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Turning the Corner: From Debate to Action: Presentation to the Standing Committee on Finance Pre-Budget Consultations

https://policybase.cma.ca/en/permalink/policy1959
Last Reviewed
2010-02-27
Date
2002-10-22
Topics
Health systems, system funding and performance
  2 documents  
Policy Type
Parliamentary submission
Last Reviewed
2010-02-27
Date
2002-10-22
Topics
Health systems, system funding and performance
Text
Canadians are deeply concerned about their health care system. They worry about situations such as whether they will have access to diagnostic testing when they need it or whether they can get a family physician if they move to a new community. This is not what was envisioned when Canada embarked upon a universal public health care system in 1966. Over the past two years an unprecedented number of reports and commissions have been examining what can and must be done to ensure the long-term sustainability of the system. But Canadians are growing inpatient. The time for studying the issues is quickly passing. They are counting on governments, to listen to the reports and then act upon them quickly – turning the corner from debate to action. This year’s submission from the CMA to the Standing Committee on Finance focuses on the need for action in the short and longer terms by identifying strategic investments that will ensure a strong health care system that is securely supported by a dependable and comprehensive public health infrastructure as its foundation. Hand in hand with new financing, the CMA firmly believes that additional financing must be accompanied by updated governance structures, including a Canadian Health Charter and a Canadian Health Commission that can inject real accountability into the system. The CMA believes that the federal government has responsibility, alongside the provinces and territories, to increase its financial support of Canada’s health care system. Only by increasing funding and identifying clearly the amount allocated to health will the federal government be able to regain its position as an equal player with the provinces. In our submission to the Commission on the Future of Health Care in Canada, the CMA recommended that the federal contribution to the public health care system be locked in for a 5-year period. We indicated that the longer-term goal would be for the federal contribution to rise to 50% of total spending for core services over time as new and improved services and technologies products became available. We also said that it should be tied to a built-in GDP-growth escalator once that target is reached. To be specific, in order to raise funding to the 50% target level the CMA recommends that funding for new services and technologies be introduced on a 50/50 cost-sharing basis. This would encourage provinces and territories to become early adopters of new technology and help to update the basket of core services available to Canadians. For illustration purposes the CMA recommends an initial investment of $16 billion over the first five years starting in 2003/04 with the majority of that funding weighted towards the back-end of the five-year period. This investment would take us partway (45 federal/55 provincial cost sharing) towards reaching our goal of 50/50 cost sharing. To further support funding for health care across the country, a buffer is needed to protect provincial and territorial health care budgets from the ebbs and flows of the economic cycle. This could be done, for example, by renewing the Fiscal Stabilisation Program or removing the cap on the current Equalisation program. In conjunction with the longer-term financing needs of Canada’s health care system, there are some urgent objectives that cannot wait for governments to finalise and implement their plan. The pressing nature of these issues warrants the use of one-time, targeted, special-purpose transfers in the areas of health human resources supply and training; capital infrastructure; and health information technology. Finally, last year, our submission reflected Canadians’ concerns following the September 11, 2001 events in the United States. It highlighted people’s anxiety about security in our country, the safety of our airlines and the vulnerability of our public health infrastructure and health care systems to potential threats. We believe that this work has not been completed and there is ongoing need to support public health as a priority for Canada’s health care system particularly in the areas of emergency preparedness, childhood immunisation and a national drug strategy. Reform of Canada’s health care system is a formidable task. It involves the participation and agreement of all levels of government as well as providers, other stakeholders and ultimately the acceptance of the end-users, Canadians. The CMA looks forward eagerly to the Romanow Commission’s recommendations and those of the Senate Committee. We will be watching carefully over the coming months on behalf of Canadian physicians, and our patients, to ensure that these discussions result in a timely, action-oriented response and that involvement of the community of providers is early, ongoing and meaningful. Canadian physicians are ready to do our part, all we ask is for the opportunity. INTRODUCTION The Canadian Medical Association (CMA) values participating once again in the Standing Committee on Finance’s Pre-Budget Consultations process. We see these consultations as an essential part of Canada’s democratic process, allowing non-government organisations and individuals the opportunity to provide input into the government’s fiscal agenda. We know Canadians value their health care system and the high-quality treatment they receive. What concerns them is whether they’ll be able to access the care they need when and where they need it. The past two years have seen the most significant public concern over Canada’s health care system in a generation. Governments have responded by examining the system through an unprecedented number of reports and commissions. In addition to the Commission on the Future of Health Care in Canada (the Romanow Commission) and the Standing Senate Committee on Social Affairs, Science and Technology’s work on the state of the health care system (the Kirby Commission), since 2000 there have been four other major provincial reviews of health care systems in Canada.i Canadians are now looking to governments to turn the corner from studying what needs to be done to acting upon this work. This year’s submission from the CMA to the Standing Committee on Finance focuses on this need for action in the short and longer terms by identifying strategic investments that will ensure a strong health care system that is securely supported by a dependable and comprehensive public health infrastructure as its foundation. In this way, it is the belief of the CMA that health and health care go hand in hand. The CMA believes that to achieve real reform, more than “tweaking” of our current system is required. We see change as requiring a fundamental rethinking of the system including its governance and accountability structures in order to move forward and turn the corner towards a sustainable health care system. The momentum created with the release of the Romanow Commission’s report provides a unique opportunity for the federal government, in partnership with the provinces and territories, to capitalise on that energy by responding in a substantive way to the report within 100 days of its release with an implementation plan. We were very encouraged by the commitment made in the September 30, 2002 Speech from the Throne to hold a First Ministers’ Meeting early in 2003 to put in place a comprehensive plan for reform. We were also encouraged by the commitment to an action plan in the areas of health policy under direct federal jurisdiction such as addressing emerging health risks and the adoption of modern technology. We will be watching carefully over the coming months on behalf of Canadian physicians, and our patients, to ensure that these discussions result in a timely, action-oriented response and that involvement of the community of providers is early, ongoing and meaningful. ACCOUNTABILITY On June 6, 2002, the CMA released its final submission to the Romanow Commission, A Prescription for Sustainability. In this submission, we outlined what the Commissioner called “bold and intriguing” changes to reaffirm and realign our health care system. Specifically, the CMA report laid out an approach for the renewal of Canada’s health care system comprised of three essential interrelated components: a Canadian Health Charter; a Canadian Health Commission; and renewal of the federal legislative framework (including federal-provincial fiscal transfers). Canada’s health care system does not have the governance structures in place to provide for real accountability or transparency. Often governments meet behind closed doors and make decisions with little or no input from those who ultimately have to implement change and use the system. Rather, full accountability requires the involvement of all key players – federal and provincial/territorial governments, health care providers and patients. Fundamentally, the current lack of accountability in Canada’s health care system comes down to an inherent conflict of interest between public accountability, which Canadians are demanding, and governments’ desire to retain maximum fiscal control and flexibility. Even with increased cash transfers identified in the September 2000 First Ministers Accord, the federal government has fallen well short of providing the necessary funding to ensure compliance with national principles today and for the future. Clearly, the financial means must be equal to the desired health outcomes. The CMA believes that with appropriate financial reinvestment and updated governance structures the federal government will be on the path towards putting national back into national heath care insurance system. Canadian Health Charter Currently, neither the Canada Health Act nor the Charter of Rights and Freedoms offers Canadians an explicit right of access to quality health care delivered within an acceptable time frame.ii Increasingly, this has resulted in an unacceptable degree of uncertainty not only for patients but also for health care providers and ultimately for those (both private and public) who contribute to the financing of the health care system. A Canadian Health Charter would underline governments’ shared commitment to ensuring that Canadians have access to quality health care within an acceptable time frame. It would clearly articulate a national health policy that sets out our collective understanding of Medicare and the rights and mutual obligations of individual Canadians, health care providers, and governments. Canadian Health Commission Creating a permanent, independent Canadian Health Commission, would help address the lack of transparency and accountability at the national level. It would create an institution, the very purpose of which would be to report annually to Canadians on the performance of the health care system and the health status of the population. It would put health on the same level as other national priorities such as the environment, transportation and research. Its legitimacy would be strengthened by not having to report to any one government or governments. Rather it would forge a direct reporting relationship with Canadians and not leave Canadians hostage to ongoing inter-governmental disputes. A Canadian Health Commission would also be uniquely situated to provide ongoing advice and guidance on other key national health care issues. Issues such as: defining the basket of core services that would be publicly financed; establishing national benchmarks for timeliness; accessibility and quality of health care; planning and coordinating health system resources at the national level; and developing national goals and targets to improve the health of Canadians. ENHANCED ACCOUNTABILITY * Implement a Canadian Health Charter and provide federal funding for a permanent Canadian Health Commission to reaffirm Medicare’s social contract and to promote accountability and transparency within the health care system. FINANCING REQUIREMENTS Long-Term Investments Improved accountability is an essential, but not complete, answer with respect to reforming Canada’s health care system. The CMA believes that the federal government has a responsibility, alongside the provinces and territories, to increase its financial support of Canada’s health care system. At the same time, the CMA also believes that governments must provide financing in an accountable and transparent manner that links the funding sources with the use of those funds. The way we see it, much of the current tension between the two levels of government on health care issues can be traced back to unilateral federal changes to the funding formula. It started with the first changes to the Established Programs Financing (EPF) in 1982, and culminated with the introduction of the Canada Health and Social Transfer (CHST – 1995) when the federal government unilaterally announced substantially reduced funding for health, social services and post-secondary education. By claiming to spend the same taxpayers dollar three times – once for health, again for post secondary education and again for social services – the federal government’s moral authority to uphold national principles for health is undermined. Together, these initiatives weaken the federal government’s legitimacy in health care and encumber its ability to stand-up for Canadians, as was highlighted in the most recent Auditor General’s report. In order to regain this authority the federal government must be willing to clearly identify a discrete contribution to health care that is large enough so as to be relevant in all jurisdictions. In our submission to the Commission on the Future of Health Care in Canada, we recommended that the federal contribution to the public health care system be locked in for a 5-year period. We indicated that the longer-term goal would be for the federal contribution to rise to 50% of total spending for core services over time as new and improved services and technologies became available. We also said that it should be tied to a built-in GDP-growth escalator once that target is reached. This submission provides more detailed financial projections and recommendations on the federal contribution to the health care system. To be specific, in order to raise funding to the 50% target level the CMA recommends that financing of new services and technologies be introduced on a 50/50 cost-sharing basis. This would encourage provinces and territories to become early adopters of new technology and help to update the basket of core services available to Canadians. How quickly 50% cost-sharing of all core services were realised would depend on the rate of uptake of new technologies. However, for illustration purposes the CMA recommends an initial investment of $16 billion over the first five years starting in 2003/04 with the majority of that funding weighted towards the back-end of the five-year period. This investment would take us partway (45 federal/55 provincial cost sharing) towards reaching our goal of 50/50 cost sharing. The expectation would also be that expansion beyond the current basket of services would be funded on a 50/50 cost-sharing basis. The key message is that the federal government must be an equal partner with the provinces and territories in providing funding for new pressures. This includes taking measures to meet the needs of Canadians living in rural and remote areas where there are unique considerations with respect to ensuring access to, and support of, physicians and other health care services. To further support funding for health care across the country, a buffer is needed to protect provincial and territorial health care budgets from the ebbs and flows of the economic cycle. As well, varying fiscal capacities of individual provinces and territories has made it increasingly difficult to ensure the provision of reasonably comparable health services across Canada. Currently, the federal Fiscal Stabilisation Program compensates provinces if their revenues fall substantially from one year to the next due to changes in economic circumstances. However, this program is not health-specific and only takes effect when provincial revenues drop by over 5%. The federal Equalisation program also provides some protection for have-not provinces. However, its effectiveness is limited by virtue of the “ceiling provision” that places a cap on increases in payments to the rate of national GDP growth. This provision was temporarily lifted for fiscal year 1999/2000 in conjunction with the September 2000 health accord, generating an additional $700 million in Equalisation payments to the have-not provinces. It is the CMA’s belief that this ceiling is one of the contributing factors to the disparity that exists between provinces in their capacity to provide