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No Date Submitted By Summary Read Submission
1501 Jan. 31, 2016 Association or Organization
Ontario Dental Hygienists’ Association (ODHA)
In conclusion, ODHA believes there has been insufficient evidence presented to support the development and implementation of a completely separate and new regulatory scheme that will inevitably and fundamentally increase the cost of health care in Ontario. A cost that by necessity will be passed on to consumers and the healthcare delivery system in general – no doubt resulting in barriers to access particularly for the vulnerable and in the areas of preventive care that will in time, add additional burden to the acute care system. Read Submission
1500 Jan. 29, 2016 Association or Organization
Dietitians of Canada (Ontario)
We strongly recommend that these settings be exempt from the proposed clinic regulation:
– private practice and consulting dietitians in solo or group practice with other regulated health professionals
– settings where only regulated health professionals are providing services
– grocery stores and other retail settings where Registered Dietitians provide consumer advice
– public health units
– recognized healthcare settings such as Family Health Teams, Community Health Centres, and other settings that employ primarily regulated health practitioners
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1499 Jan. 29, 2016 Association or Organization
Registered Massage Therapists’ Association of Ontario (RMTAO)
The RMTAO supports the concept of clinic regulation whether this is realized through the creation of a separate regulatory body under the RHPA or an expansion/evolution of the current RHPA and its College regulatory framework. However, the RMTAO concludes that until there is a completed model, and definitions contained within that model, we cannot support the proposed model as presented by the Working Group at this time for profession stakeholders and Government. We believe that this is an important discussion and thank the Working Group for identifying the issue. We believe it needs a more detailed consultation involving all stakeholders, and we look forward to participating in that discussion. Read Submission
1498 Jan. 29, 2016 Association or Organization
Ontario Society of Occupational Therapists (OSOT)
As a foundation to our following comments, the Society relays the ongoing commitment of occupational therapists to the provision of ethical, quality care across all aspects of our health care system and to the obligation to effectively address public protection. OSOT fully supports the desired outcomes articulated on the consultation website and in Working Group presentations. We wish to see clients have access to high quality health care services, from competent providers, in safe environments. The Society understands the need to consider how these outcomes can be assured, especially in light of the known incidence the Working Group reports.

This notwithstanding, OSOT withholds full support to the proposed clinic regulation model at this time. We believe the following comments will demonstrate that we are left with too many unanswered questions to feel confident in our assessment of whether the proposed model best assures public protection.

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1497 Jan. 28, 2016 Association or Organization
Ontario Opticians Association (OOA)
The OOA commends the College Working Group for putting clinic regulation on the agenda and for making stakeholders think about the topic. Nonetheless, we cannot agree with the proposed solution. There is insufficient evidence provided to make the case that regulation is required or, if regulation is required, that the proposed oversight body is the optimal response. No “business plan” has been provided indicating how the proposed oversight body would operate and how much it would cost. In short, from the information provided and from the information available to the OOA, there is insufficient evidence on which to make a proper risk management or cost-benefit analysis.

We urge the Colleges to objectively and thoughtfully analyze what more they themselves can do, both individually and collectively to address whatever risk of public harm exists through unregulated healthcare clinics. In the case of unregulated optical stores, the OOA recommends the “licensee of record” approach. Alternatively a requirement should be instituted that any entity providing, fitting or adjusting subnormal vision devices, contact lenses or eyewear for the public be required to register with the College of Opticians. The College should then conduct inspections and QA assessments of those premises and investigate complaints relating to them as the College would for opticianry professional corporations and for individual registered opticians.

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1496 Jan. 27, 2016 Association or Organization
Ontario Herbalist Association (OHA)
Having read through the details of this proposed Act, it would appear that the definition of a clinic, would capture unregulated practitioners who have an established practice, including those who work from their own residence. Further, and of more significance, is the stipulation that any & all clinics must be managed and overseen by a regulated healthcare practitioner. Should the Ministry of Health accept this proposal as currently written, this Act will have very disturbing implications for any & all unregulated CAM practitioners.

[…] it should be emphasized that herbalists in Canada do not see themselves as primary care practitioners, but simply as an adjunct to the public’s right to have access to various forms of complementary medicine. In keeping with the final Report of the 1984 HPLR and of current thought in the Ministry of Health, as long as an unregulated CAM practitioner does not perform a controlled act limited to that of a regulated practitioner, we are able to maintain our practice in the marketplace. We ask that your group acknowledge this, and look forward to your final draft to the Ministry & any assurances contained therein that may be offered in this regard.

