the intention is that the fee is not payable in respect of each subsequent potential or actual lender or investor in such non-qualified syndicated mortgage and to whom such same syndicated mortgage disclosure form is also provided.

Mortgages

Question: Can we get more information on the timing? For example , current charges and licenses are good until March 31st, 2020. The timing of the introduced changes will impact accrual principals that will require adjustment and planned for in advance of changes. (i.e. the beginning of a fiscal year would lead us to believe this change would likely take effect January 2020 based on known timing, and if so, would there be a credit taken off the annual fee's for the 3 months (Jan,Feb,Mar 2020) that were paid for as part of existing FSCO process?)

FSRA response:

FSRA is working closely with FSCO and DICO to ensure a smooth transition, including administrative and billing procedures. Once the proposed FSRA fee rule is approved, we will communicate the timing and approach to current and future invoices, licences and adjustments in advance of implementation. Until that time, there are no changes to existing billing and licensing processes with the current regulator.

Mortgages

Question: Can FSRA elaborate on the "systems transition". Will FSRA leverage components of the current FSCO Licensing Link system or will this be an entirely new platform? If it is new, how early will information be provided to a Brokerage to ensure we are well training in advance of implementation? Will Brokerages have an opportunity to provide feedback and/or suggestions prior to systems selection by FSRA? (for example, aspects of the current License Link system provide little data and basic reporting components for a Brokerage).

FSRA response:

This is outside the scope of the Fee Rule. No changes are planned for the License Link system prior to FSRA transition. Longer term, FSRA plans to engage with stakeholders to inform before making any changes.

Health Care Service Sector

Question: The rationale provided for the increased payments is to compensate for decreased revenues from HSPs with 6 or fewer claimants. Can FSRA/FSCO provide data on the number of currently licensed HSPs that fall into this category?

FSRA response:

Based on data from the 2017 Annual Information Returns filed by 4,351 HSPs, 38% of HSPs reported 6 or fewer SABS claimants. 2% of the 203,439 SABS claimants came from HSPs that reported 6 or fewer SABS claimants.

Health Care Service Sector

Question: Please clarify if the following is correct:

1. All new applicants pay a Service Provider License application Fee of $337.00, as is currently in place.

2a). New applicants with HSPs with 7 or greater number of claimants annually pay a pro-rated regulatory fee for work during a partial first year (this consists of facility fee and claimant fee) of $155 x number of locations + $16 per claimant; this is an increase from the current fees of $128/location + $15 per claimant.

2b). New applicant HSPs with 6 or fewer claimants pay no additional location / per claimant fee.

3a). Existing license holders with 7 or great number of claimant annually pay an annual fee of $155 x number of locations + $16 per claimant; this is an increase from the current fees of $128/location + $15 per claimant.

3b). Existing license holder with 6 or fewer claimants pay no additional location / per claimant fee.

FSRA response:

1. All new applicants pay a Service Provider License application Fee of $337.00, as is currently in place.

Response: This is correct. New applicants will pay a service provider licence application fee of $337.00. For additional clarity, this fee does not change based on the number of claimants, nor is there a pro-rated calculation depending on when the application is made.

2a). New applicants with HSPs with 7 or greater number of claimants annually pay a pro-rated regulatory fee for work during a partial first year (this consists of facility fee and claimant fee) of $155 x number of locations + $16 per claimant; this is an increase from the current fees of $128/location + $15 per claimant.

Response: This is correct. The proposed fee rules increase the location fee from $128/location to $155/location and increase the per claimant fee from $15 to $16. See below for an example.

Example A: An applicant who applies for a service provider’s licence on June 1, and has one (1) location and nine (9) claimants would pay an applicant’s regulatory fee using the following formula:

(A + B) x (X/12)

in which,

“A” is $155.00 multiplied by the number of locations of the applicant, “B” is $16.00 multiplied by the number of claimants of the applicant, if any, and “X” is the number of whole and partial calendar months remaining in the fiscal year, calculated from the date application is made until March 31st.

Under the above scenario, this would result in an applicant’s regulatory fee of $249.17.

(($155.00*1) + ($16.00*9)) x (10/12) = $249.17

For clarity, this is in addition to the service provider license application fee of $337.00.

2b). New applicant HSPs with 6 or fewer claimants pay no additional location / per claimant fee. 

Response: This is correct. New applicants with 6 or fewer claimants pay $0 New Applicant’s Regulatory Fee.

For additional clarity it should be noted that the Service Provider Licence Application Fee ($337.00) still applies to all new applicants, regardless or the number of claimants.

3a). Existing license holders with 7 or great number of claimant annually pay an annual fee of $155 x number of locations + $16 per claimant; this is an increase from the current fees of $128/location + $15 per claimant. 

Response: This is correct. The proposed fee rules increase the location fee from $128/location to $155/location and increase the per claimant fee from $15 to $16. See below for an example:

Example B: An existing licence holder with two (2) locations and 100 claimants would pay Licensees’ Annual Regulatory Fee using the following formula:

A + B

in which,

“A” is $155.00 multiplied by the number of locations of the licensee, and “B” is $16.00 multiplied by the number of claimants of the licensee.

 

Under the above scenario, this would result in a Licensees’ Annual Regulatory Fee of $1,910.00.

($155.00*2) + ($16.00*100) = $1,910.00

3b). Existing license holder with 6 or fewer claimants pay no additional location / per claimant fee.

Response: This is correct. 

Mortgages

Question: The current License Link system has a pre-paid component for payment, will a new system also take this into consideration?

FSRA response:

This is outside the scope of the Fee Rule. No changes are planned for the License Link system prior to FSRA transition. Longer term, FSRA plans to engage with stakeholders to inform before making any changes.

Mortgages

Question: Is the continuing education requirements also being considered for change, i.e. follows the current fee structure or every 2 years?

FSRA response:

This is outside the scope of the Fee Rule.