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.
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).
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
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.
Committee Appearance – Justice and Human Rights:
Bill C-7 – Amending the Criminal Code Regarding Medical Assistance in Dying
November 5, 2020
Dr. E. Ann Collins
President of the Canadian Medical Association
Committee Appearance – Justice and Human Rights
Bill C-7 – Amending the Criminal Code Regarding Medical Assistance in Dying
Thank you, Madam Chair.
It’s my honour to appear before you today. I’m Dr. Ann Collins. Over the past three decades practising medicine, I have taught family medicine, run a family practice, served with the Canadian Armed Forces and worked in nursing home care. Today, in my capacity as President of the Canadian Medical Association, I represent our 80,000 physician members.
In studying Bill C-7, it is incumbent upon us now to consider the effects on patients that the passing of this bill will have, but also the effects on the medical professionals who provide medical assistance in dying - MAiD.
When the original MAiD legislation was developed as Bill C-14, the CMA was a leading stakeholder. We have continued that commitment with Bill C-7. Having examined Bill C-7, we know that, in a myriad of ways, the results of our extensive consultations with our members align with the findings of the government’s roundtables.
Fundamentally, the CMA supports the government’s prudent and measured approach to responding to the Truchon-Gladu decision. This thoughtful and staged process undertaken by the government is consistent with the CMA’s position for a balanced approach to MAiD.
Nicole Gladu, whose name is now inextricably tied to the decision, spoke as pointedly as perhaps anyone could when she affirmed that it is up to people like her, and I quote, “To decide if we prefer the quality of life to the quantity of life." Not everyone may agree with this sentiment, but few can argue that it is a powerful reminder of the real stakeholders when it comes to considerations of this bill. This applies just as critically to those who are currently MAiD providers and those who will become providers. They are our members, but we can’t lose sight of the fact that we must all support both patients and providers.
Through our consultations, we learned that many physicians felt that clarity was lacking. Recent federal efforts to provide greater clarity for physicians are exceedingly welcome. The CMA is pleased to see new non-legislative measures lending more consistency to the delivery of MAiD across the country. The quality and availability of palliative care, mental health care, care for those suffering from chronic illness, and persons with disabilities, to ensure that patients have access to other, appropriate health care services is crucial.
The CMA holds firm on our convictions on MAiD from Bill C-14 to C-7.
We believe firstly that the choice of those Canadians who are eligible should be respected.
Secondly, we must protect the rights of vulnerable Canadians. This demands strict attention to safeguards.
And lastly, an environment must exist that insists practitioners abide by their moral commitments.
These three tenants remain equally valid.
Our consultations with members demonstrate strong support for allowing advance requests by eligible patients who may lose capacity before MAiD can be provided.
The CMA believes in the importance of safeguards to protect the rights of vulnerable Canadians and those who are eligible to seek MAiD.
The CMA also supports expanding data collection to provide a more thorough account of MAiD in Canada, however, this effort must not create an undue administrative burden on physicians.
The CMA views the language in the bill, which explicitly excludes mental illness from being considered an “illness, disease or disability,” problematic and has the potential to be stigmatizing to those living with a mental illness. We trust that Parliament will carefully consider the specific language used in the bill.
Finally, the CMA endorses the government’s staged approach to carefully examine more complex issues. However, we must move forward to ensure practitioners are given the tools that will be required to safely administer MAiD on a wider spectrum, such as support for developing clinical practice guidelines which aid physicians in exercising sound clinical judgment. Such guidance would also serve to reinforce consistency in the application of the legal criteria.
In conclusion, Madam Chair, allow me to thank the committee for the invitation to participate in today’s proceedings and to share the perspective of Canada’s physicians. The pursuit of a painless and dignified end-of-life is a noble one. The assurance that the providers of this privilege are supported is an ethical imperative.
Committee Appearance – Senate Legal and Constitutional Affairs Committee:
Bill C-7 – An Act to Amend the Criminal Code (medical assistance in dying)
November 23, 2020
Dr. Sandy Buchman
Past President of the Canadian Medical Association
Monday, November 23, 2020
Thank you, Madam Chair.
I appear before the committee today as the past president of the Canadian Medical Association with the honour and responsibility of speaking for all our members - the frontline physicians.
My name is Dr. Sandy Buchman. I am a palliative care physician in Toronto. I am also a MAiD Assessor and Provider.
It is incumbent upon us now to consider the effects that the passing of Bill C-7 will have on patients, but also the effects on the medical professionals who provide medical assistance in dying - MAiD.
When the original MAiD legislation was developed as Bill C-14, the CMA was a leading stakeholder. We have continued that commitment with Bill C-7. Having examined Bill C-7, we know that, in a myriad of ways, the results of our extensive consultations with our members align with the findings of the government’s roundtables.
Nicole Gladu, whose name is now inextricably tied to the government’s decision on MAiD, spoke as unequivocally as perhaps anyone could when she affirmed that it is up to people like her, and I quote, “To decide if we prefer the quality of life to the quantity of life."
Perhaps not everyone agrees with this sentiment. Few can argue, though, that it is a powerful reminder of the real stakeholders when it comes to considerations of this bill. This applies no less critically to those who are currently MAiD providers or those who will become providers. These practitioners are our members.
But we can’t overlook the fact that there must be complete support of both patients and providers.
Fundamentally, the CMA supports the government’s prudent and measured approach to responding to the Truchon-Gladu decision. This thoughtful and staged process undertaken by the government is consistent with the CMA’s position for a balanced approach to MAiD.
Through our consultations however, we learned that many physicians felt there is a lack of overall clarity. Recent federal efforts to provide precision for physicians are exceedingly welcome.
The CMA is pleased to see new non-legislative measures lending more consistency to the delivery of MAiD across the country. The quality and availability of palliative care, mental health care, and care and resources for those suffering from chronic illness, and for persons with disabilities, to ensure that all patients have access to other, appropriate health care services is crucial.
The CMA remains firm on our convictions on MAiD from Bill C-14 to C-7.
We believe that the choice of those Canadians who are eligible should be respected.