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1495 Jan. 27, 2016 Association or Organization
Ontario Kinesiology Association (OKA)
[…] the OKA does not support the model as proposed and cannot support any model that adds cost to the system and potentially reduces the number of workplaces where Registered Kinesiologists could provide services. OKA is concerned that the model as defined will increase barriers to clients and patients that can and should benefit from the expertise of a Registered Kinesiologist. Read Submission
1494 Jan. 26, 2016 Association or Organization
Ontario Association of Naturopathic Doctors (OAND)
We agree that patient safety and protection is of the utmost importance. In addition, it is important to focus on the quality of care delivered to the public and patients and to be transparent. We believe that clinic owners who are not health professionals and self-regulated under the Regulated Health Professions Act, 1991 should be subject to regulation. We believe that regulation of clinic owners is extremely important in ensuing patient safety. We do however feel that adding an additional layer of bureaucracy that will envelop regulated health care professions such as Naturopathic Doctors while the focus is regulating clinics owned by non-regulated health professionals may not be what is in the best interest of Ontario healthcare providers or their patients. Read Submission
1493 Jan. 26, 2016 Association or Organization
Association for Advanced Scope for Naturopathic Doctors (ASND)
In conclusion, the ASND is not at all convinced that a brand-new oversight body is required in the public interest to regulate clinics in the naturopathy sector. Nevertheless, the ASND is happy to work with the College of Naturopaths of Ontario and the Working Group in a risk management exercise relating to health care clinics, including the identification of the a ppropriate regu latory response or responses. Read Submission
1492 Jan. 26, 2016 Association or Organization
The Ontario Association of Speech-Language Pathologists and Audiologists (OSLA)
[…] OSLA and its members conclude that there is insufficient evidence to support the implementation of the proposed clinic regulation model, or its recommendation to the Government of Ontario.

OSLA and its members do believe that there is a need to engage in a meaningful discussion about how we, as regulated professions, can address the issues facing health care delivery in the province. We also agree that, in principle, regulation is a good thing.

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1491 Jan. 18, 2016 Association or Organization
Ontario Chiroppractic Association (OCA)
The rationale and information provided by the CRWG does not justify moving forward at this time with the proposed model. The Ontario Chiropractic Association does not support the model’s implementation or its recommendation to government. Read Submission
1490 Dec. 30, 2015 Association or Organization
Pedorthic Association of Canada (PAC)
1. For greater public protection, job one in Ontario is the establishment of legislation and title protection for new and small professions; not creating a second level of regulation for clinics of professions already regulated under RHPA. Public interest will be enhanced when the government of Ontario, through legislation, recognizes and demands professional oversight for all professions. The Pedorthic profession, like other non-RHPA regulated professions, has a very robust, self-regulatory framework. Groups like ours need to be recognized, protected and held up as a model for other non-RHPA regulated professions. This is the best way to promote public interest.

2. Good public policy ensures that Ontarians have access to quality services offered by a full range of practitioners who are best trained to conduct those services. This proposal on clinic registration would bias the public against services provided by competent professions that are not included under RHPA but that have the training and expertise in the services we provide (see below regarding Pedorthic credentials and The College of Pedorthics of Canada). The proposal is predicated on the notion that those regulated under RHPA are somehow safer and better at providing services for which no regulation is actually currently required under the RHPA. We do not agree with this. This proposal further establishes another unjustified boundary between those who are regulated under RHPA and those who are not. This line of thinking promotes vested interests but not the public’s interest.

3. It is in the public interest that clinics are run by and/or made up of quality professionals who are experts in their fields. We strongly disagree that to ensure a mark of quality, a clinic would require ownership by a RHPA-regulated health professional or the presence of a RHPA-regulated health professional. This would unnecessarily create two categories of clinics, one superior and the other inferior for the purpose of referring the public in favour of the registered clinics. Many clinics are owned and operated by non-RHPA professionals such as Canadian Certified Pedorthists. These clinics conduct a range of services within the scope of what Pedorthists were specialized and trained to perform. Such a policy would force these professionals to close perfectly legitimate clinics that serve the public very well, or to hire, or to sell part of their clinics to RHPA designated professionals in order to stay open.

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1489 Dec. 14, 2015 Association or Organization
Ontario Rehab Alliance (ORA)
The ORA urges the Working Group to carefully weigh the costs and benefits of its proposal, keeping the real needs of Ontarian’s and the value provided by RHPs in mind, and not propose the imposition of Clinic Regulation to government. Read Submission
1488 Dec. 24, 2015 Association or Organization
Ontario Podiatric Medical Association (OPMA)
Accordingly, the OPMA’s clear preference at this time is NOT to establish another regulatory entity, but to find a way for the existing Colleges to regulate clinics effectively. As the Working Group itself has acknowledged, other Colleges have apparently managed to regulate “clinics” effectively. Could those regulatory approaches provide a solution to the problem if applied by all Colleges? If changes to the RHPA are required to enable the Colleges to address the problem, those changes should be identified and requested of the Ministry. Read Submission
1487 Dec. 31, 2015 Association or Organization
Ontario Physiotherapy Clinics Association (OPCA)
OPCA believes the utility of the clinic regulation model, or any resultant legislative changes put forth from these discussions, lies in its ability to regulate the actions of non-RHP clinic owners and/or regulate who is authorized to own a private clinic and address this gap in oversight.

