The Canadian Medical Association (CMA) and its Quebec office are pleased to provide this submission to the Committee on Transportation and the Environment on Bill 44: An Act mainly to ensure effective governance of the fight against climate change and to promote electrification. The CMA maintains that governance of the fight against climate change will not be effective unless it integrates the health impacts on the Quebec population. Physicians in Quebec, across Canada, and around the world have a unique role to play in helping advance government and public understanding of the health consequences of climate change and in supporting the development of effective public health responses. The CMA’s submission provides recommendations to better prepare and mitigate the impacts of a changing climate on people’s health and the health care system in Quebec.
How Climate Change Affects Health
The World Health Organization has identified climate change as the biggest threat to global health.
1 In Canada, the immediate health effects of climate change are a growing concern. In this century, Canada will experience higher rates of warming in comparison to other countries around the world. Northern Canada, including northern Quebec (Nunavik), will continue to warm at more than triple the global rate. These warming conditions will lead to an increase in extreme weather events, longer growing seasons, melting of the permafrost, and rising sea levels.2
Physicians are at the front lines of a health care system that is seeing growing numbers of patients experiencing health problems related to climate change, including heat-related conditions, respiratory illnesses, infectious disease outbreaks and impacts on mental health. For example, the heat wave in southern Quebec in 2018 was linked to over 90 deaths.3
Examples of the extent of this issue include:
The number of extremely hot days is expected to double or triple in some parts of Canada in the next 30 years and will lead to an increase in heat-related impacts (e.g., heat stroke, myocardial infarction, kidney failure, dehydration, stroke).4
Air pollution contributes to approximately 2,000 early deaths each year in Quebec by way of heart disease, stroke, lung cancer, and respiratory disease (such as aggravated asthma).5
An increase in vector-borne diseases such as Lyme disease has increased significantly in Quebec, with the number of cases increasing from 125 in 2014 to 338 in 2018.6
Extreme weather events are increasing in frequency, intensity and duration across Quebec and can negatively impact mental health (e.g., anxiety, depression and post-traumatic stress disorder),7 as well as place additional strain on the health care system.
Increasing temperatures are affecting the ice roads used in winter, and other roads built on permafrost in northern Quebec, threatening food security.8
There are sub-populations that are more susceptible to the health-related impacts of climate change. For example, in northern Quebec, climate change is already increasing health risks from food insecurity due to decreased access to traditional foods, decreased safety of ice-based travel, and damage to critical infrastructure due to melting permafrost. For the rest of Canada, the health impacts vary by geographic region, but include a list of issues such as increased risk of heat stroke and death, increases in allergy and asthma symptoms due to a longer pollen season, mental health implications from severe weather events, and increases in infectious diseases, UV radiation, waterborne diseases and respiratory impacts from air pollution. 9
Seniors, infants and children, socially disadvantaged individuals, and people with existing medical conditions such as cardiovascular disease, are at greater risk of being affected by climate change. The susceptibility of a population to the effects of climate change is dependent on their existing vulnerabilities and their adaptive capacity. 10,11
Figure 1. Examples of Health Impact of Climate Change in Canada5
Climate Change: A Health Emergency
Recent polls have demonstrated that Canadians are very concerned about climate change and its impact on health. A 2017 poll commissioned by Health Canada revealed that 79% of Canadians were convinced that climate change is happening, and of those people 53% accepted that it is a current health risk and 40% believe it will be a health risk in the future.12 As well, a 2019 poll commissioned by Abacus Data reports that Quebecers are the most anxious about climate change and think about the climate more often than people living in the rest of Canada. The same poll reports that 59% of people in Quebec believe that climate change is currently an emergency and 12% reported that it will likely become an emergency in a few years.13 These numbers are not surprising considering the intensity and frequency of extreme weather events in Quebec in recent years. The CMA believes climate change is a public health crisis. Over the past few years in Canada, there have been numerous extreme climate events, such as wildfires in British Columbia,
extreme heat waves in Quebec, and storm surges on the east coast. In southern Quebec, a changing climate has also increased the range of several zoonoses, including blacklegged ticks, which are vectors of Lyme disease.14 Physicians across Quebec are seeing patient outcomes affected by the changing climate and are advocating for change. The health impacts of climate change were raised at last year’s COP25 meeting in Madrid, Spain, among an international group of leading environment and health stakeholders, including the CMA. The group collectively called on governments to broaden the scope of their climate change initiatives and investments to include health care.
A lack of progress in reducing greenhouse gas emissions and building adaptive capacity threatens both human lives and the viability of health systems, with the potential to disrupt core public health infrastructure and overwhelm health services, not to mention the economic and social costs. In Quebec, the research consortium Ouranos estimated in 2015 that extreme heat, Lyme disease, West Nile virus and pollen alone will cost the Quebec state an additional $609 million to $1,075 million,15 and could result in up to 20,000 additional lives lost within the next 50 years.
Canada is currently not on track to meet the international targets set out by the Paris Agreement.16 The 2019 report from Lancet Countdown, the largest international health and climate research consortium, states that continued inaction on meeting the targets set out by the Paris Agreement will result in the health of a child born today being impacted negatively by climate change at every stage of its life.
The CMA recommends that adaptation and mitigation measures be prioritized to limit the effects of climate change on public health.
Hearing Health Care Professionals on Climate Change Last June, the CMA was pleased with the announcement made by the Minister of the Environment and the Fight Against Climate Change, Benoit Charette, to create a task force to ensure effective governance of the fight against climate change, including meeting Quebec’s international climate targets.17 Climate change crosses multiple sectors and requires experts from diverse backgrounds to create solutions to adapt and mitigate the impacts of climate change. Considering the overwhelming evidence of the impacts of climate change on human health, it is paramount that a health representative sits on the committee that will be advising the Minister. Physicians and health professionals have a critical role to play in advancing public understanding of the potential impacts of climate change on health and promoting appropriate actions aimed at protecting the health of Canadians. Physicians believe that what’s good for the environment is also good for human health. Protecting human health must be at the core of all environmental and climate change strategies within Quebec.
Recommendation 2: The CMA recommends that a health representative sit on the committee that will be advising the minister.
Dedicated Funding for a Greener Health Care System
The 2019 Lancet Countdown on Health and Climate Change reports that Canada has the third-highest per capita greenhouse gas emissions coming from its health care sector in the world. Health care related emissions account for approximately 4.5% of the country’s total emissions. Hospitals produce a significant proportion of health sector emissions as they are always on, are resource intensive, and have strict ventilation standards. Hospital services also produce large amounts of waste through the use of single-use items (e.g., hospital gowns and surgical supplies).
To remedy this problem, the CMA recommends that experts from research, education, clinical practice, and policy work together to reduce greenhouse gas emissions and that funding be dedicated to measuring the carbon footprint of different institutions and addressing these issues. Health care providers are uniquely positioned to advocate for innovative solutions that will help reduce greenhouse gas emissions by the health sector and improve public health.18 By reducing greenhouse gas emissions from the health system, the Quebec government will better position itself to be consistent with the timelines and goals of the Paris Agreement for zero-emissions for healthcare by 2050.19
The CMA recommends that a portion of the Green Fund’s budget be dedicated to the greening of health systems.
The CMA’s submission highlights the need to better prepare and mitigate the health impacts of a changing climate, as well as the need for a health representative to advise the minister, and the allocation of funding for the greening of health systems in Quebec. Physicians are in a unique position to help the government develop strategies to mitigate the impacts of climate change and ultimately improve population health.
Summary of recommendations
The CMA recommends that adaptation and mitigation measures be prioritized to limit the effects of climate change on public health.
The CMA recommends that a health representative sit on the committee that will be advising the minister.
The CMA recommends that a portion of the Green Fund’s budget be dedicated to the greening of health systems.
1 Costello A, Abbas M, Allen A, Ball S, et al. The Lancet and University College London Institute for Global Health Commission, The Lancet, 2009;373( 9676):1693-1733. Available: https://www.thelancet.com/journals/lancet/article/PIIS0140-6736(09)60935-1/fulltext (accessed 2020 Jan 25).
2 Government of Canada. Canada’s Changing Climate Report. Ottawa: Government of Canada; 2019. Available: https://www.nrcan.gc.ca/sites/www.nrcan.gc.ca/files/energy/Climate-change/pdf/CCCR_FULLREPORT-EN-FINAL.pdf (accessed 2020 Jan 25).
3 Institut national de santé publique du Québec. Surveillance des impacts des vagues de chaleur extrême sur la santé au Québec à l’été 2018 [French only]. Québec : Institut national de santé publique du Québec; 2018. Available: https://www.inspq.qc.ca/bise/surveillance-des-impacts-des-vagues-de-chaleur-extreme-sur-la-sante-au-quebec-l-ete-2018 (accessed 2020 Jan 25).
4 Guilbault S, Kovacs P, Berry P, Richardson G, et al. Cities adapt to extreme heat: celebrating local leadership. Ottawa: Health Canada Institute for Catastrophic Loss Reduction; 2016. Available: https://www.iclr.org/wp-content/uploads/PDFS/cities-adapt-to-extreme-heat.pdf (accessed 2020 Jan 25).
5 Health Canada. Health Impacts of Air Pollution in Canada--an Estimate of Premature Mortalities. Ottawa: Health Canada; 2017. Available: https://www.canada.ca/en/health-canada/services/air-quality/health-effects-indoor-air-pollution.html (accessed 2020 Jan 25).
6 Santé et services sociaux Québec. Maladie de Lyme. Tableau des cas humains – Archives 2014 à 2018. [French only]. Available: https://www.msss.gouv.qc.ca/professionnels/zoonoses/maladie-lyme/tableau-des-cas-humains-lyme-archives/ (accessed 2020 Jan 25).
7 Cunsolo A, Ellis N. Ecological grief as a mental health response to climate change-related loss. Nature Climate Change 2018;8:275-81.
8 Rosol R, Powell-Hellyer S, Chan HM. Impacts of decline harvest of country food on nutrient intake among Inuit in Arctic Canada: impact of climate change and possible adaptation plan. Int J Circumpolar Health 2016;75(1):31127. Available: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4937722/pdf/IJCH-75-31127.pdf (accessed 2020 Jan 25).
9 Howard C, Buse C, Rose C, MacNeill A, Parkes, M. The Lancet Countdown on Health and Climate Change: Policy Brief for Canada. London: Lancet Countdown, Canadian Medical Association, and Canadian Public Health Association, 2019. Available: https://storage.googleapis.com/lancet-countdown/2019/11/Lancet-Countdown_Policy-brief-for-Canada_FINAL.pdf. (accessed 2020 Jan 25).
10 Canadian Medical Association (CMA). CMA Policy. Climate Change and Human Health. Ottawa: CMA; 2010. Available: https://policybase.cma.ca/en/permalink/policy9809 (accessed 2020 Jan 25).
11 Health Canada. Climate Change and Health. Ottawa: Health Canada; 2020. Available: https://www.canada.ca/en/health-canada/services/climate-change-health.html (accessed 2020 Jan 26).
12 Environics Health Research. Public Perceptions of Climate Change and Health Final Report. Ottawa: Health Canada; 2017.
13 Abacus Data. Is Climate Change “An Emergency” and do Canadians Support a Made-in-Canada Green New Deal? Ottawa: Abacus Data; 2019. Available: https://abacusdata.ca/is-climate-change-an-emergency-and-do-canadians-support-a-made-in-canada-green-new-deal/ (accessed 2020 Jan 26).
14 Howard C, Rose C, Hancock T. Lancet Countdown 2017 Report: Briefing for Canadian Policymakers. Lancet Countdown and Canadian Public Health Association. Available: https://storage.googleapis.com/lancet-countdown/2019/10/2018-lancet-countdown-policy-brief-canada.pdf. (accessed 2020 Jan 25).
15 Ouranos. Vers l’adaptation. Synthèse des connaissances sur les changements climatiques au Québec [French only]. Montreal: Ouranos; 2015. Available: https://www.ouranos.ca/publication-scientifique/SyntheseRapportfinal.pdf (accessed 2020 Jan 25).
16 Government of Canada. Greenhouse Gas Emissions. Ottawa: Government of Canada; 2018. Available: https://www.canada.ca/en/environment-climate-change/services/environmental-indicators/greenhouse-gas-emissions.html (accessed 2020 Jan 26).
17 Gouvernment du Québec. Press Release: Minister Benoit Charette announces an unprecedented process to develop the forthcoming Electrification and Climate Change Plan. Québec: Gouvernment du Québec;
2019. Available: http://www.environnement.gouv.qc.ca/infuseur/communique_en.asp?no=4182 (accessed 2020 Jan 26).
18 Eckelman MJ, Sherman JD, MacNeill AJ. Life cycle environmental emissions and health damages from the Canadian healthcare system: An economic-environmental-epidemiological analysis. PLoS Med 2018;15(7):e1002623. Available: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6067712/pdf/pmed.1002623.pdf (accessed 2020 Jan 25). (accessed 2020 Jan 26).
19 Intergovernmental Panel on Climate Change (IPCC). Global Warming of 1.5C--Summary for Policymakers, France: IPCC; 2018. Available: https://www.ipcc.ch/sr15/ (accessed 2020 Jan 25).
Primary care is the backbone of our health care system in Canada and a national priority for this government.
The echoing words of the Speech from the Throne certify that the Government will strengthen health care and “Work with provinces, territories, health professionals and experts in industry and academia to make sure that all Canadians can access a primary care family doctor.” The Health Minister’s mandate letter further confirms that the Government will work “with the support of the Deputy Prime Minister and Minister of Intergovernmental Affairs, the Minister of Finance and the Minister of Seniors, to strengthen Medicare and renew our health agreements with the provinces and territories” to “ensure that every Canadian has access to a family doctor or primary health care team”.
We recognize that strengthening primary care through a team-based, inter-professional approach is integral to improving the health of all people living in Canada. This belief is consistent across our alliance of four major groups: the Canadian Medical Association, the Canadian Nurses Association, the Canadian Association of Social Workers and the College of Family Physicians of Canada. There is nothing more suiting or fortunate than for a team-based approach to be wholeheartedly supported by an even larger team of teams.
We commend the Government’s commitment
to increasing Canadians’ access to primary care.
We have a model to make it happen.
The Primary Health Care Transition Fund 2, a one-time fund over four years, would provide the necessary funding to help establish models of primary care based on the Patient’s Medical Home, a team-based approach that connects the various care delivery points in the community for each patient. This model is rooted in the networking of family physicians, nurse practitioners, nurses, social workers and other health professionals as a team. This is the only way to provide comprehensive primary care to patients. It will enable a more exhaustive approach to patient care, ultimately leading to increased prevention and better health outcomes for Canadians. Consider it the main artery
in meeting the needs of patients and communities.
A commitment to the Primary Health Care Transition Fund 2 gives substance to the promise of building a network of care that addresses immediate health needs while connecting to ongoing social and community health services. This Fund model bolsters Canadians. It is backed by doctors, nurses, and social workers. A phalanx of Canadian care providers stand behind it. An entire country will benefit from it.
In support of the federal government’s commitment to improve Canadians’ access to primary care,
we recommend a one-time fund in the amount of $1.2 billion over four years to expand the establishment of primary care teams in each province and territory.
It is with a sense of urgency that the Canadian Medical Association (CMA) submits
the recommendations herein for emergency federal measures that, taken together,
will ensure Canadians receive appropriate care and that supportive measures are
implemented for public health protection during the COVID-19 pandemic.
While Canada has made significant strides since SARS to establish and implement
effective public health infrastructure, resources and mechanisms, the significant
resource constraints across our health systems present a major challenge in our
current response. Federal emergency measures must be developed in the context
of the current state of health resources: hospitals across the country are already at
overcapacity, millions of Canadians lack access to a regular family doctor, countless
communities are grappling with health care shortages, virtual care is in its infancy,
and so on.
Another core concern is the chronic underfunding and ongoing budget cuts of
public health resources and programming. Public health capacity and leadership at
all levels is fundamental to preparedness to respond to an infectious disease threat,
particularly one of this magnitude.
It is in this context that the Canadian Medical Association recommends that the
following emergency measures be implemented by the federal government to
support the domestic response to the COVID-19 pandemic:
1410, pl. des tours Blair / Blair Towers Place,
bur. / Suite 500, Ottawa ON K1J 9B9
1) FEDERAL RECOMMENDATION AND SUPPORT FOR SOCIAL DISTANCING
In this time of crisis, Canadians look to the federal government for leadership and guidance.
The single most important measure that can be implemented at this time is a consistent
national policy calling for social distancing. This recommendation by the federal government
must be paired with the resources necessary to ensure that no Canadian will be forced to choose
between financial hardship — whether by losing employment or not being able to pay rent —
and protecting their health.
The CMA strongly recommends that the federal government immediately communicate guidance
to Canadians to implement social distancing measures. The CMA further recommends that the
federal government deliver new financial support measures as well as employment protection
measures to ensure that all Canadians may engage in social distancing.
2) NEW FEDERAL EMERGENCY FUNDING TO BOOST PROVINCIAL/
TERRITORIAL CAPACITY AND ENSURE CONSISTENCY
It is the federal government’s role to ensure a coordinated and consistent national response across
jurisdictions and regions. This is by far the most important role for the federal government in
supporting an effective domestic response, that is, protecting the health and well-being of Canadians.
The CMA strongly recommends that the federal government deliver substantial emergency funding to
the provinces and territories to ensure health systems have the capacity to respond to the pandemic.
Across the OECD, countries are rapidly stepping up investment in measures to respond to COVID-19,
including significant investment targeting boosting health care capacity. In considering the
appropriate level of federal emergency funding to boost capacity in our provincial/territorial
systems, the CMA urges the federal government to recognize that our baseline is a position of deficit.
New emergency federal funding to boost capacity in provincial/territorial health systems should
be targeted to:
rapidly enabling the expansion and equitable delivery of virtual care;
establishing a centralized 24-hour national information hotline for health care workers to obtain
clear, timely and practical information on clinical guidelines, etc.;
expanding the capacity of and resources for emergency departments and intensive care units;
coordinating and disseminating information, monitoring and guidance within and across
rapidly delivering income stabilization for individuals and families under quarantine.
Finally, the inconsistencies in the provision and implementation of guidance and adoption of
public health measures across and within and jurisdictions is highly concerning. The CMA strongly
encourages the federal government enable consistent adoption of pan-Canadian guidance and
measures to ensure the health and safety of all Canadians.
1410, pl. des tours Blair / Blair Towers Place,
bur. / Suite 500, Ottawa ON K1J 9B9
3) ENSURING AN ADEQUATE SUPPLY OF PERSONAL PROTECTIVE
EQUIPMENT FOR CANADIAN HEALTH CARE WORKERS AND
ENSURING APPROPRIATE USAGE
The CMA is hearing significant concerns from front-line health care workers, including physicians,
about the supply and appropriate usage of personal protective equipment. It is the CMA’s
understanding that pan-Canadian efforts are underway to coordinate supply; however, additional
measures by the federal government to ensure adequate supply and appropriate usage are required.
Canada is at the outset of this public health crisis — supply issues at this stage may be exacerbated
as the situation progresses. As such, the CMA strongly recommends that the federal government
take additional measures to support the acquisition and distribution throughout health systems of
personal protective equipment, including taking a leadership role in ensuring our domestic supply via
international supply chains.
4) ESTABLISH EMERGENCY PAN-CANADIAN LICENSURE FOR
HEALTH CARE WORKERS
In this time of public health crisis, the federal government must ensure that regulatory barriers
do not prevent health care providers from delivering care to patients when and where they need
it. Many jurisdictions and regions in Canada are experiencing significant shortages in health
The CMA urges the federal government to support piloting a national licensure program so that
health care providers can opt to practice in regions experiencing higher infection rates or where
there is a shortage of providers. This can be accomplished by amending the Canadian Free Trade
Agreement (CFTA) to facilitate mobility of health care workers.
Specifically, that the following language be added to Article 705(3) of the CFTA:
(j) A regulatory authority of a Party* shall waive for a period of up to 100 days any condition of
certification found in 705(3)(a) - (f) for any regulated health care worker to work directly or
indirectly to address the Covid-19 pandemic or any health care emergency. Any disciplinary matter
emanating from work in any province shall be the responsibility of the regulatory authority of the
jurisdiction where the work is performed. Each Party shall instruct its regulatory authorities to set-up
a rapid check-in/check-out process for the worker.
*Party refers to a signatory of the CFTA
To further enable this measure, the CMA recommends that the federal government deliver targeted
funding to the regulatory colleges to implement this emergency measure as well as targeted funding
to support the provinces/territories in delivering expanded patient care.
1410, pl. des tours Blair / Blair Towers Place,
bur. / Suite 500, Ottawa ON K1J 9B9
5) ESTABLISH AN EMERGENCY NATIONAL MENTAL HEALTH SUPPORT
SERVICE FOR HEALTH PROVIDERS
Health care providers may experience trauma and hardship in meeting the increasing health needs
and concerns of Canadians in this time of crisis. The CMA strongly recommends that the federal
government establish an emergency National Mental Health Support Services hotline for all health
care providers who are at the front lines of patient care during the pandemic. This critical resource
will ensure our health care providers have the help they may need as they care for patients,
including helping them to deal with an increasing patient load.
6) IMPLEMENT A TARGETED TAX CREDIT FOR HEALTH PROVIDERS
EXPERIENCING FINANCIAL LOSS DUE TO QUARANTINE
In addition to supporting income stabilization measures for all Canadians who may benefit from
support, the CMA recommends that the federal government establish a time-limited and targeted
tax credit for health providers who may experience financial loss due to quarantine.
Many health care providers operate independently and may face significant fixed expenses as part of
their care model. As health care providers may have an increased risk of contracting COVID-19, this
may result in significant financial loss. A time-limited tax credit to ease this loss may help ensure
the continued viability of their care model. Further, the CMA supports extending the federal tax
filing timeline in recognition of the fact that health care workers and all Canadians are focused
on emergency matters.
The CMA’s recommendations align with the OECD’s call to action: “Governments need to ensure
effective and well-resourced public health measures to prevent infection and contagion, and implement
well-targeted policies to support health care systems and workers, and protect the incomes of vulnerable
social groups and businesses during the virus outbreak.”