We also believe that the rights of vulnerable Canadians must be protected. This demands strict attention to safeguards.
And we believe that an environment must exist that fosters the insistence that practitioners abide by their moral commitments.
Each of these three tenants is equally unassailable.
Our members are in strong support of allowing advance requests by eligible patients who may lose capacity before MAiD can be provided.
The CMA believes in the importance of safeguards to protect the rights of vulnerable Canadians and those who are eligible to seek MAiD.
Expanding data collection to provide a more thorough account of MAiD in Canada is important. However, this effort must not create an undue administrative burden on physicians.
The CMA views some of the language in the bill as precarious. The CMA recommends amending the language in section 2.1 which states “mental illness is not considered to be an illness, disease or disability” to avoid the unintended consequence of having a stigmatizing effect. The legislation should also clearly indicate that the exclusion is for mental illness as a sole underlying medical condition, not mental illness as a comorbidity.
To be clear, the CMA is not recommending a revision to the legislative intent. We trust that Parliament will carefully consider the specific language used in the bill.
Finally, the CMA endorses the government’s staged approach to carefully examine more complex issues. We must move forward, though, by ensuring that practitioners are given the tools that will be required to safely administer MAiD on a wider spectrum. Support for developing clinical practice guidelines that aid physicians in exercising sound clinical judgment are a prime example. Such guidance would also serve to reinforce consistency in the application of the legal criteria.
In conclusion, Madam Chair, allow me to thank the committee for the invitation to participate in today’s proceedings. Sharing the perspective of Canada’s physicians is a privilege. That together we pursue a painless and dignified end-of-life is noble. The assurance that the providers of this practice are supported is an ethical imperative.
The Canadian Medical Association (CMA) welcomes the opportunity to appear before the Sub-Committee on the Status of Persons with Disabilities to discuss issues related to the Disability Tax Credit (DTC). This tax measure, which is recognition by the federal government that persons with a severe disability may be affected by having reduced incomes, increased expenses or both, compared to those who are not disabled i, helps to account for the intangible costs associated with a severe and prolonged impairment. It also takes into account disability-related expenses that are not listed in the medical expense deduction or which are excluded by the 3% threshold in the Medical Expense Tax Credit.
Physicians are a key point of contact for applicants of the DTC and, given the way the program is structured, a vital participant in its administration. It is for these reasons that we come before you today to address specific concerns related to the program’s performance. In addition, we would like to discuss the broader issue of developing a coherent set of tax policies in support of health and social policy.
The Integration of Tax Policy with Health Policy and Social Policy
The federal government, through a variety of policy levers such as taxation, spending, regulation and information, has played a key role in the development of our health care and social systems. To date however, discussion about the federal role in these areas has centered largely on federal transfers to the provinces and territories and the Canada Health Act.
However, in looking at how to renew Canada’s health and social programs, we should not limit ourselves to these traditional instruments. Today we have a health system that is facing a number of pressures that will challenge its sustainability. These pressures range from an aging and more demanding population in terms of the specialty care services and technology they will seek; the cry for expanding the scope of medicare coverage to include homecare and pharmacare; and a shortage of health personnel. These are only some of the more immediate reasons alternative avenues of funding health care, and thus ensuring the health and well-being of our citizens, must be explored.
In our pre-budget consultation document to the Standing Committee on Finance ii, the CMA recommended that the federal government establish a blue ribbon National Task Force to study the development of innovative tax-based mechanisms to synchronize tax policy with health policy. Such a review has not been undertaken in over 25 years since the Royal Commission on Taxation in 1966 (Carter Commission).
The CMA is echoing its call for a National Task Force to develop new and innovative ways to synchronize tax policy with health policy and social policy. A study of this nature would look at all aspects of the taxation system, including the personal income tax system, in which the DTC is a component.
The remainder of our brief addresses issues specific to the DTC.
Physician Involvement in the DTC Program
The CMA has in the past provided input with respect to the DTC program. Our working relationship on the DTC program with the Canada Customs and Revenue Agency (CCRA) has been issue-specific, time-limited and constructive.
Our first substantive contact in regard to the DTC program was in 1993 when the CMA provided Revenue Canada with a brief review of the program and the T2201form. It is interesting to note what our observations were in 1993 with regard to this program because many of them still hold true today.
Here are just some of the issues raised by the CMA in 1993 during our initial review of the program:
* The tax credit program may not address the needs of the disabled, it is too hit and miss. The DTC program should be evaluated in a comprehensive way to measure its overall effectiveness in meeting the needs of persons with disabilities.
* The program should be called the “Severe Disability Tax Credit Program” – or something equivalent to indicate that not everyone with a disability is eligible.
* The program puts physicians in a potential conflict with patients—the responsibility of the physician to advocate for the patient vs. gate-keeper need for Revenue Canada. The physician role should be to attest to legitimate claims on the patients’ behalf.
* Revenue Canada should clarify the multiplicity of programs. There are numerous different federal programs and all appear to have varying processes and forms. These overlapping efforts are difficult for patients and professionals.
* A major education effort for potential claimants, tax advisers and physicians should be introduced.
* A suitable evaluation of claimant and medical components of the process should be undertaken.
The CMA does not have a standardized consultative relationship with the CCRA in regard to this program. An example of this spotty relationship is the recent letter sent by the CCRA Minister asking current DTC recipients to re-qualify for the credit. The CMA was not advised or consulted about this letter. If we had been advised we would have highlighted the financial and time implications of sending 75 to 100 thousand individuals to their family physician for re-certification. We also would have worked with the CCRA on alternative options for updating DTC records. Unfortunately, we cannot change what has happened, but we can learn from it. This clearly speaks to the need to establish open and ongoing dialogue between our two organizations.
Policy Measure: The CMA would like established a senior level advisory group to continually monitor and appraise the performance of the DTC program to ensure it is meeting its stated purpose and objectives. Representation on this advisory group would include, at a minimum, senior program officials preferably at the ADM level; those professional groups qualified to complete the T2201 Certificate; various disability organizations; and patients’ advocacy groups.