funding for health care services and as such, should be permanently removed. Making improvements to either or both of these programs would help address the concern raised in the CMA’s submission to the Romanow Commission on the need to provide provinces with ways to curb the impact on the health care system from the ebbs and flows of the business cycle. LONG-TERM FINANCING REQUIREMENTS ($16 Billion over 5 years) * Provide funding for new core services and technologies on a 50/50 cost-shared basis with the ultimate goal of reaching 50% of provincial/territorial spending on core services over time. * Provide greater protection against provincial/territorial revenue shortfalls for example by removing the ceiling on the federal Equalisation program or enhancing the federal Fiscal Stabilisation Program. Short-Term Bridge Financing of Health Infrastructure In conjunction with the longer-term financing needs of Canada’s health care system, there are some urgent objectives that cannot wait for governments to finalise and implement their plan. We think of these shorter-term objectives as requiring “bridge financing” in areas of health infrastructure that are necessary to support health care innovation. As roads and highways are the backbone to the production and delivery of products, so too is Canada’s health infrastructure the foundation on which the health care system delivers care to Canadians. We applaud the Canadian Foundation for Innovation and other similar programs for their important contributions in this area. Increasingly, however, “infrastructure” incorporates more than bricks and mortar – it can also mean providing improving health information capacity in hospitals; providing human resource infrastructure or the latest diagnostic equipment. Experience has taught us that investments of this type lead to increased innovation, productivity and efficiency. The pressing nature of these issues warrants the use of one-time, targeted, special-purpose transfersiii specifically in the areas of: * Health human resources supply and training; * Capital infrastructure; and * Health information technology. Health Human Resources Supply and Training Consistently, Canadians point to the shortage of physicians as a key health care system concern. Factors underlying this shortage include physician demographics (e.g., age and gender distribution), changing lifestyle choices and productivity levels (expectations of younger physicians and women differ from those of older generations), and insufficient numbers entering certain medical fields. According to 2001 data from the Organisation for Economic Co-operation and Development (OECD), Canada ranked 21st out of 26 countries in terms of the ratio of practising physicians to population.iv The need is particularly great in rural and remote areas where 30% of Canadians live but where only approximately 10% of Canadian physicians practice.v This is complicated by the fact that accessing services for patients in rural and remote areas can be difficult. In a survey done by the CMA in 1999, physicians living in rural communities indicated that their level of professional satisfaction – i.e., how they are able to meet the health care needs of their patients – fell significantly since the early 1990s. In a striking example, only 17% reported being very satisfied with the availability of hospital services in 1999 compared to 40% in 1991. The necessary increases in undergraduate enrolment in medicine needed to address this situation require funding not only for the positions themselves, but also for the infrastructure (human and physical resources) needed to ensure high-quality training that meets North American accreditation standards. In addition, capacity must be sufficient to provide training to international medical graduates and allow currently practising physicians the opportunity to return to school to obtain postgraduate training in new skill areas.vi As well, the CMA remains very concerned about high and rapidly escalating increases in medical school tuition fees across Canada. According to data from the Association of Canadian Medical Colleges (ACMC), between 1996 and 2001 average first-year medical school tuition fees increased 100%. In Ontario, they went up by 223% over the same period. Student financial support through loans and scholarships has simply not kept pace with this rapid escalation in tuition fees. Findings from recent research show that high tuition fees and fear of high debt loads create barriers that discourage people to apply to medical school and potentially threaten the socio-economic diversity of future physicians serving the public. They may also exacerbate the “brain drain” of physicians to the United States where newly graduated physicians can pay down their large student debts much more quickly. In addition, high debt loads may influence physicians’ choice of specialty and practice location. Medical Equipment and other Capital Infrastructure The crisis in health human resources is exacerbated by an underdeveloped capital infrastructure - brick, mortar and tools. This is seriously jeopardising timely access to quality care within the health care system. In September 2000, the federal government announced a series of new investments to support agreements by First Ministers on Health Renewal and Early Childhood Development. One of these investments was a two-year $1 billion fund for the provinces and territories, the Medical Equipment Fund (MEF), to purchase new health technologies and diagnostic equipment. However, analysis done by the CMA suggests that of the $1 billion allocated through the Medical Equipment Fund, only approximately 60% was used to pay for new (incremental) expenditures on medical equipment. It appears the remaining 40% replaced what provinces and territories would have already spent in this area from their own funding sources. Additional analysis suggests that there continues to be a significant gap between access in Canada to medical equipment and availability of medical equipment in other OECD countries. Cost estimates suggest that an additional investment of some $1.15 billion in health technology is still needed to bring Canada up to the level of the 7-country OECD comparator country average. Of that amount $650 million is required for capital expenditures and $500 million is required to provide the provinces/territories with 3 years of operating funds. All governments have the responsibility to be transparent and accountable to taxpayers for health care spending. The conditions of the Medical Equipment Fund did not live up to this responsibility. Provinces and territories provided widely variable and often incomplete information that is largely inaccessible to the public, and at the very least difficult to trace. To this end, one of the responsibilities envisioned for a Canadian Health Commission would be to report on the health of health care in Canada and keep Canadians informed as to how their taxpayer dollars are being spent. Health Information Technology While the health sector is as information intensive as other industries, it has lagged behind other sectors in investing in information and communication technologies (ICTs). The benefits that ICT promises to deliver the health care system include better quality care, enhanced access to health services (particularly for those 30% of Canadians living in rural and remote locations), and better utilisation of scarce human health resources. As part of the September 2000 Health Accord, the federal government invested $500 million to create Canada Health Infoway Inc. with a mandate to accelerate the development and adoption of modern systems of information technology, such as electronic patient records. The CMA applauds this investment, but notes that the $500-million needs to be seen as a “down-payment”. It provides only a fraction of the $4.1 billion the CMA estimates it would cost to fully connect the Canadian health care system with all the health benefits that would flow from this in terms of improved national safety and a reduced number of duplicate tests. Studies point to two key ingredients for successful uptake of information and communication technology: creating mechanisms to help people adapt to the new environment and testing out solutions in real work situations before moving to full-scale implementation. To date, very little investment has been directed towards helping providers prepare for new investments in infrastructure being made by the provinces, territories and the federal government. The CMA is prepared to play a pivotal partnership role in achieving the buy-in and cooperation of physicians and other health care providers through a multi-stakeholder process. As well, currently the majority of ICT investments have targeted acute care and primary care settings. Changing demographics in the Canadian population suggest that new pressures are likely to emerge in home care settings – an area that has hitherto been largely neglected with respect to ICT and is currently ill equipped to cope with growing demand. A potential safety valve that could be made available, however, is the application of remote healthcare solutions amenable to care provided in the home. SHORT-TERM BRIDGE FINANCING ($2.5B over five years) * Establish a $1-billion, five-year Health Resources Education and Training Fund. * Increase targeted funding to post-secondary institutions to alleviate some of the pressures driving the rise in tuition fees. Provide enhanced direct financial support to students, in particular, through bursaries and scholarships. * Establish a one-time catch-up fund of $1.15 billion to restore medical equipment to an acceptable level. * Assist providers to improve and/or gain skill sets to work to become more ICT enabled and provide for aggressive piloting of remote ICT solutions. Revenue Sources The proposals as outlined above for the overall financing of the health care system recommend an incremental approach to increased federal support for health care with the more significant investments not beginning until after 2005/06. We feel that this approach would allow for the majority of funds to come from within existing (or anticipated) fiscal frameworks. Within the context of broader discussion, the CMA brought together key experts on September 25, 2002 to discuss issues related to the interface between tax and health. One of the issues discussed was the potential for using earmarked taxes as a mechanism for raising revenue, particularly for short-term capital-type investments. With respect to any new funding mechanism, there was agreement on the need to take into account the principles of fairness, progressivity and horizontal and vertical equity in determining any new source of funding for health care services. While some suggest that efficiencies remain in the system, that if eliminated could provide funding for future health care needs, this is not the view of CMA members working on the front-line of the health care system. CMA’s challenge to governments is to not allow the lack of a revenue source to provide an excuse for not proceeding with health care reform in Canada. The CMA is looking forward to the recommendations in the Kirby and Romanow reports to further inform work in this area. INVESTMENTS IN PUBLIC HEALTH In essence, public health is the organised response by society to protect and promote health and to prevent illness, injury and disability. These efforts require co-ordination and co-operation between individuals, federal, provincial, territorial, and municipal governments, community organisations and the private sector. A major component of public health is focused on the promotion of healthy living to improve the health status of the population and reduce the burden and impact of chronic and infectious diseases. A recent commitment of $4.3 billion in the U.S. for the Centers for Disease Control and Prevention challenges us to equally support activities that further strengthen Canada’s public health system.vii The September 30, 2002 Speech from the Throne noted the importance of a strong public health system and promised to “move ahead with an action plan in health policy areas under its direct responsibility” including addressing emerging risks, adapting to modern technology and emphasizing health prevention activities. We see this as an important commitment and will be watching closely as the plan is developed. In the meantime, we have identified three areas of public health that require more immediate federal assistance. Emergency Preparedness Last year our submission to the Standing Committee addressed the urgent health security and health care issues arising out of the tragic events of September 11, 2001 in the United States. The CMA raised serious concerns with the ability of Canada’s public health care system to respond to disasters and made a number of recommendations to address national preparedness in terms of security, health and capacity of the system. While there has been some movement towards meeting these needs, the CMA firmly believes that there remain significant shortcomings in our capacity to respond to health care emergencies. At the time of an emergency, among the first points of contact with the health system for Canadians are doctors’ offices and hospital emergency rooms. As noted in past CMA submissions to the Standing Committee, we have witnessed in recent years the enormous strain these facilities can face when even something quite routine like influenza strikes a community. Regardless of how well prepared any municipality is, under certain circumstances public health officials will need to turn to the province, territory and/or the federal government for help. The success of such a multi-jurisdictional approach is contingent upon good planning beforehand between the federal, provincial/territorial and local-level governments. There is an important role for the federal government to urgently improve the co-ordination amongst authorities and reduce the variability between various response plans in co-operation with provincial authorities (including assisting in the preparation of plans where none exist). Childhood Immunisation At the beginning of the last century, infectious diseases were the leading cause of death worldwide. In Canada, they are now responsible for less than 5% of all deaths thanks to immunisation programs. Immunisation protects an entire population by preventing the spread of disease from one individual to another: the more people immunised, the less chance of disease. To minimise the spread of vaccine-preventable diseases the maintenance of very high levels of immunisation is required. The National Advisory Committee on Immunisation (NACI) has provided general Canadian recommendations on the use of vaccines, drawing upon the expertise of specialists in public health, infectious diseases and paediatrics from across the country. Canadian children in all provinces are routinely immunised against nine diseases. For approximately $150 worth of vaccines, a Canadian child can be vaccinated against these diseases from infancy to adolescence, the impact of which can last a lifetime. Unfortunately, the level of immunisation varies across Canada. This is unacceptable. All children in Canada should and must have the protection that current science has made available against vaccine-preventable diseases according to the recommendations of public health experts. The CMA recommends a two-step strategy. First we encourage the federal government to work with the provinces and territories to jointly develop goals in the area of vaccination, such as linking record-keeping systems, implementing vaccine safety guidelines and seeking purchasing partnerships. Second, we urge the federal government to work within this framework to ensure that three new vaccines be introduced across the country to prevent children from contracting varicella (chicken pox); meningitis and pneumococcus (the leading cause of invasive bacterial infections, bacterial pneumonia and middle ear infection in children). National Drug Strategy The development of a national strategy for addressing issues related to illicit drug use should be a priority for federal leadership and investment. Illicit drug use has adverse effects on the personal health of Canadians and the well-being of society. The CMA believes that the government must take a broad public-health policy approach to address illicit drug use. A single-handed criminal justice approach to dealing with illicit drug use is inappropriate particularly when there is increasing consensus that it is ineffective and exacerbates harm. Addiction should be regarded as a disease and therefore, individuals suffering with drug dependency should be diverted, whenever possible, from the criminal justice system to treatment and rehabilitation. We applaud the recent commitment in the September 30, 2002 Speech from the Throne to implement a national drug strategy to address addiction while promoting public safety. In keeping with this, the CMA urges the government to fully implement and evaluate a national drug strategy prior