Application Changes and Dues Increase 2020 FAQ

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Preamble

With the enactment of the Professional Governance Act (PGA) forthcoming, the College is facing a shortfall in its capacity to execute its statutory obligations. Implementation of the PGA will require significant effort from the College. Concurrently the College must continue to perform its statutory obligations under the College of Applied Biology Act (CABA), which altogether will require more resources. The Act also potentially enables practice rights for applied biology professionals and the College has been and will continue to work towards that goal.

The PGA allows for governing councils to raise fees without referendum. As this provision has not yet been enabled, the government introduced and passed a miscellaneous bill (Bill 35) in the fall sitting of the legislature. The subsequent Regulation to enable the College Council to approve dues increases was approved by Cabinet on December 2, 2019 and Council subsequently approved the fee increases to Schedule 1 of the College Rules on December 17, 2019.

The newly amended Professional Governance General Regulation specifically allows for the College of Applied Biology to increase annual fees up to 25 per cent by the first year – and seven per cent in a subsequent year – to gain the resources to execute its statutory mandate of protecting the public interest.

In addition to the increase in dues, the College Council has approved a revision in application fees (Schedule 1, Group II of the College Rules) to take effect when the new credentials pathways are activated. Like member dues, application fees had not been addressed in many years: the last update to Registered Professional Biologist (RPBio) and Biologist in Training (BIT) application fees was September 2005.

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FAQ Table of Contents

Section 1 -- College Operations

1.1 Why does the College require more capacity?

The primary reason that the College requires more capacity is to continue its regulatory mandate while also implementing and making contributions to resolutions of the Professional Governance Act. Serving both purposes will result in the College having a budget shortfall. Without more revenue, the College will not be successful in continuing its current statutory mandate under the College of Applied Biology Act (audits, credentialing, discipline, etc.) while fulfilling its responsibilities to the Office of the Superintendent of Professional Governance (OSPG) in implementing the Professional Governance Act.

The second reason is that the College must ensure that it remains on a sound financial footing. Having not raised dues in 10 years, the College has not been able to adequately supplement its operational contingency fund, nor position itself for any unforeseeable expenses such as the Professional Reliance Review. It must also maintain its legal contingency fund.

Finally, the government is acknowledging that applied biology professionals are equal partners to forestry professionals, engineers and geoscientists in resource management and therefore are capable of operating with full practice rights. Now, more than ever, is the opportunity to work towards right to practice, and successfully implementing practice rights will require additional resources.

1.2 When was the last time the College raised fees?

The College hasn’t raised the annual dues for the RPBio title since 2009, the same year that the Registered Biology Technologist (RBTech) professional category was established. The Applied Biology Technician (ABT) designation was introduced in 2016.

Overall, the dues for the RPBio title have only increased twice: 2009 and, previous to that increase, in 2003 with the enactment of the College of Applied Biology Act. Each increase to dues was $100. According to the Bank of Canada’s inflation calculator, goods and services cost nearly 20 per cent more in 2019 than they did in 2009.

1.3 Didn’t you just enact a special levy, what happened with that?

The special levy was enacted under Section 19, subsection 1, part c of the College of Applied Biology Act to ensure that it had the capacity to maintain its statutory obligations. The funds already collected will be used to deliver on the College’s statutory mandate. Now that the government of BC has granted the College Council authority to raise fees it was deemed judicious to implement the option of a permanent increase, which replaces the special levy.

In addition, the special levy did not apply to new registrants of the College who become credentialed in 2020, therefore potentially creating an inequality in how much registrants are paying in dues and ancillary costs (levy) to be registered professionals..

1.4 I thought the College was stable financially?

While the College has been diligent with sound fiscal management, it is also projecting a deficit for 2019 as a result of the Professional Reliance Review process and the subsequent implementation of the Professional Governance Act. For fiscal year 2019 the College has been able to draw down on the operational contingency fund. The use of contingency funds is not a sustainable business.