We would now like to draw the Sub-committee’s attention to three areas that, at present, negatively impact on the medical profession participation in the program, namely program integrity, program standardization (e.g., consistency in terminology and out-of-pocket costs faced by persons with disabilities) and tax advisor referrals to health care providers.
A primary concern and irritation for physicians working with this program is that it puts an undue strain on the patient-physician relationship. This strain may also have another possible side effect, a failure in the integrity of the DTC program process.
Under the current structure of the DTC program, physicians evaluate the patient, provide this evaluation back to the patient and then ask the patient for remuneration. This process is problematic for two reasons. First, since the patient will receive the form back immediately following the evaluation, physicians might receive the blame for denying their patient the tax credit—not the DTC program adjudicators. Second, physicians do not feel comfortable asking for payment when he or she knows the applicant will not qualify for the tax credit.
For the integrity of the DTC program, physicians need to be free to reach independent assessment of the patient’s condition. However, due to the pressure placed by this program on the patient-physician relationship, the physician’s moral and legal obligation to provide an objective assessment may conflict with the physician’s ethical duty to “Consider first the well-being of the patient.
There is a solution to this problem it’s a model already in use by government, the Canadian Pension Plan (CPP) Disability Program. Under the CPP Disability Program, the evaluation from the physician is not given to the patient but, it is sent to the government and the cost to have the eligibility form completed by a physician is subsumed under the program itself. Under this system, the integrity of patient-physician relationship is maintained and the integrity of the program is not compromised.
Policy Measure: The CMA recommends that the CCRA take the necessary steps to separate the evaluation process from the determination process. The CMA recommends the CPP Disability Program model to achieve this result.
Fairness and Equity
The federal government has several programs for people with disabilities. Some deal with income security (e.g., Canada Pension Plan Disability Benefits), some with employment issues (e.g., Employability Assistance for People with Disabilities), and some through tax measures (e.g., Disability Tax Credit). These government transfers and tax benefits help to provide the means for persons with disabilities to become active members in Canadian society.
However, these programs are not consistent in terms of their terminology, eligibility criteria, reimbursement protocols, benefits, etc. CMA recommends that standards of fairness and equity be applied across federal disability benefit programs, particularly in two areas: the definition of the concept of “disability”, and standards for remuneration to the physician. These are discussed in greater detail below.
1) Defining “disability”
One of the problems with assessing disability is that the concept itself is difficult to define. In most standard definitions the word “disability” is defined in very general and subjective terms. One widely used definition comes from the World Health Organization’s International Classification of Impairments, Disabilities and Handicaps (ICIDH) which defines disability as “any restriction or inability (resulting from an impairment) to perform an activity in the manner or within the range considered normal for a human being.”
The DTC and other disability program application forms do not use a standard definition of “disability”. In addition to the inconsistency in terminology, the criteria for qualification for these programs differ because they are targeted to meet the different needs of those persons with disabilities. To qualify for DTC, a disability must be “prolonged” (over a period of at least 12 months) and “severe” i.e. “markedly (restrict) any of the basic activities of daily living” which are defined. Though CPP criteria use the same words “severe” and “prolonged” they are defined differently (i.e., “severe” means “prevents applicant from working regularly at any job” and “prolonged” means “long term or may result in death”). Other programs, such as the Veterans Affairs Canada, have entirely different criteria.
This is confusing for physicians, patients and others (e.g., tax preparers/advisors) involved in the application process. This can lead to physicians spending more time than is necessary completing the form because of the need to verify terms. As a result if the terms, criteria and the information about the programs are not as clear as possible this could result in errors on the part of physicians when completing the forms. This could then inadvertently disadvantage those who, in fact, qualify for benefits.
Policy Measures: The CMA would like to see some consistency in definitions across the various government programs. This does not mean that eligibility criteria must become uniform.
In addition, the CMA would like to see the development of a comprehensive information package for health care providers that provides a description of each program, its eligibility criteria, the full range of benefits available, copies of sample forms, physical assessment and form completion payment information, etc.
The remuneration for assessment and form completion is another area where standardization among the various government programs would eliminate the difficulties that some individuals with disabilities currently face. For example, applicants who present the DTC Certificate Form T2201 to their physicians must bear any costs associated with its completion out of their own pockets. On the other hand, if an individual is applying to the CPP Disability Program, the cost to have the eligibility form completed by a physician is subsumed under the program itself.
Assessing a patient’s disabilities is a complex and time-consuming endeavour on the part of any health professional. Our members tell us that the DTC Certificate Form T2201 can take as much time and effort to complete as the information requested for CPP Disability Program forms depending, of course, on the patient and the nature of the disability. In spite of this fact, some programs acknowledge the time and expertise needed to conduct a proper assessment while other programs do not.
Although physicians have the option of approaching the applicant for remuneration for the completion of the DTC form, they are reluctant to do so because these individuals are usually of limited means and in very complex cases, the cost for a physician’s time for completing the DTC Form T2201 can reach as much as $150. In addition, physicians do not feel comfortable asking for payment when he/she knows the applicant will not qualify for the tax credit. Synchronizing funding between all programs would be of substantial benefit to all persons with disabilities, those professionals completing the forms and the programs’ administrators.
Policy Measure: We strongly urge the federal government to place disability tax credit programs on the same footing when it comes to reimbursement of the examining health care provider.
Tax Advisor Referrals
With the complexity of the income tax system today, many individuals seek out the assistance of professional tax advisors to ensure the forms are properly completed and they have received all the benefits they are entitled to. Tax advisors will very often refer individuals to health professionals so that they can be assessed for potential eligibility for the DTC. The intention of the tax advisors may be laudable, but often, inappropriate referrals are made to health professionals. This not only wastes the valuable time of health care professionals, already in short supply, but may create unrealistic expectations on the part of the patient seeking the tax credit.
The first principle of the CMA’s Code of Ethics is “consider first the well-being of the patient.” One of the key roles of the physician is to act as a patient’s advocate and support within the health care system. The DTC application form makes the physician a mediator between the patient and a third party with whom the patient is applying for financial support.