to proceeding with any movement toward changes in the legal status of marijuana. INVESTMENTS IN PUBLIC HEALTH ($700 million over three years) * Create an assistance fund for municipal and provincial authorities to support public health infrastructure renewal at a local level, improve the co-ordination among public health officials, police, fire and ambulance services, hospitals and other services and to support the infrastructure for public health emergency response. * Continue to invest in the resources and infrastructure (i.e., medical supplies, equipment, laboratory facilities, and training for health care professionals) needed to anticipate and respond to disasters. * Implement a National Immunisation Strategy to achieve the optimal level of immunisation for all Canadians and ensure coverage of all children with routinely recommended childhood vaccines. * Develop a comprehensive national drug strategy on the non-medical use of drugs that re-balances the distribution of resources so that a greater proportion is allocated to drug treatment, prevention, cessation and harm reduction. CONCLUSION Reform of Canada’s health care system is a formidable task. It involves the participation and agreement of all levels of government. It also requires that providers, other stakeholders and ultimately the acceptance of the end-user, Canadians are at the planning table. The Commission on the Future of Health Care in Canada, over the past year and a half, has undertaken a vast review of the issues impacting Canada’s health care system including Canadians’ values. As providers of care at the front-line of the health care system, Canadian physicians see themselves as key partners in this reform. The CMA will be looking eagerly at the Romanow Commission’s recommendations and those of the Senate Committee. We will be holding the federal, provincial and territorial governments accountable for implementing, in a timely fashion, a response with clear deliverables. Clearly, we see the report’s release as offering a short window of opportunity to turn the corner on health care system reform. We need to act now and not just wait for the system to fix itself. Canadian physicians are ready to do our part, all we ask is for the opportunity. ENDNOTES i Since 2000 there have been four major provincial reviews of their health care systems (Caring for Medicare: Sustaining a Quality System (the Fyke Commission), April 2001; la commission d’étude sur les services de santé et les services sociaux (the Clair Commission); Patients First: Renewal and Reform of British Columbia’s Health Care System, December 2001; A Framework for Reform: Report of the Premier’s Advisory Council on Health (the Mazankowski Report), January, 2002. ii A recent article by Patrick Monahan and Stanley Hartt published by the C.D. Howe Institute argues that Canadians have a constitutional right to access privately-funded health care if the publicly funded system does not provide access to care in a timely way. iii Precedents for these types of transfers include the National Health Grants Program created in 1948 to develop hospital infrastructure across the country. More recently, several funds were created to support early child development, medical equipment, the health infoway and primary care renewal at the time of the First Ministers’ Agreement on Health in September 2000. iv Organisation for Economic Cooperation and Development. Health at a Glance. Paris, France: OECD; 2001. v The CMA has developed a policy on Rural and Remove Practice Issues which was released on October 17, 2000 (CMAJ, October 17, 2000, Vol. 163 (8)). vi Canadian Medical Forum membership includes: CMA, Association of Canadian Medical Colleges, College of Family Physicians of Canada, Royal College of Physicians and Surgeons of Canada, Canadian Federation of Medical Students, Canadian Association of Interns and Residents, Federation of Medical Licensing Authorities of Canada, Medical Council of Canada, and Association of Canadian Academic Healthcare Organizations. vii As announced on December 20, 2001 by the United States Department of Health and Human Services. Copy available at: http://www.hhs.gov/news
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A Prescription for SUFA : CMA Submission to the F/P/T Ministerial Council on Social Policy Renewal

https://policybase.cma.ca/en/permalink/policy1961
Last Reviewed
2010-02-27
Date
2002-10-18
Topics
Pharmaceuticals/ prescribing/ cannabis/ marijuana/ drugs
Health systems, system funding and performance
  1 document  
Policy Type
Parliamentary submission
Last Reviewed
2010-02-27
Date
2002-10-18
Topics
Pharmaceuticals/ prescribing/ cannabis/ marijuana/ drugs
Health systems, system funding and performance
Text
It has been over three years since the Social Union Framework Agreement (SUFA) was signed by the federal and provincial/territorial governments, with the exception of Quebec. At the time, it was heralded as an important breakthrough in federal-provincial relations that would clear the way for greater intergovernmental cooperation on pressing social policy issues such as health care renewal. Functional federalism is essential to achieving social policy objectives that will be of benefit to Canadians from coast to coast. While SUFA may not be perfect, it is better than the alternative of federal-provincial paralysis and dysfunction. And as SUFA acknowledges, Canada’s social union is about more that how governments relate to each other: it is about how governments can and should work with external stakeholders and individual Canadians to improve the social policies and programs. The health sector is an important test case for SUFA. It is the most cherished of Canada’s social programs. Canadians want and expect their governments to work together to improve the health care system and ensure its future sustainability. Ironically, it is also the area where government intergovernmental discord has been the greatest. On the eve of the final report of the Commission on the Future of Health Care in Canada, it is timely to reflect on SUFA and its role in the renewal of Canada’s health system. SUFA and the Health Sector – Strengths and Weaknesses The attached table provides a summary of the key elements of SUFA and the CMA’s assessment of how well SUFA provisions have been applied in the health sector. On the positive side, the health sector has fared relatively well in the area of mobility within Canada. Physicians and other regulated health care providers generally enjoy a high degree of mobility. Portability of hospital and medical benefits is largely ensured through interprovincial eligibility and portability agreements. There are, however, two areas of concern. First, there is the longstanding failure to resolve the non-portability of medical benefits for Quebec residents. Second, there is growing disparity in coverage for services that are currently not subject to national standards under the Canada Health Act, particularly prescription drugs and home care. In the area of dispute avoidance and resolution, governments have agreed to a formal process to address concerns with the Canada Health Act. This is a positive step, though few details have been made public. The real test will be whether this new process accelerates the resolution of non-compliance issues (most of which, as the Auditor-General recently pointed out, have remained unresolved for five years or longer), and whether the federal government will have the political will to levy discretionary penalties for non-compliance. There has also been progress on public accountability and transparency as governments have begun reporting results in 14 health indicator areas pursuant to the September 2000 health accord. The CMA is disappointed, however, that governments did not fulfil their pledge to involve stakeholders at all levels in the development of these indicators. Moreover, governments have short-changed Canadians by not providing them with a national roll-up of indicators that would facilitate comparisons across jurisdictions. Looking to the future, it will be critical to put in place a process that moves from benchmarks (indicators) to the bedside (best practices, better outcomes). This must be done in collaboration with health care researchers, providers and health managers—those individuals who understand the importance of taking research and importing it into practice. Clinical researchers across the country are doing this work and must to be supported. Overshadowing these relative successes in the first three years of the Social Union Framework Agreement are three key challenges that must be addressed: * inadequate institutional mechanisms to improve accountability across the system * failure to reduce uncertainty about what the health system will deliver, now and into the future * resistance on the part of governments to engage stakeholders in a true partnership for health system renewal The CMA is concerned that if these fundamental weaknesses are not addressed, they will undermine future attempts to renew Canada’s health system. Improving accountability With the adoption of SUFA, governments have significantly increased emphasis on performance measurement and public reporting. While this is a positive development, it also has the potential to lead towards information overload and paralysis, unless two critical elements are addressed. First, there is a need for a clear accountability framework that sets out the roles, rights and responsibilities of all key players in Canada’s health system: patients, health care providers and governments. This, in turn, requires the creation of a credible arm’s length institution to monitor compliance with this framework and rise above the fray to give Canadians the straight goods on health care. One has to look no further that the recent rekindling of the so-called “shares debate” between the federal and provincial governments as an example of why these changes are necessary. Reducing uncertainty Over the past decade, Canada’s health system has been plagued by an escalating crisis of uncertainty. Patients have faced increasing uncertainty about the accessibility and timeliness of essential health care services. Health care providers have seen working conditions deteriorate. Employers and private insurers have seen their contribution to funding health services increase unpredictably as governments have scaled back their funding commitments. Furthermore, provincial and territorial governments have had to contend with an unstable federal funding partner. Canadians deserve better. They need more certainty that their public health system will care for them when they need it most. They need more transparency from governments about “what’s in” and “what’s out” in terms of public or private coverage. They need their governments to act on their SUFA undertaking to make service commitments for social programs publicly available such as establishing standards for acceptable waiting times for health care. And they need governments to follow through with their SUFA commitment to ensure stable and adequate funding for the health system and other social programs. Fostering real partnerships In the health care field, deliberations and agreements have taken place behind closed doors and governments have discounted the role that non-governmental organizations and citizens should play in decision-making. It is these very providers and patients who are expected to implement and live with the results of such cloistered decision-making. The consequences of this systematic exclusion are all too evident in the current critical and growing shortages of physicians, nurses and other health professionals. If we are to achieve the vision of a sustainable Medicare program, it is critical that governments come clean on their SUFA commitment to work in partnership with stakeholders and ensure opportunities for meaningful input into social policies and programs. CMA’s Prescription for Sustainability – Building on SUFA The Social Union Framework Agreement has created the necessary, but not sufficient, conditions for health system renewal. It has codified the emerging consensus on federal-provincial relations and has clarified the "rules of the game". However, it is an enabling framework that is of limited value in the health sector unless it is given life through institutional mechanisms that establish enduring partnerships not just between governments, but between governments health care providers, and patients. In its final submission to the Commission on the Future of Health Care in Canada entitled “Prescription for Sustainability”, the CMA proposes the implementation of three integrated “pillars of sustainability” that together would improve accountability and transparency in the system: a Canadian Health Charter, a Canadian Health Commission, and federal legislative renewal. Canadian Health Charter A Canadian Health Charter would clearly articulate a national health policy that sets out our collective understanding of Medicare and the rights and mutual obligations of individual Canadians, health care providers, and governments. It would also underline governments’ shared commitment to ensuring that Canadians will have access to quality health care within an acceptable time frame. The existence of such a Charter would ensure that a rational, evidence-based, and collaborative approach to managing and modernizing Canada’s health system is being followed. Canadian Health Commission In conjunction with the Canadian Health Charter, a permanent, independent Canadian Health Commission would be created to promote accountability and transparency within the system. It would have a mandate to monitor compliance with and measure progress towards Charter provisions, report to Canadians on the performance of the health care system, and provide ongoing advice and guidance to the Conference on Federal-Provincial-Territorial ministers on key national health care issues. Recognizing the shared federal and provincial/territorial obligations to the health care system, one of the main purposes of the Canadian Health Charter is to reinforce the national character of the health system. Federal legislative renewal Finally, the CMA’s prescription calls for the federal government to make significant commitments in three areas: 1) a review of the Canada Health Act, 2) changes to the federal transfers to provinces and territories to provide increased and more targeted support for health care, and 3) a review of federal tax legislation to realign tax instruments with health policy goals. While these three “pillars” will address the broader structural and procedural problems facing Canada’s health care system, there is many other changes required to meet specific needs within the system in the short to medium term. The CMA’s Prescription for Sustainability provides specific recommendations in the following key areas: * Defining the publicly-funded health system (e.g. a more rational and transparent approach to defining core services, a “safety valve” if the public system fails to deliver, and increased attention to public health and Aboriginal health) * Investing in the health care system (e.g. human resources, capital infrastructure, surge capacity to deal with emergencies, information technology, and research and innovation) * Organization and delivery of services (e.g. consideration of the full continuum of care, physician compensation, rural health, and the role of the private sector, the voluntary sector and informal caregivers) Conclusion On balance, the Social Union Framework Agreement has been a positive step forward for social policy in Canada, though its potential is far from being fully realized. The CMA’s proposal for a Canadian Health Charter, a Canadian Health Commission and federal legislative review entail significant changes to the governance of Canada’s health system. These changes would be consistent with the Social Union Framework Agreement and would help “turn the corner” from debate to action on health system renewal. The early, ongoing and meaningful engagement of health care providers is the sine qua non of securing the long-term sustainability of Canada’s health system. Canada’s health professionals, who have the most to contribute, and next to patients – who have the most at stake – must be at the table when the future of health and health care is being discussed. The CMA’s Assessment of the Social Union Framework Agreement ANNEX [TABLE CONTENT DOES NOT DISPLAY PROPERLY. SEE PDF FOR PROPER DISPLAY] SUFA provisions CMA assessment Principles 1. All Canadians to be treated with fairness and equity 2. Promote equality of opportunity for all Canadians 3. Respect for the equality, rights and dignity of all Canadian women and men and their diverse needs 4. Ensure access for all Canadians to essential social programs and services of reasonably comparable quality 5. Provide appropriate assistance to those in need 6. Respect the principles of Medicare: comprehensiveness, universality, portability, public administration and accessibility 7. Promote the full and active participation of all Canadians