1.5 Membership is already too expensive, how can you possibly raise the cost further?

Being a member of a regulated profession carries both privilege and responsibility. Applied biology professionals do important work in the province, but the public should be confident that the work is being done competently and accountably. The College exists to ensure that the public interest is protected, and it needs to be appropriately funded to accomplish this mandate. The Professional Governance Act legislates additional protections for the public, such as declarations of competency and regulation of firms, for which the College will be responsible. These programs require added levels of funding, funding that the College does not currently have and cannot generate under the status quo of membership and dues.

The College understands the apprehension about the added cost. However, even with the increase, the College’s dues are less than the dues of the majority of the other regulatory associations under the PGA (see below). As a self-regulated professional, applied biology professionals have a responsibility to the public and payment of dues assures the public that the individual can be held to standards of competency, professionalism and accountability for the work he or she executes.

1.6 How sure are you that you can get practice rights enabled for applied biology professionals?

The College is working with government and our resource regulatory partners to develop the best pathway to move to practice rights for applied biology professionals. While there is no certainty in these types of endeavours, the College is optimistic that it will be successful in its efforts.

1.7 If applied biology professionals are not granted practice rights, will our fees go down?

Notwithstanding practice rights, there are still many more responsibilities that the College has under the PGA, including accommodating requests or orders from the OSPG outside of the written legislation. Any changes to requirements or obligations in the future will be considered by the Council as part of more regular reviews of the fee schedule.

1.8 Isn’t a membership vote required to increase fees?

The legislation passed by government during the fall 2019 session as Bill 35 and enacted under the Professional Governance General Regulation grants the College Council the authority to increase member dues by up to 25 per cent in order to ensure the College has the resources necessary to come into compliance with the Professional Governance Act.

1.9 How will the College use the funds generated by the increased fees?

The revenue from increased fees will primarily be used in the statutory budget under the chart of accounts. This budget funds the College’s statutory committees, such as Council, Audit and Practice Review, Credentials, and Discipline. The budget also includes the Credentials and Practice Review Task Forces, which are executing key tasks in support of the statutory committees.

Figure 1 - College of Applied Biology 2019 budget, from Business Plan 2019; 2020 budget expected to have similar allocations

1.10 I just wanted a professional title for my resumé, why do I now have to pay more for it?

Membership to the College has traceable benefits to a professional career; in fact, many applied biology jobs in the province list membership to the College (or imminent membership) as a requisite for hiring. However, becoming credentialled to the College is not simply an avenue to gainful employment.

The College’s mandate is to protect the public interest by ensuring that the professionals to whom it grants credentials are competent, accountable and held to a code of ethics. Therefore, any title granted to a member by the College comes with responsibilities to the public. In order to ensure the ongoing competency and accountability of its members – through programs like audits, continuing professional development, discipline and practice review – the College must be funded to a level that allows it to act on its mandate without being obstructed by financial or other resource limitations.

This mandate carries with it the effects of making applied biology professionals more valuable to an employer because the professionals are held legally accountable for their professional ethics, competence and responsibility, which instills confidence in the employer.

Furthermore, if practice rights are enabled for applied biology professionals then registration to the College won’t be just a professional title for a job, it will be compulsory for practicing applied biology.

1.11 Can I defer payment for a few months?

Members are obligated to pay their dues by the dues deadline in order to avoid losing their status in good-standing and to avoid risk of removal from the register. The College begins taking dues payment in October and payments made after December 31 are considered late; the College does not have a mechanism to allow for payment plans.

While a member can choose to “defer” payment until later, what they would be doing is choosing to pay their dues late, and they would then be subject to a late fee and to the risks mentioned above.

1.12 What happens if I do not pay?

Failure to pay the annual dues after receiving written notice of impending suspension will result in a member being suspended from the register and losing their right to use their professional title as provided by Rule 10.8 in the College Rules. Reinstatement to the College would be subject to payment of outstanding fees (including a late fee and administration fee) and any other measures set out by Council via the Registrar’s office as per Rule 10.11 in the Rules.