This “policing” role can place a strain on the physician-patient relationship – particularly if the patient is denied a disability tax credit as a result a third-party adjudicator’s interpretation of the physician’s recommendations contained within the medical report. Physicians and other health professionals are not only left with having to tell the patient that they are not eligible but in addition advising the patient that there may be a personal financial cost for the physician providing this assessment.
Policy Measure: Better preparation of tax advisors would be a benefit to both patients and their health care providers. The CMA would like CCRA to develop, in co-operation with the community of health care providers, a detailed guide for tax preparers and their clients outlining program eligibility criteria and preliminary steps towards undertaking a personal assessment of disability. This would provide some guidance as to whether it is worth the time, effort and expense to see a health professional for a professional assessment.
As raised in a previous meeting with CCRA, the CMA is once again making available a physician representative to accompany DTC representatives when they meet the various tax preparation agencies, prior to each tax season, to review the detailed guide on program eligibility criteria and initial assessment, and to highlight the implications of inappropriate referral.
The DTC is a deserving benefit to those Canadians living with a disability. However, there needs to be some standardization among the various programs to ensure that they are effective and meet their stated purpose. Namely, the CMA would like to make the following suggestions:
1. The CMA would like established a senior level advisory group to continually monitor and appraise the performance of the DTC program to ensure it is meeting its stated purpose and objectives. Representation on this advisory group would include, at a minimum, senior program officials preferably at the ADM level; those professional groups qualified to complete the T2201 Certificate; various disability organizations; and patient advocacy groups.
2. The CMA recommends that the CCRA take the necessary steps to separate the evaluation process from the determination process. The CMA recommends the CPP Disability Program model to achieve this result.
3. That there be some consistency in definitions across the various government programs. This does not circumvent differences in eligibility criteria.
4. That a comprehensive information package be developed, for health care providers, that provides a description of each program, its eligibility criteria, the full range of benefits available, copies of sample forms, physical assessment and form completion payment information, etc.
5. That the federal government applies these social programs on the same footing when it comes to their funding and administration.
6. That CCRA develop, in co-operation with the community of health care providers, a detailed guide for tax advisors and their clients outlining program eligibility criteria and preliminary steps towards undertaking a personal assessment of disability.
7. That CCRA employ health care providers to accompany CCRA representatives when they meet the various tax preparation agencies to review the detailed guide on program eligibility criteria and personal assessment of disability, and to highlight the implications of inappropriate referral.
These recommendations would certainly be helpful to all involved - the patient, health care providers and the programs’ administrators, in the short term. However what would be truly beneficial in the longer term would be an overall review of the taxation system from a health care perspective. This could provide tangible benefits not only for persons with disabilities but for all Canadians as well as demonstrating the federal government’s leadership towards ensuring the health and well being of our population.
i Health Canada, The Role for the Tax System in Advancing the Health Agenda, Applied Research and Analysis Directorate, Analysis and Connectivity Branch, September 21, 2001
ii Canadian Medical Association, Securing Our Future… Balancing Urgent Health Care Needs of Today With The Important Challenges of Tomorrow”, Presentation to the Standing Committee on Finance Pre-Budget Consultations, November 1, 2001.
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:
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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.
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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.
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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.
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
Hockey is one of the most popular sports for Canadian children and youth. While the health benefits of physical activity and sport participation are well recognized, there is increasing concern around the frequency and severity of hockey-related injuries, particularly concussion. Studies consistently identify bodychecking as the primary mechanism associated with youth hockey injuries, including concussion. Policy to delay bodychecking until bantam league play (when participants are 13 to 14 years of age) will reduce the risks of injury and concussion in young ice hockey players. Bodychecking should be eliminated from non-elite youth ice hockey. The age at which bodychecking is introduced in competitive hockey leagues must be reconsidered. Both initiatives require policy change in many provinces/territories, and must be re-evaluated prospectively in light of emerging research.
More than 4.5 million Canadians are involved in ice hockey, as coaches, officials, administrators or direct volunteers, and hockey is the most popular winter sport among Canadian children and youth. Hockey Canada reported over 550,000 registered players under the age of 19 in 2008, and participation rates are increasing, especially among girls and young women. While the health benefits of physical activity and sport participation are well recognized, there is increasing concern around the frequency and severity of hockey-related injuries in youth, particularly concussion. The American Academy of Pediatrics (AAP) classifies hockey as a collision sport because of unintentional and intentional body contact, including bodychecking.
The AAP published a policy statement on youth ice hockey in 2000, recommending that bodychecking not be allowed for children younger than 15 years of age. There is passionate debate about the risk factors for injury in youth hockey and the relative merits of early or later introduction of bodychecking. Because bodychecking is not allowed in girls' or women's hockey in Canada, the present statement pertains to play in boys' and men's hockey leagues. It reviews the scientific literature on bodychecking injuries, outlines positions in the current debate and makes recommendations on when bodychecking should be introduced into the game.
DEFINING BODY CONTACT AND BODYCHECKING
Body contact is an individual defensive tactic designed to legally block or impede the progress of an offensive puck carrier. The defensive player moves to restrict action by the puck carrier anywhere on the ice, by skating, angling and positioning. The defensive player cannot hit the offensive player by travelling in an opposite direction to him or by physically extending toward him in an effort to initiate contact. There must be no action where the puck carrier is pushed, hit or shoved into the boards. In contrast, bodychecking is an individual defensive tactic designed to legally separate the puck carrier from the puck. The defensive player physically extends his body toward the puck carrier while moving in an opposite or parallel direction, a deliberate and forceful move not solely determined by the movement of the puck carrier. Bodychecking is taught based on a four-step skill development program outlined by Hockey Canada, with progression through positioning and angling, stick checking, body contact and bodychecking skills. Instruction in bodychecking includes techniques for receiving bodychecks, adhering to rules, and safe play.