in Canada’s economic and social life 8. Work in partnership with stakeholders and ensure opportunities for meaningful input into social policies and programs 9. Ensure adequate, affordable, stable and sustainable funding for social programs 10. Respect Aboriginal treaties and rights [#4] Progress towards the objective of ensuring access to essential health services of reasonably comparable quality is difficult to assess. First, there is no agreed-upon definition of essential health services. Second there the development of indicators and benchmarks of health care quality is still in its infancy. However, the CMA is very concerned that the system is not headed in the right direction, with growing shortages of physicians, nurses and other health care providers. According to Statistics Canada’s recently released survey on access to health care services, an estimated 4.3 million Canadians reported difficulties accessing first contact services and approximately 1.4 million Canadians reported difficulties accessing specialized services. [#6]Although there is broad support for the five principles of Medicare, there continue to be a number of longstanding violations of Canada Health Act that are not being addressed, including the portability of medical benefits for Quebec residents. The emergence of privately-owned clinics that charge patients for medically-necessary MRI scans is also cause for concern. [#8] There is no formal, ongoing mechanism for input from stakeholders and the individual Canadians in debates about national health policy issues. (See also #17 below). [#9] Ensuring adequate, affordable, and stable funding for Canada’s health system is essential to its long-term sustainability. During the 1990s, billions of dollars were siphoned out of the system to eliminate government deficits. To put Medicare back on a sustainable path, governments must make long-term funding commitments to meet the health care needs of Canadians. The CMA has recommended that the federal government should significantly increase its financial contribution to restore the federal-provincial partnership in health care, and increase accountability and transparency through a new earmarked health transfer. Mobility within Canada 11. Removal of residency-based policies governing access to social services 12. Compliance with the mobility provisions of the Agreement on Internal Trade [#11] Residency-based policies are generally not an issue for physician and hospital services, where inter-provincial portability is guaranteed through reciprocal billing arrangements. As noted above, however, the portability of medical benefits for many Quebec residents is limited because the province only reimburses out-of-province services at home-province (as opposed to host-province) rates. [#12] Regulatory authorities initiated work towards meeting the obligations of the Labour Mobility Chapter of the Agreement on Internal Trade in fall 1999. A Mutual Recognition Agreement has been developed and endorsed by all physician licensing authorities. Public accountability & transparency 13. Performance measurement and public reporting 14. Development of comparable indicators to measure progress 15. Public recognition of roles and contributions of governments 16. Use funds transferred from another order of government for purposes agreed and pass on increases to residents 17. Ensure effective mechanisms for Canadians to participate in developing social priorities and reviewing outcomes 18. Make eligibility criteria and service commitments for social programs publicly available 19. Have mechanisms in place to appeal unfair administrative practices 20. Report publicly on appeals and complaints [#13-14] Pursuant to the September 2000 Health Accord, the federal government and provinces have developed common health indicators in 14 areas and have released a first slate of reports. However, the usefulness of these reports is hampered by missing data elements on quality of care (access and waiting times in particular) and the absence of a national roll-up to facilitate inter-provincial comparisons. [#15] Continuing federal-provincial bickering about shares of health funding makes it clear that this provision is not being met. [#16] The CMA’s analysis of the Medical Equipment Fund found that incremental spending by provinces on medical technology accounted for only 60% of the $500 million transferred by the federal government for this purpose. [#17] There is no mechanism in place to ensure ongoing input from Canadians and health care providers in national health policy development. The CMA has recommended the creation of a Canadian Health Commission, with representation from the public and stakeholders to provide advice and input to governments on key national health policy issues. [#18] Although there have been proposals to this effect in a couple of provinces, governments currently do not make explicit commitments about the quality and accessibility of health services. In order to reduce the uncertainty Canadians are feeling with respect to Medicare, the CMA has recommended the creation of a Canadian Health Charter that would set out the rights and responsibilities of patients, health care providers and governments. In particular, the health charter would require all governments to set out care guarantees for timely access to health services based on the best available evidence. [#19-20] The Auditor-General recently reported that Health Canada provides inadequate reporting on the extent of compliance with the Canada Health Act. Governments working in partnership 21. Governments to undertake joint planning and information sharing, and work together to identify priorities for collaborative action 22. Governments to collaborate on implementation of joint priorities when this would result in more effective and efficient service to Canadians. 23. Advance notice prior to implementation of a major policy or program change that will substantially affect another government 24. Offer to consult prior to implementing new social policies and programs that are likely to substantially affect other governments. 25. For any new Canada-wide social initiative, arrangements made with one province/territory will be made available to all provinces/territories. 26. Governments will work with the Aboriginal peoples of Canada to find practical solutions to address their pressing needs [#21-25] The requirement for governments to work together collaboratively is perhaps the most important part of SUFA, yet there it is impossible for organizations and individuals outside of government to assess the degree to which these provisions have been met. This so-called “black box of executive federalism” is not serving Canadians well. In the health sector, there are too many examples of governments developing policy and making decisions with little or no input from those who will ultimately have to implement change. To achieve a true social union, the tenets of good collaborative working relationships – joint planning, advance notice and consultation prior to implementation – must be extended beyond the ambit of federal-provincial decision-making. The CMA’s proposal for a Canadian Health Commission would go some distance in addressing these concerns. A key part of its mandate would be to bring the perspective of health providers and patients into national health policy deliberations and decision-making. Federal spending power 27. Federal government to consult with P/T governments at least one year prior to renewal or significant funding changes in social transfers 28. New Canada-wide initiatives supported by transfers to provinces subject to: a) collaborative approach to identify Canada wide objectives and priorities b) Agreement of a majority of provincial governments c) Provincial discretion to determine detailed design to meet agreed objectives d) Provincial freedom to reinvest funding in related area if objectives are already met e) Jointly developed accountability framework 29. For new Canada-wide initiatives funded through direct transfers to individuals or organizations, federal government to provide 3-months notice and offer to consult [#27-28] There have been three new Canada-wide health initiatives supported by the federal spending power: the $500M Medical Equipment Fund, the $800 Primary Health Care Transition Fund and the $500M fund for health information technology. The Medical Equipment Fund was created to respond to a genuine need for more modern diagnostic and treatment equipment. However, objectives were vague, money was transferred with no strings attached, and there was no accountability framework. The result, as the CMA’s analysis has shown, is that a significant portion of the funding did not reach its destination. The jury is still out in the case of the Primary Care Transition Fund. Delivery of this program through normal government machinery will entail a higher degree of accountability than in the case of the Medical Equipment Fund. However, objectives of this initiative may be too broad to have a significant steering effect on the system as a whole. Canada Infoway Inc. is an arm’s length body created by the federal government to disburse the $500M in health information technology funding. While this model has the advantage of being less politicized than government-run programs; accountability to Parliament and to Canadians is weaker. Dispute avoidance & resolution 30. Governments committed to working together and avoiding disputes 31. Sector negotiations to resolve disputes based on joint fact-finding, including the use of a third party 32. Any government can require a decision to be reviewed one year after it enters into effect 33. Governments will report publicly on an annual basis on the nature of intergovernmental disputes and their resolution [#30-33] Federal and provincial governments have agreed to a formal dispute avoidance and resolution process under the Canada Health Act. The Canadian Health Commission recommended by the CMA could play a useful role as an independent fact-finder. Review of SUFA 34. By the end of the 3rd year, governments will jointly undertake a full review of the Agreement and its implementation. This review will ensure significant opportunities for input and feedback from Canadians and all interested parties, including social policy experts, the private sector and voluntary organizations. [#34] Governments have taken a minimalist approach to the SUFA review by opting for an internet-based consultation and closed meetings with invited external representatives. This approach is not sufficient. Future reviews should be more inclusive of all stakeholders. [TABLE END]
Documents
Less detail

Seizing the opportunity: one time federal investments in health : Supplementary Brief to the Standing Committee on Finance Pre-Budget Consultations

https://policybase.cma.ca/en/permalink/policy1962
Last Reviewed
2010-02-27
Date
2002-11-08
Topics
Health systems, system funding and performance
  1 document  
Policy Type
Parliamentary submission
Last Reviewed
2010-02-27
Date
2002-11-08
Topics
Health systems, system funding and performance
Text
This year’s submission from the Canadian Medical Association (CMA) to the Standing Committee on Finance focused on the need for action in the short and longer terms by identifying strategic investments that will ensure a strong health care system supported by a dependable and comprehensive public health infrastructure as its foundation. Specifically, the CMA recommended an initial investment of $16 billion over five years starting in 2003/04 and an additional $3.2 billion for shorter-term and public health initiatives. Following our October 22, 2002 presentation to the Standing Committee on Finance, the CMA has developed four supplementary specific proposals for one-time funding in areas of urgent national need. They represent highly visible initiatives that, taken together, would substantially enhance Canada’s capacity in the health care sector in areas of federal jurisdiction. They are: ACCESS HOME (Accelerating Community Care through Electronic Services) Funding of specific sites across Canada to undertake aggressive, large scale project implementation of remote information and communication technology (ICT) solutions to facilitate care in home and community based settings. PRO-MISe (Pro Medical Immigrant Selection) Establishment of an international off-shore assessment program to pre-screen potential medical graduates who wish to immigrate to and practice medicine in Canada. RREAL HEALTH Communication and Coordination Initiative (Rapid, Reliable, Effective, Accessible and Linked) Increased capacity in areas of public health system to ensure communication in real time, both between multiple agencies and with health care providers, especially in times of national emergency or to meet national health needs. PAN-CANADIAN NETWORKS OF CLINICAL EXCELLENCE Improved national planning for specialty care across Canada by implementing needs-based planning tools; building synergies around areas of expertise; maximizing the efficiency in the delivery of care; and creating mechanisms for ensuring timely access to highly specialized quaternary care throughout Canada. This initial facet of a comprehensive federal reinvestment strategy corresponds with priorities identified in the Speech from the Throne and with the strategic priorities identified in our submission to the Standing Committee on Finance. Together, they constitute an important next step toward implementing the government’s Speech from the Throne commitments. However, given the particular urgency of these initiatives, and their ability to stand as independent projects, we feel they would be excellent candidates for modest but meaningful allocations from the federal surplus that may become available towards the end of this fiscal year. Each of these proposals incorporates a highly visible, targeted approach that not only builds the necessary evidence for transition to a renewed health care system but is also amenable to one-time funding. They reflect priorities that, due to their inter-jurisdictional nature, are highly unlikely to be undertaken by the provinces and territories without federal assistance. They would substantially reduce the uncertainties that Canadians feel and experience in dealing with the health system. Indeed, these initiatives provide an opportunity for the federal government to show immediate leadership in areas that fall clearly under its jurisdiction in ways that are certain to be complementary to the recommendations from the Commission on the Future of Canada (the Romanow Commission). The Canadian Medical Association believes that the time for targeted action is now as part of a comprehensive strategy for a sustainable health care system. Canadians are counting on governments to turn the corner from debating what needs to be done to implementing necessary changes. We see time-limited, targeted reinvestments as an essential part of this renewal. ACCESS HOME Accelerating Community Care through Electronic Services RATIONALE In the September 2000 Health Accord, health information and communications technology (ICT) was highlighted as an area where First Ministers agreed to work together to strengthen a Canada-wide health infostructure to improve quality, access and timeliness of health care for Canadians. As part of the funding initiatives announced at that time, Canada Health Infoway Inc. (CHII), received $500 million in funding to accelerate the adoption of modern ICTs to provide better health care. Given that implementation of a full health ICT strategy will require significantly more funding, CHII has given priority to the development of the electronic health record. Further, with the sunsetting of the two-year $80 million Canada Health Infostructure Partnerships Program (CHIPP) there are no other federal programs that provide funding for ITC pilot projects. Changing demographics in the Canadian population point to emerging pressures to meet increased non-institutional care needs of our aging population. To date, the home care sector has been largely neglected with respect to ICT – the majority of current ICT investments target acute and, to a lessor extent, primary care settings – and is currently ill equipped to cope with growing demand. Remote healthcare solutions show considerable potential to improve the care provided in home and community settings. Current projects in this area have demonstrated the benefits of using ICTs to facilitate care in non-traditional settings. Larger scale testing of remote ICT solutions should be undertaken to determine how best they can be applied to facilitate the provision of care in home and community based settings, and the implications for provider practice. GOAL Through funding of specific sites across Canada (mini centres of excellence), engage in aggressive, large scale project implementations of remote ICT solutions to facilitate care in home and community based settings. This would involve working through how best to apply ICTs in these settings, determining what works best and developing practice procedures for the