Now is the time to ensure that appropriate leadership continues and that targeted investments are
made to protect the health of Canadians.
During these unprecedented times, Canada’s physicians, along with all front-line health care workers (FLHCWs), have not only put themselves at risk but have made enormous personal sacrifices while fulfilling a critical role in life-threatening circumstances.
The CMA recognizes and strongly supports the measures the federal government has taken to date to mitigate the health and economic impacts of COVID-19 on Canadians. However, given the unique circumstances that Canada’s FLHCWs face, additional measures are required to acknowledge their role, the risks to themselves and their families, and the financial burden they have taken on through it all.
To gain a better understanding of this issue, the CMA commissioned MNP LLP (MNP) to conduct a thorough economic impact study. They assessed the effects of the COVID-19 pandemic on physician practices in Canada and identified policy options to mitigate these effects.
This brief summarizes the findings, provides an overview of the impact of the COVID-19 pandemic on physician practices across the country and highlights targeted federal measures that can significantly mitigate the evident challenges physicians are experiencing. It is important to note that the recommended measured were developed through the lens of recognizing the important contribution of Canada’s FLHCWs.
UNDERSTANDING HOW THE PANDEMIC
IS IMPACTING PHYSICIAN PRACTICES
Canada’s physicians are highly skilled professionals, providing an important public service and making a significant contribution to the health of Canadians, our nation’s health infrastructure and our knowledge economy. In light of the design of Canada’s health care system, the vast majority of physicians are self-employed professionals operating medical practices as small business owners. Like most small businesses in Canada, physician practices have been negatively impacted by the necessary measures governments have established to contain this pandemic.
Under the circumstances of the pandemic, the provinces postponed non-emergent procedures and surgeries, indefinitely. According to data from the 2019 Physician Workforce Survey conducted by the CMA, approximately 75% of physicians reported practising in settings that would be expected to experience a reduction in patient volumes as a result of COVID-19 measures. This suggests “the vast majority of physicians in Canada anticipate declines in earnings as a result of COVID-19 restrictions.”
Physician practices include a variety of structures, which relate to the practice setting or type. In their economic impact study, MNP estimates that across the range of practice settings, the after-tax monthly earnings of physician practices are estimated to decline between 15% and 100% in the low-impact scenario, and between 25% and 267% in the high-impact scenario. These two scenarios are in comparison to a baseline scenario, prior to the pandemic. The low-impact scenario is based on the reduction of physician services reported during the 2003 experience with the Severe Acute Respiratory Syndrome (SARS) while the high-impact scenario estimates more significant impacts, being approximately double those observed during SARS.
Unlike salaried public sector professionals, such as teachers, nurses or public servants, most physicians operate as small business owners who are solely responsible for the management of their practices. They employ staff, rent office space and have numerous other overhead costs related to running a small business, which they are still responsible for regardless of decreased earnings. According to data published by Statistics Canada in 2019 there were 120,241 people employed in physician offices in Canada and an additional 28,054 employed in medical laboratories. Additionally, physicians manage significant overhead expenses that are unique to medical practice such as practice insurance, licence fees and continuing medical education. It’s important to understand that even hospital-based physicians may be responsible for significant overhead expenses, unlike other hospital staff. Like any small business owner grappling with drastic declines in revenue, physicians may be forced to reduce their staffing levels or even close their practices entirely in response to the COVID-19 pandemic.
ADDRESSING THE GAPS: ENSURING THAT FEDERAL ECONOMIC PROGRAMS CAPTURE PHYSICIAN PRACTICES
To reiterate, the CMA supports the federal government’s decisive and meaningful response to the pandemic, including delivering critical economic relief programs. However, more detailed analysis is revealing that segments of physician practices are not eligible for these critical economic programs, because of technicalities.
At this time, the CMA has identified three key segments of physician practice models who may
not currently be eligible for the economic relief programs because of technicalities. These are:
1. hospital-based specialists
2. physician practices that operate as a small business but may not meet technical criteria
3. physicians delivering locum medical care
These technical factors reflect the complexity of the health system infrastructure in Canada. Although hospital-based specialists may receive some form of salary, they may still be structured as a small business and be responsible for paying overhead fees to the hospital. Many physicians may operate as a small business and remit a statement of self-employment, and they may not have a business number or a business bank account. As is common amongst other self-employed professionals, many physicians operate practices within cost-sharing structures. The CMA is deeply concerned that these structures are presently being excluded for the federal government’s critical economic relief programs. As a result, this exclusion is affecting the many employees of practices structured as cost-sharing arrangements. Finally, physicians providing care in other communities, known as locum practice, would also be responsible for overhead expenses.
It is the CMA’s understanding that the federal government is seeking to be inclusive in delivering economic relief programs to mitigate the impacts of the pandemic, such as closures or unemployment. For physician practices, eligibility for federal economic relief programs would extend the reach of these mitigation measures to maintaining Canada’s critical health resources and services, as physician practices are responsible for a
significant portion of health system infrastructure.
As such, the CMA respectfully recommends that the federal government ensure that these critical economic programs be made available to all segments of physician practices.
To this end, the CMA recommends that
the federal government expand eligibility
for the federal economic relief program to:
1. Include hospital-based specialists paying fees for overhead expenses to the hospitals
(e.g., staff, equipment, space);
2. capture physician-owned medical practices using a “personal” banking account as well
as those in cost-sharing structures to access programs; and,
3. include physicians who provide locum medical care.
NEW FEDERAL TAX MEASURES TO SUPPORT AND RECOGNIZE FRONT-LINE HEALTH CARE WORKERS
It is also important to note that the impact of COVID-19 on FLHCWs goes well beyond the financial impacts.
All FLHCWs face numerous challenges trying to carry out their work during these difficult times. They put their health and the health of their families at risk. They make enormous sacrifices, sometimes separating themselves from their families to protect them. These risks and sacrifices can strain an individual’s mental health, especially when coupled with anxiety over the lack of proper personal protective equipment (PPE). A survey conducted by the CMA at the end of April showed that almost 75% of physicians who responded to the survey indicated feeling very or somewhat anxious about the lack of PPE. FLHCWs deserve to be recognized for their unique role during
Given the enormous sacrifices and risks that FLHCWs are making every day, the federal government should enact measures to recognize their significant contributions during these unprecedented times.
The CMA recommends that the federal government implement the following
new measures for all FLHCWs:
1. An income tax deduction for FLHCWs put at risk during the COVID-19 pandemic,
in recognition of their heroic efforts. All FLHCWs providing in-person patient care during the pandemic would be eligible to deduct a designated amount against their income earned. This would be modelled on the deduction provided to members
of the Canadian Armed Forces serving in moderate- and high-risk missions.
2. A non-taxable grant to support the families of FLHCWs who die in the course of responding to the COVID-19 pandemic or who die as a result of an occupational illness or psychological impairment related to this work. The grant would also apply to cases in which the death of an FLHCW’s family member is attributable to the FLHCW’s work in responding to the pandemic. The CMA is recommending that access to the Memorial Grant program, or a similar measure, be granted to FLHCWs and
their family member(s).
3. A temporary emergency accommodation tax deduction for FLHCWs who incur additional accommodation costs as well as a home renovation credit in recognition of the need for FLHCWs to adhere to social distancing to prevent the spread of COVID-19 to their family members. The CMA recommends all FLHCWs earning income while working at a health care facility or in a capacity related thereto
(e.g., paramedics or janitorial staff) be eligible for the deduction and credit.
4. Provide additional child-care relief to FLHCWs by doubling the child-care deduction.
The CMA recommends the individuals listed above be eligible for the enhanced deduction.
It is important that any measures enacted be simple for the government to implement and administer as well as simple for FLHCWs to understand and access. The recommendations above will ensure that relief applies to a wide range of Canada’s FLHCWs who are battling COVID-19.
More details on these recommendations are provided in Appendix A to this brief.
INCREASING FEDERAL HEALTH FUNDING
TO SUPPORT SYSTEM CAPACITY
It is due to the action of the federal and provincial/territorial governments, together with Canadians, in adhering to public health guidance that our health systems have been able to manage the health needs of Canadians during the pandemic. However, as governments and public health experts consider how we may proceed in lifting certain restrictions, we are beginning to comprehend the enormity of the effort and investment required to resume health care services. During the pandemic, a significant proportion of health care services, such as surgeries, procedures and consults considered “non-essential” have been delayed. As health services begin to resume, health systems will be left to grapple with a significant spike in already lengthy waiting times. Further, all health care facilities will need to adopt new guidance to adhere to physical distancing, which may necessitate longer operating hours, increasing staff levels and/or physical renovations. Given these issues, the CMA is gravely concerned that Canada’s already financially struggling health systems will face significant funding challenges at a time when provincial/
territorial governments are grappling with recession economies. The CMA is strongly supportive of new
federal funding to ensure Canada’s health systems are resourced to meet the care needs of Canadians
as the pandemic continues.
As outlined in this brief, the overwhelming majority of Canada’s physician practices will be
negatively impacted financially by COVID-19. The indefinite postponement of numerous medical procedures, coupled with restrictions related to physical distancing resulting in reduced patient
visits, will have a material effect on physician practices, risking their future viability. As well,
all FLHCWs will be severely impacted by COVID-19 personally, through risks to themselves and their families. Many families of FLHCWs will also be impacted financially, from increased child-care costs
to, tragically, costs associated with the death of a loved one because of COVID-19.
In light of these substantial risks and sacrifices, the CMA urges the adoption of the above-mentioned recommendations designed to recognize the special contribution of Canada’s FLHCWs during these
The CMA has always taken an interest in and a stand on various health issues affecting the medical profession and patients. Access to health care is one such issue.
The CMA recently commissioned Ipsos to conduct an extensive survey on the population’s concerns regarding access to health care. The data indicates that Quebecers are the most pessimistic in the country—and this sentiment is even more pronounced when respondents think about the future. Forty percent of survey respondents are concerned about access to health care, and more than half (55%) have a negative perception of the future of the health care system, compared with 26% and 47%, respectively, for the rest of Canada.1 It also appears that Quebecers are significantly affected by the shortage of health professionals and the increase in system costs due to the aging population and the growing number of seniors with health care needs.
The public’s worries are also shared by our members and physicians in Quebec, who are concerned by the fact that their patients are not receiving the care and services they need in a timely manner.
The government of Quebec is making a significant investment in the health care network, a budget item that accounts for almost 50% of total program expenditures.2 The CMA applauds this effort.
The CMA submission proposes certain measures that have a two-fold objective: improving the health of Quebecers and ensuring the sustainability of the health care system for future generations.
The CMA submission is divided into three parts: improving support to elderly patients and caregivers; tobacco and vaping control; and reducing unnecessary examinations and treatments to optimize use of the health care system’s financial and human resources.
Seniors and caregivers
It is no secret that Quebec’s population is aging rapidly. According to data from the Institut de la statistique du Québec cited in the Plan stratégique du ministère de la Santé et des Services sociaux, seniors are expected to make up 25% of the population in 2031 and 28% in 2066, compared with 18% in 2016.3
Although aging is not necessarily synonymous with poor health or disability, the likelihood of both of these conditions increases with age. Close to seven out of ten Quebecers aged 65 and over report two or more long-term health conditions, and 93% of these individuals take medication.4 The most common health issues among people aged 65 and over are arthritis and hypertension.5 Moreover, the incidence of cancer rises significantly with age.6
The aging population thus exerts additional pressure on a health care system that is already stretched thin. The CMA has long been lobbying the federal government to increase the Canada Health Transfer to take into account the needs of the aging population when calculating the Transfer. Consequently, the CMA supports the Quebec government’s negotiations with the federal government to secure an increase in federal health transfer payments.
To ensure a sustainable health care system, it is important to invest in measures that will allow the public to maintain their health as they age, and that foster seniors’ independence—such as a healthy lifestyle, adequate nutrition and treatment adherence, where applicable. The Quebec government has already taken steps to foster the well-being of elderly persons, such as implementing the senior assistance tax credit and increasing support for home support services. The Minister Responsible for Seniors and Informal Caregivers has announced the development of a provincial policy for caregivers in 2020–2021, as indicated in the recently submitted strategic plan.3
These initiatives aimed at improving the lives of seniors and caregivers are to be commended. The CMA believes that the scope of these initiatives should be widened.
Support for seniors
In its economic update presented on December 3, 2018, the Quebec government announced a new tax credit for seniors over age 70. More specifically, this tax credit provides annual assistance of up to $200 per senior and $400 per couple.
The CMA welcomes this initiative, but it should be noted that seniors aged 65 and overspend more than $2,200 on health care fees each year7 (health care items, medication, dental care, insurance premiums, etc.). Given that this level of spending is significant and that 60% of seniors have an annual income under $30,000,8 this tax credit appears to be insufficient for those who have to bear these additional daily health expenses. We must collectively
ensure that certain seniors will not have to forego treatment because they cannot afford it.
Quebecers’ health care expenses have been increasing in recent years,9 and the CMA believes it is essential that this growing problem be dealt with right now. The CMA recommends that the Quebec government create an allowance for seniors aged 65 and over. This new allowance, which would be modelled after the family allowance, would provide financial assistance to low- and medium-income seniors to help them manage additional health-related expenses.
The CMA also believes that the senior assistance tax credit should be extended to people ages 65 to 69.
Like seniors’ advocacy groups, the CMA recommends greater recognition of family caregivers’ contribution to the Quebec health care system. This could take the form of a greater tax credit for caregivers offered in Quebec.
Family caregivers are an integral part of the health care system, as they play an active role in enabling seniors to stay at home—which is what most seniors prefer.10
The Ministère de la Santé et des Services sociaux plans to increase home support services as part of its 2019–2023 strategic plan.10 The CMA believes that this initiative should be combined with increased assistance for family caregivers.
In 2016, the demographic portrait of caregivers in Quebec indicated that 35% of Quebecers, or 2.2 million people, provided care to a senior. Of these, around 15% acted as caregivers for more than 10 hours a week. With the aging of the population set to accelerate in the coming years and decades, caregivers’ unpaid working hours will increase significantly. In Canada, according to a 2011 study, close to 80% of all assistance to recipients of long-term care was provided by family caregivers. This represents a contribution of over five billion dollars’ worth of unpaid services for the public health network.11
According to the CMA, the tax credit for caregivers is an indispensable and necessary financial contribution for these people and the seniors receiving care, but this measure in no way reflects the costs assumed by caregivers. More support should be provided to people who give their time every day, sustain financial losses and compensate for the lack of resources in the health care system.
Given the indispensable role family caregivers play, the CMA recommends that the government increase the tax credit for caregivers so that it better reflects their contribution to society—and this should apply to all four types of family caregivers defined by Revenu Québec:12
Caregivers who take care of a senior spouse who is unable to live alone
Caregivers who house an eligible relative
Caregivers who cohabit with an eligible relative who is unable to live alone
Caregivers who support an eligible relative whom they regularly and continuously assist in carrying out basic activities of daily living
The CMA recommends:
1. Expanding the senior assistance tax credit to support people who are between the ages of 65 and 69
2. Creating a seniors’ allowance to provide financial assistance to low- and medium-income seniors to help them manage additional health-related expenses
3. Increasing the tax credit for caregivers, for all types of family caregivers recognized by Revenu Québec
Smoking and vaping prevention
Although the government of Quebec must pay specific attention to seniors’ care to lighten the burden on the health care system, prevention is still just as important. Prevention has proven to be useful in reducing health care costs by eliminating the need for certain treatments and hospitalizations.13 Measures to control smoking and vaping fall under this category.
For decades, the CMA has been promoting the benefits of a smoke-free society with the support of our physician members, who are witnesses to tobacco’s harmful effects on health. The CMA issued its first public health warning on the risks associated with tobacco use in 1954, and since then has made a significant contribution to the development of public policies related to the industry. One needs only to think of the role that the CMA played in the federal government’s decision to require that tobacco products be sold in plain packaging and standard sizes.
Every government in the country has been actively committed to the fight against tobacco for years, and there has been a significant drop in tobacco use over time. However, regular tobacco use in Quebec has settled at around 15% of the population aged 12 or older.14 Unfortunately, this proportion is still too high.
There is another growing phenomenon among young people that we believe merits the attention of the Minister of Finance: e-cigarettes, also referred to as vaping devices. According to the Enquête québécoise sur la santé des jeunes du secondaire 2016-2017 [Quebec health survey of high school students 2016-2017], one third of youths have used e-cigarettes.15 Although these types of products do not contain tobacco, they do contain nicotine and aromatic substances that could be harmful to people’s health. The CMA recommends increasing research on the potential health consequences these devices can have on people, and the validity of claims that they are an effective means to quit smoking. We also support prohibiting e-cigarette sales to minors, enforcing strict regulation of the sale of these products and prohibiting vaping in locations where smoking is currently forbidden. We also recommend that the marketing restrictions on tobacco products be applied to vaping products and devices as well.
The CMA also believes that governments would be well advised to draw inspiration from strategies that have been successful in curbing tobacco use and reducing the appeal of e-cigarettes, particularly among young people. According to the World Health Organization (WHO), a 10% increase in the price of tobacco results in a 4% to 8% drop in consumption. Taxes on vaping products could therefore have the same deterrent effect, especially among young people, who are more sensitive to price variations.16 This is why it is imperative that we do not wait for the outcome of the work carried out by the special vaping intervention group led by the Ministère de la Santé et des Services sociaux (MSSS) before taking action.
Effective January 1, 2020, the government of British Columbia raised the sales tax on vaping products from 7% to 20%17 to prevent and reduce the use of these products by young people. The CMA recommends that the government of Quebec emulate this policy by increasing taxes on vaping and tobacco products.
The right care at the right time
According to data from the Canadian Institute for Health Information (CIHI), up to 30% of tests, treatments and procedures in Canada are potentially unnecessary. Unnecessary tests, treatments, and procedures not only add zero value to care, but they may also expose patients to additional risks and waste health resources.18
In 2012, as certain treatments were being overused or not adding value for patients, the CMA was a leading partner in the Choosing Wisely Canada campaign, which was launched in Quebec in 2014. This program helps health care professionals and patients engage in a dialogue about unnecessary tests and treatments and helps them make smart and effective choices to ensure quality health care. Guides and recommendations for patients and health
care professionals have been developed through this campaign to make them aware of overuse and overdiagnosis.
The ultimate goal of Choosing Wisely is to improve the performance of the health care system.
A survey indicates that almost half of physicians (48%) agree that they need more support and tools to help them determine which services are not suitable for their patients.19 The tools provided by the Choosing Wisely campaign have proven effective. The CMA believes that their use by Quebec physicians and patients is beneficial.
Publicizing campaigns and developing and updating tools and recommendations require significant financial resources. Elsewhere in the country, several provinces are providing financial support to Choosing Wisely. However, Quebec ended its financial commitment in the past year.
Given the Quebec government’s commitment regarding the appropriateness of care, the CMA recommends supporting the Choosing Wisely Quebec campaign with a long-term financial commitment.
Summary of CMA recommendations
Senior and caregiver support
The CMA is proposing three main recommendations to support seniors and their caregivers. The recommended measures are aimed at ensuring healthy aging and recognizing family caregivers’ economic and social contribution in Quebec.
1. Expand the senior assistance tax credit to support people who are between the ages of 65 and 69.
2. Create an allowance for seniors to help them manage private health care costs.
3. Increase the tax credit for caregivers, for all types of caregivers recognized by Revenu Québec.
Implementation of a tax on tobacco and vaping products
The government of British Columbia announced its intent to increase the sales tax on vaping products from 7% to 20%, effective January 1, 2020,20 to prevent and reduce the use of these products by young people. The CMA recommends that the government of Quebec emulate this policy by heavily taxing vaping and tobacco products.
Contribution to the Choosing Wisely Canada program
Given the Quebec government’s commitment regarding the appropriateness of care, the CMA recommends supporting the Choosing Wisely Quebec campaign with a long-term financial commitment.
1 Ipsos, Canadian Medical Association (CMA). Canadians are Nervous About the Future of the Health System. Ottawa: CMA; 2019. Available: https://www.cma.ca/sites/default/files/pdf/news-media/Canadians-are-Nervous-About-the-Future-of-the-Health-System-E.pdf (accessed 2020 Jan 13).
2 Gouvernement du Québec. Update on Québec’s Economic and Financial Situation. Quebec: Gouvernement du Québec; Fall 2019. Available : http://www.finances.gouv.qc.ca/documents/Autres/en/AUTEN_updateNov2019.pdf (accessed 2020 Jan 13).
3 Ministère de la Santé et des Services sociaux. Plan stratégique 2019-2023(French only). Quebec : Ministère de la Santé et des Services sociaux; December 2019. Available : https://cdn-contenu.quebec.ca/cdn-contenu/adm/min/sante-services-sociaux/publications-adm/plan-strategique/PL_19-717-02W_MSSS.pdf (accessed 2020 Jan 13).
4 Institut de la statistique du Québec. Enquête québécoise sur les limitations d’activités, les maladies chroniques et le vieillissement 2010-2011(French only). Quebec : Institut de la statistique du Québec; October 2013. Available: http://www.stat.gouv.qc.ca/statistiques/sante/services/incapacites/limitation-maladies-chroniques-utilisation.pdf (accessed 2020 Jan 13). 5 Statistics Canada. Table 13-10-0096-01 Health characteristics, annual estimates. Ottawa: Statistics Canada; 2019. Available: https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1310009601&%3BpickMembers%5B0%5D=1.6&%3BpickMembers%5B1%5D=2.6&%3BpickMembers%5B2%5D=3.1&request_locale=en. (accessed 2020 Jan 13).