Hockey Canada groups children and adolescents by age into six play levels: initiation (5 to 6 years of age), novice (7 to 8 years), atom (9 to 10 years), peewee (11 to 12 years), bantam (13 to 14 years), and midget (15 to 17 years). Historically, from the early 1980s until the 2002/2003 season, bodychecking was introduced at age 12 years in Canadian boys' ice hockey. In 2003, four of 13 provincial/territorial branches allowed checking for players as young as nine years old. Hockey Canada mandated the introduction of bodychecking in peewee leagues (ages 11 to 12) in 2009. Quebec has delayed bodychecking until bantam (age 14 from 1978 to 2002, then age 13 following an age change mandated nationally).
Despite lack of evidence, proponents of bodychecking argue that it is a fundamental skill which, learned early, may prevent future injuries. However, the evidence supports that bodychecking is the most common mechanism of injury. The Canadian Academy of Sports Medicine recommends that bodychecking be introduced only in boys' competitive hockey, and no earlier than the bantam (ages 13 to14) or midget (ages 15 to 17) level. The AAP recommends a ban on bodychecking for male players younger than 15 years of age. The present statement marks the first CPS position on this issue.
BODYCHECKING AND INJURY
Hockey is recognized as a high-risk sport. The speed of play, body contact and bodychecking all contribute to injury risk. The injury rate is also high, with Canadian data suggesting that hockey injuries account for 8% to 11% of all adolescent sport-related injuries. Unfortunately, serious injuries such as concussion, other brain injuries and spinal cord trauma are not uncommon in hockey. The incidence of traumatic brain injury appears to be rising. Ice hockey-related fatality rates are double those reported in American football, and catastrophic spinal cord and brain injury rates are almost four times higher for high school hockey players than for high school and college football players. Bodychecking is the predominant mechanism of injury among youth hockey players at all levels of competition where it is permitted, accounting for 45% to 86% of injuries.- Several published studies, including two recent systematic reviews, reported on risk factors for injury (including bodychecking) in youth hockey. Emery and colleagues conducted a systematic review of 24 studies and a meta-analysis including only studies which examined policy allowing bodychecking as a risk factor for injury. Policy allowing bodychecking was found to be a risk factor for all hockey injuries, with a summary incidence rate ratio (IRR) of 2.45 (95% CI 1.7 to 3.6). Furthermore, policy allowing bodychecking was found to be a risk factor for concussion, with a summary OR of 1.71 (95% CI 1.2 to 2.44). These data confirm that bodychecking increases the risk of all injuries and the risk of concussion specifically. Nine of ten studies examining policy allowing bodychecking provided evidence to support a greater risk in bodychecking leagues. The second systematic review found the RR of injury associated with policy allowing bodychecking ranged from 0.6 to 39.8; all but one of these studies found an increased risk of injuries associated with bodychecking.
Since the publication of these systematic reviews there have been five additional studies. A Canadian prospective cohort study compared injury rates between peewee ice hockey players in a league where bodychecking is permitted at age 11 years (Alberta) versus players in a league where bodychecking is not permitted until age 13 (Quebec). During the 2007/2008 season, a validated injury surveillance system was used to capture all injuries requiring medical attention and/or time loss from hockey (ie, time between injury and return to play) in 2154 players. There was a threefold increased risk of all game-related injuries (IRR =3.26 [95% CI; 2.31 to 4.60]) and of injury resulting in >7 days time lost from sport (IRR=3.30 [95% CI; 1.77 to 6.17]) in 11- to 12- year-old peewee players from Alberta when compared with Quebec. There was also an almost fourfold increased risk of game-related concussion (IRR=3.88 [95% CI; 1.91 to 7.89]) in Alberta peewee players. Further evidence was reported in a five-year cohort study (2002 to 2007) including all age groups, which demonstrated that injury risk increases 3.75 times (IRR=3.75 [95% CI; 1.51 to 9.74]) in leagues that allow bodychecking compared with those that do not.
A second prospective cohort study by Emery et al examined whether the introduction of bodychecking at 11 years of age (Alberta) or 13 years of age (Quebec) affected injury rates in later years (at 13 to 14 years of age). During the 2008/09 season, the same injury surveillance system cited above was used to study 1971 bantam players (13- to 14-year-olds). There was no reduction in game-related injury risk (all injuries) for this age group (IRR=0.85 [95% CI 0.63 to 1.16]), of concussion specifically (IRR=0.84 [95% CI 0.48 to 1.48]), or of concussions resulting in >10 days time lost from sport (IRR=0.6 [95% CI 0.26 to 1.41]) in the Alberta league, compared with Quebec. In fact, the concussion rate found in Alberta peewee players was higher than in bantam players in either province. Injuries to bantam players resulting in >7 days time lost from sport were reduced by 33% (IRR=0.67 [95% CI 0.46 to 0.99]) in the Alberta league, where players had had two years of bodychecking experience. However, these findings must be interpreted in light of the three- to fourfold greater injury and concussion risk among peewee players in Alberta, along with a possibly higher 'survival effect' among peewee players moving on to bantam in Quebec when compared with Alberta, where bodychecking is allowed in peewee league play.
Recent retrospective studies have examined the influence of policy change based on the Canadian Hospitals Injury Reporting and Prevention Program (CHIRPP) surveillance data. Injury rates among boys presenting to emergency departments in the Kingston, Ontario area both before and after the 2002 rule change to allow bodychecking in younger players, were reported. There was no change between bodychecking injury rates in 1997 to 2002 (with bodychecking introduced at 11 years of age) and 2003 to 2007 (when bodychecking was introduced at nine years of age). Overall rates of injury actually declined over the later period. However, this retrospective study may also be biased by stronger rule enforcement, better coaching certification and temporal declines in emergency department use for this type of injury over that period. In contrast, retrospective research of CHIRPP data from 1994 to 2004 in five Ontario hospitals examined injury risk following a rule change in 1998 that allowed bodychecking in nine- and 10-year-old hockey players. A 2.2 times greater risk of injury in atom players (9 and 10 years of age) after the rule change was reported (OR=2.2 [95% CI 1.7 to 2.84]). Another retrospective study using CHIRPP data (from 1995 to 2002) compared hockey injuries in children 10 to 13 years of age playing in Ontario, where bodychecking was allowed, with data from Quebec, where bodychecking was not allowed. There was a 2.6 times greater risk of bodycheck-related injuries reported for this age group when bodychecking was allowed (OR=2.65 [95% CI 2.21 to 3.18]).