provider community. GUIDING PRINCIPLES The ACCESS-HOME proposal is based on the underlying principle of a collaborative model and the following potential key partners have been identified: provinces and territories, regional health authorities, and the private sector (e.g., March Networks). DELIVERABLES Undertake, over a three year period, a variety of home and community care projects to learn how best to apply remote ICT solutions to facilitate provision of care in these settings. These could include projects to link primary care physicians to elderly frail patients in their home; to link patients with severe chronic conditions to specialists for remote monitoring of their conditions; to link home care nurses to patients to carry out preventive and promotion related activities on line; and to link physicians with recently discharged patients to monitor their rate of recovery. Part of the project funding proposal would include an evaluation component to build a knowledge base of what works and why. The assessments then would be placed on the Health Canada web site to promote knowledge transfer. FUNDING & ACCOUNTABILITY MECHANISMS A one-time, lump sum endowment of $50 million in this fiscal year to Canada Health Infoway Inc. (CHII) to manage the program and funds. Over a three-year period, CHII would operate under a very clear mandate set out by Health Canada to fund projects ($1-2 million each) across the country, in urban, rural and isolated settings, to more aggressively apply ICTs to facilitate provision of care in home and community based settings and to explore the implications for practice management. Accountability for the funds and the program implementation would be set out in a Memorandum of Understanding between Health Canada and CHII. Funds would be allocated on a cost-shared basis with a threshold of 70% federal funding. The remaining 30% would come from partnership contributions (in-kind costs, human resources, etc.). It is anticipated that it would take one year to get the projects operational and a second year to implement their mandates. The third year would be dedicated to completing the projects and undertaking evaluations in a format that would contribute to the overall knowledge base in this area. PRO-MISe Pro Medical Immigrant Selection PURPOSE The establishment of an assessment program to pre-screen international medical graduates wanting to immigrate to Canada and practice medicine in this country. RATIONALE International medical graduates have always been, and continue to be, a valuable addition to the Canadian medical workforce. Recently, the federal government passed new immigration legislation, changing the focus of immigration requirements away from an occupation basis toward a concentration on skills, training, and potential for successful integration into the Canadian workforce and society. In light of the implementation of these provisions, the Canadian Medical Association (CMA) and the Medical Council of Canada (MCC) propose the establishment of a Pro Medical Immigrant Selection (PRO-MISe) program for foreign-trained physicians seeking to immigrate to Canada. The purpose of this program would be to ensure that the anticipated increased numbers of foreign-trained medical graduates applying to immigrate to Canada receive fair treatment. The CMA and MCC have already had a preliminary meeting with a senior advisor to the Honourable Minister Denis Coderre, Minister of Citizenship and Immigration in follow-up to a meeting with his predecessor, the Honourable Elinor Caplan in May 2001. GOAL The goal of the project is to expedite the remote processing of applications by highly qualified international medical graduates who wish to immigrate to, and practice medicine in, Canada. This could be facilitated by creating an off-shore electronic assessment system for pre-screening in their country of origin. GUIDING PRINCIPLES In these times of physician workforce shortages, Canadian jurisdictions must be cautioned against “poaching” physicians from under-serviced parts of the world to meet their own health care needs (particularly in under-serviced areas or disciplines). Ethical recruitment practices must be established and maintained. In the longer term, the Canadian medical community strongly believes that Canada must strive for reasonable self-sufficiency in the production of physicians, while continuing to offer opportunities to qualified international medical graduates. Even in times of physician shortages, it remains imperative that foreign applicants who wish to practise medicine in Canada undergo a comprehensive assessment of knowledge and skills, on par with the assessment of graduates of Canadian medical schools. The process for assessing international medical graduates must be, and be seen to be, fair, transparent, and accountable to all stakeholders, expedient and cost-effective (for both the applicant and the government). DELIVERABLES The project would be comprised of a three-phased approach. Phase I would set up five pilots sites over 4-6 months in varied geo-political areas (e.g., London, Paris, Tokyo, Hong Kong and Port-of-Spain) that would test an Internet-based assessment system providing: 1. Updated and comprehensive information on the Canadian health care system and the Canadian medical education system, with a view to managing expectations regarding opportunities to practise medicine in Canada; 2. Electronic self-assessment tools for international medical graduates, containing questions comparable to those in the official Medical Council of Canada Evaluating Exam (MCCEE); 3. An electronic assessment system for the official MCCEE; and 4. Electronic forms, including the waiver currently used by CIC (Citizenship and Immigration Canada) indicating that the applicant understands there is no guarantee of an opportunity to practise medicine in Canada. Phase II would evaluate the project’s success. Phase III, full implementation on a global scale, would follow. FUNDING & ACCOUNTABILITY MECHANISMS $5 million for Physician Assessment A one-time, lump sum endowment of a $5 million sequestered fund in this fiscal year to be made to the Medical Council of Canada, to be managed and administered in keeping with the goals and objectives of the project (disbursement criteria would be set in collaboration with Health Canada and Human Resources Development Canada, as required). $15 million for Assessment of Other Health Care Providers There is a shortage of many health care providers. The CMA has had preliminary discussions with the Canadian Nurses Association (CNA) and the Canadian Pharmacists Association (CPhA). The Federal Government should consider funding the development of similar programs for other professions, in partnership with CNA, CPhA and others. RREAL HEALTH COMMUNICATION & COORDINATION INITIATIVE Rapid, Reliable, Effective, Accessible and Linked RATIONALE Through its public health initiatives society protects and promotes health and works to prevent illness, injury and disability. In today’s world these public health functions require an increasingly specialized and well-trained workforce; sophisticated surveillance, monitoring and information systems; and adequate and continuously available laboratory support. Its ultimate effectiveness, however, is dependent on the ability of the system to communicate crucial information and health advice to the right professional in real time when they need it. The devastating impact of the failure to effectively communicate essential information is evident in examples as diverse, as the water tragedy in Walkerton, and the untimely death of Vanessa Young who died as the result of a fatal adverse drug reaction 1. In both cases, the information health professionals needed to make optimum treatment decisions was not accessible in a reliable and timely manner. The public health infrastructure is put to the test whenever there is a disaster, large or small, in Canada and, not withstanding the best efforts of dedicated public health professionals, it does not always receive a passing grade. The public health system is further challenged by the potential for a disconnect in communications between differing jurisdictions that may be found when, for example, First Nations communities under federal jurisdiction overlap areas of provincial jurisdiction. In the aftermath of 9/11 and the anthrax scare in the United States, Canadians must be assured of a rapid, knowledgeable, expert response to emergency public health challenges. It is essential that the federal government take a leadership role to ensure that the communication tools and information technology necessary to allow for a more rapid and informed response to situations such as natural disasters, disease out-breaks, newly-discovered adverse drug reactions, man-made disasters, or bio-terrorism is accessible in real time in all regions of the country. A one time infusion of $30 million for the creation of a RREAL Health Communication and Co-ordination Initiative would strengthen Canada’s public health infrastructure and enhance co-ordination and communication among all levels of government, public health officials, health care providers and multiple agencies such as police, fire, ambulance and hospitals. GOAL The RREAL Health Communication and Co-ordination Initiative would address current deficiencies, and increase the capacity of the public health system to communicate in real time, both between multiple agencies and with health care providers in order to: * Provide a focal point for inter-jurisdictional communication and co-ordination in order to be better prepared in times of emergency; and * Disseminate emergency information, health alerts and current best practices in public health to health professionals and targeted public health officials in real time and in an effective and accessible fashion. GUIDING PRINCIPLES The RREAL Health Communication and Co-ordination Initiative would involve such key players in public health service and delivery as the Canadian Public Health Association, the Canadian Paediatrics Society, the Chief Medical Officers of Health, the Canadian Federation of Municipalities, the Canadian Red Cross and Health Canada in a collaborative model to ensure integrated co-ordination and communication. DELIVERABLES The initiative would undertake a planned program of demonstration projects over a five-year period. 1. To enable the widespread accessibility of information such as newly discovered adverse drug reactions to physicians and other health providers by rapid, reliable, and effective dissemination. 2. To ensure that rural and remote areas of the country and First Nations, Metis and Inuit communities under federal health jurisdiction are linked to public health information systems. 3. To enhance clinical practice guidelines to make them more user friendly and accessible to health care providers. 4. To improve the interoperability of communication technology between multiple agencies such as public health, police and fire services, disaster relief agencies and hospitals in times of emergency. FUNDING & ACCOUNTABILITY MECHANISMS A one-time, lump sum endowment of $30 million in this fiscal year to a designated organization positioned to manage the administration of these funds over a five-year project duration. One option would be to establish a new Canadian Foundation for Public Health as an arms-length agency associated with the Office for Public Health at the Canadian Medical Association. PAN-CANADIAN NETWORKS OF CLINICAL EXCELLENCE RATIONALE Canada’s health care system commits to providing Canadians with reasonably comparable access to medically necessary care. This commitment must be met across the spectrum, from primary care to highly specialized care. However, low volumes associated with highly specialized care often does not warrant the ongoing maintenance of the physical and human resources necessary in all regions of the country to be able to respond to patients’ needs. Recent evidence has found that a critical volume of patients is required to ensure a high quality standard of care. In the Canadian Institute for Health Information’s 2002 Health Care in Canada report, they state that “for many types of care and for many different surgeries, research shows that patients treated in hospitals with higher numbers of cases are often less likely to have complications or to die after surgery”. 2 Although clinical centres of excellence (hospitals/clinics that house the human and physical resources necessary to deliver care that meets or exceeds accepted professional standards) currently exist, in Canada they are generally focussed on serving the patient needs of a single province and, in some cases, the city in which they reside. There are no formal mechanisms at the national level to facilitate needs-based planning and sharing of best practices and pooling of resources for highly specialized care. The resulting capacity “deficit” manifests itself in difficulties in accessing care – an issue that has become central to the debate on the renewal of Canada’s health care system. This proposal is about networking existing centres to achieve improved economies of scale and to accelerate quality improvement. It would build the infrastructure necessary to support and link these centres across the country. It would not aim to further consolidate or centralize the delivery of highly specialized services. GOAL Implement a Pan-Canadian Networks of Clinical Excellence program as a means to improve the quality and accessibility of highly specialized care in Canada. GUIDING PRINCIPLES This proposal is premised on: * A collaborative/partnership model between health organizations such as the Canadian Stroke Network, the Association of Canadian Academic Health Organizations (ACAHO); and the Canadian Medical Association (CMA); * Support the Provincial/Territorial Premiers’ commitment to develop Sites of Excellence in various fields such as paediatric cardiac surgery and gamma knife neurosurgery 3 ; * Consensus building and consultation; * Build on, and learn from, existing provincial models (e.g., Cardiac Care Network of Ontario, Ontario Stroke System); * Reliance on evidence-based practices; * Improved quality of care; * Rapid diffusion and adoption of new and emerging technologies; * Pilots and on-going evaluation leading to additional networks; and * Adoption of an evidence-based approach to network development. DELIVERABLES Building on the experience of earlier network models, activities envisioned for a Pan-Canadian Networks of Clinical Excellence program would be to: * Develop electronic registries to track and connect patients and physicians across the country; * Support collaborative research extending from the bench to bedside 4 ; * Establish and implement clinical best practices; * Develop and implement knowledge translation plans; and * Promote the sharing of human capital and expertise across jurisdictions. Beyond striving to reach optimum efficiency in the delivery of sub-acute care specialties, a Pan-Canadian Networks of Clinical Excellence program would support the development of internationally competitive centres of excellence that would offer attractive employment opportunities for the best and brightest in health human resources thereby helping to attract and retain health human resources in Canada. FUNDING & ACCOUNTABILITY MECHANISMS A five year phased approach to the development of the networks is envisaged. The first phase (two years) would involve piloting and evaluating a small number of networks. Based on detailed evaluation of the pilots, the second phase (year 2) could involve additional networks to be determined through consultation with partners. It is anticipated that by year 5, there would be five networks fully operational. The funding would be ideally delivered through a single year endowment of $25 million to existing foundations such as the Canadian Stroke Network. The new consortium would allocate funding over a 5-year period based on established criteria with regular reporting to the funding consortium partnership and ultimate accountability to report back to Parliament. A steering committee would be struck with representatives from each of the participating partners to provide direction and guidance on the project’s implementation. 1 Canadian Medical Association Journal, May 1, 2001, 164(9), page 1269. 2 Dudley RA, Johansen KL, Brand R, Rennie DJ, Milstein A. (2000). Selective referral to high-volume hospitals: Estimating potentially avoidable deaths. Journal of the American Medical Association, 283(9), 1159-1166 as cited in Health Care in Canada, 2002, Canadian Institute for Health Information, Ottawa: May 2002, p. 52. 3 As agreed to at the January 24-25, 2002 Provincial-Territorial Premiers’ Meeting in Vancouver. Information available at: www.scics.gc.ca/cinfo02/850085004_e.html 4As discussed in a presentation to the House of Commons Standing Committee on Health regarding Bill C-13: An Act to Establish the Canadian Institutes of Health Research. Dr. Peter Vaughan, Secretary General and CEO, Canadian Medical Association, December 6, 1999, Ottawa, Ontario.