1.13 Why didn’t the College set aside more money in contingency funds?

Part of the communication of the 2015 dues referendum suggested that an increase in dues would allow the College to increase the value of its contingency and operational fund. However, that dues referendum was defeated. Post referendum, the Council also predicted that unforeseen statutory obligations would strain the operational budget: the Professional Reliance Review initiated in 2017 and its consequent legislation enacted in 2018 have put an unsustainable pressure on the College’s current operating balance. The College’s 2020 budget will also be adding $10,000 to each of the legal and operational contingency funds as part of the ongoing organizational commitment to maintenance of contingency funds.

1.14 Did the College consider any other methods to cut expenditures?

The College undergoes a financial audit every year that is presented to the membership at the Annual General Meeting. Based on the result of the 2015 dues referendum, the College Council already made cuts to various budget lines, including events and committees. As explained above, several large expenditures have occurred in the subsequent four years that would have been counterbalanced by a 2015 dues increase. Since that increase didn’t happen, the College has been left with a relatively stagnant budget and increasing expenses. To remain in compliance with our governing statute (currently the College of Applied Biology Act and soon under the Professional Governance Act) the College must never be in a position where expenditure reductions would create an obstacle to fulfilling our mandate including following through on complaints or executing other statutory obligations in the public interest.

1.15 Why were other expenditures approved?

The College, with the approval of Council, has begun positioning itself for the successful implementation of the new Act. The 2019 budget included the upgrades to the College’s IT capabilities; more capacity at staff level; and adequate funding for the Scope of Practice and Credentials Task Forces to consult on and refine the scope of practice for applied biology with the goal of implementing practice rights. These costs were critical for the College to successfully manage the transition to the new Act; delaying on investment in these items would have put the College sorely behind schedule and limited its ability to balance new challenges with current responsibilities.

1.16 Can the government help offset these expenditures?

No, the government has not offered grants to assist organizations in coming into compliance with the PGA. Self-regulation means that the it is the organization’s responsibility to be financially independent.

The government of BC does however offer grants for special projects and the College will apply for applicable grants that can assist the College during the transition between statutes. The College has already received a grant for an online self-assessment tool for prospective members.

1.17 What other options were considered?

While the College reviewed its expenditures and found some efficiencies, there was still a shortfall. An increase in fees was the only way to alleviate a large deficit and allow the College to fulfill its statutory obligations. Roughly 87 per cent of the College’s income is from dues and other registration costs. This is consistent with other regulators.

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Section 2 -- The Dues Increase

2.1 What's your authority to do this?

The government introduced and passed a miscellaneous bill (Bill 35) in the fall 2019 sitting of the legislature. The subsequent Regulation to enable the College Council to approve dues increases was approved on December 2, 2019.

The newly amended Professional Governance General Regulation specifically allows for the College of Applied Biology to increase annual fees up to 25 per cent by the first year – and seven per cent in a subsequent year – to gain the resources to execute its statutory mandate of protecting the public interest.

2.2 Didn’t you just enact a special levy, what happened with that?

The special levy was enacted under Section 19, subsection 1, part c of the College of Applied Biology Act to ensure that it had the capacity to maintain its statutory obligations. The funds already collected will be used to deliver on the College’s statutory mandate. Now that the government of BC has granted the College Council authority to raise fees it was deemed judicious to implement the option of a permanent increase, which replaces the special levy.

In addition, the special levy did not apply to new registrants of the College who become credentialed in 2020, therefore potentially creating an inequality in how much registrants are paying in dues and ancillary costs (levy) to be registered professionals.