6 Canadian Cancer Statistics Advisory Committee. Canadian Cancer Statistics, September 2019. Toronto: Canadian Cancer Society; September 2019. Available: https://www.cancer.ca/~/media/cancer.ca/CW/cancer%20information/cancer%20101/Canadian%20cancer%20statistics/Canadian-Cancer-Statistics-2019-EN.pdf?la=en-CA (accessed 2020 Jan 13). 7 Institut de la statistique du Québec. Dépenses moyennes des ménages déclarants, selon le groupe d'âge de la personne de référence, Québec, 2006 (French only). Quebec: Institut de la statistique du Québec; 2006. Available: http://www.stat.gouv.qc.ca/statistiques/conditions-vie-societe/depenses-avoirs-dettes/depenses/depdeclar_age.htm (accessed 2020 Jan 13). 8 Santé et des Services sociaux. Les aînés du Québec - Quelques données récentes (2e édition)(French only). Quebec: Santé et des Services sociaux; June 2018. Available: https://publications.msss.gouv.qc.ca/msss/fichiers/ainee/aines-quebec-chiffres.pdf (accessed 2020 Jan 13).
9 Santé et des Services sociaux. Dépenses moyennes des ménages en dollars courants, selon le poste de dépenses, ensemble des ménages, Québec, 2010-2017(French only): http://www.stat.gouv.qc.ca/statistiques/conditions-vie-societe/depenses-avoirs-dettes/depenses/tab1_dep_moy_menage.htm (accessed 2020 Jan 13).
10 Ministère de la Santé et des Services sociaux, Plan stratégique 2019-2023 [2019–2023 Strategic plan] (French only). Quebec: Santé et des Services sociaux; December 2019. Avalable: https://cdn-contenu.quebec.ca/cdn-contenu/adm/min/sante-services-sociaux/publications-adm/plan-strategique/PL_19-717-02W_MSSS.pdf (accessed 2020 Jan 13).
11 Fast J, Lero D, Duncan K, et al. Employment consequences of family/friend caregiving in Canad. Population Change and Lifecourse Strategic Knowledge Cluster Research/Policy Brief, Vol. 1, No. 2 , Art. 2. Edmonton: Research on Aging, Policies and Practice, University of Alberta; 2011. Available: https://ir.lib.uwo.ca/cgi/viewcontent.cgi?article=1004&context=pclc_rpb (accessed 2020 Jan 13).
12 Revenu Québec. Tax Credit for Caregivers. Quebec: Revenu Québec; 2019. Available: https://www.revenuquebec.ca/en/citizens/tax-credits/tax-credit-for-caregivers/ (accessed 2020 Jan 13).
13 Public Health Agency of Canada. Investing in Prevention: The Economic Perspective. Ottawa: Public Health Agency of Canada; May 2009. Available: http://www.phac-aspc.gc.ca/ph-sp/pdf/preveco-eng.pdf (accessed 2020 Jan 13).
14 Statistics Canada. Table 13-10-0096-10 Smokers, by age group. Ottawa: Statistics Canada; 2018. Available:
https://www150.statcan.gc.ca/t1/tbl1/en/tv.action?pid=1310009610 (accessed 2020 Jan 13).
15 Institut de la statistique du Québec. Enquête québécoise sur la santé des jeunes du secondaire 2016-2017. Résultats de la deuxième édition. La santé physique et les habitudes de vie des jeunes, Tome 3 (French only). Quebec: Institut de la statistique du Québec; December 2018. Available: https://www.stat.gouv.qc.ca/statistiques/sante/enfants-ados/alimentation/sante-jeunes-secondaire-2016-2017-t3.html(accessed 2020 Jan 13).
16 World Health Organization (WHO). Tobacco Free Initiative: https://www.who.int/tobacco/economics/taxation/en/
17 Legislative Assembly of British Columbia, Bill 45 – 2019: Taxation Statutes Amendment Act. Geneva: WHO; 2019. Available: https://www.leg.bc.ca/parliamentary-business/legislation-debates-proceedings/41st-parliament/4th-session/bills/first-reading/gov45-1 (accessed 2020 Jan 13).
18 Choosing Wisely Canada. Implementing Choosing Wisely Canada Recommendations. Toronto: Choosing Wisely Canada; 2020. Available: https://choosingwiselycanada.org/implementation/ (accessed 2020 Jan 13).
19 Canadian Medical Association, e-Panel Survey Summary: Choosing Wisely Canada (distributed to 3,864 e-Panel members and completed in November 2016): https://www.cma.ca/e-panel-survey-summary-choosing-wisely-canada.
20 Legislative Assembly of British Columbia. Bill 45 – 2019: Taxation Statutes Amendment Act. Vancouver: Legislative Assembly of British Columbia; 2019. Available: https://www.leg.bc.ca/parliamentary-business/legislation-debates-proceedings/41st-parliament/4th-session/bills/first-reading/gov45-1 (accessed 2020 Jan 13).
Subject: Improving Long-term Care for People in Canada
Dear Minister Hajdu and Minister Schulte,
We are writing to you with recommendations for responding to the staggering effects COVID-19 has had on our health-care system, particularly in long-term care (LTC) homes across Canada. These recommendations were recently unveiled by the Canadian Nurses Association (CNA) on May 27 through a report entitled 2020 Vision: Improving Long-term Care for People in Canada (attached to this letter). We invite you to read it and consider the proposals we are bringing forward.
As you know, Canada has had unacceptable rates of COVID-19-related deaths in LTC; by late April, 79% of the country’s deaths due to COVID-19 were linked to outbreaks in these homes. These tragic numbers are in part a result of decades of neglect of the LTC sector and a growing mismatch between the level of care required by people living in those settings, and the level of care available. Furthermore, the recent reports from the military deployed to Ontario and Quebec’s long-term care homes have emphasized the shocking and horrific conditions that exist in some nursing homes in Canada.
We applaud the Prime Minster’s recent commitment to work closely and support the province’s efforts to improve standards of care for older people in long-term care
homes across the country. Moreover, further decisive action needs to be undertaken. To address the flaws COVID-19 has revealed in the support and care systems available to Canada’s older people, we recommend that your Government take immediate action on three important fronts:
The Government of Canada should immediately appoint a commission of inquiry on aging;
Federal public health leaders must work with provincial, territorial and Indigenous governments and public health leaders to review the country’s COVID-19 response and organize preparations for the next pandemic;
Federal, provincial and territorial governments must increase investments in community, home and residential care to meet the needs of our aging population.
As the Prime Minister indicated last week, providing support in the short term and having broader discussions in the long term is critical. We believe many solutions can be put in place now in some long-term care homes if they had better funding, for example. In the long term, a deeper look to identify the best models for delivering better health and social services will support safe and dignified aging for every person in Canada.
We recognize the challenges involved to address the issues in the support and care systems for older people in Canada. The benefits of redesigning how we provide care for older people (Canada’s largest growing demographic) and others with complex continuing care needs will go beyond improving their lives and health. A good long-term care system, in tandem with effective, well-organized community and home care, will ease pressure on the acute-care system and eliminate many of the gaps in the continuum of care that too often result in previously independent older people landing in the hospital or long-term care.
Acting on these three recommendations will help to provide a solid foundation on which to build a safe and dignified future for Canada’s older people. Canada is known
for its humanitarian work around the world. It’s time we brought those values home, to care for the people to whom this country and each one of us owes so much.
We look forward to discussing these proposals with you and your staff as soon as possible. Sincerely,
RN, MN, PhD, CCHN(C) President Canadian Nurses Association
RN, BSN, MN, PhD(c) President,
Canadian Association for Rural and Remote Nursing
Canadian Association of Social Workers
RN, BN, ASMH, Med President Canadian Family Practice Nurses Association
RPN, MN, PhD(c)President,
Lori Schindel Martin,
RN, PHD President
Canadian Gerontological Nursing Association
BN, RN, CPMHN(C) Past President
Canadian Federation of Mental Health Nurses
RN, BScN, President
Canadian Indigenous Nurses Association
MD CCFP (PC) FCFP President Canadian Medical Association
Canadian Public Health Association
Miranda R Ferrier
MD CM, CCFP, FCFP, CAE, ICD. D
Executive Director & Chief Executive Officer College of Family Physicians of Canada
Ontario Personal Support Workers Association
Canadian Support Workers Association
RPN-GPNC(C), BAHSc (Hons), MHSc(c)
Professional Advocacy Director
Gerontological Nursing Association
MN, NP, President NPAC-AIIPC
Nurse Practitioner Association of Canada
Re: Federal measures to recognize the significant contributions of Canada’s front-line health care workers during the COVID-19 pandemic
Dear Ministers Morneau and Hajdu:
On behalf of the Canadian Medical Association (CMA) and HEAL’s member organizations, representing 650,000 health care workers in Canada, we are writing to you with recommendations for new federal measures to support the financial hardships and risks posed to front-line health care workers (FLHCWs) during the COVID-19 pandemic.
To begin, we strongly support the measures the federal government has taken to date to mitigate the health and economic impacts of COVID-19. However, given the unique circumstances that FLHCWs face, additional measures are required to acknowledge their role, the risks being posed to themselves and their families, and the financial burden they have taken on through it all. All FLHCWs face numerous challenges trying to carry out their life-saving work during these incredibly difficult times and they deserve to be recognized for their significant contributions.
As such, we are recommending that the federal government implement the following new measures for all FLHCWs:
1) An income tax deduction for FLHCWs put at risk during the COVID-19 pandemic, in recognition of their heroic efforts. All FLHCWs providing in-person patient care during the pandemic would be eligible to deduct a designated amount against their income earned. This would be modelled on the deduction provided to members of the Canadian Armed Forces serving in moderate- and high-risk missions.
2) A non-taxable grant to support the families of FLHCWs who die in the course of responding to the COVID-10 pandemic or who die as a result of an occupational illness or psychological impairment related to this work. The grant would also apply to cases in which the death of a FLHCW’s family member is attributable to the FLHCW’s work in responding to the pandemic. We are recommending that access to the Memorial Grant program, or a similar measure, be granted to FLHCWs and their family member(s).
3) A temporary emergency accommodation tax deduction for FLHCWs who incur additional accommodation costs as well as a home renovation credit in recognition of the need for FLHCWs to adhere to social distancing to prevent the spread of COVID-19 to their family members. We are recommending all FLHCWs earning income while working in a health care facility or public health unit or in a capacity related thereto (e.g. paramedics or janitorial staff) be eligible for the deduction and credit.
1410, pl. des tours Blair / Blair Towers Place, bur. / Suite 500
Ottawa ON K1J 9B9
Ministers Morneau and Hajdu
June 2, 2020
4) Provide additional child-care relief to FLHCWs by doubling the child-care deduction. We recommend the individuals listed above be eligible for the enhanced deduction.
We recognize that it is important that any measures enacted be simple for the government to implement and administer, as well as simple for FLHCWs to understand and access. The recommendations above will ensure that relief applies to a wide range of Canada’s FLHCWs who are battling COVID-19, where the primary intention is to be as inclusive as possible.
Once again, we commend the federal government for its decisive and meaningful response to the pandemic. Now is the time to ensure comprehensive supports are provided to those who have stepped up to protect the health and safety of all Canadians. We welcome the opportunity to discuss these recommendations with you.
Sandy Buchman, MD, CCFP(PC), FCFP
President, Canadian Medical Association
This letter is signed by the following organizations:
1410, pl. des tours Blair / Blair Towers Place, bur. / Suite 500
Ottawa ON K1J 9B9
Ministers Morneau and Hajdu
June 2, 2020
Canadian Medical Association
Canadian College of Health Leaders
Canadian Podiatric Medical Association
Association of Faculties of Medicine of Canada
Canadian Counselling and Psychotherapy Association
Canadian Psychiatric Association
Canadian Association of Community Health Centres
Canadian Psychological Association
Canadian Association for Interventional Radiology
Canadian Dental Association
Canadian Association of Medical Radiation Technologists
Canadian Dental Hygienists Association
Canadian Society for Medical Laboratory Science
Canadian Society of Nutrition Management
Canadian Association of Midwives
Canadian Association of Nuclear Medicine
Canadian Massage Therapist Alliance
Canadian Society of Respiratory Therapists
Canadian Association of Occupational Therapists
Royal College of Physicians and Surgeons of Canada
College of Family Physicians of Canada
Canadian Association of Optometrists
Canadian Nurses Association
Dietitians of Canada
Canadian Association of Social Workers
Canadian Ophthalmological Society
Canadian Cardiovascular Society
Canadian Orthopaedic Association
Paramedic Association of Canada
Canadian Chiropractic Association
Canadian Pharmacists Association
Canadian Physiotherapy Association
Speech-Language & Audiology Canada
Submission in Response to the Consultation on the Canada Emergency Wage Subsidy: Keeping Medical Clinic Employees on the Payroll June 5, 2020
Since the outset of the COVID-19 pandemic, the CMA has been actively engaged as part of Canada’s domestic response. In addition to our engagement on key public health issues such as the supply and distribution of personal protective equipment, the CMA has addressed physician practice needs, including releasing a
Virtual Care Playbook to support the rapid conversion of medical practices to virtual care delivery.
In the context of physician practices operating as small businesses, the CMA strongly supports the federal government’s emergency economic relief programs. Access to these programs is critical to the viability of
many physician practices — and the ability of medical clinics across Canada to retain vital front-line health care workers (FLHCWs) and keep their doors open to continue serving the needs of their patient population.
However, despite the dire need for these programs by medical professionals — who constitute a strategic
resource and sector at the best of times, but particularly in a pandemic — presently, the CMA is concerned
that many physicians are experiencing administrative barriers to accessing these critical federal support
programs for their employees.
This submission provides a briefing on physician practices and the need to access the CEWS, an overview of
the technical and administrative factors impeding access, as well as proposed remedies to enable a rapid
Physician Practices and Access to the CEWS
While health care in Canada is predominantly publicly funded, it is primarily privately delivered. In Canada’s health care system, the vast majority of physicians are self-employed professionals operating medical practices as small business owners. Physician-owned and -run medical practices ensure that Canadians are able to access the health care they need, in communities across all jurisdictions. In doing so, Canadian physicians are directly responsible for 167,000 jobs across the country, contributing over $39 billion to Canada’s GDP. Including the expenses and overhead associated with running physician practices, nearly 289,000 jobs indirectly relate to physician practices.
However, as much as physician practices resemble small businesses on the basis of key criteria like employing staff and paying rent, it is imperative to recognize that they are in fact core stewards of a substantial portion of Canada’s health care system and critical health system infrastructure.
It is a national imperative to ensure the viability of such a core component of Canada’s health care system as our medical clinics and the staff they employ. To this end, both federal and provincial/territorial governments have a role in ensuring Canada’s medical clinics are there to serve the health care needs of Canadians, through the pandemic and beyond.
Physician practices have experienced significant impacts related to changing volumes of patient care and delivery models of care in light of public health restrictions since the pandemic was declared on Mar. 11, 2020. The CMA commissioned an economic impact analysis to better understand the impacts across various practice settings. This analysis reveals that across the range of practice settings, the after-tax monthly earnings of physician practices are estimated to decline between 15% and 100% in the low-impact scenario, and between 25% and 267% in the high-impact scenario.
Despite meeting the revenue reduction and employer eligibility factors, the CMA is concerned that many physicians are ineligible for the CEWS because of technical and administrative factors that are inconsistent with other existing federal legislative frameworks.
The CMA conducted a survey of its membership between May 22 and June 1 to better understand physicians’ experiences accessing the federal economic relief programs; 3,730 physicians participated in this survey. Overall, about a third (32%) of physicians polled had attempted to apply to at least one of the federal programs available and 15% of all physicians who responded applied for the CEWS, making it the second most applied-to program.
Of those physicians who applied to the CEWS, 60% were successful, 7% were denied and the remaining 33% were still awaiting response at the time of the survey. Of those who applied but were denied the CEWS, a third (33%) indicated it was because of their cost-sharing structure, 3% responded it was because they worked in a hospital-based setting and a further 22% simply didn’t know. Finally, as part of the survey, physicians shared comments that speak to the issues outlined in this brief. A few excerpts are below:
“We are a group of 4 surgeons and have a cost sharing agreement to pay our office expenses. Our office is outside of the hospital. We tried to apply for the CEWS but have recently received accounting advice supported by legal advice that cost sharing agreements will not be candidates for the CEWS. We are therefore presently exploring other options such as a work share situation or temporary/permanent layoffs.” CMA member, survey respondent
“I work in a group with 11 other OBGYNs. We are still unsure to this point about whether the CEWS applies to our situation. Our revenue is certainly down by ~30% or more. The issue is that our structure doesn't fall into one of the neat categories for CEWS … We are awaiting clarification from our accountant on our status but it seems that the way the rules are currently written, we will not benefit from CEWS, and unfortunately, we are reducing staff hours to cope with our reduction in revenue.” CMA member, survey respondent
“My main frustration is that I can't find a clear answer on whether a clinic made up of multiple doctors with a cost sharing agreement is eligible for CEWS for our employees. I imagine many family practice clinics are set up this way … So as it stands we have not been able to access any financial programs in order to help pay our overhead/staff despite 50% reduction in patient volume.” CMA member, survey respondent
A. Cost-Sharing Arrangements — Front-Line Health Care Workers Employed in Physician Clinics
One of the main types of practices that are unable to access the CEWS because of technical administrative barriers, despite meeting the key eligibility criteria, are physicians operating independently within a cost-sharing business structure.
Like many other independent professionals, physicians operate in group settings. In fact, according to the Canadian Institute for Health Information, in 2019, 65% of family practices operated in a group setting. However, unlike other independent professionals, physicians have been encouraged to operate in a group setting, both by accreditation bodies as well as by provincial health authorities, to meet system delivery goals.
Appendix A provides a case study based on Sudbury Medical Associates (SMA), an illustrative example of three doctors (Dr. Brown, Dr. Lee and Dr. Assadi) who coordinated the operations of their medical practices together to open an integrated health care clinic. While they provide care to their own respective patient rosters, these three physicians share in the clinic space rent and employ 10 employees together. Because
of the way SMA is structured, these physicians are unable to access the CEWS for their proportionate share
of their employees’ salaries. Each physician has met all the CEWS criteria except for the fact that SMA administers the payroll for their 10 employees under its own payroll number.
SMA illustrates a typical family medicine clinic representative of the many medical practices in Canada who employ numerous FLHCWs.
B. Cost-Sharing Arrangements — Front-Line Health Care Workers Employed by Specialist Physicians Practising in a Hospital-Based Environment
Another type of physician structure unable to access the CEWS because of the use of cost-share arrangements are specialist physicians practising in a hospital-based environment or academic health science centre (an “AHSC”). The purpose of an AHSC is to provide specialized health care services, carry out medical research and train the next generation of Canada’s health care professionals.
Provincial funding agreements are designed to align the interest of all parties in an AHSC (clinical care, teaching, research and innovation) and often contain governance and accountability requirements. In order to discharge responsibilities under provincial funding agreements and to run a practice that can meet certain metrics, physicians are required to hire their own staff. Consequently, cost-sharing arrangements are utilized by these physicians to efficiently hire staff while meeting their other responsibilities.
In response to the COVID-19 pandemic, hospitals have implemented strategies designed to protect the health care system from collapsing or being overwhelmed. For example, many hospitals have cancelled elective surgeries; coupled with the fear many patients have of going to the hospital, this has resulted in a decline in patient care volume as hospitals and physician practices adhere with public health guidelines. This has led to a significant decline in revenue, requiring physicians to access the CEWS program in order to continue to employ their staff.
Like all physicians in Canada, specialist physicians practising in a hospital-based health care setting are responsible for significant levels of fixed overhead expenses related to a medical practice. This includes medical insurance, licensing fees, maintaining an office and other professional fees. As a standard practice, employees of physicians who practise in AHSCs are often paid by a third party. In many instances, physicians have established an agency relationship pursuant to which they delegate authority to the hospital to act as their agent with respect to withholding taxes, source deductions and filing T4 returns. The main reason for this agency is to ensure that the physician focuses on teaching, researching and patient care. For clarity,
the administrator (hospital) has no legal authority to conclude on any employment matter such as the determination of a bonus or a wage increase or the payout of any severance. All these matters would
be the responsibility of the physician in his/her capacity as employer.
Anticipating a second wave of COVID-19, many physicians are concerned about maintaining their staff during a future work stoppage given their current inability to apply for the CEWS. As employers, physicians can appreciate that the hospital’s payroll number is creating additional administrative complexity for the
Canada Revenue Agency (CRA). However, as an employer and small business, their ability to access
the CEWS program is an integral part of their strategy to retain and maintain their staff.
C. Technical Analysis — CEWS Legislation and the Principal-Agent Relationship
i) CEWS Legislation — Qualifying Entity
Pursuant to the COVID-19 Emergency Response Act, an entity will qualify for CEWS to the extent that it is a Qualifying Entity under ss. 125.7(1) of the Income Tax Act (ITA). One of the criteria to be a qualifying entity is that the entity had, on Mar. 15, 2020, a business number in respect of which it is registered with the Minister to make remittances required under ITA s. 153. By virtue of how cost-sharing arrangements are structured, the administrator (agent) handles the payroll filings using their own payroll number, which can be different from the employing physician (principal). On the basis of the uniqueness of cost-sharing structures and the definition in the legislation, physicians who employ individuals under these arrangements need to rely on principal-agent concepts in order to qualify
for the CEWS provided all other criteria are met.
Presently, the CEWS application portal does not recognize principal-agent arrangements, which are common among physician practices as they employ FLHCWs. It is recognized that each participant or physician in a cost-sharing arrangement is in fact its own business and that physicians share the costs
of certain overhead expenses, which include wage-related costs for FLHCWs. In these structures, the payroll number for the employee(s) may be associated with one of the independently operating physicians or it may be associated with a separate entity. As such, these physicians are not likely to have a distinct payroll number associated with their eligible employee under the CEWS. The case law and the administrative position of the CRA demonstrate the following:
1. The principals in a cost-sharing arrangement are the employers; and
2. The agent’s payroll number should be considered the payroll number for the principal for the purposes of making a CEWS application.
ii) Case Law
Subsection 9(1) of the ITA provides for the basic rules as they relate to computing the income or loss from business or property. In both Avotus Corporation v The Queen and Fourney v The Queen , the Tax Court of Canada determined that where a person carries on business as agent for another, it is the principal that is carrying on the business and not the agent.