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Notes for an address by Dr. Eugene Bereza, Chair, Committee on Ethics, Canadian Medical Association : Bill C-13 - An act respecting assisted human reproduction : Presentation to the House of Commons Standing Committee on Health

https://policybase.cma.ca/en/permalink/policy1963
Last Reviewed
2010-02-27
Date
2002-11-20
Topics
Ethics and medical professionalism
  1 document  
Policy Type
Parliamentary submission
Last Reviewed
2010-02-27
Date
2002-11-20
Topics
Ethics and medical professionalism
Text
BILL C-13 - AN ACT RESPECTING ASSISTED HUMAN REPRODUCTION Presentation to the House of Commons Standing Committee on Health Ottawa, Ontario November 20, 2002 BILL C-13 - AN ACT RESPECTING ASSISTED HUMAN REPRODUCTION Madame Chair and Members of the Committee: My name is Dr. Eugene Bereza. I am a physician and clinical ethicist at the Royal Victoria Hospital in Montreal and Chair of the Canadian Medical Association Committee on Ethics. I am here today representing our members, more than 54,000 physicians from across Canada. I also wish to speak as a advocate for our patients, especially those affected by infertility and those who are or will suffer from diseases for which medical science is searching for cures. I am accompanied today by Dr. John Williams, our Director of Ethics. You will recall that we appeared before this Committee on October 23, 2001 in company with representatives from eight other national health provider and scientific organizations to present our views on draft legislation on assisted human reproduction. Although we were pleased that your December 2001 report recommended the establishment of an assisted reproduction regulatory body outside the Department of Health, we were disappointed that you did not find favour with other recommendations we put forward. The government responded to your report with Bill C-56, now Bill C-13. It is this bill that we are here to address today. Although there are many details in the bill on which we would like either clarification or changes, we intend to focus our remarks on the issue that we consider of greatest importance for our patient’s wellfare and the practice of medicine. That issue is the use of the criminal power to deal with medical and scientific activities. The Standing Committee Report and Bill C-13 In your December 2001 report, you acknowledged our position on this issue: “Some witnesses recommended the elimination of the prohibited activities category altogether. Citing the benefits of regulatory flexibility, they felt that all activities should come under the controlled activity category, including the more reprehensible activities like reproductive cloning for which licences, arguably, would never be allowed under the regulations” (page 9). However, you rejected this view on the grounds that “a licence-related prohibition of this sort would not carry the same weight or degree of social censure as the statutory prohibition…. An outright statutory ban signals more clearly that certain activities are either unsafe or socially unacceptable. The use of the statutory ban also signals that these activities are of such concern to Canadians that their status as a prohibited activity may not be altered except with the approval of Parliament” (page 9). Bill C-13 reflects your views on this matter. We recognize your good faith in proposing and defending this position but we are convinced that its potential for harm outweighs its potential benefits. And so we are pleased to have this opportunity to reiterate the reason why the CMA believes that Bill C-13 will adversely affect the patient-physician relationship and the advance of medical science. Need to Change Bill C-13 As you know, our position on this matter is supported by legal scholars such as Patrick Healy, McGill University Faculty of Law, Tim Caulfield, Director of the University of Alberta Health Law Institute, and Bartha Knoppers, Université de Montréal Centre de Recherche en Droit Publique. In essence, our position is that the criminal law is a blunt instrument and very difficult to change and is therefore appropriate for activities whose status is unlikely to change over time, such as murder and theft, rather than medical and scientific activities that are constantly developing. The latter are better left to a representative regulatory body to determine if and when changes in health and safety considerations and public attitudes and values might justify allowing certain formerly prohibited activities to take place under specific conditions. Bill C-13 begins with the statement: “This enactment prohibits assisted reproduction procedures that are considered to be ethically unacceptable.” This echoes the conclusions in your report. However, as the transcripts of your hearings demonstrate, many Canadians, especially those who are infertile, do not consider some or all of these procedures to be ethically unacceptable. As a matter of public policy, should Canadians who hold this view be denied access to medical treatment for infertility because others consider such treatments to be ethically unacceptable? Should patients who suffer from conditions for which research that is forbidden in Bill C-13 might lead to a cure be denied that opportunity? We question whether criminal prohibitions are appropriate for dealing with activities on which there is considerable ethical disagreement among Canadians. In Canada legislators have been justifiably reluctant to use the criminal law to deal with medical and scientific issues such as abortion, withdrawal of life-sustaining treatment and the conduct of medical research. Why is an exception being made for assisted reproduction? What sort of precedent will this set for other controversial bioethical issues? We are also concerned about the bill’s penalties for infractions: jail terms up to 10 years and fines up to $500,000. These are disproportionate to the penalties for crimes that injure persons or property and, as such, will create a climate of undue fear and excessive caution for physicians and scientists working in this area, such that they will avoid any activity that is potentially covered by the bill, even to the detriment of patient care. Given the rapid advance of science and medical practice and the difficulty of anticipating new developments, it will be difficult to adjust the law to deal with new applications of prohibited activities that may be ethically acceptable. An Alternate Solution The CMA has stated repeatedly that we are not opposed to the prohibition of certain assisted human reproduction activities. Instead of instituting criminal prohibitions within the legislation, we remain convinced that an independent body on an ongoing basis should determine the activities that are permissible or prohibited on the basis of up-to-date scientific research, public input and ethical review. This can be accomplished very easily in Bill C-13 by moving the procedures listed under “Prohibited Activities” (sections 5-9) to “Controlled Activities” and adding the words “except in accordance with the regulations and a licence” to each of the provisions in sections 5-9. Consistent with this recommendation we consider that the regulatory agency should be established as soon as possible and be given as much authority as possible over the matters that Bill C-13, section 65, reserves to regulations of Governor in Council. We hope that the agency will build upon the experience and expertise of existing organizations and structures in the field of assisted reproduction that deal with practice standards, education, certification and accreditation. Conclusion To summarize, we strongly support government efforts to regulate assisted human reproduction and related activities, including the prohibition of certain practices either temporarily or permanently. However, like others who have appeared before this Committee, we do not believe that criminalizing the medical and scientific activities named in the bill is an appropriate way to achieve those objectives. We consider that the objectives could be as well achieved by far less drastic means than criminalization and, moreover, that criminalization would create major obstacles to legitimate medical and scientific progress in the treatment of infertility. We recommend that the proposed agency be empowered to regulate these practices and that the criminal power be invoked when controlled activities are performed without authority of a licence from the agency or in defiance of the licensing conditions established by the agency. Thank you, Madame Chair and members of the Committee. We will be pleased to respond to your questions.
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Toward a Dementia Strategy for Canada: CMA Submission to the House of Commons Standing Committee on Finance

https://policybase.cma.ca/en/permalink/policy10674
Date
2013-01-21
Topics
Population health/ health equity/ public health
  1 document  
Policy Type
Parliamentary submission
Date
2013-01-21
Topics
Population health/ health equity/ public health
Text
As Canada's population ages, concern is growing about the capacity of our health care system to respond to the increased demands that will be placed on it. Of particular concern is the capacity to deal with an expected surge in the prevalence of Alzheimer's disease and other dementias, a major cause of disability in Canadians aged 65 and older. The Canadian Medical Association (CMA) shares this concern. In August 2012, CMA's General Council passed a resolution supporting the development of a national dementia strategy. Background About three quarters of a million Canadians currently live with Alzheimer's disease and other forms of dementia and cognitive impairment. People with dementia may live for years with the condition, and will eventually need round-the-clock care. Our knowledge of how to prevent dementia is limited, and we do not fully understand its causes. Though treatments are available that may delay progression of the patient's condition, there is no known cure. Dementia currently costs Canada roughly $33 billion per year, both in direct health care expenses and in indirect costs, such as lost earnings of the patient's caregivers. Since the number one risk factor for dementia is age, there is no question that with the aging of Canada's population, its prevalence will increase. The Alzheimer Society of Canada predicts that by 2031, 1.4 million Canadians will have dementia, and by 2040 the annual cost to the country will reach $293 billion. Other countries, including Australia, Norway, Netherlands, France, and the United Kingdom, have developed national strategies to address the dementia epidemic. CMA recommends strongly that Canada join this list. A national strategy could address issues of pressing concern such as * The need for research on the prevention and treatment of dementia; * The occupation of acute-care hospital beds by patients with dementia while awaiting placement in more appropriate long-term care settings. This both increases health-care costs and exacerbates Canada's waiting-list problem, blocking hospital beds which could otherwise be used for other patients. * The emotional and financial burden faced by spouses, children or other informal caregivers of patients with dementia. A Dementia Strategy for Canadians Given the terrible toll that dementia currently takes on Canadians and their health care, and given the certainty that this toll will grow more severe in coming decades, the CMA believes that it is vital for Canada to develop a focused strategy to address it. The Alzheimer Society of Canada recommends that a national dementia strategy encompass the following elements: 1. Increased investment in research on key aspects of dementia, including prevention, treatment options, and improving quality of life. 2. Increased support for informal caregivers. This should take several forms. a. Financial support. The 2011 federal budget introduced a Family Caregiver Tax Credit of up to $300 a year. However, this does not adequately reimburse the cost of a caregiver's time, which studies have shown is often much higher. b. Programs to relieve the stress experienced by caregivers; this can include education and skill-building, and the provision of respite care and other support services. 3. An emphasis on brain health and risk reduction, early diagnosis and intervention. 4. An integrated system of care facilitated by effective co-ordination and case management. 5. A strengthened dementia workforce, which includes both developing an adequate supply of specialists and improving the diagnosis and treatment capabilities of all frontline health professionals. The Government of Canada has supported similar condition-specific strategies, most recently the Canadian Cancer Strategy, initially funded in 2006 and renewed for five years beyond 2012. This strategy focuses on prevention and screening, early detection, clinical care, supporting the patient's journey, targeted research, and work with the First Nations, Inuit and Metis communities. We believe that a national strategy for dementia, bringing together partners such as the Alzheimer Society of Canada, the Canadian Institutes of Health Research (Institute of Aging), the Canadian Caregiver Coalition, and other patient and health professional groups, will enhance the ability of our health care system to respond to the coming dementia epidemic in a compassionate and cost-effective manner. In 2012, the Canadian Institutes of Health Research (Institute of Aging) and the Alzheimer Society of Canada have invested about $30 million in research. We propose that an initial investment in a National Dementia Strategy be $25 million per year for five years: $10 million for research, $10 million for caregiver support and respite care, and $5 million for knowledge transfer, partnership development and administrative support. Therefore the Canadian Medical Association recommends: That the Government of Canada fund the development and implementation of a National Dementia Strategy for an initial five-year period. The CMA is ready to work with governments, patients and their families, health professional associations and other stakeholders to make this recommendation a reality. Sources: Alzheimer Society of Canada. A New Way of Looking at Dementia in Canada. Based on a study conducted by RiskAnalytica. C. 2010 Canadian Medical Association. A More Robust Economy Through a Healthier Population. 2012-2013 pre-budget submission.