2.3 I already paid my dues, including the special levy, do I get a refund on the levy?

The special levy applied to the former dues (e.g. $325 dues and $75 levy for RPBios) equates to the dues increase approved by Council (e.g. 2020 dues for RPBio category are now $400). The purpose of the special levy and now the increase in dues were to allow the College the budget to fulfill its statutory mandates under the College of Applied Biology Act while transitioning to the Professional Governance Act and any refund of the special levy runs counter to that stated purpose by allowing someone to functionally pay less for membership than is required.

2.4 Why couldn't fees increase incrementally over time?

Incremental increases were considered, however as the College has not raised its dues in 10 years it is not a workable option at this juncture. By failing to keep pace with the increasing cost of doing business over the past decade a large singular increase is necessary. Incremental increases over multiple years would not be sufficient to service projected costs for 2020 nor beyond. Furthermore, if membership remains roughly the same over the next two years (as retirements may balance with new professional designations), the College would continue to run deficits over the next two years and exhaust contingency funds. College Council has only authorized one year of operation at a deficit (2019).

2.5 Won't mandatory right to practice result in more members and therefore more revenue?

It’s unclear at this time what the increase in membership will be if right to practice for applied biology professionals comes into effect. While there may be a considerable increase in membership, a transition to right to practice would take several years. The College requires increased revenue beginning with the 2020 fiscal year. An increase in membership will also demand more administrative resources.

Other aspects of implementing the PGA also have increased financial pressures and will require increased resources, such as creation of more guidance documents, administering declarations of competency and the regulation of firms.

2.6 I am retired from the College, are my dues going up?

College Council approved changes to Schedule 1 of the College Rules for the full memberships -- Registered Professional Biologist (RPBio), Registered Biology Technologist (RBTech), and Applied Biology Technician (ABT) categories for 2020 -- only.

2.7 If I am on leave, do I have to pay more?

As stated above, the dues increase only applies to active members. Nevertheless, an on-leave member will have to pay the current dues upon reinstatement – whenever that reinstatement occurs – along with any other fees owing.

2.8 Why do I need to cover for the College's increased expenditures?

Simply put, self-regulation of a profession means that membership always has to fund the statutory activities of a regulatory association: the organization does not have any other means of generating substantial revenue. The College operates in the interest of the public who should be confident that the College has enough resources to fulfill its obligations..

2.9 Why is the dues increase applied at different values for different categories of membership?

The fee was applied as a percentage of the annual dues rather than a flat rate across all membership categories.

2.10 How did you determine the amount of the dues increase?

The dues increase has been approved to match the amounts imposed by the 2019 special levy on dues. This ensures that all registered members of the College pay the same for 2020 as other members in the same category, regardless of whether they paid their dues with a levy at the end of 2019 or if they joined the College in 2020. As well the Regulation restricts increases to 25 per cent for each category.

As for the total increase, a cost analysis was executed to estimate the costs of the College’s statutory obligations over the coming years, inclusive of both its ongoing mandate and the probable implementation of specific elements of the Professional Governance Act via regulation. The goal of the College’s annual budget is to achieve a balance in revenue and expenditure, and the dues increase allows the College to approach that balance. College Council felt that the increase was reasonable given the lack of an increase for 10 years.

2.11 Will the College still use special levies in future?

Special levies exist to ensure that in extraordinary cases an association can draw on added resources to secure its continued execution of statutory obligations. The College has seen two special circumstances in the past two years: a lengthy discipline case and the Professional Reliance/Governance processes.

The College recognizes that using special levies presents a strain to members and endeavours to avoid using them. The College will be proactive in projecting its costs and maintaining its operational and contingency funds. By not raising dues for 10 years the College was facing a shortfall in being able to deliver on its statutory mandate while also acting on its responsibilities during the enactment of the PGA. Thus, the College must sensibly analyze its revenue and either increase or decrease annual dues to maintain balance with its expenditures.

While the College will try to avoid using levies in the future, they remain an important resource for the organization. This is especially the case since large expenditures (such as discipline cases) tend to be unpredictable.

