To: Board of the College of Health and Care Professionals of BC (CHCPBC)
Date: March 3rd, 2025

Dear CHCPBC Board Members,

I am writing to formally express concerns regarding the 22% increase in registration fees for physical therapists, which is the largest percentage increase among the regulated professions under CHCPBC. A thorough analysis of the financial data from the audited financial statements of the legacy colleges does not support such a substantial increase for physical therapists. The following points outline why this increase is both unjustified and inequitable:

1. The College of Physical Therapists Had One of the Strongest Financial Positions

The College of Physical Therapists of BC (CPTBC) had a net asset balance of $2.9 million as of June 27, 2024. This was among the highest of all the legacy colleges and indicated a well-managed, financially stable organization. In comparison:

• The College of Psychologists had a deficit of (-$232,701) and a declining financial position.
• The College of Optometrists had net assets of $3.05 million, slightly higher than CPTBC, yet they received no fee increase.
• Other colleges with financial struggles, such as the College of Opticians and College of Dietitians, had significantly smaller net assets.

Despite its financial strength, physical therapists are facing the highest percentage fee increase while optometrists, who also had a strong financial position, are not seeing any increase. This inconsistency suggests that the burden is not being equitably distributed.

2. Physical Therapists Are Being Penalized for Responsible Financial Management

CPTBC demonstrated fiscal responsibility and sustainability before amalgamation. If the argument for fee increases is to “ensure financial sustainability,” then it is unreasonable to disproportionately burden a profession that was already in a stable position.

• The CPTBC had a budget surplus of $268,119, meaning it was generating more revenue than expenses.
• The total assets of $5.89 million far exceeded total liabilities of $2.98 million, meaning the college was not financially strained.
• The fee model used by CHCPBC does not take into account individual colleges' financial health, instead applying an arbitrary increase that disproportionately affects physical therapists. 

3. The “Normalization” Model Unfairly Disadvantages Physical Therapists

CHCPBC states that the fee model applied a general percentage increase, adjusted based on the size of the profession. However, this approach is flawed for the following reasons:

• It assumes that larger professions inherently benefited from economies of scale in legacy colleges. However, CPTBC was already operating efficiently and did not need a fee increase to maintain financial health.
• The College of Psychologists, which had a financial deficit, received only a 15% increase, while physical therapists received a 22% increase despite having a surplus.
• The College of Optometrists, which had comparable financial strength to CPTBC, received no increase at all, further highlighting inconsistencies in fee allocation.

4. Inflation and Increased Costs Do Not Justify the Disparity

While inflation and increasing regulatory costs are cited as reasons for fee increases, these factors apply equally to all professions regulated under CHCPBC. If inflation is the primary justification, it does not explain why physical therapists’ fees are increasing at nearly double the rate of some other professions.

Furthermore, CHCPBC has acknowledged that it does not yet have a clear understanding of the “true costs involved in regulating a multi-disciplinary regulator.” Increasing fees without clear data on actual cost distribution places an undue burden on physical therapists while subsidizing other professions that had weaker financial positions prior to amalgamation.

5. Transparency and Consultation Are Lacking
The FAQ states that fee increases were determined by the Board without consultation with registrants. Given the significant financial impact of these changes, registrants deserve a more transparent and consultative process to ensure that fees are truly equitable.

Conclusion & Requested Actions:

Based on the financial data and fee structure inconsistencies, we urge CHCPBC to:

1. Re-evaluate the fee model to ensure it aligns with the financial positions of the legacy colleges.

2. Provide a clear, data-driven justification for why physical therapists require a 22% increase.

3. Consider a more gradual, phased approach to fee increases that does not disproportionately impact financially stable professions.
Engage in direct consultation with affected registrants to allow for fair input on financial planning.

4. The fee increases should reflect actual regulatory costs and financial need rather than an arbitrary normalization model that disproportionately impacts one profession over others.

I strongly encourage CHCPBC to reconsider this approach to avoid creating unnecessary financial strain on physical therapists, who have historically demonstrated financial responsibility and sustainability.

Sincerely,
Brandon Watson
Registered Physical Therapist, CHCPBC