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CMA Response: Health Canada's Medical Marijuana Regulatory Proposal

https://policybase.cma.ca/en/permalink/policy10702
Date
2013-02-28
Topics
Pharmaceuticals/ prescribing/ cannabis/ marijuana/ drugs
  1 document  
Policy Type
Parliamentary submission
Date
2013-02-28
Topics
Pharmaceuticals/ prescribing/ cannabis/ marijuana/ drugs
Text
The Canadian Medical Association welcomes the opportunity to comment on proposed changes to Health Canada's Marihuana for Medical Purposes Regulations, published in the Canada Gazette, Part I on December 15, 2012. CMA provided comments on the proposed changes when Health Canada first announced them in June 2011. Our position on these changes, and indeed on the entire Medical Marihuana Access Program (MMAP), has been consistent since the program was initiated. We remain deeply concerned that, though the program has made a physician's authorization the key to a patient's access to medical marijuana, physicians and other health professionals have little to no evidence-based information about its use as medical therapy. As our President, Dr. Anna Reid, noted in December, the regulatory proposals are "equivalent to asking doctors to prescribe while blindfolded." Health Canada gives two reasons for its regulatory proposal: first, to address concerns about the safety of home grow-ops; and secondly, to reduce the cost of administering a program that has proven more popular than anticipated. Neither of these reasons is related to improving patient care or advancing our clinical knowledge of marijuana as a medical treatment. CMA understands that many Canadians suffer constant pain from chronic or terminal illnesses and are searching for anything that will provide relief. We know that some patients find that use of marijuana relieves their symptoms and that some health professionals also believe it has therapeutic value. However, we are concerned that these claims remain inadequately supported by scientific research. Controlled studies of medical marijuana have been published recently and some have shown benefits. However, these studies are few in number, of short duration and with small samples, and knowledgeable clinicians say that more research is required. In addition, some say that marijuana has become more potent since it became a popular recreational drug in the 1960s, though others disagree,1 and growers say they can develop strains tailored to the needs of individual medical users.2 Though these claims are part of the popular understanding of medical marijuana, there is no scientifically valid evidence that supports them. What Physicians Have Told Us In May 2012, CMA surveyed members of its "e-panel" of physicians to obtain more information about their attitudes and needs regarding medical marijuana. The survey received just over 600 responses out of more than 2,200, for a 27 per cent response rate. Among the findings: * About 70 per cent of respondents had been asked by patients to approve medical marijuana, though only four per cent said they were asked to do so "often." Of those who were asked, one-third reported that they "never" supported such requests, while 18 per cent "usually" did so. * 64 per cent of respondents were concerned that patients who request medical marijuana may actually be using it for recreational purposes; * A large majority of respondents said they would find more information on the appropriate use of marijuana for medicinal purposes, and on its therapeutic benefits and risks, useful or very useful. * About two-thirds agreed or strongly agreed that they would feel more comfortable if: o Physicians wishing to use medical marijuana in their practices were required to undergo special training and licensing; and, o Health Canada offered them protection from liability. * In open-ended questions, some respondents expressed favourable views on marijuana's medical benefits. However, a larger number expressed concern over its harmful effects, such as: psychotic symptoms, especially in younger people; potential for addiction and dependency; and the risks to lung health from smoking it or any other substance. Marijuana is Not Like Other Therapeutic Products Theoretically, marijuana, when used for medicinal purposes, is regulated under the Food and Drugs Act. However, because of its unique legal position, Health Canada has exempted it from the applications of the Act and its regulations, and it has not undergone the scrutiny of benefits and risks required of other therapeutic products approved for use in Canada, be they prescription-only or over-the-counter. According to the Food and Drugs Act (FDA), all drugs requiring a health professional's authorization must be approved for use by Health Canada, based on evidence of effectiveness obtained from controlled clinical trials, which remain the best currently available means of validating knowledge. In addition, Health Canada has a system of post-market surveillance to keep track of problems that arise with prescription drugs in real-world use. Though the CMA has been critical of some aspects of this system,3 we acknowledge that it has added to our body of knowledge on drug safety risks. If marijuana were not an illegal product, it might have been assessed through some form of pre-approval and post-approval surveillance. By exempting marijuana from the FDA's pre-approval and post-approval requirements, Health Canada has lost an opportunity to improve our knowledge of the drug's therapeutic uses. The Views of Canadians A recent online survey conducted by Ipsos-Reid on behalf of the CMA provides insight into the views of Canadians on Health Canada's regulatory proposal.4 The survey found: * 92 per cent of Canadians think it is very or somewhat important that Health Canada not remove itself from its oversight role until guidelines are put in place for physicians; * 90 per cent believe that research on the effectiveness, safety and risks of medical marijuana is needed before Health Canada removes itself from the authorization process; * 85 per cent of Canadians believe medical marijuana should be subject to the same rigorous testing and approval standards as other medicines; * 79 per cent agree that Health Canada has a responsibility to maintain its role in the authorization process.; The Role of the Physician The CMA cannot with certainty predict the consequences of these regulatory changes for the practising physician (and, if the regulations are approved, for the nurse practitioner as well). However, we have several causes for concern: * The gatekeeper role of health professionals: The most significant change, from our point of view, is that Health Canada is removing itself from the approval process, making it a transaction between the patient, the practitioner and the licensed producer. In addition, Section 125 of the regulatory proposal would reduce the content of the authorization form, from its current two-page format to a brief document requiring little more information than is required for a standard medical prescription. We are concerned that these changes will put an even greater onus on physicians than do the current regulations. The CMA agrees with the Federation of Medical Regulatory Authorities that the lack of evidence to support the use of marijuana for medicinal purposes signifies that it is not a medical intervention. In our opinion, putting physicians in the role of gatekeeper for access to marijuana is inappropriate and may be an abdication of responsibility on Health Canada's part.5 Such a move could increase physicians' liability risk and put them at odds with their medical regulatory authorities, which have no choice but to continue to advise physicians to exercise extreme caution. The CMA believes, as does the Canadian Medical Protective Association, that a drug's approval under the Food and Drugs Act does not impose a legal obligation on physicians or nurse practitioners to authorize its use if, in their judgment, it is clinically inappropriate. The Ontario Court of Appeal reached a similar decision recently in the case of R. v. Mernagh. * Protection of Physician Privacy. Under the proposed regulations, health information and physician data - such as the patient's name and date of birth, or the provider's licence number - will be collected by licensed producers who may not be subject to the same regulatory and privacy constraints as the health care sector. The draft regulations also indicate that the licensed producer is expected to confirm that the data on the "medical document" is correct and complete - in other words, health providers who authorize medical marijuana use will receive correspondence from the producer. We are very concerned about the risks this would pose to the privacy of patient and health care provider information. We believe Health Canada should conduct a privacy impact assessment of its proposed regulations or, if it has done so, to share the results. * Physicians as Dispensers. Section 124 of the proposed regulations would allow authorized health care practitioners to "sell, provide or administer dried marijuana." This is contrary to Article 46 of the CMA Guidelines for Physicians in Interactions with Industry, which states that "Physicians should not dispense pharmaceuticals or other products unless they can demonstrate that these cannot be provided by an appropriate other party."6 * Other possible consequences. We are also concerned about other potential consequences of the regulatory changes. Will more people go to health professionals requesting an authorization, on the assumption that the new regulations will make it easier to get? Will entrepreneurs seize the opportunity to establish "dispensaries" whose intended clientele are not those in legitimate medical need, as recent news stories have suggested?7 Will medical marijuana advocates put increased pressure on physicians to authorize its use? Meeting the Information Needs of Physicians In one respect, Health Canada has listened to physicians' concerns regarding the lack of evidence about medical marijuana, and acknowledged the need to remedy this problem. Though it is not addressed in the draft regulations, Health Canada has established an Expert Advisory Committee (EAC) to help provide comprehensive information to health professionals. The CMA has attended meetings of this committee in an observer capacity, suggested the names of practising physicians to serve as members, and made a presentation to the committee at its meeting in November 2012. If the EAC follows the CMA's suggestions, it will consider actively supporting the following activities: * Funding of scientific research on the clinical risks and benefits of marijuana; * Knowledge translation activities to convert this research into accessible, user-friendly tools for education and practice; * Development of best practice guidelines in the therapeutic use of marijuana. Though this guideline would of necessity be based on "C" level evidence, it would be an improvement on what now exists; and * Support for a compulsory training and licensing program for physicians wanting to authorize marijuana for medicinal purposes. The CMA believes that the EAC should be given the mandate and resources to undertake these activities. Conclusion Health Canada's stated mission is to help the people of Canada maintain and improve their health. The CMA believes that if Health Canada wants its Medical Marihuana Access Program to serve this mission, it should not withdraw from administering the program, leaving it to health professionals working within a large knowledge gap. Rather, it should support solid research into the use of marijuana as medication and make a commitment to share this knowledge with the health professional community and to support best clinical practices. 1 Bonsor K: "How marijuana works". Accessed at http://science.howstuffworks.com/marijuana5.htm 2 http://medicalmarijuana.ca/learning-center/marijuana-strains 3 CMA Submission to the House of Commons Standing Committee on Health: Post-Market Surveillance of Prescription Drugs (February 28, 2008). Accessed at http://www.cma.ca/multimedia/CMA/Content_Images/Inside_cma/Submissions/2008/brief-drug-en-08.pdf 4 Online survey of 1,000 Canadians the week of Feb. 24, 2013 conducted by Ipsos-Reid. Summary report of the poll can be accessed at www.cma.ca/advocacy/cma-media-centre. 5 Letter to Health Canada from Yves Robert, MD, President of the Federation of Medical Regulatory Authorities of Canada, November 4, 2011. 6 CMA. 2004. Guidelines for Physicians in Interactions with Industry. Guideline can be accessed online: http://policybase.cma.ca/dbtw-wpd/Policypdf/PD08-01.pdf 7 Lee J. "Ross Rebagliati to Open medical marijuana franchise." Vancouver Sun. January 23, 2013. Accessed at http://www.vancouversun.com/health/Ross+Rebagliati+open+medical+marijuana+franchise/7860946/story.html
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CMA Submission: The need for health infrastructure in Canada

https://policybase.cma.ca/en/permalink/policy10705
Date
2013-03-18
Topics
Health systems, system funding and performance
  2 documents  
Policy Type
Parliamentary submission
Date
2013-03-18
Topics
Health systems, system funding and performance
Text
In its Economic Action Plan 2011(Budget 2011), the Government of Canada committed to consult stakeholders on the next long-term plan for public infrastructure which would extend beyond the expiry of the current framework, the Building Canada Plan, on March 31, 2014. The CMA’s 2012-13 pre-budget brief recommends that the federal government ensure health infrastructure is eligible for funding as part of the next long-term plan for public infrastructure. The purpose of which is to address a particular health infrastructure deficit that is preventing the optimization of health care resources and exacerbating wait times and ensure that Canadian communities are able to meet the current and emerging care needs of their older seniors. The CMA has prepared this brief to provide further details on the scope of the proposed infrastructure funding for the health sector, its rationale and economic benefit, and how it could be applied. 2. Overview of proposal The CMA recommends that the federal government ensure health sector infrastructure for long-term care facilities is eligible for funding under the next long-term infrastructure program. This funding should be applicable both for new capital projects and for renovating/retrofitting existing facilities. This recommendation, and the recognition of the need for additional capacity in the long-term care sector, is part of a pan-Canadian approach to redirect alternate level of care patients from hospitals to homes, communities and long-term care facilities, where they can receive more appropriate care at a lower cost. It costs $842 per day for a hospital bed versus $126 per day for a long-term care bed. If ALC patients were moved to more appropriate care settings, in this case, from hospital to long-term care, this would save the health care system about $1.4 billion a year. For the purposes of this recommendation, long-term care facilities include long-term care residential homes, assisted living units and other types of innovative residential models that ensure residents are in the setting most appropriate to their needs. The long-term care sector is facing significant change due to increasing numbers of older seniors and their increasingly complex care needs. These pressures not only relate to the construction of new facilities but apply to the need to maintain existing facilities, including retrofitting to meet higher regulatory requirements, as well as struggling to meet higher care needs of their increasingly elderly population. The CMA’s recommendation to ensure that long-term care infrastructure qualify under the next long-term infrastructure plan is one component of the association’s Health Care Transformation initiative and would support a pan-Canadian approach for continuing care, which would integrate home care and facility-based long-term, respite and palliative care services fully within the health care system. 