OTHER RISK FACTORS
After policy that permits bodychecking, the most commonly investigated risk factors for injury in the scientific literature are: age, session-type (ie, a practice versus a game), level of play, player position, physical size, and a previous history of injury and/or concussion. Most studies examining age found that injury risk increased with age; others suggest no elevated injury risk in older age groups.- Relative age has been examined to "describe the potential advantages (or disadvantages) that result from age differences between peers within one age group". One study examining relative age among hockey players found no evidence that younger (or older) players within a grouping were at elevated injury risk. Additional research supports this finding at the peewee level, where no increased risk was found in first-year players. In bantam leagues, however, there was a 40% greater risk of injury in first-year players when compared with players in their second year.
Based on session-type, injury risk is reported to be consistently higher in games than in practices, with RR estimates ranging from 2.45 to 6.32. One study also indicated that injury rates were higher in regular season play than during preseason, postseason or tournament games.
In general, studies examining level of play have found that injury risks rise with increasing skill levels across all age groups. However, one study reported that only peewee players in the highest skill division were at the greatest risk of injury, with no significant increase by skill level in other age groups. Larger cohort studies confirmed a consistently greater risk of injury among peewee players who were more highly skilled, but this trend was not observed in the bantam age group.
When examining player position, some researchers found that forwards were at higher risk of injury than defencemen or goalies,  while others reported the relative risk of injury was 2.18 times higher for defencemen than forwards. In all three studies, goalies were shown to be at much lower risk than other players. Additional research shows a consistent protective effect for goalies at both the peewee and bantam levels.
Research on player size has shown conflicting results, with some studies citing increased risk for smaller players in some age groups. Prospective Canadian data show a significantly greater risk of injury in peewee players in the lowest 25th percentile by weight,  though this finding was not reflected in the bantam cohort. However, additional research has found lighter bantam players to be at greater risk, while other studies report a significant weight difference, at all levels, between players who sustained a bodychecking-related injury and those who did not. Other research examining body weight as a risk factor for shoulder injuries found that heavier players were at greater risk for these injuries. One study looked at height as a possible risk factor for injury and found no evidence of effect among bantam players.
By contrast, a history of previous injury or concussion is consistently reported as a significant risk factor for reinjury and further concussion, respectively. One recent Canadian peewee cohort study showed that the risk of injury doubled for players who reported being injured within the past year (IRR=2.07 [95% CI 1.49 to 2.86]), while the risk of concussion tripled for players reporting any previous concussion (2.76 [95% CI 1.1 to 6.91]). The bantam cohort also showed greater risk of reinjury and concussion in players reporting previous injury within the past year (IRR=1.39 [95% CI 1.13 to 1.71]) or any previous concussion (IRR=1.87 [95% CI 1.19 to 2.94]), respectively.
INJURY PREVENTION AND RISK REDUCTION
Injury prevention and risk reduction programs have been implemented but have not been evaluated rigorously. The STOP (Safety Towards Other Players) program (www.safetytowardsotherplayers.com) is supported by the Ontario Minor Hockey Association (www.omha.net), and includes an education component and the "STOP patch", which is sewn on the back of players' uniforms to remind opponents not to hit from behind. A study evaluating another injury prevention program, "Fair Play", which awards points for sportsmanlike play (based on penalty minutes), suggests an approximate 60% reduction in the risk of injury (OR=0.41 [95% CI 0.11 to 1.47]) where the program is in effect, but the results were not statistically significant.
Players, parents, coaches, officials and trainers must be mindful of the potential risks of playing hockey. Hockey Canada has player development, coaching, education and safety promotion programs and resources for coaches, officials, players and parents at www.hockeycanada.ca. Concussion awareness is vital. Athletes and all those involved in their care need to know about the risks, symptoms/signs and how to manage concussive injuries. The CPS statement on concussion evaluation and management is essential reading , with additional information available from the Canadian Academy of Sport and Exercise Medicine (www.casm-acms.org), ThinkFirst Canada (www.thinkfirst.ca) and the US Centers of Disease Control and Prevention (www.cdc.gov/ncipc/tbi/Coaches_Tool_Kit.htm).
Studies consistently identify bodychecking as the primary mechanism of hockey-related injuries, including concussion. It is expected that delaying the introduction of bodychecking until the bantam level and restricting bodychecking to elite leagues for older age groups will reduce the risks of injury and concussion substantially. Delaying bodychecking until bantam will have a clear benefit in reducing the risks of injury and concussion in young ice hockey players. Bodychecking should be eliminated from recreational youth ice hockey and the age at which it is introduced in competitive hockey leagues should be reconsidered. Both initiatives require policy change in many provinces/territories in Canada, and policy changes will need to be evaluated on a regular basis in light of emerging research.
The Canadian Paediatric Society recommends the following:
* Eliminating bodychecking from all levels of organized recreational/non-elite competitive male ice hockey. (Grade II-2A evidence) *
* Delaying the introduction of bodychecking in elite male competitive leagues until players are 13 to 14 years of age (bantam level) or older. (Grade III-C evidence)*
* Implementing Hockey Canada's four-stage skill development program for bodychecking (body positioning, angling, stick checking and body contact) for all leagues.
* Educating coaches and trainers, schools, and policy-makers in sport about the signs and symptoms of common hockey injuries, especially concussion.
* Improving injury surveillance to better identify the risk factors for, and mechanisms of, hockey injuries.
* Policies to reduce injury and promote fair play in hockey, for all age groups and league levels.
Clinicians who see young hockey players in their practice should offer the following advice:
* Girls and young women should continue participating in non-bodychecking leagues.
* Boys should play in recreational/non-elite hockey leagues that do not allow bodychecking.