The Fourney case provides for several concepts that extend to the unique nature of cost-sharing arrangements. These concepts should provide clarity about a principal’s ability to make a CEWS claim if it had a payroll agent that had a business number to make remittances before Mar. 15, 2020. The concepts are summarized as follows:
1. Corporations can act as Agent
In Fourney, at paragraphs 41 and 42, it was concluded that a corporation can act as its shareholder’s agent:
It is established, then, that corporations can act as agents, and this concept is not repugnant to the rule that corporations have separate legal personality a matter addressed in the oft-cited Salomon case.
2. Business Activities belong to the Principal
At paragraphs 60 and 65 of Fourney, the Tax Court examined the following activities and ultimately concluded that the activities were in fact the activities of the principal and not the agent. The following conclusions can be drawn from the case:
Payments made to the corporate agent were found to be revenues of the principal.
Contracts entered into by the corporate agent were contracts entered into by the principal.
T4s issued under the corporate agent’s name were deductible expenses to the principal.
Lastly, at paragraph 65, the Tax Court characterized the corporate agent as a mere conduit for the appellant.
iii) Administrative Policy
For GST/HST purposes, the CRA accepts the concept of an agency relationship typically utilized by physicians in cost-sharing practices. In RITS 142436 “Implementation of Cost Sharing Arrangement,” the CRA concluded that GST/HST does not apply to payments made to “Company A” because it was an agent in relation to remuneration paid to the employees of Company B and Company C. In this ruling, Companies A, B and C were all employers with Company A administrating the payroll as agent.
The CRA’s conclusions appear to take the follow matters into account:
Employees are jointly employed by the principals in the cost-sharing arrangement.
Principals have legal responsibility for the employees.
The principals would delegate responsibility or authority to an agent, which could be a corporation or another physician.
That agent would be given discretion to pay the employees, withhold and remit the appropriate amount of taxes, file T4 slips, hire and terminate at the determination of the principals.
Each principal would pay the agent for their proportionate share of payroll and report such payroll on their respective financial statements and tax returns.
The CRA also concluded that the “employment status of a person for GST/HST purposes is the same for income tax purposes.”
The Department of Finance provides that the CEWS helps businesses keep employees on the payroll, encourages employers to rehire workers previously laid off, and better positions businesses to bounce back following the crisis. In keeping with this objective, a payroll number for an agent should extend itself to the principals for the purposes of applying for the CEWS because it is supported by case law and the administrative practices of the CRA. Application of any federally legislated program should be conceptually consistent with historical frameworks already established.
The CMA holds that the legislation as written can remain as currently drafted as it provides for the majority of applicants looking to access the CEWS. However, to address the unintended exclusion of cost-sharing arrangements, the CMA recommends that the CRA provide administrative guidance consistent with and based on existing case law and administrative positions.
The CMA recommends that the Federal Government and the CRA enable physicians to claim their proportionate share of eligible remuneration paid through a cost-sharing arrangement provided all other program eligibility criteria are met.
Administratively, this may be achieved by the following:
a “check-box” on the application denoting the applicant is a participant in a cost sharing arrangement
identification of the cost-sharing arrangement payroll number
a joint election between the agent and employer allowing the employer to utilize the agent’s payroll number and denoting the percentage allocation of salary costs to the particular employer
If this recommendation is not feasible, the CMA recommends that the Federal Government and the CRA implement an alternate approach whereby a cost-share administrator is permitted to make a CEWS claim in their capacity as agent on behalf of each eligible entity (principal). Since period 3 is almost complete, there could be less administration regarding these claims as agents have not made application.
Similar to the preferred remedy above, this may be achieved by the following:
a “check box” on the application indicating that an “agent” is filing the claim on behalf of eligible employers
the applicant could also provide (either initially or upon desk audit) the business numbers to CRA for each employer
a joint election among the agent and the employers allowing the agent to act on behalf of the employers for purposes of the CEWS
This would provide ease of audit for the CRA as the claim can be verified against the T4 and payroll remittances. The election and disclosure requirements would also alleviate any concerns the CRA or Department of Finance may have regarding potential abuse of the program.
In Appendix B we also outline supporting documentation to be retained for a CEWS Claim by a Cost-Sharing Entity, which will ensure cost-sharing entities have the appropriate documentation to submit a claim and also assist the CRA in conducting pre-assessment audits.
The CMA would be pleased to provide further detail on this issue or consider other alternatives to ensure FLHCWs receive wages during these unprecedented times.
Canada’s physicians are important employers. Not only are they responsible for almost 167,000 in direct employment, together with their staff, they are at the front lines of Canada’s response to the COVID-19 pandemic. Our health care system cannot withstand loss of employment or risks to the viability of medical clinics, at this crucial time — and indeed at any time. The CMA strongly encourages the Federal Government to address the issues outlined above in preventing physicians from accessing this critical economic relief program. On behalf
of the doctors of Canada, the CMA stands ready to collaborate in resolving these technical and administrative barriers.
Appendix A: Welcome to Sudbury Medical Associates (SMA)
Dr. Christopher Brown (60) settled in his hometown of Sudbury to practise family medicine about 30 years ago. He operated in his own space, with his own employees until SMA was formed. Dr. Jennifer Lee (45) has been practising in Sudbury for her entire career. Dr. Lee handles all family patients with a special focus on maternity and young family care. Dr. Sarah Assadi (30) recently completed her residency. Dr. Assadi spent time in Sudbury as a locum and enjoyed the strong community feel.
Dr. Brown and Dr. Lee are long-time colleagues and recently approached Dr. Assadi to open an integrated health care clinic. Together they would require 10 employees (comprised of nurse practitioners, medical assistants and receptionists) to effectively operate the clinic. Optically, SMA appears to be one business when in fact it is comprised of three distinct medical practices. Each physician or their professional corporation maintains their own distinct patient list. Upon the advice of professional advisors, the physicians entered into a cost-sharing agreement to realize cost efficiencies related to the integrated health care clinic (administration and lease). This structure will ensure the needs of the community are met by the expansion of operating hours facilitated by a flexible staffing model. Understanding that cost-sharing arrangements are accepted by provincial health authorities and the Canada Revenue Agency (CRA), Dr. Brown, Dr. Lee and Dr. Assadi documented this arrangement, which includes the following details:
Dr. Brown Dr. Lee Dr. Assadi SMA
Legal entity Prof corp Prof corp Sole-proprietor Corp
Proportionate share of costs 20% 40% 40%
Legal employer (10 staff) ü ü ü
Legally responsible — all contracts ü ü ü
Payroll, T4 and remittances ü
Report for income tax purposes:
Proportionate share of costs administered by SMA including payroll ü ü ü
The impact of COVID-19 resulted in a significant slowdown of patient visits between Mar. 15 and May 31 as the residents of Sudbury were social distancing and were only leaving their homes for urgent matters. Dr. Brown, Dr. Lee and Dr. Assadi are concerned about keeping their front-line health care workers employed and at the same time maintaining a sufficient level of family health care in the community. Considering a possible second wave of COVID-19, these physicians need to ensure that their community health clinic remains open and safe so there is no unintended stress on hospitals.
Like many small businesses that have experienced significant revenue declines, these physicians are hopeful to access the Canada Emergency Wage Subsidy (CEWS) to ensure they can retain their specialized employees and pivot to the new environment they need to operate within. Upon further review, only Dr. Lee and Dr. Assadi experienced sufficient revenue declines to access the CEWS, but currently they do not qualify because of how they structured the payroll for these 10 employees. They are concerned that without the CEWS, they will not be able to retain all of their staff or see as many patients. The following table summarizes the CEWS analysis:
CEWS criteria Dr. Brown Dr. Lee Dr. Assadi SMA
Eligible entity ü
Prof corp ü
Prof corp ü
Sole proprietor ü
Revenue decline test: March 2020 Not met ü ü No revenues to report
(eligible remuneration ) ü ü ü
Qualified for the CEWS No
(revenue decline test not met) No
(payroll account number held by SMA, which manages payroll on behalf of Dr. Lee) No
(payroll account number held by SMA, which manages payroll on behalf of Dr. Assadi) No
(has no revenue and is not the legal employer)
As employers, Dr. Lee and Dr. Assadi do not understand why their businesses are unable to access the CEWS for their proportionate share of their employees’ salaries. Each has met all of the CEWS criteria except for the fact that SMA administers the payroll for their 10 employees under its own payroll number.
Appendix B: Illustration of Supporting Documentation to be Retained for a
CEWS Claim by Cost-Sharing Entity
To the extent that employers operating through a cost-sharing structure are permitted to make a CEWS claim, the following documentation could be requested by the CRA to verify the claim upon desk audit.
For illustrative purposes, let’s assume that Dr. Lee and Dr. Assadi both made a CEWS claim.
Supporting Documentation Request
1. The legal documentation establishing the agency relationship pursuant to which Dr. Lee and Dr. Assadi delegated authority to SMA to handle the income tax remittances, source deductions and T4 reporting.
2. The employment contracts, which clearly indicate that each of Dr. Lee, Dr. Assadi (and Dr. Brown) are the employers.
Alternatively, confirmation from the employees that SMA is not the employer and that they are employed
by Drs. Lee, Assadi and Brown.
3. SMA’s accounting records or financial statements, which clearly support its position as an agent. Note: Typically, most cost-share administrators will have NIL revenue and account for all cash inflows and outflows on their balance sheet in a manner similar to a lawyer’s trust account.
4. An analysis demonstrating the revenue decline for the relevant period for Dr. Assadi’s business and Dr. Lee’s business.
5. Calculations supporting the proportionate share of “baseline remuneration” and “eligible remuneration” paid to the employees by Dr. Assadi’s business and Dr. Lee’s business.
6. A reconciliation of the wage subsidy received along with their proportionate share of the wage subsidy so it can be properly accounted for and taxed.
That the government create a one-time Health Care and Innovation Fund to resume health care services, bolster public health capacity and expand primary care teams, allowing Canadians wide-ranging access to health care.
That the government recognize and support the continued adoption of virtual care and address the inequitable access to digital health services by creating a Digi-Health Knowledge Bank and by expediting broadband access to all Canadians.
That the government act on our collective learned lessons regarding our approach to seniors care and create a national demographic top-up to the Canada Health Transfer and establish a Seniors Care Benefit.
That the government recognize the unique risks and financial burden experienced by physicians and front line health care workers by implementing the Frontline Gratitude Tax Deduction, by extending eligibility of the Memorial Grant and by addressing remaining administrative barriers to physician practices accessing critical federal economic relief programs.
Five months ago COVID-19 hit our shores. We were unprepared and unprotected. We were fallible and vulnerable. But, we responded swiftly.
The federal government initiated Canadians into a new routine rooted in public health guidance.
It struggled to outfit the front line workers. It anchored quick measures to ensure some financial stability.
Canadians tuned in to daily updates on the health crisis and the battle against its wrath.
Together, we flattened the curve… For now.
We have experienced the impact of the first wave of the pandemic. The initial wake has left Canadians, and those who care for them, feeling the insecurities in our health care system.
While the economy is opening in varied phases – an exhaustive list including patios, stores, office spaces, and schools – the health care system that struggled to care for those most impacted by the pandemic remains feeble, susceptible not only to the insurgence of the virus, but ill-prepared to equally defend the daily health needs of our citizens.
The window to maintain momentum and to accelerate solutions to existing systemic ailments that have challenged us for years is short. We cannot allow it to pass. The urgency is written on the faces of tomorrow’s patients.
Before the onset of the pandemic, the government announced intentions to ensure all Canadians would be able to access a primary care family doctor. We knew then that the health care system was failing.
The pandemic has highlighted the criticality of these recommendations brought forward by the Canadian Medical Association. They bolster our collective efforts to ensure that Canadians get timely access to the care and services they need. Too many patients are succumbing to the gaps in our abilities to care for them. Patients have signaled their thirst for a model of virtual care. The magnitude of our failure to meet the needs of our aging population is now blindingly obvious. Many of the front line health care workers, the very individuals who put themselves and their families at risk to care for the nation, are being stretched to the breaking point to compensate for a crumbling system.
The health of the country’s economy cannot exist without the health of Canadians.
Long wait times have strangled our nation’s health care system for too long. It was chronic before COVID-19. Now, for far too many, it has turned tragic.
At the beginning of the pandemic, a significant proportion of health care services came to a halt. As health services are resuming, health care systems are left to grapple with a significant spike in wait times. Facilities will need to adopt new guidance to adhere to physical distancing, increasing staff levels, and planning and executing infrastructure changes. Canada’s already financially atrophied health systems will face significant funding challenges at a time when provincial/territorial governments are concerned with resuscitating economies.
The CMA is strongly supportive of new federal funding to ensure Canada’s health systems are resourced to meet the care needs of Canadians as the pandemic and life continues. We need to invigorate our health care system’s fitness to ensure that all Canadians are confident that it can and will serve them.
Creating a new Health Care and Innovation Fund would focus on resuming the health care system, addressing the backlog, and bringing primary care, the backbone of our health care system, back to centre stage.
The CMA will provide the budget costing in follow-up as an addendum to this submission.
RECOMMENDATION 1 Creating a one-time Health Care and Innovation Fund
It took a global pandemic to accelerate a digital economy and spark a digital health revolution in Canada. In our efforts to seek medical advice while in isolation, Canadians prompted a punctuated shift in how we can access care, regardless of our location or socio-economic situation. We redefined the need for virtual care.
During the pandemic, nearly half of Canadians have used virtual care. An incredible 91% were satisfied with their experience. The CMA has learned that 43% of Canadians would prefer that their first point of medical contact be virtual.
The CMA welcomes the $240 million federal investment in virtual care and encourages the government to ensure it is linked to a model that ensures equitable access.
A gaping deficit remains in using virtual care. Recently the CMA, the Royal College of Physicians and Surgeons of Canada and the College of Family Physicians of Canada established a Virtual Care Task Force to identify digital opportunities to improve health care delivery, including what regulatory changes are required across provincial/territorial boundaries. To take full advantage of digital health capabilities, it will be essential for the entire population, to have a functional level of digital health literacy and access to the internet.
The continued adoption of virtual care is reliant on our ability to educate patients on how to access it. It will be further contingent on consistent and equitable access to broadband internet service.
Create a Digi-Health Knowledge Bank
Virtual care can’t just happen. It requires knowledge on how to access and effectively deliver it, from patients and health care providers respectively. It is crucial to understand and promote digital health literacy across Canada. What the federal government has done for financial literacy, with the appointment of the Financial Literacy Leader within the Financial Consumer Agency of Canada, can serve as a template for digital health literacy.
We recommend that the federal government establish a Digi-Health Knowledge Bank to develop indicators and measure the digital health of Canadians, create tools patients and health care providers can use to enhance digital health literacy, continually monitor the changing digital divide that exists among some population segments.
Pan-Canadian broadband expansion
It is critical to bridge the broadband divide by ensuring all those in Canada have equitable access to affordable, reliable and sustainable internet connectivity. Those in rural, remote, Northern and Indigenous communities are presently seriously disadvantaged in this way. With the rise in virtual care, a lack of access to broadband exacerbates inequalities in access to care. This issue needs to be expedited before we can have pride in any other achievement.
RECOMMENDATION 2 Embedding virtual care in our nation’s health care system
Some groups have been disproportionately affected by the COVID-19 crisis. Woefully inadequate care of seniors and residents of long-term care homes has left a shameful and intensely painful mark on our record. Our health care system has failed to meet the needs of our aging population for too long.
The following two recommendations, combined with a focus on improving access to health care services, will make a critical difference for Canadian seniors.
A demographic top-up to the Canada Health Transfer
The Canada Health Transfer (CHT) is the single largest federal transfer to the provinces and territories. It is critical in supporting provincial and territorial health programs in Canada. As an equal per-capita-based transfer, it does not currently address the imbalance in population segments like seniors.
The CMA, hand-in-hand with the Organizations for Health Action (HEAL), recommends that a demographic top-up be transferred to provinces and territories based on the projected increase in health care spending associated with an aging population, with the federal contribution set to the current share of the CHT as a percentage of provincial-territorial health spending. A top-up has been calculated at 1.7 billion for 2021. Additional funding would be worth a total of $21.1 billion to the provinces and territories over the next decade.
Seniors care benefit
Rising out-of-pocket expenses associated with seniors care could extend from 9 billion to 23 billion by 2035. A Seniors Care Benefits program would directly support seniors and those who care for them. Like the Child Care Benefit program, it would offset the high out-of-pocket health costs that burden caregivers and patients.
RECOMMENDATION 3 Ensuring that better care is secured for our seniors
The federal government has made great strides to mitigate the health and economic impacts of COVID-19. Amidst the task of providing stability, there has been a grand oversight: measures to support our front line health care workers and their financial burden have fallen short.
The CMA recommends the following measures:
1. Despite the significant contribution of physicians’ offices to Canada’s GDP, many physician practices have not been eligible for critical economic programs. The CMA welcomes the remedies implemented by Bill C-20 and recommends the federal government address remaining administrative barriers to physicians accessing federal economic relief program.
2. We recommend that the government implement the Frontline Gratitude Tax Deduction, an income tax deduction for frontline health care workers put at risk during the COVID-19 pandemic. In person patient care providers would be eligible to deduct a predetermined amount against income earned during the pandemic. The Canadian Armed Forces already employs this model for its members serving in hazardous missions.
3. It is a devastating reality that front line health care workers have died as a result of COVID-19. Extending eligibility for the Memorial Grant to families of front line health care workers who mourn the loss of a family member because of COVID-19, as a direct result of responding to the pandemic or as a result of an occupational illness or psychological impairment related to their work will relieve any unnecessary additional hardship experienced. The same grant should extend to cases in which their work contributes to the death of a family member.
RECOMMENDATION 4 Cementing financial stabilization measures for our front line health care workers
Those impacted by COVID-19 deserve our care. The health of our nation’s economy is contingent on the health standards for its people. We must assert the right to decent quality of life for those who are most vulnerable: those whose incomes have been dramatically impacted by the pandemic, those living in poverty, those living in marginalized communities, and those doubly plagued by experiencing racism and the pandemic. We are not speaking solely for physicians. This is about equitable care for every Canadian impacted by the pandemic.
Public awareness and support have never been stronger. We are not facing the end of the pandemic; we are confronting an ebb in our journey. Hope and optimism will remain elusive until we can be confident in our health care system.
Dear First Ministers:
Re: Protecting and supporting Canada’s health-care providers during COVID-19
Given the rapidly escalating situation both globally and in our country, we know that the health and safety of all people and health-care providers in Canada is uppermost on your minds. We appreciate the measures that have been taken by all levels of government to minimize the spread of COVID-19. However, we must ensure those working directly with the public, including physicians, nurses, pharmacists, and social workers, are properly protected and supported, so that they can continue to play their role in the response.
First and foremost, we urge all levels of government to put measures in place to ensure the personal protective equipment that point-of-care providers require to deliver care safely throughout this outbreak is immediately deployed and ready to use. Coordinated measures and clear, consistent information and guidelines will ensure the appropriate protection of our health-care workforce.
Given the increased pressure on point-of-care providers, we ask that all governments support them by providing emergency funding and support programs to assist them with childcare needs, wage losses due to falling ill or having to be quarantined, and support of their mental health needs both during and after the crisis has subsided.
We also expect all governments to work together to provide adequate, timely, evidence-based information specifically for health-care providers. Clear, consistent and easily accessible guidance will enable them to do their jobs more efficiently and effectively in times of crisis. This can and should be
done on various easily accessible platforms such as online resources, an app, or through the creation of a hotline.
We know there will be challenges in deploying resources and funding, particularly around the supply of personal protective equipment. We ask that you consider any and all available options to support health-care providers through a coordinated effort both during and following this crisis. Our organizations look forward to continuing to work with you in these difficult times. If there is anything we can do to help your teams, you need only ask.
Claire Betker, RN, MN, PhD, CCHN(C)
President, Canadian Nurses Association
Jan Christianson-Wood, MSW, RSW
President, Canadian Association of Social Workers
kinanâskomitin (I’m grateful to you)
Lea Bill, RN BScN
President, Canadian Indigenous Nurses Association
Sandy Buchman, MD, CCFP(PC), FCFP
President, Canadian Medical Association
Dear Prime Minister,
We are writing to you today to ask you to bring attention and resources to Canada’s drug supply challenges. These shortages have existed for the past decade but have been greatly exacerbated due to the COVID-19 pandemic.
As frontline pharmacists and physicians, we have seen and heard of serious shortages of essential, critical medications. These drugs are often used simultaneously in ORs, ERs and palliative care wards, as well as ICUs. And while our ICUs are thankfully seeing fewer COVID-19 patients, the pandemic has been placing a heavy burden on their drug supply, where patients often require weeks’ worth of treatment on ventilators.
The shortages of these drugs imperil the lives of patients seeking care all over the country. Currently, the vast majority (24/32) of the drugs on Health Canada’s own Tier 3 list, which represents drugs for which there are no suitable alternatives, are essential for treating COVID-19. With the likely upcoming second wave in Canada, the potential for further exacerbation of these shortages is inevitable unless we implement rigorous preparedness measures.
At first glance, the federal government may conclude that this is a provincial and territorial area of jurisdiction. We can assure you, that there is a considerable role for the federal government to play on this issue of national concern if you so choose to take action. We believe you should.
Many of these critical care drugs should be part of the National Strategic Emergency Stockpile. However, it is clear that Canada simply did not invest enough into its stockpiles to meet the demand during the COVID-19 pandemic. In order for the stockpiling strategy to be effective, it is vital that the federal, provincial, and territorial governments work closely with hospitals, long-term care facilities, hospices and primary care facilities nationwide to establish a
comprehensive list of critical medicines and develop a plan to procure medicines
in a coordinated manner to prevent unintended competition for resources.
The 2019 budget had earmarked funds for a new Canada Drug Agency which
would have oversight over a national formulary. This proposed agency could
similarly identify essential medicines to aid in an efficient stockpiling response,
whether through stimulating domestic production or through importation and
coordination of purchasing strategies to ensure that jurisdictions that have a
greater need for medications gain access to them. We know that COVID-19’s
impact on the health system across provinces and territories and within each and
every jurisdiction was not equal or consistent.