2.12 Will the College be raising dues in the future?

The College Council will always have to review the annual budget and the possibility of increasing dues in the context of fulfilling its mandate.

The PGA grants to the College Council the authority to raise dues without referendum – other organizations like the ABCFP and EGBC already have this authority. Even with the authority to raise dues, the College will continue to demonstrate prudent fiscal management with oversight from the OSPG and independent financial auditors.

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Section 3 -- Professional Regulators

3.1 How much do professionals at other natural resource sector regulators have to pay for membership?

Members of other regulatory bodies categorically pay more in dues than do members of the College. A review of several other professional regulators, including the Association of BC Forestry Professionals (ABCFP), BC Institute of Agrologists (BCIA), Engineers & Geoscientists of BC (EGBC) and the Planning Institute of BC (PIBC) was presented in the 2015 referendum. At that time, the College was already the least expensive regulator for annual dues among those organizations that were compared.


Figure 2 - Professional Dues, 2015/2019 *Includes GST ^2015 dues est. from revenue/membership

Since 2015, each regulator has further increased its dues. On average, each organization has increased their dues by 15%, although BCIA increased the dues for its P.Ag title by 19% in 2019. With the enactment of the Professional Governance Act, the Applied Science Technologists & Technicians of BC (ASTTBC) are included alongside the above organizations -- while PIBC is now excluded -- in the context of the discussion. Dues for the AScT and CTech titles at ASTTBC are $353.60, meaning that the College’s dues are currently the lowest of any regulator that is included in the Act, and even with the proposed fee, the RPBio title would only surpass the AScT and CTech titles in cost.

3.2 How do professional dues in the natural resource sector compare to those in other sectors?

Regulation in the natural resource sector is a more recent development than regulation in the financial and medical sectors for example. Professionals in more mature sectors are responsible for higher annual dues. Nevertheless, the public expectation is that professionals are being well-regulated and the professionals’ payment of dues ensures to the public that proper oversight is maintained.


Table 1 - Annual dues at selected regulators outside of natural resources sector

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Section 4 -- Change to Application Fees

4.1 Why did the College choose to change application fees now?

College Council felt it was prudent to review application fees as part of a holistic review of the application and credentialing process ahead of full implementation of the Professional Governance Act. The College will transition to the new credentialing requirements for the RPBio designation in January 2020 and Council determined the need to introduce changes to application fees concurrently.

4.2 How did the College determine the increase to application fees?

The College did a cost analysis as part of its review of the application standards and found that the former fees were insufficient to cover the administrative costs of processing applications. The changes to credentialing pathways come with increased rigour over assessment of applications, which means that College will spend more resources – both staff and volunteer – on assessment and processing of applications. The increase to application fees was made to account for this increased processing time and to alleviate any administrative burdens faced by the College should registrations increase over the coming years with the new credentialing standards.

4.3 Why are application fees for the RPBio and RBTech categories the same under the new standard?

The administrative and review time required for RPBio and RBTech applications is identical, so the fee associated with applying for each category should also be identical. The College also reviewed the application practices of other regulators and determined that the College’s practice of assessing different fees for each designation was atypical for the sector.

In addition, the College has identified in a variety of contexts a perception that the RBTech designation is an inferior title to the RPBio. In reality, the two designations have important, independent scopes of practice, and are both professional designations that perform different tasks in the natural resource sector.

4.4 What is the reassessment fee and what is it for?

The reassessment fee applies to any past applicant that wishes to be re-assessed under the new credentialing standard that comes into effect January 1, 2020. In some circumstances, an applicant may benefit for the revised streams of entry and academic requirements. The cost of the fee will cover the administrative costs of reviewing the additional documentation required under the new standard.

Going forward, the reassessment fee can be used by a “not-accepted’ applicant that takes longer than one year to complete outstanding requirements. Currently, not-accepted applicants are given on-year to complete outstanding requirements.

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