* Elite male players should play in hockey leagues that introduce bodychecking later, when players are 13 to 14 years of age (bantam level) or older.
* All players should adhere to fair play and a non-violent sport culture.
* Parents and caregivers should learn injury prevention and risk reduction strategies, including concussion prevention, recognition and management.
*The levels of evidence and strength of recommendations are based on the Canadian Task Force on Preventive Health Care (See Table 1). 
TABLE 1: [SEE PDF]
Levels of evidence and strength of recommendations
Level of evidence
Evidence obtained from at least one properly randomized controlled trial.
Evidence obtained from well-designed controlled trial without randomization.
Evidence obtained from well-designed cohort or case-controlled analytical studies, preferably from more than one centre or research group.
Evidence obtained from comparisons between times and places, with or without the intervention. Dramatic results in uncontrolled experiments could also be included in this category.
Opinions of respected authorities, based on clinical experience, descriptive studies or reports of expert committees.
There is good evidence to recommend the clinical preventive action.
There is fair evidence to recommend the clinical preventive action.
The existing evidence is conflicting and does not allow a recommendation to be made for or against use of the clinical preventive action; however, other factors may influence decision-making.
There is fair evidence to recommend against the clinical preventive action.
There is good evidence to recommend against the clinical preventive action.
There is insufficient evidence to make a recommendation; however, other factors may influence decision-making.
This statement was reviewed by the Community Paediatrics and Injury Prevention Committees of the Canadian Paediatric Society. Thanks to Drs. Claire MA LeBlanc, Stan Lipnowski, Peter Nieman, Christina G Templeton and Thomas J Warshawski for their input as past members of the CPS Healthy Active Living and Sports Medicine Committee.
HEALTHY ACTIVE LIVING AND SPORTS MEDICINE COMMITTEE
Members: Catherine Birken MD; Tracey L Bridger MD (Chair); Mark E Feldman MD (Board Representative); Kristin M Houghton MD; Michelle Jackman MD; John F Philpott MD
Liaison: Laura K Purcell MD, CPS Paediatric Sports and Exercise Medicine Section
Principal authors: Kristin M Houghton MD; Carolyn A Emery PT PhD
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Disclaimer: The recommendations in this position statement do not indicate an exclusive course of treatment or procedure to be followed. Variations, taking into account individual circumstances, may be appropriate. Internet addresses are current at time of publication.
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.
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.
Dear Minister Freeland:
We are a national consortium of experts who serve and advocate for the needs and rights of older people. We are delighted by the recent appointment of a new Minister of Seniors, and send our congratulations to the Honourable Filomena Tassi. We are also encouraged by our Government’s commitment to support the health and economic well-being of all Canadians, and heartened by your promise to listen to, and to be informed by feedback from Canadians. It is in this spirit that we are writing today regarding the need for Canada to provide support and leadership with a goal of developing and ratifying a United Nations (UN) Convention on the Rights of Older Persons.
In the context of massive global demographic shifts and an aging population, insightful and careful reflection by the leaders of our organizations has led to universal and strong support for the creation and implementation of a UN Convention to specifically recognize and protect the human rights of our older persons.
A UN Convention on the Rights of Older Persons will:
enshrine their rights as equal with any other segment of the population with the same legal rights as any other human being;
categorically state that it is unacceptable to discriminate against older people throughout the world;
clarify the state’s role in the protection of older persons;
provide them with more visibility and recognition both nationally and internationally, which is vitally important given the rate at which Canadian and other societies are ageing;
advance the rights of older women at home and as a prominent factor in Canada’s foreign policy;
have a positive, real-world impact on the lives of older citizens who live in poverty, who are disproportionately older women, by battling ageism that contributes to poverty, ill-health, social isolation, and exclusion;
support the commitment to improve the lives of Indigenous Peoples; members of the LGBTQ community, and visible and religious minorities; and,
provide an opportunity for Canada to play a leadership role at the United Nations while at the same time giving expression to several of the Canadian government’s stated foreign policy goals.
We have projected that the cost and impact of not having such a Convention would have a significant negative impact on both the physical and mental health of older Canadians. The profound and tragic consequence would have a domino effect in all domains of their lives including social determinants of health, incidence and prevalence of chronic diseases, social and psychological functioning, not to mention massive financial costs to
society. There is recognition of this need internationally and ILC-Canada, along with other Canadian NGOs and organizations have been active at the UN to help raise awareness of the ways a UN Convention on the Rights of Older Persons would contribute to all countries.
Changes have already been implemented by our Government that are consistent and aligned with a UN Convention, such as improving the income of vulnerable Canadian seniors, funding for long term care and support for community based dementia programs. These initiatives are all in keeping with support for a Convention on the Rights of Older Persons. They are also reflective of our country’s commitment to engage more fully with the United Nations and provide Canada the stage to demonstrate leadership on a vital international issue. It is an opportunity to champion the values of inclusive government, respect for diversity and human rights including the human rights of women.
Scientific evidence demonstrates that human rights treaties help to drive positive change in the lives of vulnerable groups of people. In many countries in the world, older people are not adequately protected by existing human rights law, as explicit references to age are exceedingly rare. Even in countries like Canada, where there are legal frameworks that safeguard older people, a Convention would provide an extra layer of protection, particularly if the Convention has a comprehensive complaints mechanism.
Older adults need to be viewed as a growing but underutilized human resource. By strengthening their active role in society including the workforce, they have tremendous capacity, knowledge, and wisdom to contribute to the economy and general well-being of humankind.
We are requesting you meet with our representatives, to discuss the vital role of a UN Convention on the Rights of Older Persons and the role your government could play in improving the lives of older people in Canada and around the world. The fact that Canada is ageing is something to celebrate. We are all ageing, whether we are 20 or 85. This is a ”golden opportunity” to showcase Canada as a nation that will relentlessly pursue doing the “right thing” for humanity by supporting a UN Convention that ensures that our future is bright.