We appreciate the active efforts of Health Canada to resolve current or projected
shortages of critical drugs through its Tier Assignment Committees. Furthermore,
Ontario has a Critical Care COVID-19 Command Centre and has created a
Critical Care Drug Shortage Task Team. Certainly, the short-term deficit will need to
be resolved through this mechanism and importing from all available suppliers.
However, to support the system at large, provincial and territorial governments will
need national support, resources and (where welcomed by provinces) a certain
level of national coordination.
Regardless of well-established Federal-Provincial-Territorial dynamics, without
concrete preventative action, Canada will perpetually face drug shortages. This is
why we recommend that your government commit to working on a long-term
solution involving a three-pronged strategy:
1. Stockpiling of a Critical Medications List which the government commits to
ensuring are always in stock for long enough to meet the needs in an emergency
(likely through the Canada Drug Agency). a. A Critical Medications List would
allow the parties involved in addressing the drug shortages to have a clear picture
of what drugs to monitor closely, and provides a more comprehensive approach
to the problem.
2. A publicly owned generic, critical drugs manufacturer, or at the bare minimum,
public support for spare capacity by Canadian-based and controlled drug
manufacturers to be used for critical drugs. a. This manufacturer or manufacturers
would specialize in manufacturing the critical drugs on the Critical Medications List,
and would be primarily involved in satisfying significant portions of our national
3. Greater transparency and communications to and from governments and
the health sector around the essential drug supply. This would include efforts to
better track the supply of drugs in hospitals across the country and push
notifications on shortages through the appropriate channels to frontline workers.
We encourage your government to give this urgent issue attention and efforts
now, so that Canadians can have the confidence that their healthcare system
will be there when they most need it.
Re: Recommendations for Canada’s long-term recovery plan
Dear Prime Minister Trudeau,
We would like first to thank and commend you for your leadership throughout this pandemic. Your government’s
efforts have helped many people in Canada during this unprecedented time and have prevented Canada from facing
outcomes similar to those seen in other countries experiencing significant pandemic-related hardship and suffering.
We are writing to you with recommendations as you develop a plan for Canada’s long-term recovery and the
upcoming Speech from the Throne on September 23rd.
The COVID-19 pandemic has further exposed and amplified many healthcare shortfalls in Canada such as care for
older adults and mental health-care. Added to that, the economic fallout is impacting employment, housing, and
access to education. These social determinants of health contribute to and perpetuate inequality, which we see the
pandemic has already exacerbated for vulnerable groups. Action is needed now to address these challenges and
improve the health-care system to ensure Canada can chart a path toward an equitable economic recovery.
To establish a foundation for a stronger middle class, Canada must invest in a healthier and fairer society by
addressing health-care system gaps that were unmasked by COVID-19. We firmly believe that the measures we are
recommending below are critical and should be part of your government’s long-term recovery plan:
1. Ensure pandemic emergency preparedness
2. Invest in virtual care to support vulnerable groups
3. Improve supports for Canada’s aging population
4. Strengthen Canada’s National Anti-Racism Strategy
5. Improve access to primary care
6. Implement a universal single-payer pharmacare program
7. Increase mental health funding for health-care professionals
We know the months ahead will be challenging and that COVID-19 is far from over. As a nation, we have an
opportunity now, with the lessons from COVID-19 still unfolding, to bring about essential transformations to our
health-care system and create a safer and more equitable society.
1. Ensure pandemic emergency preparedness
We commend you for your work with the provinces and territories to deliver the $19 billion Safe Restart Agreement
as it will help, in the next six to eight months, to increase measures to protect frontline health-care workers and
increase testing and contact tracing to protect Canadians against future outbreaks. Moving forward, as you develop a
plan for Canada’s long-term recovery, we strongly recommend the focus remains in fighting the pandemic. Beyond
the six to eight months rollout of the Safe Restart Agreement, it is critical that a long-term recovery plan includes provisions to ensure a consistent and reliable availability of personal protective equipment (PPE) and large-scale
capacity to conduct viral testing and contact tracing.
2.Invest in virtual care to support vulnerable groups
The sudden acceleration in virtual care from home is a silver lining of the pandemic as it has enabled increased
access to care, especially for many vulnerable groups. While barriers still exist, the role of virtual care should
continue to be dramatically scaled up after COVID-19 and Canada must be cautious not to move backwards. Even
before the pandemic, Canadians supported virtual care tools. In 2018, a study found that two out of three people
would use virtual care options if available.i During the pandemic, 91% of Canadians who used virtual care reported
We welcome your government’s $240 million investment in virtual health-care and we encourage that a focus be
given to deploying technology and ensuring health human resources receive appropriate training in culturally
competent virtual care. We also strongly recommend accelerating the current 2030 target to ensure every person in
Canada has access to reliable, high-speed internet access, especially for those living in rural, remote, northern and
3.Improve supports for Canada’s aging population
Develop pan-Canadian standards for the long-term care sector
The pandemic has exposed our lack of preparation for managing infectious diseases anywhere, especially in the longterm
care sector. The result is while just 20% of COVID-19 cases in Canada are in long-term care settings, they
account for 80% of deaths — the worst outcome globally. Moreover, with no national standards for long-term care,
there are many variations across Canada in the availability and quality of service.iii We recommend that you lead the
development of pan-Canadian standards for equal access, consistent quality, and necessary staffing, training and
protocols for the long-term care sector, so it can be delivered safely in home, community, and institutional settings,
with proper accountability measures.
Meet the health-care needs of our aging population
Population aging will drive 20% of increases in health-care spending over the next years, which amounts to an
additional $93 billion in spending.iv More funding will be needed to cover the federal share of health-care costs to
meet the needs of older adults. This is supported by 88% of Canadians who believe new federal funding measures
are necessary.v That is why we are calling on the federal government to address the rising costs of population aging
by introducing a demographic top-up to the Canada Health Transfer. This would enhance the ability of provinces and
territories to meet the needs of Canada’s older adults and invest in long-term care, palliative care, and community
and home care.
4.Strengthen Canada’s National Anti-Racism Strategy
Anti-Black racism exists in social structures across Canada. Longstanding, negative impacts of these structural
determinants of health have created and continue to reinforce serious health and social inequities for racialized
communities in Canada. The absence of race and ethnicity health-related data in Canada prevents identification of
further gaps in care and health outcomes. But where these statistics are collected, the COVID-19 pandemic has
exploited age-old disparities and led to a stark over-representation of Black people among its victims. We are calling
for enhanced collection and analysis of race and ethnicity data as well as providing more funding under Canada’s
National Anti-Racism Strategy to address identified health disparities and combat racism via community-led
5. Improve access to primary care
Primary care is the backbone of our health-care system. However, according to a 2019 Statistics Canada surveyvi,
almost five million Canadians do not have a regular health care provider. Strengthening primary care through a teambased,
interprofessional approach is integral to improving the health of all people living in Canada and the
effectiveness of health service delivery. We recommend creating a one-time fund of $1.2 billion over four years to
Page 3 of 4
expand the establishment of primary care teams in each province and territory, with a special focus in remote and
underserved communities, based on the Patient’s Medical Home visionvii.
6. Implement a universal single-payer pharmacare program
People across Canada, especially those who are vulnerable, require affordable access to prescription medications that
are vital for preventing, treating and curing diseases, reducing hospitalization and improving quality of life.
Unfortunately, more than 1 in 5 Canadians reported not taking medication because of cost concerns, which can lead
to exacerbation of illness and additional health-care costs. We recommend a comprehensive, universal, public system
offering affordable medication coverage that ensures access based on need, not the ability to pay.
7.Increase mental health funding for health-care professionals
During the first wave of COVID-19, 47% of health-care workers reported the need for psychological support. They
described feeling anxious, unsafe, overwhelmed, helpless, sleep-deprived and discouraged.viii Even before COVID-
19, nurses, for instance, were suffering from high rates of fatigue and mental health issues, including PTSD.ix
Furthermore, health-care workers are at high risk for significant work-related stress that will persist long after the
pandemic due to the backlog of delayed care. Immediate long-term investment in multifaceted mental health supports
for health-care professionals is needed.
We look forward to continuing to work with you and your caucus colleagues on transforming the health of people in
Canada and the health system.
Tim Guest, M.B.A., B.Sc.N., RN
Canadian Nurses Association (CNA)
Tracy Thiele, RPN, BScPN, MN,
Canadian Federation of Mental Health
Lori Schindel Martin, RN, PhD,
Canadian Gerontological Nursing
E. Ann Collins, BSc, MD
Canadian Medical Association (CMA)
Canadian Support Workers Association
Dr. Cheryl L. Cusack RN, PhD
Community Health Nurses of Canada
Lenora Brace, MN, NP
Nurse Practitioner Association of
~ r. Cheryl
Hon. Chrystia Freeland, Minister of Finance
Hon. Patty Hajdu, Minister of Health
Hon. Deb Schulte, Minister of Seniors
Hon. Navdeep Bains, Minister of Innovation, Science and Industry
Ian Shugart, Clerk of the Privy Council and Secretary to Cabinet
Dr. Stephen Lucas, Deputy Minister of Health
Dr. Theresa Tam, Chief Public Health Officer of Canada
Submission prepared by the CMA – Quebec office
Valuing Caregivers and Recognizing Their Contribution to Quebec’s Health
Bill 56, An Act to recognize and support caregivers and amend to various legislative provisions
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
Table of contents
Introduction ....................................................................................................................... 2
About the CMA .............................................................................................................. 2
National policy on caregivers and home care ................................................................ 2
Importance of caregivers in Quebec .............................................................................. 3
CMA’s observations on Bill 56 .......................................................................................... 3
Definition of informal caregivers .................................................................................... 4
Better financial support for family caregivers ................................................................. 4
More respite for caregivers ............................................................................................ 4
Supporting caregivers through virtual care .................................................................... 5
Meeting caregivers’ training needs ................................................................................ 5
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
About the CMA
Founded in Quebec city in 1867, the Canadian Medical Association (CMA) unites the medical profession in Canada to improve the health of Canadians and strengthen the various health care systems. Speaking on behalf of the medical profession, the CMA stands for professionalism, integrity and compassion. The CMA and its Quebec office complement and collaborate with Quebec’s existing medical bodies.
The CMA has in recent years defined the need to improve seniors’ care and well-being as a priority. Optimizing the performance of our health care system is largely dependent on our ability to improve the care provided to our seniors. The work done by the CMA includes seeking a coordinated national seniors’ health care strategy, seeking a United Nations convention on the human rights of older persons, and researching policies to support seniors and their caregivers.
The CMA has also proposed solutions and recommendations to federal authorities: that the federal government ensure that the provinces’ and territories’ health care systems meet the care needs of their aging populations by means of a demographic top-up to the Canada Health Transfer, and that the federal government create a Seniors Care Benefit that would be an easier, fairer and more effective way to support caregivers and care receivers alike.
The CMA applauds the government of Quebec’s commitment to “making known the contribution and commitment of caregivers and supporting them in their role.” For a number of years, the CMA has been calling for greater recognition of caregivers’ contribution to the health care system as partners in health care delivery.
By recognizing caregivers in its legislation, Quebec is leading the way as the second Canadian province, after Manitoba, to grant legal status to these essential persons.
National policy on caregivers and home care According to the CMA, it is vital that the government of Quebec consider the situation of caregivers, but it is also important to recognize the wider context in which this bill has been proposed. Firstly, we recognize and strongly suggest that a rethink of how long-term care is dispensed in Quebec is needed. For example, we believe that a rethinking of senior care in residential and long-term care homes (CHSLDs) is needed. This is an area that needs reform, and the CMA looks forward to commenting on the draft bill that will be introduced by the government of Quebec on this matter in the fall. In order to properly support our seniors, the CMA supports a major and urgent change to home care and community care. According to a new study conducted by Campaign Research Inc. on behalf of Home Care Ontario, almost all seniors in Ontario (91%) wish to remain in their own homes for as long as possible.1 We believe that this figure is similar among Quebec seniors.
A good example of aging in place is Denmark, which has implemented a number of progressive policies such as: increasing investment in community care to support seniors at home; at least one preventive home visit per year for all seniors age 75 and
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
up; and a freeze on the construction of new long-term care homes that has been in pace for close to 20 years. These types of changes require better support to improve home services and new measures to support caregivers. A recent report by the Canadian Institute for Health Information indicates that 96% of long-term care recipients have an unpaid caregiver and that one third of them are distressed. The report also notes that caregivers who are distressed spend an average of 38 hours a week providing care—the equivalent of a full-time job.2
Importance of caregivers in Quebec
In 2016, the demographic portrait of caregivers in Quebec indicated that 35% of Quebecers, or 2.2 million people, provided care to a senior. Of these, around 15% acted as caregivers for more than 10 hours a week. With the aging of the population—including the senior and caregiver population—set to accelerate in the coming years and decades, caregivers’ unpaid working hours will increase significantly. In Canada, according to a 2011 University of Alberta study, close to 80% of all assistance to recipients of long-term care was provided by family caregivers. This represents a contribution of over five billion dollars’ worth of unpaid services for the public health network.3 We should also note that the pandemic has highlighted the importance of caregivers and of their contributions to the health system and the services provided to seniors. As many health care services were closed during the pandemic, caregivers have been asked to work twice as hard and play an even bigger role, which has placed these individuals under even more stress than usual. We believe there is no better time to acknowledge the contributions of caregivers. Now it’s time to take action. We need to learn the lessons from the first wave of the pandemic and avoid the horrors of potential subsequent waves. According to Statistics Canada, seniors in Quebec are more likely to live alone than seniors in other provinces. It is important to note that many caregivers do not live with the person they are caring for. In addition, many seniors live alone and do not have a caregiver.
CMA’s observations on Bill 56
Caregivers are the backbone of our health care system. They provide in-home care as well as care in hospitals, homes for seniors and CHSLDs. They deserve all the support we can give them. Unfortunately, the measures in place to support caregivers in Quebec and elsewhere in Canada are inadequate. Other countries have been doing a lot more and are way ahead of us on this issue.
The CMA supports the main objectives of Bill 56. We commend the government for recognizing the important contribution caregivers make in our society. The CMA supports the creation of a committee to monitor government action and a committee of partners concerned by caregiver support, and also supports the creation of a Quebec observatory on informal caregiving.
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
Definition of caregivers
The pandemic has revealed a number of shortcomings in our health care system. One of these shortcomings is the lack of support and services provided to seniors during lockdowns of health care facilities, CHSLDs and senior centres. We must provide better support to seniors during these lockdowns. The Canadian Foundation for Healthcare Improvement (CFHI) and a consulting group have determined a number of specific steps to guide the examination of policies, including reviewing policies on family presence as well as the participation of patients and family members and caregiver partners. The CFHI also indicated that it is important to distinguish between family caregivers, who are essential partners in care, and visitors.4 The role of family caregivers should be officially recognized throughout the delivery of care. The CMA is pleased to note that this was the case with the recent action plan for the second wave of the pandemic.5
Better financial support for family caregivers
Seniors and their caregivers are an important and growing segment of the population. Family caregivers often provide funding for their family members’ home and long-term care. These added expenses can also coincide with the caregiver’s withdrawal from the workforce in order to provide care. Caregivers carry many responsibilities, including financial ones. It is estimated that private expenditures for seniors’ care will increase 150% faster than available household income between 2019 and 2035.6
Given their enormous contributions, caregivers need help in the form of financial support, education, peer support and respite care.
The CMA recommends:
1. Implementing a caregivers’ allowance to deal with increased home care expenses (similar to the family allowance); a caregiver’s allowance exists in Nova Scotia7 and the United Kingdom8
2. An increased tax credit for caregivers
More respite for caregivers
The CMA supports the desire of the Minister Responsible for Seniors and Informal Caregivers to “ensure that more seniors are able to stay at home.” Indeed, the vast majority of seniors remain at home (93.2%),9 even though many are dealing with reduced autonomy.
Caregivers are essential wellness supports for seniors. However, these caregivers are at risk of developing health problems such as stress, anxiety and exhaustion. They need a complete range of support services to prevent health problems. Even though the CMA applauds the refundable tax credit announced in Quebec’s 2020–2021 budget, we believe that the draft bill should include concrete measures to provide greater respite to caregivers.
The CMA recommends:
1. Increasing the tax credit for caregiver respite
2. Increasing resources for caregiver respite, such as respite and psychological support centres, and the rollout of respite homes for caregivers across the province
3. Increasing home support services for seniors and caregivers
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
Supporting caregivers through virtual care
New technologies such as telemedicine and telehealth offer quick access to health care while eliminating travel and related expenses. In February 2020, the CMA, the Royal College of Physicians and Surgeons of Canada, and the College of Family Physicians of Canada created a framework for expanding virtual medical services in Canada, identifying the national standards, legislation and policy that must be put in place. As we have seen during the pandemic, telemedicine and telehealth can play an important role in improving seniors’ access to primary care.
Several recommendations have come from the Report of the Virtual Care Task Force, such as:
1. Maintaining the fee schedule for virtual care that was put in place for the COVID-19 pandemic
2. Simplifying the licensing system to allow the provision of virtual care throughout the country
3. Integrating virtual care into physician learning
4. Creating national standards for patients’ access to health information10
The CMA also recognizes the need to improve digital health literacy. Accordingly, we have asked the federal government to recognize and support the adoption of virtual care and address inequities in access to digital health services by creating a digital health care knowledge bank and accelerating the expansion of high-speed internet services to the entire Canadian population.
Meeting caregivers’ training needs
Another key support element for caregivers is the provision of accessible training.
Caregiver training must comprise a significant element of the government’s action plan, particularly with respect to our capacity to respond more effectively to the second wave of the pandemic. The CMA is encouraged that the government’s action plan recognizes the important role that caregivers play in supporting seniors and the fact that their safety must not be compromised: “Maintain secure access to CHSLD and RPA facilities for family and informal caregivers.”11
The CMA looks forward to developing solutions with government authorities and offers its full cooperation with respect to recommendations on the national policy, action plans and the situation of caregivers in Quebec.
One of the objectives of the CMA in Quebec is to disseminate knowledge, skills and best practices in senior care from other Canadian and international regions.
The CMA is ready and willing to work with governments, caregivers and health care providers so that caregivers may prosper along with the people they care for.
600 De Maisonneuve Blvd. West, Suite 500, Montréal, Quebec H3A 3J2
1 Home Care Ontario. New Poll Shows Over 90% of Ontario Seniors Want to Live at Home as They Age, and Want Government to Invest to Help Them Do It. August 7, 2020. https://www.newswire.ca/news-releases/new-poll-shows-over-90-of-ontario-seniors-want-to-live-at-home-as-they-age-and-want-government-to-invest-to-help-them-do-it-857341964.html.
2 Canadian Institute for Health Information. 1 in 3 unpaid caregivers in Canada are distressed. August 6, 2020. https://www.cihi.ca/en/1-in-3-unpaid-caregivers-in-canada-are-distressed.
3 Fast, J., lero, D., Duncan, K., and coll. Employment consequences of family/friend caregiving in Canada. Edmonton: Research on Aging, Policies and Practice, University of Alberta, 2011.
4 Canadian Foundation for Health care Improvement. Re-Integration of Family Caregivers as Essential Partners in Care in a Time of COVID-19. July 8, 2020. https://www.cfhi-fcass.ca/about/news-and-stories/news-detail/2020/07/08/re-integration-of-family-caregivers-as-essential-partners-in-care-in-a-time-of-covid-19.
5 Government of Quebec, 2020. COVID-19: Action Plan for a Second Wave. https://publications.msss.gouv.qc.ca/msss/fichiers/2020/20-210-257W.pdf.
6 The Conference Board of Canada (2019). Measures to Better Support Seniors and Their Caregivers. https://www.cma.ca/sites/default/files/pdf/health-advocacy/Measures-to-better-support-seniors-and-their-caregivers-e.pdf.
9 Statistics Canada, 2016 Census.
10 Canadian Medical Association, College of Family Physicians of Canada and Royal College of Physicians and Surgeons of Canada. Virtual Care: Recommendations For Scaling Up Virtual Medical Services. Report of the Virtual Care Task Force. February 2020. https://www.cma.ca/sites/default/files/pdf/virtual-care/ReportoftheVirtualCareTaskForce.pdf.
11 Government of Quebec, 2020. COVID-19: Action Plan for a Second Wave. https://publications.msss.gouv.qc.ca/msss/fichiers/2020/20-210-254W-A.pdf.
Thank you Madam Chair and Committee members for the opportunity to speak to you today. I am Briane Scharfstein, Associate Secretary General at the Canadian Medical Association (CMA) and a family physician by training. I am speaking on behalf of the CMA and our 67,000 physician members across the country.
We commend the Senate for striking this Committee. We are concerned that the aging population has not received sufficient national policy attention. With regard to today's discussion I would note that the CMA has advocated for the elimination of mandatory retirement and we are pleased to see that in general, provincial jurisdictions have eliminated mandatory retirement based on what has become an arbitrary age cutoff. With some obvious exceptions, such as athletics, competence is not related to age per se for most areas of human endeavour. Where human activity may pose risk to the safety of others we believe that the best approach is to develop evidence-based tools and procedures that can be used to assess competence on an ongoing basis.
While physicians play a significant role on a variety of fronts related to aging, I am going to focus my remarks on two specific areas:
* Ensuring the competence of physicians; and
* Fitness to operate motor vehicles and the role of physicians.
Turning first to the competence of the medical workforce, physicians are making diagnoses and performing procedures on a daily basis, both of which may entail a significant amount of risk for our patients. I would add that this is being done in an era where medical knowledge is rapidly increasing.
As a profession that continues to enjoy a high degree of delegated self-regulation, we recognize the importance of ensuring that physicians are and remain competent across the medical career lifecycle. This entails both an individual and collective obligation to:
* engage in lifelong learning;
* recognize and report issues of competence in one's self and one's peers; and
* participate in peer review processes to assure ongoing competence.