Adding another layer of similar regulation for RHP clinic owners has many consequences, including monetary, temporal and administrative burdens, and will stifle the ability of RHPs to respond to changes in the business environment and innovate to further improve patient care.

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1486 Dec. 23, 2015 Association or Organization
Orthotics Prosthetics Canada (OPC)
From our perspective, this initiative has the capability to unfairly bias the public to select regulated health care providers over unregulated health care providers that, in some cases, are more qualified to deal with certain patient conditions than regulated health care professionals. This would not be in the patients’ best interests.

The fact that there are unregulated health professions is not necessarily of a reflection of the skills, qualifications or capabilities of those professions but more an issue of the inadequacies of the process to regulate competent health professions. Governments are reluctant to add more health professions to the regulated health profession acts for a variety of reasons. In some cases, it has absolutely nothing to do with the training, skills and capabilities of the professionals in that discipline but rather due to the small number of professionals that does not make it financially feasible to support the creation of provincial colleges. Certified Orthotists and Prosthetists, who have a long history both in this country and around the globe, are legitimate and qualified health care professionals that are self-regulated (much like the provincial colleges are), provide valuable treatments and services to their patients and clients, are integral team members within the healthcare continuum, yet are arbitrarily locked out of being recognized as regulated health professions simply due to small numbers and the government mandated structure required of a regulated health profession.

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1485 Dec. 18, 2015 Association or Organization
Ontario Physiotherapy Association (OPA)
[…] the OPA concludes at this time that there is insufficient rationale to support the implementation of the proposed model as outlined, or its recommendation to government. We do believe that there is a need for a fulsome, transparent analysis of the issues identified by the Working Group […] Read Submission
1484 Dec. 24, 2015 Association or Organization
Ontario Athletic Therapist Association (OATA)
The OATA unequivocally supports the objective of ensuring that patients receive quality and ethical healthcare, regardless of where and by whom that healthcare is delivered. The OATA also recognizes that we are falling short of achieving that objective in Ontario. For that reason, the Working Group deserves commendation for initiating the dialogue.

Nevertheless, the OATA cannot support the Working Group’s proposal to establish an independent, standalone, oversight body for “clinics”; at least not without substantially more information and justification being provided. Instead, we urge the existing Colleges to use to their absolute fullest all the tools that are currently at their disposal to regulate clinics to address whatever public protection concerns actually exist —– and to enhance their regulatory reach whenever opportunities to do so present themselves.

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1483 Dec. 31, 2015 Association or Organization
Massage Addict
We agree and believe that regulation is positive for health care. We also believe that regulation should not be implemented for regulation sake – it is a cumbersome and arduous process. Based on what we know today, we are not completely convinced that there truly is a gap in public safty. […] Read Submission
1482 Dec. 31, 2015 Association or Organization
Canadian Life and Health Insurance Association (CLHIA)
We support the concept of clinic regulation for protection of the public, which includes mitigation of fraud. We recognize that it is only a small portion of any profession that engages in fraudulent activity, however, the impact is significant on group benefit plans. Group benefit plans are purchased by employers and any fraudulent activity has the potential of impacting the plans overall costs, and ultimately the sustainability of the plan. As a result, to manage these increased costs, an employer may consider implementing plan changes such as reduced benefits, increased coinsurance or deductibles, etc which places more responsibility on the plan member in addition to potentially increased premiums for plan members. Read Submission
1481 Dec. 31, 2015 Association or Organization
Association of Ontario Midwives (AOM)
The AOM does not support the proposed model without a better understanding of the exemptions to clinic regulation. In summary, the AOM recommends the following:
a) an exemption be made for those clinics that are owned solely or in partnership or in a corporation where the owners are all regulated health professionals;
b) any clinic that is already regulated by the Independent Health Facilities Act be excluded;
c) the definition of “clinic” be modified such that the home setting is excluded.
As currently proposed, we have serious concerns about the proposal to increase regulation, without apparent increased benefit, to those clinics that are run by regulated health care providers and those that are already subject to oversight from their regulator or the IHFA legislation.
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