Please accept our regards, and thank you for your attention to this request. We await your response. Sincerely,
Margaret Gillis, President, International Longevity Centre Canada
Dr. Kiran Rabheru, Chair of the Board, International Longevity Centre Canada
Linda Garcia, Director, uOttawa LIFE Research Institute
cc: The Right Honourable Justin Trudeau Prime Minister of Canada
The Honourable Filomena Tassi Minister of Seniors
The Honourable Jean Yves Duclos
Minister for Families, Children and Social Development
Ambassador Marc-Andre Blanchard
Permanent Representative to Canada at the United Nations
The Honourable Ginette Petitpas Taylor
International Longevity Centre Canada
Dr. Kiran Rabheru
Chair of the Board, International Longevity Centre Canada
Linda Garcia, PhD
LIFE Research Institute
Dr. Laurent Marcoux
Canadian Medical Association
Andrew Padmos, BA, MD, FRCPC, FACP
Chief Executive Officer
Dani Prud’Homme Directeur général FADOQ
Peter Lukasiewicz Chief Executive Officer Gowling WLG
Dr. Dallas Seitz, MD, FRCPC
Dr. Frank Molnar
President, Canadian Geriatrics Society
Dr. David Conn
Canadian Coalition for Senior’s Mental Health
Director - Canadian Coalition for Seniors’ Mental Health
Chief Executive Officer, Speech-Language & Audiology Canada
President Canadian Nurses Association
Janice Christianson-Wood, MSW, RSW Title/Organization: President, Canadian Association of Social Workers / Présidente, l’Association canadienne des travail-
Chief Executive Officer/Chef de la direction
Ondina Love, CAE
Chief Executive Officer Canadian Dental Hygienists Association
National Association of Federal Retirees /Association nationale
des retraités fédéraux
Laura Tamblyn Watts
National Initiative for the Care of the Elderly
Dr. Keri-Leigh Cassidy
Founder Fountain of Health
Dr. Beverley Cassidy Geriatric Psychiatris Seniors Mental Health
Dalhousie University Dept of Psychiatry
Jenny Neal and Janet Siddall
CO Chairs, Leadership Team Grandmothers Advocacy Network (GRAN)
President and CEO
Dr. Becky Temple, MD, CCFP, CCPE
Medical Director Northeast, Northern Health Medical Lead Privilege Dictionary Review, BCMQI
J. Van Aerde, MD, MA, PhD, FRCPC
Clinical Professor of Pediatrics - Universities of Alberta & British Columbia, Canada
Associate Faculty - Leadership Studies - Royal Roads Univ, Victo- ria, BC, Canada
Past-President - Canadian Society of Physician Leaders Editor-in-Chief / Canadian Journal of Physician Leadership
Dr. Rollie Nichol, MD, MBA, CCFP, CCPE
Associate Chief Medical Officer, Alberta Health Services
Dr. Shannon Fraser, MSc, FRCSC, FACS
Secretary / Treasurer, CSPL Chief General Surgery Jewish General Hospital
Linda Gobessi MD FRCPC
Geriatric Psychiatry Community Services of Ottawa Ottawa
Executive Director / Directrice générale
Services communautaires de géronto- psychiatrie d’ Ottawa Geriatric Psychiatry Community Services of Ottawa
Ging-Yuek Robin Hsiung, MD MHSc FRCPC FACP FAAN
Ralph Fisher and Alzheimer Society of BC Professor Director of Clinical Research
Director of Fellowship in Behavioural Neurology UBC Hospital Clinic for Alzheimer and Related Disorders
Division of Neurology, Department of Medicine University of British Columbia
Senior Social Worker Baycrest Health Sciences
Harinder Sandhu, D.D.S., Ph.D
Professor and Past Director
Schulich Dentistry & Vice Dean, Schulich School of Medicine & Dentistry
Dr. Christopher Frank,
Chair of Geriatric Education and Recruitment Initiative
Jennie Wells, MD
Associate Professor, University of Western Ontario Department of Medicine
Chair/Chief Division of Geriatric Medicine Parkwood Institute
Laura Diachun, MD
Program Director, Undergrad Geriatric Education University of Western Ontario
Department of Medicine, Division of Geriatric Medicine Parkwood Institute
Sheri-Lynn Kane, MD Program Director Internal Medicine Dept of Medicine Education Office
Niamh O’Regan, MB ChB,
Assistant Professor, University of Western Ontario Parkwood Institute
Michael Borrie, MB ChB, FRCPC
Professor, University of Western Ontario Department of Medicine, Division of Geriatric Medicine
Jenny Thain, MRCP (Geriatrics)
Assistant Professor, University of Western Ontario Department of Medicine, Division of Geriatric Medicine Victoria Hospital
Peter R. Butt MD CCFP FCFP
Assoc. Professor, Department of Family Medicine, College of Medicine,
University of Saskatchewan
Mamta Gautam, MD, MBA, FRCPC, CCPE Dept of Psychiatry, University of Ottawa Psychiatrist, Psychosocial Oncology Program, The Ottawa Hospital
President and CEO, PEAK MD Inc.
Dr. Shabbir Amanullah
Arun V. Ravindran, MBBS, MSc, PhD, FRCPC, FRCPsych
Professor and Director, Global Mental Health and the Office of Fellowship Training, Department of Psychiatry,
Graduate Faculty, Department of Psychology and Institute of Medical Sciences, University of Toronto
Sarah Thompson, MD, FRCPC Geriatric Psychiatrist Seniors’ Mental Health Team
Addictions and Mental Health Program
Louise Plouffe, Ph.D.
Director of Research, ILC Canada (retired)
Kimberley Wilson, PhD, MSW
Assistant Professor, Adult Development & Aging, Department of Family Relations & Applied Nutrition, University of Guelph
Andrew R. Frank M.D. B.Sc.H. F.R.C.P.(C)
Cognitive and Behavioural Neurologist Medical Director, Bruyère Memory Program Bruyère Continuing Care
Diane Hawthorne Family Physician BSc, MD, CCFP, FCFP
Dr. Ken Le Clair
Prof Emeritus Queens University and. Lead Policy Physician Consultant to Ontario. Seniors Behavioral Support Initative Queens University
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
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