First and foremost, physicians have an individual ethical and professional obligation to maintain their competence throughout their career lifecycle. The CMA Code of Ethics calls on physicians to:
* practise the art and science of medicine competently, with integrity and without impairment;
* engage in lifelong learning to maintain and improve professional knowledge skills and attitudes;
* report to the appropriate authority any unprofessional conduct by colleagues; and
* be willing to participate in peer review of other physicians and to undergo review by your peers1
I would stress the importance of peer review in medicine, which is one of the defining characteristics of a self-regulating profession. Simply put, physicians are expected to hold themselves and their colleagues accountable for their behaviour and for the outcomes they achieve on behalf of their patients.2
The individual accountability that physicians have to themselves and to each other is reinforced by a collective accountability for lifelong learning and peer review that is mandated by the national credentialing bodies and by the province/territorial licensing bodies.
With regard to lifelong learning, both national credentialing bodies require evidence of ongoing continuing professional development as a condition of maintaining credentials. The College of Family Physicians of Canada operates a Maintenance of Proficiency program that requires its certificants to earn 250 credits over five years.3 The Royal College of Physicians and Surgeons of Canada operates a Maintenance of Certification Program that requires its Fellows to achieve 400 credits over a five year period with a minimum 40 in any single year.4
The Canadian Medical Protective Association, the mutual defence organization that provides liability coverage for the vast majority of physicians in Canada also plays a role in identifying high risk areas of medical practice and providing a range of educational materials and programs designed to mitigate such risk.5
Each province and territory has a licensing body - usually known as a College of Physicians and Surgeons that is established to protect the public interest. These colleges operate mandatory peer review programs that ensure that physician's practices are reviewed at regular intervals. These programs typically involve a review of the physician's practice profile based on administrative data, a visit to the physician's office by a medical colleague in a similar type of practice and an audit of a sample of patient charts, followed by a report with recommendations.
In addition, most jurisdictions now have or will soon have in place a program pioneered in Alberta that provides a 360o assessment by administering questionnaires to a sample of a physician's patients, colleagues, and co-worker health professionals. These probe several aspects of competence and reports are provided back to the physician.6
Peer review is even more rigorous in the health care institutions where physicians carry out practices and procedures that involve the greatest potential risk to patients. Physicians are initially required to apply for hospital privileges that are reviewed annually by a credentials committee. These committees have the authority to renew, modify or cancel a physician's privileges. In between annual reviews a physician's day-to-day performance is subject to review by a variety of quality assurance processes and audit/review committees such as morbidity and mortality. Health care institutions in turn are subject to regular scrutiny by the Canadian Council on Health Services Accreditation which would include the oversight of physician practice among its review parameters.
In summary, the medical profession subscribes to the notion that competence is something that must regularly be reviewed and enhanced across the medical career life cycle, and that such reviews and assessments must be grounded in evidence that is gathered from peers and other validated tools.
Turning to our patients, one area that our members are regularly called on to assess competence is the determination of medical fitness to operate motor vehicles. To assist physicians in carrying out this societal responsibility, the CMA recently released our 7th edition of the Driver's Guide.7 What you will note about this 134 page guide is that the section on aging is only 3 pages long. The focus of the guide is on how substances such as alcohol and medications and a range of disease conditions such as cardiovascular and cerebrovascular disease may impose risks on fitness to operate a range of motor vehicles including automobiles, off-road vehicles, planes and trains. It provides graduated guidelines that relate to the severity and stage of the condition. As is noted in the section on aging, while the guide acknowledges the greater prevalence of health conditions in older age groups and hence the higher crash rates among the 65 and over age group, it states that the high crash rates in older people cannot be explained by age-related changes alone. In fact, by avoiding unnecessary risk and possessing the most experience, healthy senior drivers are among the safest drivers on the road. Rather, it is the presence and accumulation of health-related impairments that affect driving that is the major cause of crashes for older people. Because older age per se does not lead to higher crash rates, age-based restrictions on driving are not supportable.
Rather than focusing on arbitrary age cutoffs what are required are evidence-based tools such as the Driver's Guide that can be used to detect and assess conditions that may present at any point in the life cycle.
I would like to return to the physician workforce and the practical implications of arbitrary age cutoffs. As you may know Canada is experiencing a growing shortage of physicians - the effects of which are about to be compounded as the first of the baby boomers turn 65 in 2011. Currently we rank 24th out of the 30 OECD countries in terms of physician supply per 1,000 population - our level of 2.2 physicians per 1,000 is one third below the OECD average of 3.0.
As of January 2008, according to the CMA physician Master File there are just over 8,200 licensed physicians in Canada who are aged 65 or older. They represent more than 1 in 10 (13%) of all licensed physicians. Moreover, they are very active; they work on average more than 40 hours per week and in addition more than 40% of them still have on-call responsibilities each month. These doctors make vital contributions to our health care system.
In conclusion, the CMA believes that the public interest is best served by ensuring that all competent physicians, regardless of age, are able to practice medicine. Artificial barriers to practice based on age are simply discriminatory and counter productive in an era of health human resource shortages.
Finally Madam Chair, we hope that the CMA will be invited back to appear before your committee. We have long been concerned with the access of the senior population to health care services and I will leave you with a copy of our policy on principles of medical care of older persons.8 We also hope you will examine the issue of long-term care which has had little if any national policy attention. I will also leave you with a copy of our recent technical background report on pre-funding of long-term care that we tabled at the Federal Minister of Finance's Roundtable in November 2007.9
Thank you again for this opportunity and I would be pleased to answer any questions.
1 Canadian Medical Association. CMA Code of ethics.(Update 2004). http://policybase.cma.ca/PolicyPDF/PD04-06.pdf. Accessed 01/23/08.
2 Canadian Medical Association. Medical professionalism (Update 2005). http://policybase.cma.ca/dbtw-wpd/Policypdf/PD06-02.pdf. Accessed 01/23/08.
3 College of Family Physicians of Canada. Mainpro(r)Maintenance of Proficiency. http://www.cfpc.ca/English/cfpc/cme/mainpro/maintenance%20of%20proficiency/default.asp?s=1. Accessed 01/23/08.
4 Royal College of Physicians and Surgeons of Canada. Maintenance of Certification Program. http://rcpsc.medical.org/opd/moc-program/index.php. accessed 01/23/08.
5 Canadian Medical Protective Association. Risk management @ a glance. http://www.cmpa-acpm.ca/cmpapd03/pub_index.cfm?FILE=MLRISK_MAIN&LANG=E. Accessed 01/23/08.
6 College of Physicians and Surgeons of Alberta. Physician Achievement Review Program. http://www.cpsa.ab.ca/collegeprograms/par_program.asp. Accessed 01/23/08.
7Canadian Medical Association. Determining medical fitness to operate motor vehicles. CMA Driver's Guide 7th edition.Ottawa, 2006.
8 Canadian Medical Association. Principles for medical care of older persons. http://policybase.cma.ca/dbtw-wpd/PolicyPDF/PD00-03.pdf. Accessed 01/23/08.
9 Canadian Medical Association. Pre-funding long-term care in Canada: technical backgrounder. Presentation to the Federal Minister of Finance's roundtable, Oshawa, ON, November 23, 2007.
The Canadian Medical Association (CMA) welcomes the opportunity to provide comments to the Senate Committee on Legal and Constitutional Affairs concerning its study of Bill C-2 (An Act to amend the Criminal Code and to make consequential amendments to other Acts). We will confine our comments to the portion of the proposed legislation that relates to impaired driving.
Canada's physicians support measures aimed at reducing the incidence of drug-impaired driving. We believe impaired driving, whether by alcohol or another drug, to be an important public health issue for Canadians that requires action by all governments and other concerned groups.
Published reports indicate that the prevalence of driving under the influence of cannabis is on the rise in Canada. We note that:
* Results from the Canadian Addictions Survey suggest that 4% of the population have driven under the influence of cannabis in the past year, an increase from the 1.5% in 2003 and that rates are higher among young people.1
* It was estimated that in 2003, 27.45% of traffic fatalities involved alcohol, 9.15% involved alcohol and drugs, and 3.66% involved drugs alone while 13.71% of crash injuries involved only alcohol, 4.57% involved alcohol and drugs, and 1.83% involved drugs alone.2
* In a 2002 survey, 17.7% of drivers reported driving within 2 hours of using a prescribed medication, over-the-counter remedy, marijuana, or other illicit drug during the past 12 months.
* These results suggest that an estimated 3.7 million Canadians drove after taking some medication or drug that could potentially affect their ability to drive safely.
* The most common drugs used were over-the-counter medications (15.9%), prescription drugs (2.3%), marijuana (1.5%), and other illegal drugs (0.9%).
* Young males were most likely to report using marijuana and other illegal drugs.
* While 86% of the drivers were aware that a conviction for impaired driving results in a criminal record, 66% erroneously believed that the penalties for drug-impaired driving were less severe than those for alcohol-impaired driving. In fact, the penalties are identical.
* Over 80% of drivers agreed that drivers suspected of being under the influence of drugs should be required to participate in physical coordination testing for drug impairment. However, only about 70% of drivers agreed that all drivers involved in a serious collision or suspected of drug impairment should be required to provide a blood sample.3
The CMA has, on several occasions, provided detailed recommendations on legislative changes concerning impaired driving. In 1999, the CMA presented a brief to the House of Commons Standing Committee on Justice and Human Rights during its review of the impaired driving provisions of the Criminal Code. While our 1999 brief focused primarily on driving under the influence of alcohol, many of the recommendations are also relevant to the issue of driving under the influence of drugs.
In June 2007, the CMA provided comments to the Standing Committee on Justice and Human Rights of the House of Commons during their study of Bill C-32 (An Act to amend the Criminal Code (impaired driving) and to make consequential amendments to other Acts) which was later incorporated in the omnibus Bill now before your Committee.
Last year, the CMA published the 7th edition of its guide, Determining Medical Fitness to Operate Motor Vehicles. It includes chapters on the importance of screening for alcohol or drug dependency and states that the abuse of such substances is incompatible with the safe operation of a vehicle. This publication is widely viewed by clinical and medical-legal practitioners as the authoritative Canadian source on the topic of driver competence.
While changing the Criminal Code is an important step, the CMA believes further actions are also warranted. In our 2002 presentation to the Special Senate Committee on Illegal Drugs, the CMA put forth our long standing position regarding the need for a comprehensive long-term effort that incorporates both deterrent legislation and public awareness and education campaigns. We believe such an approach, together with comprehensive treatment and cessation programs, constitutes the most effective policy in attempting to reduce the number of lives lost and injuries suffered in crashes involving impaired drivers.
Drug-impaired drivers may be occasional users of drugs or they may also suffer from substance dependence, a well-recognized form of disease. Physicians should be assisted to screen for drug dependency, when indicated, using validated instruments. Government must create and fund appropriate assessment and treatment interventions.
Physicians can assist in establishing programs in the community aimed at the recognition of the early signs of dependency. These programs should recognize the chronic, relapsing nature of drug addiction as a disease, as opposed to simply viewing it as criminal behaviour.
While supporting the intent of the proposed legislation, the CMA urges caution on several significant issues, with regard to Clause 20 that amends the act as follows:
254.1 (1) The Governor in Council may make regulations
(a) respecting the qualifications and training of evaluating officers;
(b) prescribing the physical coordination tests to be conducted under paragraph 254(2)(a); and
(c) prescribing the tests to be conducted and procedures to be followed during an evaluation under subsection 254(3.1).
CMA contends that it is important that medical professionals and addiction medicine specialists in particular, should be consulted regarding the training offered to officers to conduct roadside assessment and sample collection.
Provisions in the Act conferring upon police the power to compel roadside examination raises the important issue of security of the person and the privacy of health information. As well, information obtained at the roadside is personal medical information and regulations must ensure that it be treated with the same degree of confidentiality as any other element of an individual's medical record. Thus, the CMA would respectfully submit that Clause 25 of Bill-C2 on the issue of unauthorized use or disclosure of the results needs to be strengthened because the wording is too broad, unduly infringes privacy and shows insufficient respect for the health information privacy interests at stake.
For instance, clause 25(2) would permit the use, or allow the disclosure of the results "for the purpose of the administration or enforcement of the law of a province". This latter phrase needs to be narrowed in its scope so that it would not, on its face, encompass such a broad category of laws.
Moreover, clause 25(4) would allow the disclosure of the results "to any other person, if the results are made anonymous and the disclosure is made for statistical or other research purposes" CMA would expect the federal government to exercise great caution in this instance, particularly since the results could concern individuals who are not actually convicted of an offence.
One should query whether the Clause 25(4) should even exist in a Criminal Code as it would not appear to be a matter required to be addressed. If it is, then CMA would ask the government to conduct a rigorous privacy impact assessment on these components of the Bill, studying in particular, such matters as sample size, degree of anonymity, and other privacy related issues, especially given the highly sensitive nature of the material.
CMA would ask whether clause 25(5) should specify that the offence for improper use or disclosure should be more serious than a summary conviction. Finally, it is important to base any roadside testing methods and threshold decisions on robust biological and clinical research.
CMA also notes with interest Clause 21, specifically the creation of a new offence of being "over 80" (referring to 80mg of alcohol in 100ml of blood, or a .08 blood alcohol concentration level or BAC) and causing an accident that results in bodily harm which will carry a maximum sentence of 10 years and life imprisonment for causing an accident resulting in death. (Clause 21)
We would also urge the Committee to take the opportunity that the review of this proposed legislation provides to recommend to Parliament a lower BAC level. Since 1988 the CMA has supported 50 mg% as the general legal limit. Studies suggest that a BAC limit of 50 mg% could translate into a 6% to 18% reduction in total motor vehicle fatalities or 185 to 555 fewer fatalities per year in Canada.4 A lower limit would recognize the significant detrimental effects on driving-related skills that occur below the current legal BAC.5
In our 1999 response to the Standing Committee on Justice and Human Rights' issue paper on impaired driving6 and again in 2002 when we joined forces with Mothers Against Drunk Driving (MADD), CMA has consistently called for the federal government to reduce Canada's legal BAC to .05. Canada continues to lag behind countries such as Austria, Australia, Belgium, Denmark, France and Germany, which have set a lower legal limit. 7
CMA expressed the opinion that injuries and deaths resulting from impaired driving must be recognized as a major public health concern. Therefore we once again recommend lowering the legal BAC limit to 50 mg%. or .05%.
We also wanted to note our support for Clause 23 which addresses the issue of liability by extending the existing umbrella of immunity for qualified medical practitioners to the new provision under 254(3.4)
23. Subsection 257(2) of the Act is replaced by the following:
(2) No qualified medical practitioner by whom or under whose direction a sample of blood is taken from a person under subsection 254(3) or (3.4) or section 256, and no qualified technician acting under the direction of a qualified medical practitioner, incurs any criminal or civil liability for anything necessarily done with reasonable care and skill when taking the sample.
Finally, CMA believes that comprehensive long-term efforts that incorporate deterrent legislation, such as Bill C-2, must be accompanied by a public awareness and education strategy. This constitutes the most effective long-term approach to reducing the number of lives lost and injuries suffered in crashes involving impaired drivers. The CMA supports this multidimensional approach to the issue of the operation of a motor vehicle regardless of whether impairment is caused by alcohol or drugs.
Again, the CMA appreciates the opportunity to provide input into the legislative proposal on drug-impaired driving. We stress that these legislative changes alone would not adequately address the issue of reducing injuries and fatalities due to drug-impaired driving, but support their intent as a partial, but important measure.
Brian Day, MD
1 Bedard, M, Dubois S, Weaver, B. The impact of cannabis on driving, Canadian Journal of Public Health, Vol 98, 6-11, 2006
2 G. Mercer, Estimating the Presence of Alcohol and Drug Impairment in Traffic Crashes and their Costs to Canadians: 1999 to 2003 (Vancouver: Applied Research and Evaluation Services, 2005).
3 D. Beirness, H. Simpson and K. Desmond, The Road Safety Monitor 2002: Drugs and Driving (Ottawa: Traffic Injury Research Foundation, 2003). Online: www.trafficinjuryResearch.com/whatNew/newsItemPDFs/RSM_02_Drugs_and_ Driving.pdf
4 Mann, Robert E., Scott Macdonald, Gina Stoduto, Abdul Shaikh and Susan Bondy (1998) Assessing the Potential Impact of Lowering the Blood Alcohol Limit to 50 MG % in Canada. Ottawa: Transport Canada, TP 13321 E.
5 Moskowitz, H. and Robinson, C.D. (1988). Effects of Low Doses of Alcohol on Driving Skills: A Review of the Evidence. Washington, DC: National Highway Traffic Safety Administration, DOT-HS-800-599 as cited in Mann, et al., note 8 at page 12-13
6 Proposed Amendments to the Criminal Code of Canada (Impaired Driving): Response to Issue Paper of the Standing Committee on Justice and Human Rights. March 5, 1999
7 Mann et al
On behalf of the Canadian Medical Association (CMA), I want to thank you for the opportunity to provide the following information to the House of Commons Standing Committee on Industry, Science and Technology during its review of the service sector in Canada. The committee's study of the strengths and challenges facing this sector, overall employment percentage, overall average of salaries across the sector its impact on Canada's overall economy and the role of the Government of Canada in strengthening this sector comes at an opportune time.
CANADA'S HEALTH SERVICES SECTOR
Canada's health services sector is facing a critical shortage of physicians and other health care professionals and the CMA and our over 67,000 physician members are pleased to have the opportunity to present practical solutions within the jurisdiction of the federal government - working collaboratively with provincial/territorial governments and other health system stakeholders.
Health care delivery in Canada is a $160 billion industry, representing over 10% of our country's gross domestic product (GDP).1 The 30,120 physicians' offices across Canada make important contributions to our economy. In 2003, the latest year for which data are available, offices of physicians employed 142,000 Canadians and contributed $11.6 billion to the Canadian economy.2 This represents almost 39 per cent of all Health Service Delivery establishments, and almost 11% of all HSD employees. As a standard measure of economic productivity, physician offices report the highest levels of GDP per employee within the Health Service Delivery sector. On this measure, they are approximately twice as productive as other components of Health Service Delivery.
There are simply not enough physicians to continue providing the quality health care that Canadians expect and deserve. Here are the facts:
- Almost 5 million Canadians do not have access to a family physician;
- By 2018 an additional 4.5 million Canadians could be without a doctor;
- Canada ranks 24th in Organisation for Economic Co-operation and Development (OECD) nations in terms of physicians-per-population ratio. Canada would need 26,000 more doctors right now to meet the OECD average;
- Canada spends only a third of the OECD average on information technology (IT) and diagnostic equipment in our hospitals; and
- Canada has the highest hospital occupancy rate of all OECD countries and among the highest waits for access to specialty care services.
The lack of physicians and other health care providers has resulted in restricted access to health care services and the growth of wait times for necessary medical procedures. In January 2008, CMA released new research by the Centre for Spatial Economics that proved that, in addition to the human health cost, waiting for care results in dramatic and excessive costs to our economy. Researchers addressed just four priority areas targeted in the 2004 First Ministers Health Accord. They used government and other data to determine how many Canadians were waiting longer than the maximum medical consensus established by the Wait Time Alliance.
Selected for analysis were: joint replacement, cataract surgery, heart bypass grafts, and MRI scans. Costs, as calculated for all provinces varied from $2,900 to over $26,000 per patient. The cumulative cost of waiting in 2007, for treatment in just 4 areas, was $14.8 billion.
This reduced economic activity lowered government revenues in 2007 by $4.4 billion. That is equivalent to over 1/3rd of the total Ontario health budget. The reduction in economic activity included the impact of the patient's inability to work while waiting, and direct losses from decreased production of goods and services, reduced income, and lowered discretionary spending.
It is important to note that the figure of 14.8 billion dollars is based only on patients that exceed designated maximum waiting times in just 4 clinical areas. In the example of hip replacements, the research only factored in costs for waits that exceed 6 months. Of those waiting longer than the maximum recommended time, average waits were 1 year for hip and knee replacement surgery, 7 months for cataract surgery, and twice maximum for heart bypass surgery. Those who didn't make the MRI target waited an average of 12 weeks.
Reduced economic activity included informal caregiver costs. These costs are generated when caregivers reduce work hours to care for family members on wait lists, or attend appointments with family members. Patients languishing on wait lists also incur additional costs for drug and other treatments that timely care would eliminate.
Estimates in this study are extremely conservative. They address only the wait time to treatment after a specialist's consultation and recommendation. And exclude the growing, and significant costs of waiting to see the GP or specialist. They do not include anyone who is not working. They do not include the costs, short and long term, of the deterioration that occurs while waiting.
To solve Canada's doctor shortage, the CMA believes governments must:
- Adopt a long-term policy of self-sufficiency to provide Canadians with the health care professionals they need when and where they need them;
- Establish a dedicated health human resource renewal fund to educate, retain and enhance the lives of health care professionals; and
- Invest in health technology, infrastructure and innovation to make our health care system more responsive and efficient.
Over the past decade, there have been increasing concerns that Canada is not producing an adequate number of health providers to meet the growing demand for health services - now and into the future. These concerns have been consistently registered by physicians, nurses, pharmacists, technicians, in addition to other groups that represent other providers and the institutional and heath facilities community.
Furthermore, the policy challenges related to health human resources (HHR) have been identified in several seminal reports - including the Royal Commission on the Future of Health Care in Canada, the Standing Senate Committee on Social Affairs, Science & Technology, and the Health Council of Canada.3
A growing number of health providers are looking to retire over the next decade (or leave the health system all together) relative to the number of trainees who are entering the health system, and at a time where a growing number of Canadians will be turning to the health system for diagnosis and treatment. Over 6% of physicians who responded to the National Physician Survey 20074 said they plan to retire from clinical practice and 1% plan to permanently leave practice for other reasons in the next 2 years. The effect of these changes could mean that, as the baby boom generation gets older, over 4,000 physicians will cease their medical practice within the next 2 years, making it even more difficult for Canadians to find a family physician.
At the same time, the HHR challenges facing Canada's health care system are not unique to our country - over the next decade all western developed countries can expect intensified global competition for talent when it comes to health providers.5
While there are, no doubt, other provider groups who are also concerned about the future supply of health providers, there is a growing national consensus that, in addition to the primary role that the provinces and territories play in supporting the training of health providers across the country, there is a significant, catalytic and strong complementary role for the federal government in the area of health human resources.
CMA, like many health care organizations, is of the view that there is a legitimate role for the federal government to strengthen its working relationship with the provinces and territories, and health providers through the creation of a time-limited, issue-specific and strategically-targeted fund to accelerate training capacity in the health system.
The World Medical Association's ethical guidelines for international recruitment of physicians16 (2003), fully supported by the CMA, recommend that every country "should do its utmost to educate an adequate number of physicians, taking into account its needs and resources. A country should not rely on immigration from other countries to meet its need for physicians."7 However, in reality Canada continues to rely heavily on recruitment of internationally educated health professionals. Approximately one-third of the increase in physician supply each year is due to International Medical Graduates (IMGs) who are either recruited directly to practice or who have taken significant postgraduate medical training in Canada. In nursing, the number of internationally educated nurses applying for licensure is increasing rapidly, almost tripling from 1999 to 2003.
Previous recommendations of the CMA to the House of Commons included improved medium- to longer-term supply projection models; sufficient opportunities for Canadians to train for health professional careers in Canada; and integration of international graduates, who are permanent residents or citizens of Canada, into practice. The CMA recognizes that professionals are working in an increasingly global world in terms of the exchange of scientific information, mutual recognition of qualifications between countries and the movement of people.
The greatest barrier to enhancing Canada's ability to become more self-sufficient, in terms of physician resources, is the capacity of our medical schools. Despite recent increases in enrolment, Canada continues to turn away approximately 3 equally qualified students for every 1 that is accepted into an undergraduate medical program. This has resulted in over 1500 Canadian students, with the financial means to do so, who are training in medical schools outside of Canada.
INTERNATIONAL MEDICAL GRADUATES
In the larger context, Canada's current fertility rate is not sufficient to support self-sufficiency in general in relation to any professions. And, while self-sufficiency in the production of physicians is a desirable goal, it is also important to promote the international exchange of teaching and research, particularly in an increasingly global society. In this regard, IMGs should be considered as a planning component for a sustainable Canadian physician workforce. Historically IMGs have entered the practice of medicine through a variety of routes, which most typically include a recognized period of post-MD training in Canada.
CMA's best estimate is that there are about 400 IMGs newly licensed to practice in Canada each year who have not completed postgraduate training in Canada. In addition, there are another 300 or so who are exiting Canadian postgraduate training programs and heading into practice. In fact, for the past few years, the College of Physicians and Surgeons of Ontario has licensed more IMGs than new Ontario medical graduates.
In recent years, there have been an increasing number of opportunities for IMGs already living in Canada to achieve the required credentials for licensure. The number of ministry-funded IMG postgraduate residents has more than tripled in the past seven years from 294 to 1065 trainees. In 2007, there were almost 1500 IMGs who were qualified to compete in the Canadian Resident Matching Service (CaRMS) match. By the end of the second round, close to 300 had matched and about 60 were placed through other provincial programs.
The federal government should make a clear policy commitment to increasing self-sufficiency in the education and training of health professionals in Canada that would incorporate the following.
- Short term - increase number of community preceptors to train Canadian graduates and assess internationally educated health professionals already living in Canada. Recognition of the time and value of community teaching is needed.
- Medium term - support increased capacity for academic health science centres and other institutions that train health professionals.
- Long term - creation of new academic health science centres to increase capacity for self-sufficiency.
REPATRIATING CANADIAN DOCTORS WORKING ABROAD
It is known that there are thousands of Canadian-trained health professionals practising in the United States and abroad. Between 1991 and 2004, almost 8,000 physicians left Canada (although some 4,000 returned for a net loss of 4,000).8 Of this number, roughly 80% went to the US.9 During the 1990s, approximately 27,000 nurses migrated from Canada to the US.1011 A more recent indicator of nursing outmigration is that in 2006, 943 Canadian-trained Registered Nurses and Licensed Practical Nurses wrote the US licensing board examination for the first time.12 Data for other health professional disciplines are not readily available.
In 2007, with the assistance of the American Medical Association, the Canadian Medical Association (CMA) surveyed all (n=5,156) Canadian-trained physicians practicing in the US who were age 55 or under, with regard to the likelihood of their return to Canada and the importance of various factors that might be incentives to return. A 32% response rate was achieved with a single mailing with no follow-up - this is considered exceptionally high.
While only 13% of respondents indicated that they were likely or very likely to return to Canada, a further 25% were neutral in their opinion. What is more telling is that more than one-half of respondents indicated that they would be willing to be contacted by CMA to explore practice opportunities and provided their contact information for this purpose. When asked about a range of potential incentives to return to Canada, 57% agreed that a relocation allowance would be somewhat or very important.13 It must be stressed, however, that it is clear from the results that a number of factors would need to be taken into consideration, such as practice opportunities. This would also be true of other disciplines; in the case of nursing, nurses will only come back for full-time jobs and healthy work environments.14
Nonetheless, expatriate Canadian medical graduates should be good candidates for recruitment on the basis of the greater likelihood that they will meet Canadian standards for full medical licensure, and it is expected that this would also apply to nursing and other disciplines.
As well, significant progress has been made in restoring and adding capacity to our medical schools but, to achieve self-sufficiency, much more needs to be done. For example, we must try and repatriate Canadian medical students and doctors who are studying and working abroad. There are currently some 1500 Canadian medical students and residents training abroad, we must act now, before things get worse.
During that past few years there have been efforts to enhance national coordination in the health human resources arena. One area of national focus has been the integration of International Medical Graduates, since extended to nursing and other disciplines. There have been several initiatives undertaken in this area such as the establishment of the Canadian Information Centre for International Medical Graduates15 which provides a clearinghouse of information and links to provincial/territorial jurisdictions.
Relocation grants, from $10,000 up to $20,000 could be offered to Canadian-trained physicians practising in the US. It is suggested that advertising be concentrated in and around US cities where Canada maintains a consulate/office (in states with a significant concentration with recruitment candidates) and in major national and selected state health professional journals. The cost of a repatriation secretariat is estimated at $162,500 per year. Assuming that 1,500 health professionals are recruited back over the 3-year period, the total cost would range from $21.5 million to $36.5 million.
This would further translate to a per recruit cost that ranges from $14,325 to $24,325. Even at the high end of the range this would be cost-effective as compared to the total cost of training a practice-entry level graduate of any licensed health professional discipline in Canada.
In light of the foregoing, the CMA has recommended that the federal government should establish a Health Professional Repatriation Program in the amount of $30 million over 3 years that would include the following:
- secretariat within Health Canada that would include a clearinghouse function on issues associated with returning to Canada such as licensure, citizenship and taxation;
- An advertising campaign in the US to encourage health professionals practicing south of the border to return home; and
- A program of one-time relocation grants for health professionals returning to active practice in Canada.
NATIONAL HEALTH HUMAN RESOURCES INFRASTRUCTURE FUND
The implementation of Medicare in Canada in the 1960s required a major investment in the capacity to train more health professionals. The 1966 Health Resources Fund Act played a key role in enabling a significant expansion in training capacity across the provinces for a range of health professionals. Forty years later, Canada faces growing shortages across most health disciplines. Clearly another giant step up is required in the human and physical infrastructure needed to train health professionals if Canadians are to have timely access to care.
During the years of fiscal famine of the 1990s, health professional enrolment was either reduced (e.g., 10% in the case of medicine) or flat-lined. While there have been increases since 2000, we are about to face the double impact of both an aging population as the first of the baby boomers reach 65 in 2011 and aging health professions. For example, more than 1 out of 3 physicians (35%) are aged 55 or older. As mentioned, as many as 4,000 physicians are expected to retire in the next 2 years.
If we are going to have sufficient numbers of health providers to meet the needs of the next few decades, it is imperative to expand the human and physician infrastructure capacity of our health professional education and training system. The federal investments in health human resources over 2003-2005 of some $200 million have been welcome, but fall far short of what is needed.
It is proposed that the federal government implement a National Health Human Resources Infrastructure Fund in the amount of $1 billion over 5 years that would be made available to the provinces/territories on an equal per capita basis, and awarded through a competitive process that would include federal/ provincial/territorial representation with consultation/engagement of health professional organizations. The fund would address the following elements:
1. The direct costs of training providers and developing leaders (e.g., cost of recruiting and supporting more community- based teachers/preceptors).
2. The indirect or infrastructure costs associated with the educational enterprise (e.g., physical plant [housekeeping, maintenance]; support for departments [information systems, library resources, occupational health, etc.]; education offices, and the materials and equipment necessary for clinical practice and practical training.
3. Resources that improve the country's overall data management capacity when it comes to health human resources, and in particular, facilitate the ability to model and forecast health human resource requirements in the face of the changing demand for health services.
Clearly it would be necessary to develop guidelines around the types of expenditures that would be eligible as was done for the 1966 Health Resources Fund, and more recently for the Medical Equipment Fund II.
The federal government should establish a National Health Human Resources Fund in the amount of $1 billion over 5 years to expand health professional education and training capacity by providing funding to support the:
- direct costs of training providers
- indirect or infrastructure costs associated with the educational enterprise
- resources that improve Canada's data collection and management capacity in the area of health human resources.
More than 85% of the health care delivered in Canada occurs within the community. This is the most under-invested segment of the health care delivery system in terms of information technology. Dr. Brian Postl in his June 2006 wait-time report16 to the federal government noted health information technology is essential in improving wait times. He quantified the investment needed at $2.4 billion with the largest portion of this investment ($1.9 billion) targeted to automating physician offices, which are located at the front line of care in community settings and are key to managing and resolving the wait time issue in Canada.
Why invest in physician office automation? Because it will lead to improved productivity from the provider community through more efficient resource usage and through improved coordination in the delivery of care; it will enable labour mobility of health care workers through portability of records; it will support the wait time agenda by improving the flow of timely information; it will build an electronic infrastructure platform to enhance patient care and health research and will provide a direct financing vehicle for the federal government to influence and shape the health care sector.
The federal government has made similar types of infrastructure investment. The CFI Program was established to fund research infrastructure, which consists of the state-of-the-art equipment, buildings, laboratories and databases required to conduct research. Investing in EMR infrastructure will lead to the creation of state of the art clinical environments across Canada, electronic data base of health information and the foundational underpinnings of a health information network to support enhanced population health and health research.
Under this scenario the federal contribution would provide a direct benefit to physicians without any need for provincial or territorial involvement. Second, the federal government could use existing government machinery to manage the program. Third, the federal contribution to infrastructure would only flow after a physician has introduced an EMR into his/her clinic ensuring that the funding is directly tied to building the EMR infrastructure platform.
The recent National Physician Survey notes that some progress is being made across the country to automate community clinics. However without incentives the adoption trend will be incremental and extend over a further 20-year time frame. Financial incentives can shorten the timelines since it addresses one of the main adoption barriers physicians identify.17
Diffusion theory18 of new technologies into any sector of the economy demonstrates that without appropriate incentives it will take approximately 25 years the technology to reach the saturation point of integration. It is estimated that a financial incentive can shorten this timeline by 15 years.
The federal government, over a 5-year time frame, should provide a full tax credit to any physician who takes the steps to automate his or her clinical office. The tax credit would only apply to 1-time costs to establish a state of the art clinical environment. It is estimated, on average, 1-time costs would be $22,000. Total costs of the program if fully subscribed would amount to $880 million.
The health services sector makes significant contributions to the Canadian economy, both in terms of direct stimulus and by keeping Canadians healthy and productive. However, Canada's health services sector is facing a critical shortage of physicians and other health care professionals. By:
- Adopting a long-term policy of self-sufficiency to provide Canadians with the health care professionals they need when and where they need them;
- Establishing a dedicated health human resource renewal fund to educate, retain and enhance the lives of health care professionals;
- Investing in health technology, infrastructure and innovation to make our health care system more responsive and efficient;
the federal government, in partnership with provincial/territorial governments and other health system stakeholders can strengthen this sector. A strong health services sector means healthy Canadians and a vibrant Canadian economy.
Again, on behalf of the Canadian Medical Association, Canada's doctors appreciate the opportunity to provide information to the Committee.
Brian Day, MD
President, Canadian Medical Association
1 National Health Expenditure Trends, 1975-2007. Canadian Institute for Health Information. 2007
2 Source: Business Register (STC 2003) and TIM (Informetrica Limited)
3 The Royal Commission on the Future of Health Care in Canada, November 2002. Senate Standing Committee on Social Affairs, Science & Technology, October 2002. The Health Council of Canada "Modernizing the Management of Health Human Resources in Canada: Identifying Areas for Accelerated Change: November 2005.
4 The National Physician Survey is a major ongoing research project conducted by the College of Family Physicians of Canada, Canadian Medical Association and Royal College of Physicians and Surgeons of Canada that gathers the opinions of all physicians, 2nd year medical residents and medical students from across the country. It is the largest census survey of its kind and is an important barometer of where the country's present and future doctors are on a wide range of critical issues.
5 The Economist, The Battle for BrainPower - A Survey of Talent, October 7, 2006.
7 World Medical Association. The World Medical Association Statement on Ethical Guidelines for the International Recruitment of Physicians. Geneva: The World Medical Association; 2003. Available: www.wma.net/e/policy/e14.htm
8 Canadian Institute for Health Information.
2. Canadian Institute for Health Information.
10 Zaho J, Drew D, Murray T. Barin drain and brain gain: the migration of knowledge workers from and to Canada. Education Quarterly Review 2000;6(3):8-35.
12 Little L, Canadian Nurses Association, personal communication, January 8, 2008.
13 Buske L. Analysis of the survey of Canadian graduates practicing in the United States. October 2007. http://www.cma.ca/multimedia/CMA/Content_Images/Policy_Advocacy/Policy_Research/US_survey_ver_4.pdf. Accessed 02/04/08.
14 Little L, Canadian Nurses Association, personal communication, January 28, 2008.
16 Postl, B. Final Report of the Federal Advisor on Wait Times. Ottawa: Minister of Health Canada, Health Council of Canada; 2005.
17 Canadian Medical Association/Canada Infoway. Physician Technology Usage and Attitudes Survey. Ottawa: CMA/CanadaInfoway; 2005. Available: www.cma.ca/index.cfm/ci_id/49044/la_id/1.htm (accessed 8 Jan 2008).
18 Bower, Anthony. The Diffusion and Value of Healthcare Information Technology. Santa Monica (CA): RAND Corporation; 2005
The CMA appreciates the opportunity to present to the Standing Committee on Health today.
My presentation will focus on:
1. Wait Times
2. Health Human Resources; and
3. Patient Focused Care
In regard to the issue of wait times, I would echo the two main points of my colleagues from the Wait Time Alliance:
* First, while progress is being made on wait times, that progress is limited and not consistent across the country; and second,
* Health workforce and infrastructure capacity shortages remain the primary barriers to effectively addressing wait times.
Wait times don't only exact a heavy human toll - they also carry severe economic costs.
A CMA-commissioned report released earlier this year found that the economic cost of having patients wait longer than medically recommended was $14.8 billion in 2007. That stunning total was for just four of the five procedures identified as priorities in the 10-year plan - joint replacement, diagnostic imagining and cataract and bypass surgery - and it was only for one year.
Over a million Canadians continue to suffer on wait lists because of deficiencies in our system. This is unacceptable.
We need to "break the back" of wait times for the sake of our patients and for the economic health of Canada.
This will require:
* More federal leadership, not less;
* A revolutionary change in the "focus" of our health care system; and
* Substantial investments.
Health Human Resources
The 10-Year Plan to Strengthen Health Care acknowledged the need to increase the supply of health care professionals in Canada. However, not enough progress has been made.
Canada is 26,000 doctors short of the average of developed countries, and we now rank a lowly 24th among OECD countries in doctors per population.
A poll released today by the CMA found that Canada's doctor shortage ranked second only to the economy as a top public issue. In this same poll, 91% of Canadians say having a plan to address the doctor shortage will influence their vote in the next federal election. Federal political parties who ignore this issue in the next election could pay a price at the polls.
In the 10-year plan to strengthen health care, $1-billion was set aside for the last four years (2010-2014) of the agreement. We can't afford to wait that long.
This funding should be immediately fast-tracked to focus on the three priority areas in the CMA's "More Doctors. More Care" Campaign:
* One, expanding health professional education and training capacity;
* Two, ensuring self sufficiency in health human resources by investing in long-term health human resource planning; and.
* Three, investing in health information technology to make our health care system more responsive and efficient.
In terms of IT, we should be ashamed that we only spend a third of the OECD average on IT in our hospitals. Canada's poor record in avoidable adverse effects is, in part, due to our system's inability to share available information in a timely manner.
Patient Focused Care
Many countries have systems that provide universal care, have no wait lists and cost the same or less to run as our system does. Wait lists can and must be eliminated in Canada. The momentum to do just that depends simply on making the system work for patients, not on forcing patients to work the system.
We must reposition patients to the centre of our health-care system, which requires that we move beyond block funding or global budgets for health institutions. We need a system where funds follow the patient - patient-focused funding.
Block funding blocks access. Patient-focused funding will increase productivity, lead to greater efficiencies and reduce wait lists. A patient will become a value to an institution, not a cost.
Canada remains the last country in the developed world to fund hospitals with block funding. In England, patient-focused funding helped eliminate wait lists in less than four years.
So, my question to the Committee is why do we wait?
Why do we continue to keep patients on wait lists when research shows it costs a lot less to cut wait times then it does to have them?
Why do we not make the necessary reforms and investments to provide Canadians with timely access to quality care?
On behalf of the CMA, I thank you very much for the opportunity to be here today and commend the Subcommittee for focusing on the critical issue of child health.
My presentation today will focus on three areas:
1. What the CMA has done and plans to do in the area of children's health;
2. Why the CMA has chosen to focus on the early years as a priority; and
3. What the CMA recommends to the Subcommittee and government for action in the area of children's health.
The CMA's Role & Next Steps
Physicians see the adverse effects of poor child health all too often and we strongly believe that all children should have access to the best possible start in life. That healthy start includes opportunities to grow and develop in a safe and supportive environment with access to health services as needed.
The CMA is proud to have been a partner in the Child Health Initiative (CHI), an alliance between the CMA and the Canadian Paediatric Society (CPS) and the College of Family Physicians of Canada (CFPC) that has pressed for improvements in child health and the development of Child Health Goals.
The CHI held the Child and Youth Health Summit last year where it developed a child health charter based on three principles:
* a safe and secure environment;
* good health and development; and
* a full range of health resources available to all.
The Charter states that all children should have things such as clean water, air and soil; protection from injury and exploitation; and prenatal and maternal care for the best possible health at birth. Further, the charter recognizes the need for proper nutrition for proper growth and long term health; early learning opportunities and high-quality care, at home and in the community; and a basic health care including immunization, drugs, mental and dental health.
Delegates at the Summit also endorsed the Child Health Declaration and the Child and Youth Health Challenge, a call to action to make the charter a reality.
Going forward, the CMA will invest considerable time and effort to develop policy targeting children from birth to five years of age.
To that end the CMA will host the Child Health Expert Consultation and Strategy Session on June 5-6, 2008. The purpose of this consultation is to create a discussion paper to:
* First, identify how CMA can help physicians improve the health of children under five; and second,
* Identify the key determinants of early child health and identify goals and recommend ways to achieve optimal health outcomes for children under five.
This paper will inform a Roundtable Discussion of Child Health Experts in Fall 2008 where we hope to produce a final report on the Key Determinants of Children's Health for the Early Years.
We then hope to be invited to come before this Subcommittee once again to present this report and discuss our conclusions and recommendations.
Why the Early Years
The CMA is focusing on the period from birth to five years old because it is a critical time for children and when the physicians of Canada are perhaps in the best position to make a difference.
Recent human development research suggests that the period from conception to age six has the most important influence of any time in the life cycle on brain development. As well, we are all well aware that Canada could be and should be performing better in comparison to other OECD nations in a number of key areas such as infant mortality, injury and child poverty.
We also know that:
* Early screening for hereditary or congenital disease must take place between the ages of zero and five in order to provide effective intervention; and
* Brain and biological pathways in the prenatal period and in the early years affect physical and mental health in adult life.
Physicians are well positioned to identify and optimize certain conditions for healthy growth and development. Physicians can identify and prescribe effective interventions following many adverse childhood experiences in order to improve health outcomes for children and as they grow into adults.
The CMA believes that there are a number of actions government could be taking today in the area of children's health.
First, Canada should not be at the bottom of the list of developed countries when it comes to spending, as a percentage of GDP, on early childhood programs and development. Investing in early development is essential for an optimal start to life and a physically, mentally and socially healthy childhood.
Second, we need to improve our surveillance capability to better monitor changes in children's health because we can't manage what we can't measure. That is why the CMA recommends the creation of an annual report card on child health in Canada.
Third, nearly one child in six lives in poverty in Canada. This can impact a child's growth and development, his or her physical and mental health and ultimately the ability to succeed as teenagers and adults. Governments can and must do more.
Finally, there are a number of recommendations within the recently released Leitch Report in areas such as injury prevention, environment vulnerabilities, nutrition, aboriginal and mental health. The CMA strongly supports these recommendations and urges this Subcommittee to consider them.
However, if there are two recommendations within the Leitch Report that the CMA believes government could and must act upon immediately, they would be the creation of a National Office of Child Health and a Pan-Canadian Child Health Strategy.
In conclusion, the CMA strongly supports the Subcommittee's work and its focus on child health.
Again, we hope to return to see you again this fall with specific recommendations to address child health determinants, especially those affecting children from birth to age five.
Canada can and should be among the leading nations on earth in terms of children's health status. Our children deserve no less.
By many measures Canada's health care system is underperforming. One symptom of this weak performance are exceedingly long wait times that have an impact on care and cost patients, the system and governments money1. There are a number of responses to this poor performance including increasing the supply of health human resources2. Another response is to maximize the resources we have on the front lines and work smarter through information technology. This productivity approach is aligned with the assumptions set out in the federal government's Advantage Canada strategy. This strategy involves principally a 'knowledge advantage' and an 'infrastructure advantage'. Consequently, the Canadian Medical Association (CMA) is recommending that the federal government make a strategic "strings attached" $570-million investment to create an interconnected health information technology network3 through a Health Information System Transition Fund and time-limited accelerated IT tax incentives.
This investment aims to integrate all Canadian patient health care records, an effort that will take time. However, there are foundations upon which to build thanks to federal government investments - most recently in providing $400 million for wait-time related health information systems. But for these investments to bear fruit further connectivity and integration is vital. In other words, our current system is like having an ATM card that only works at the bank's head office. We believe that additional investments must concentrate on connecting patient records in physician offices with hospitals and medical laboratories. Physicians also believe in accountability, and suggest investments should not be made unless the clinical community confirms a high level of system integration.
The CMA recommends that the federal government should invest $570 million over five years in an interconnected pan-Canadian health information system that includes:
=> A $225 million, 5-year Health Information System Transition Fund aimed at change management training and support to convert 26-million patient records in 36,000 physician offices and community care facilities into interoperable electronic records across Canada.
=> $305 million for a 3-year time-limited and accelerated Capital Cost Allowance for software and hardware costs related to health information technologies that connect patient records from physician offices to laboratories and hospitals.
=> $10 million to sponsor a cross-country education campaign to inform Canadians of the health and system benefits of e-health connectivityi.
=> $2 million annually for Canada Research Chairs to promote and demonstrate the value of interconnectivity in health information between the faculties of Medicine, Management and Engineering.
The federal government must also encourage provinces to increase their support of these initiatives and work to reduce the barriers to health information system interfacing, by ensuring patient record systems use similar codes in labs, hospitals and physician offices. Federal government guidance, encouragement and cooperation with the provinces is integral to making these connectivity investments a success. It is time that the federal government helped finish the job of health information system connectivity. A health information network will improve patient outcomes, system efficiency, increase accountability and save billions of dollars.
Why advance e-health interconnectivity now? Our health system e-performance is poor
Both national and international studies confirm that Canada lags behind nearly every major industrial country when it comes to health information technology (Figure 8). The impact of this underinvestment is longer wait times, poorer quality, and a severe lack of financial accountability especially of federal dollars. Investments in connectivity are needed now because Canada's health care system compares poorly in both value and efficiency compared to other countries. The Conference Board of Canadaii, the OECDiii, the World Health Organizationiv, the Commonwealth Fundv, and the Frontier Centre for Public Policy all rate Canada's health care system poorly in terms of "value for money" as well as efficiency.
Benchmarking health information connectivity-where we stand, where we must go
According to the 2007 National Physician Survey, just 30% of physicians have an electronic interface with a medical laboratory or diagnostic imaging facility, while fewer than 5% have such an interface with a pharmacy/pharmacistvi. Imagine if just 30% of Canadian banks had ATMs throughout the country? This is a difference of not only convenience, but quality and cost savings. In comparison, Denmark and New Zealand have near 100% use of electronic medical records (EMRs) in ambulatory care. According to Dr. Allan Brookstonevii an EMR expert, "If most physicians in a health region or geographic area implemented an EMR system, the incentive for a local hospital or region to connect to those physicians would be significantly enhanced". In an emergency situation right now in Canada it is easier to access critical financial information than critical health information. This reality is not a matter of technology but the lack of will to put it in place.
2. Why the federal government should be interested in e-health interconnectivity.
-Health information technology connectivity yields returns on investment: 8:1
International strategy and technology consulting firm Booz Allen Hamilton found that viii the benefits of an interconnected Electronic Health Record (EHR) in Canada could provide annual system-wide savings of $6.1 billion. These savings would come from reduced duplicate testing, transcription savings, fewer chart pulls and filing time, reductions in office supplies and reduced expenditures due to fewer adverse drug reactions. The study went on to state that the benefits to health care outcomes would equal or surpass these annual savings, thus providing a possible combined annual savings of $12.2 billion. In addition, a comprehensive literature reviewix comparing health IT productivity gains to similar industries in the U.S. concludes that effective EMR implementation and networking could eventually save more than $81 billion annually by improving health care efficiency and safety. Similarly, health information technology-enabled prevention and management of chronic disease could eventually double those savings while increasing health and other social benefits. Assuming that the Canadian health system is one-tenth the size of US system, savings would range from $8 to $16 billion annually.
Connected health information technology - increasing performance and accountability
A fundamental question the Standing Committee on Finance may ask is where $22 billion (growing at 6 % annually) in federal health care transfers to the provinces is going and what are the results of this support? Right now, we do not know exactly. Health care in Canada represents 10% of our economy ($160 billion annually and growing at 6% per year) and is larger than the total agricultural sector.
The question Canadians are asking is not whether tax dollars should be spent on health care, but whether the money being spent is worth the services receivedx. Moreover, in health care, there are legitimate questions as to whether improvements to date have justified the associated costs. The public institutions and organizations that deliver health care in Canada could deliver more value than they do at present. With a national health information (management) system in place they could work to reduce variations in the quality of service and in the way services are used across the system. However at a national level, we do not have an accounting systemxi in place to uniformly measure quality across the country.
3. Who: Canadians - our patients - want and need e-health interconnectivity.
Health information technology is critical to managing wait times
Quality of care is an important concern for Canadians, but first they must be able to get the care they need. But waiting for health care is the principal concern for Canadiansxii. Excessive wait times result in mental anguish for patients and their families and also cost the Canadian economy billions of dollars each year. In 2007 a study commissioned by the CMAxiii conservatively calculated that excessive wait times in just four procedures (joint replacements, cataract surgery, coronary artery bypass grafts and MRIs) cost the economy over $14 billion in lost output and government revenues. It is important to note that beyond these hospital procedures there is potential to reduce wait times and cost in physician offices through information technology. This is why we have suggested accelerating the capital cost allowance tax for EMR related software and hardware purchases and that they go to community care and physician offices where most patient visits occur every day. Figure 1 below shows that in Ontario for example, just 3,000 out of an average of 247,000 patient visits per day or 1.2% of the total are made in hospitals. That is why this submission is aimed at (the circle area in the chart) increasing connectivity and tying investments to the 99% of the places where patients visit most.
Figure 1 Patient visits per day in Ontario, Source: Canada Health Infoway
Most of the emphasis on connectivity in Canadian health care to date has not focused on the point of care -even though the number of patient interactions with hospitals is greatly exceeded by the number of visits to physicians' officesxiv. Thus patient-physician office interactions outnumber patient-hospital interactions by a ratio of 18 to 1. It is also important that patients understand the value of electronic health records, which is why we are recommending a $10 million cross-country educational campaign to impact the demand side of this critical health and industrial equation.
4. Why physicians are involved in e-health interconnectivity
The physician community can play a pivotal role in helping the federal governments make a connected health care system a realizable goal in the years to come. Through a multi-stakeholder process encompassing the entire health care team, the CMA will work toward achieving cooperation and buy-in. This will require a true partnership between provincial medical associations, provincial and territorial governments and Canada Health Infoway (CHI).
Accelerating Advantage Canada through health information technologies
The CMA's pre-budget submission, related to health system connectivity, incorporates the five tenets of Advantage Canadaxv. This submission principally addresses the infrastructure and knowledge advantages that are involved in investing in an interconnected network that is useless unless the 'knowledge' advantage to provide stewardship of the Electronic Health Record through our physicians' is in place. That is why we recommend that the federal government help support research, development and knowledge transfer at our major universities in health information technology by supporting 10 Canada Research Chairs in the faculties of Medicine, Management and Engineering. In addition, a pan-Canadian health information technology network will provide the kind of infrastructure that supports labour mobility where for example a migrant worker from Atlantic Canada can access his health records in Fort McMurray Alberta.
5. How to speed-up health information technology connectivity -a green tax incentive approach
Thus far the strategy applied to health information connectivity in Canada has been focused on a top-down approach that has produced limited success. That is why the CMA is suggesting that the federal government accelerate the Capital Cost Allowance (CCA) on EMR-related software and hardware equipment over the next three years - an early-bird special or incentive. The CMA does not pretend to be tax policy experts however we do appreciate the federal governments' recent increase in the CCA rates for software and hardware. Our recommendation would mean changing the current software CCA (Class 12xvi) from 100% over two years to 100% in the first year specifically for EMR related investments. And for EMR hardware (Class 50xvii) accelerate the CCA to 100% in the first year from the current 55% rate for a limited time only of three years. These accelerated CCA rate proposals are also consistent with the governments' environmentally friendly CCA initiative as EMRs would save tonnes of paper for years.
Mixed results for Canada Health Infoway => Health Information System Transition Fund
The CMA lauds the federal government's 2008 Budget for making a $400-million investment in Canada Health Infoway (CHI) to support early movement toward patient wait time guarantees through the development of health information systems and electronic health records. At the same time the physician community believes that CHI has had mixed results, especially when it comes to digitizing and integrating patient records at the places where most patients contact the health care system: physician offices, laboratories and emergency rooms. However, we believe with targeted, conditional policies CHI can be an effective vehicle to accelerate the transition of current health centre paper practices into electronic operations through a time limited five-years Health Information Transition Fund. We also believe that federal transition funds should be matched at a fifty-fifty rate by the provinces. Although this may not be easy, there are other non-monetary policy levers (e.g. regulatory) that the federal government could and should use to persuade the provinces of the value of investing in electronic health record system integration. This is particularly true since the provinces will yield most of the return on the investment. It is imperative that the current health information technology gap be closed and be set at levels for similar service-intensive industries (see Figure 2 in the Appendix 1). That is why; beyond the figures outlined in this submission, the CMA recommends continued federal health information technology support for the next 10 years.
Conclusion - Big investments. but big payoffs too
As the Health Council of Canada stated in their 2008 annual reportxviii, "Change is underway, but too slowly". The OECD, WHO, The Commonwealth Fund and the Conference Board of Canada's research all strongly suggest that Canada lags behind the rest of the industrialized world in terms of health information technology investments and system integration. The investments made so far may seem large but they will be wasted if a second effort in connecting the entire system is not made now. It is time that the federal government finishes the job of health information system connectivity at the point of care.
A Pan-Canadian network of health information will improve patient outcomes, health system efficiency and dramatically increase system accountability. The Health Council of Canada also said that, "These [health information technology] are big investments but the payoff is big too". Accordingly we suggest that over the next five years the following investments will improve the running of Medicare as well as the Canadian economy.
The CMA recommends that the federal government should invest $570 million over five years in an interconnected pan-Canadian health information system that includes:
=> A $225 million, 5-year Health Information System Transition Fund aimed at change management training and support involved in converting 26 million patient records in 36,000 physician offices and community care facilities into interoperable electronic records across Canada.
=> $305 million for a 3-year time limited accelerated Capital Cost Allowance for EMR software and hardware costs related to health information technologies that connect patient records from physician offices to laboratories and hospitals.
=> $10 million to sponsor a cross-country education campaign to inform Canadians of the health and system benefits of e-health connectivityxix.
=> $2 million annually for Canada Research Chairs promoting the value of interconnectivity in health information between the faculties of Medicine, Management and Engineering.
1The cumulative economic cost of waiting for treatment across just 4 priority areas in 2007 was an estimated $14.8 billion. This reduction in economic activity lowered federal and provincial government revenues in 2007 by a combined $4.4 billion. See:www.cma.ca/multimedia/CMA/Content_Images/Inside_cma/Media_Release/pdf/2008/EconomicReport.pdf
2 Almost 5-million Canadians do not have a family physician. Canada would need 26,000 more doctors to meet the OECD average of physicians per population. Physicians spend more time on paperwork and less with patients than they did 20 years ago. See: "More Doctors. More Care.": www.moredoctors.ca/take_action/
3 Please see Table l in Appendix 1 for full investment horizon details.
i Patient perspective on electronic medical record.
Meldgaard M; International Society of Technology Assessment in Health Care. Meeting (19th : 2003 : Canmore, Alta.). Annu Meet Int Soc Technol Assess Health Care Int Soc Technol Assess Health Care Meet. 2003; 19: abstract no. 148.
CONCLUSIONS: Patient confidence and perceived quality of care is influenced by a well informed forward-looking staff as can be obtained in settings where EPR is successfully implemented. Patient satisfaction and the functional level of EPR implementation are interdependent.
ii A Report Card on Canada see: http://sso.conferenceboard.ca/HCP/overview/health-overview.aspx
iii Organization for Economic Co-operation and Development [OECD] (2007). OECD Health
Data 2007. Version 07/18/2007. CD-ROM. Paris: OECD.
iv World Health Organization [WHO] (2007). World Health Statistics 2007. see: http://www.who.
v Mirror, Mirror on the Wall: An International Update on the Comparative Performance of American Health Care May 15, 2007 (updated May 16, 2007)
Authors: Karen Davis, Ph.D., Cathy Schoen, M.S., Stephen C. Schoenbaum, M.D., M.P.H., Michelle M. Doty, Ph.D., M.P.H., Alyssa L. Holmgren, M.P.A., Jennifer L. Kriss, and Katherine K. Shea
Editor(s):Deborah Lorber see: www.commonwealthfund.org/publications/publications_show.htm?doc_id=482678
vi See Tables Q39 and Q40a in the 2007 National Physician Survey at:www.nationalphysiciansurvey.ca/nps/
vii Dr. Alan Brookstone is a family physician in Richmond, BC and the founder of CanadianEMR. The quote was taken from: Online resource enables MDs to rate EMRs. See: www.cma.ca/multimedia/CMA/Content_Images/Inside_cma/Future_Practice/English/2007/November/Online-e.pdf
The CanadianEMR Physician Resource Directory provides access to a province specific searchable list of vendors of products and services to support the EMR-based practice. http://www.canadianemr.ca/
viii Booz, Allan, Hamilton Study, Pan-Canadian Electronic Health Record, Canada's Health Infoway's 10-Year Investment Strategy, March 2005-09-06.
ix Can Electronic Medical Record Systems Transform Health Care? Potential Health Benefits, Savings, And Costs
Richard Hillestad, James Bigelow, Anthony Bower, Federico Girosi, Robin Meili, Richard Scoville and Roger Taylor, Health Affairs, 24, no. 5 (2005): 1103-1117.
x In November 2008 the Auditor General of Canada will present it's performance audit on, "Reporting on Health Indicators-Health Canada" to Parliament. See: www.oag-bvg.gc.ca/internet/English/oag-bvg_e_29401.html
xi There has been heavy emphasis is being placed on "accountability" and "performance measurement," endorsed by the Romanow Commission (Commission on the Future of Healthcare in Canada 2002), the Kirby Committee (Standing Senate Committee on Social Affairs, Science and Technology 2002), and the First Ministers' accord (First Ministers 2004). See Raisa Deber Why Did the World Health Organization Rate Canada's Health System as 30th? Some Thoughts on League Tables. Some Thoughts on League Tables
xii The results of an Ipsos Reid poll (January 2008) finds that eight in ten (78%) Canadians believe that hospital and other health care wait times cost Canada money because people who are waiting for treatment are less productive and miss work. This is compared to just two in ten (19%) who think that wait times save Canada money because governments don't have to put as many resources into healthcare.
xiii The economic cost of wait times in Canada, January 2008. This study was commissioned by the Canadian Medical Association (CMA) to analyze the economic costs of wait times in Canada's medical system. The CMA's membership includes more than 67,000 physicians, medical residents and medical students. It plays a key role by representing the interests of these members and their patients on the national stage. Located in Ottawa, the CMA has roots across the country through its close ties to its 12 provincial and territorial divisions.
xiv Sources: Physician visits - CIHI - Physicians in Canada: Fee-for-Service Utilization 2005-2006. Table 1-21. Hospital contacts - CIHI - Trends in Acute Inpatient Hospitalizations and Day surgery Visits in Canada 1995-1996 to 2005-2006 and CIHI -National Ambulatory Care Reporting System - Visit Disposition by Triage Level for All Emergency Visits - 2005-2006.
xvAdvantage Canada builds on Canada's strengths and seeks to gain a global competitive advantage in five areas:
1. Tax Advantage-Reducing taxes for all Canadians and establishing the lowest tax rate on new business investment in the G7.
2. Fiscal Advantage-Eliminating Canada's total government net debt in less than a generation.
3. Entrepreneurial Advantage-Reducing unnecessary regulation and red tape and increasing competition in the Canadian marketplace.
4. Knowledge Advantage-Creating the best-educated, most-skilled and most flexible workforce in the world.
5. Infrastructure Advantage-Building the modern infrastructure we need.
CLASS 12 , (100 per cent)
Property not included in any other class that is....
(o) computer software acquired after May 25, 1976, but not including systems software or property acquired after August 8, 1989 and before 1993 that is described in paragraph (s).
CLASS 45 , (45 per cent)
Property acquired after March 22, 2004 (other than property acquired before 2005 in respect of which an election is made under subsection 1101(5q)) that is general-purpose electronic data processing equipment and systems software for that equipment, including ancillary data processing equipment.
(a) electronic process control or monitor equipment;
(b) electronic communications control equipment;
(c) systems software for equipment referred to in paragraph (a) or (b); or
(d) data handling equipment (other than data handling equipment that is ancillary to general-purpose electronic data processing equipment).
Class 50 (55 per cent)
Property acquired after March 18, 2007 that is general-purpose electronic data processing equipment and systems software for that equipment, including ancillary data processing equipment, but not including property that is principally or is used principally as
(a) electronic process control or monitor equipment;
(b) electronic communications control equipment;
(c) systems software for equipment referred to in paragraph (a) or (b); or
(d) data handling equipment (other than data handling equipment that is ancillary to general-purpose electronic data processing equipment).
xviii Health Council of Canada, Rekindling Reform: Health Care Renewal in Canada, 2003 - 2008, June 2008 (page 23).
(Table does not display correctly -- See PDF)
Table 1 -Health Interconnectivity investments over five years.
Figure 2 -Major Canadian health centers are well below industry IT investment standard
It is a pleasure to address the Standing Committee on Finance today as part of your pre-budget consultations.
In keeping with the theme set by the Committee, our presentation - Tax Incentives for Better Living - focuses on changing the tax system to better support the health and well being of all Canadians.
Today I will share with you three recommendations improving the health of Canadians and productivity of the Canadian economy:
First, tax incentives for pre-paid long-term care insurance;
Second, tax incentives to retain and recruit more doctors and nurses;
Third, tax incentives to enhance health system productivity and quality improvements.
1. Long Term Care insurance
Canada's population is ageing fast. Yet, long-term care has received little policy attention in Canada. Unlike other countries like the UK and Germany who have systems in place, Canada is not prepared to address these looming challenges.
The first of the baby-boomers will turn 65 in 2011. By 2031, seniors will comprise one quarter of the population - double the current proportion of 13%. The second challenge is the lack of health service labour force that will be able to care for this ageing population.
Long-term care cannot and should not be financed on the same pay-as-you-go basis as medical/hospital insurance. Therefore the CMA urges the Committee to consider either tax-pre-paid or tax-deferred options for funding long-term care. These options are examined in full in the package we have supplied you with today.
2. Improving access to quality care
Canada's physician shortage is a critical issue. Here in Quebec, 1 in 4 people do not have access to a family physician. Overall 3.5 people in Canada do not have a family Physician. Despite this dire shortage, the Canada Student Loans program creates barriers to the training of more physicians.
Medical students routinely begin their postgraduate training with debts of over $120,000. Although still in training, they must begin paying back their medical school loans as they complete their graduate training. This policy affects both the kind of specialty that physicians-in-training choose, and ultimately where they decide to practice.
We urge this Committee to recommend the extension of interest-free status on Canada Student Loans for all eligible health professional students pursuing postgraduate training.
3. Health System IT: increasing productivity and quality of care
The last issue I will address is health system automation. Investment in information technology will lead to better, safer and cheaper patient care. In spite of the recent $400 million transfer to Canada Health Infoway, Canada still ranks at the bottom of the G8 countries in access to health information technologies. We spend just one-third of the OECD average on IT in our hospitals. This is a significant factor with respect to our poor record in avoidable adverse health effects.
An Electronic Health Record (EHR) could provide annual, system-wide savings of $6.1 billion - every year - and reduce wait times and thereby absenteeism. But, the EHR potential can only be realized if physician's offices across Canada are fully automated.
The federal government could invest directly in physician office automation by introducing dedicated tax credits or by accelerating the capital cost allowance related to health information technologies for patients.
Before I conclude, the CMA again urges the Committee to address a long-standing tax issue that costs physicians and the health care system over $65 million a year. When you add hospitals - that cost more than doubles to over $145 million-or the equivalent of 60 MRI machines a year.
The application of the GST on physicians is a consumption tax on a producer of vital services and affects the ability of physicians to provide care to their patients. And now with the emphasis on further sales tax harmonization, the problem will be compounded.
Nearly 20 years ago when the GST was put into place, physician office expenses were relatively low for example: tongue depressors, bandages and small things. There was practically no use computers or information technology. How many of you used computers 20 years ago?
Now Canadian physicians' could be and should be using 21st century equipment that is expensive but powerful. This powerful diagnostic equipment can save lives and save the system millions of dollars in the long run. It provides a clear return on investment.
Yet, physicians still have to pay the GST (and the PST) on diagnostic equipment that costs a minimum of $500,000 that's an extra $30,000 that physicians must pay.
The result of this misalignment of tax policy and health policy is that most Radiologists' diagnostic imaging equipment is over 30-years old. Canadians deserve better.
It's time for the federal government to stop taxing health care. We urge the Committee to recommend the "zero-rating" publicly funded health services or to provide one-hundred percent tax rebates to physicians and hospitals.
In conclusion, we trust the Committee recognizes the benefits of aligning tax policy with health policy in order to create the right incentives for citizens to realize their potential.
1. Tax Incentives for Long-Term Care
2. Tax Incentives to Bolster Health Human Resources and,
3. Tax Incentives to Support Health System Automation.
This committee can respond to immediate access to health care pressures that Canadians are facing. Delaying a response to these pressures will have an impact on the competiveness of our economy now, and with compounding effects in the future.
I appreciate the opportunity of entering into a dialogue with members of the Committee and look forward to your questions.