3. Rationale The rationale behind the recommendation for health infrastructure to qualify for the next long-term infrastructure plan is based primarily on the care needs of Canada’s growing seniors’ population and its impact on Canada’s health care system. Communities across Canada face a common problem of a lack of resources to properly meet the housing and care needs of their seniors population. Demographic trends indicate this problem will only intensify. However, as demonstrated below, investing in seniors can generate substantial direct and indirect economic benefits. Meeting the needs of Canada’s growing seniors population and their changing care needs While all advanced countries are expected to age over the coming decades, the Canadian population is projected to age more rapidly than that of most other OECD countries, according to a recent report from Finance Canada. Statistics Canada reports the number of seniors (65+) in Canada is projected to increase from 4.2 million in 2005 to 9.8 million in 2036, with their share of the total population increasing from 13.2 per cent to 24.5 per cent. The number and proportion of older seniors – those 75 and older – are expected to increase significantly as well. Ontario’s population of people aged 75 and up is expected to grow by almost 30 per cent between 2012 and 2021. According to Statistics Canada’s medium-growth population projection scenario, the population aged 80 years or over will increase 2.6 times by 2036 – to 3.3 million persons. While the rate of residency in long-term care facilities among seniors has been declining, as the aging of Canada’s population accelerates, the demand for residential care will nonetheless increase significantly over the near term due to higher numbers of elderly seniors. Not only is the size of the elderly population increasing, but their health needs are changing too, particularly among those requiring residential care. Long-term care residents are older today than in previous years and have more complex health needs than ever before. A Canadian Institute for Health Information (CIHI) comparison of home care clients and seniors who are living in residential care found that “seniors in residential care were more likely to require extensive assistance with activities of daily living (ADLs), such as bathing and toileting (74 per cent versus 18 per cent). They were also more likely to have moderate to severe cognitive impairment (60 per cent versus 14 per cent). The number of residents with dementia is expected to increase. In 2011, 747,000 Canadians were living with cognitive impairment, including dementia – that’s 14.9 per cent of Canadians 65 and older. By 2031, this figure will increase to 1.4 million. At the request of the House of Commons Finance Committee, the CMA submitted a national dementia strategy. This proposal to fund long-term care facilities supports such a strategy. Many existing residential facilities are poorly equipped to meet the care needs of their residents, which are more complex now than when these facilities were originally built. For example, many facilities do not meet current building safety standards and the limited provincial and municipal funding available is usually insufficient to bring them up to code. Also, there is a lack of units with shared space to better support residents with dementia, as well as a shortage of appropriate units to care for residents who are disabled or obese. Renovations are also required to make better use of long-term care beds for other purposes such as providing short-stay respite care or transitional care. According to the Ontario Association of Community Care Access Centres, the lack of physical facilities necessary for care was the reason most often given by homes for declining to admit a long-term care wait-list client. Opportunity to improve health care efficiency and reallocate existing program spending We recognize that addressing the current gap in long-term care residency options is only one strategy to improve the effectiveness of Canada’s health care system. However, we believe it is a critical component of an integrated continuum of care strategy that provides for increased home and community supports. Improving options for seniors will have a positive cascading effect on many other elements of the system. Not only will seniors reside in more appropriate and safer settings but acute care resources will be better used. Consider that about 45 per cent of provincial and territorial governments’ health care spending in 2009 went toward those 65 years and older, while this group constituted only 14 per cent of the population. A major issue facing Canada’s health care system is the high number of alternate level of care patients (ALC) who occupy acute care beds. ALC patients are those who have completed the acute care phase of their treatment but remain in an acute care bed or who are admitted into a hospital bed due to the lack of a more appropriate care setting. In most cases, these people would be better served living in their own home with the appropriate level of supports or in a long-term care residence. The high number of ALC patients in hospitals is a problem experienced across the country. The total number of hospital bed days for ALC patients in 2007-2008 (latest figures) was 1.7 million. Furthermore, the lack of options for ALC patients also contributes to a high percentage of these patients being readmitted to hospital within 30 days of discharge (see Appendix A). According to CIHI figures, 85 per cent of ALC patients were older than age 65, with almost half waiting for placement in long-term care. A high percentage of ALC patients suffer from dementia. It costs $842 per day for a hospital bed versus $126 per day for a long-term care bed. If ALC patients were moved to more appropriate care settings, in this case, from hospital to long-term care, this would save the health care system about $1.4 billion a year. The presence of ALC patients in hospitals also lead to longer surgical wait times and longer delays in the emergency department as acute care beds remain unavailable. In fact, the Wait Time Alliance – an alliance of 14 national medical organizations and specialties – has said “the most important action to improve timely access to specialty care for Canadians is by addressing the ALC issue.” Available wait-time data (See Appendix B) for long-term care show that wait times to access a long-term care bed can often be measured in, not months or days, but years. Data from Ontario for 2004 to 2008 found that less than 50 per cent of seniors with high or very high needs were placed in a long-term care facility within a year of being put on a wait list. The average wait time for placement in Quebec is 13 months (ranging between five months and four years). The most recent report by Ontario’s Auditor General found that 15 per cent of patients on the provincial wait list for long-term care passed away while waiting for placement. The wait to access residential care can vary immensely depending on where one resides. Often the wait is longer for residents in small, rural and northern communities. Sometimes the only route to securing a placement is for the resident to move to a facility in another community. Investment required According to Statistics Canada, there are 261,945 long-term care beds in operation in Canada (latest figures, 2009/10.) How many residential beds will be required in the future to meet the growing number of elderly seniors? The Conference Board of Canada has produced a bed forecast tied to the growth of the population aged 75 and over and based on a decreased bed ratio demand of 0.59 per cent per year to reflect the greater shift to community-based services and supportive housing options being advanced at the provincial level. This bed ratio demand is described by the Canadian Healthcare Association as representing a modest shift from the current reliance on long-term care to community services. Based on these assumptions, it has been estimated that Canada will require an average of 10,535 new beds per year over the next 35 years, for a total of 637,721 beds by 2047. Demand would vary over the 35-year period, peaking between 2022 and 2040 (See Appendix C). The five-year projection for beds is as follows: Table 1: Projected shortage in long-term care beds, 2014 to 2019 [SEE PDF FOR CORRECT DISPLAY OF TABLE] Year Number of additional beds required 2014 4,331 2015 4,715 2016 6,028 2017 6,604 2018 8,015 Projected 5-year shortage 29,693 As shown, there is a projected shortage of 29,693 beds over the next five years. For the purposes of longer-term planning, the gap in beds required for the following five-year period (2019-2023) is as follows: Table 2: Projected shortage in long-term care beds, 2019 to 2023 [SEE PDF FOR CORRECT DISPLAY OF TABLE] Year Number of additional beds required 2019 8,656 2020 8,910 2021 10,316 2022 14,888 2023 14,151 As previously outlined, the rising gap in bed numbers is affected by the increased numbers in people aged 75 and older anticipated over the next 35 years. The estimated cost to construct 10,535 beds (the average number of beds required to be built per year from 2013 to 2047) is $2.8 billion, based on a cost estimate of $269,000 per bed. This figure could include both public and private spending. The purpose of this bed projection is to provide a sense of the immense challenge Canada faces in addressing the needs of a vulnerable segment of its older seniors population. It is important to note that this forecast does not include the significant investments required to renovate and retrofit the existing stock of residential facilities, not only to meet the current standards but to effectively respond to the complex care needs of residents requiring long-term care today and in the future. Similarly, the potential facility capacity expansions through retrofit or renovation are not included. Moreover, innovative capital investment in residential facilities can provide opportunities for their greater use by other members of the community. They can, for example, provide short-stay respite to support families and convalescent care programs such as those found in the United Kingdom. We also recognize that supportive housing and healthy aging programming are important components of an integrated solution to the ALC issue and to ensuring seniors reside in the most appropriate place. 4. How the funding would work Health infrastructure could qualify under a communities component of the next long-term infrastructure plan where this federal funding can be leveraged with provincial and and / or municipal investment (e.g. 1/3 federal component matched by + 2/3 provincial and / or municipal). This funding allocation could also include the use of public-private partnership models. Investing in Canada’s Continuing Care Sector Provides a Wide Range of Economic Benefits Construction of new residential care models and renovating/retrofitting existing facilities will provide significant economic opportunities for many communities across Canada (See Appendix E for detailed figures). Based on Conference Board of Canada estimates, the construction and maintenance of 10,535 long-term care beds (the average number of new beds needed per year from 2013 to 2047) will yield direct economic benefits on an annual basis that include $1.23 billion contribution to GDP and 14,141 high value jobs during the capital investment phase and $637 million contribution to GDP and 11,604 high value jobs during the facility operation phase (based on an average annual capital investment); and close the significant gap between the projected long-term care bed shortages and current planned investment. When indirect economic contributions are included, the total estimated annual contribution to Canada’s GDP reaches almost $3 billion, yielding 37,528 new jobs (construction, care providers and other sectors). Details on these economic benefits are provided in Appendix F, but a summary is presented below: Table 3: Average annual total economic contribution of new residential care facilities [SEE PDF FOR CORRECT DISPLAY OF TABLE] (10, 535 new beds per year at market prices) GDP (in 2013 $millions) Number of jobs created Average direct contribution to GDP of investing in new facilities (construction) $1,225.4 14,141 Average direct contribution to GDP of operating the new facilities $637.0 11,604 Average indirect contribution to GDP of investing in new facilities (construction) $969.9 10,115 Average indirect contribution to GDP of operating the new facilities $135.4 1,667 TOTAL (both direct and indirect) $2,968 37,528 For every 100 jobs created in the construction of long-term care facilities, an additional 72 jobs would be created in other sectors, while for every 100 jobs created in the long-term care sector, 14 jobs would be created in other sectors. The numbers provided above reflect the annual average contribution. On a time specific level, covering the five-year period between 2014 and 2018, an estimated 167,840 jobs would be created, based on the construction of 29,693 new beds. Another important economic benefit is the return in government revenues. The increase in construction and operating spending per average year will provide over $425 million in federal government revenues and over $370 million in provincial revenues (See Appendix G). As previously identified, an improved stock of long-term care beds will provide many other economic spinoffs, including savings in health care costs that can be reallocated to better meet Canadians’ health care needs and to provide greater support for families in their role as caregivers. Without adequate provision of long-term care resources, Canada’s labour force may experience a productivity drag through increased leaves and absenteeism to care for elderly relatives. 5. Conclusion The aging of our population touches all Canadians – from seniors who need the services to families who serve as caregivers and/or contribute financially to the care of aging relatives. Recent data show that 32 per cent of caregivers who provide more than 21 hours of care per week report distress in their role – four times the proportion of distressed caregivers who provide less than 10 hours of informal care per week. The federal government has a long history of allocating capital investment in the health sector. Previous examples include the Hospitals and Construction Grants Program in 1948, the Health Resources Fund established in 1966 and, more recently, the funding of capital projects at research hospitals under the Canada Foundation for Innovation Leading Edge and New Initiatives Funds in 2012. All communities across Canada are strongly affected by the social and health care needs of their growing senior and long-term care populations (see Appendix H for a sample of recent news stories.) Federal capital investment will help narrow the significant gap between the projected long-term care bed shortages and current planned investment in the area of residential care facilities. Further, it would have a cascading effect leading to a more effective and efficient Canadian health care system. Recommendation The Canadian Medical Association recommends that the federal government allocate $2.3 billion over a five-year period in the next long-term infrastructure plan for the construction, renovation and retrofitting of long-term care facilities. Long-term care facilities include long-term care residential homes, assisted living units and other types of innovative residential models that ensure residents are in the most care setting most appropriate to their needs. This funding could be delivered as part of the communities component of the next long-term infrastructure plan. 1 Department of Finance Canada. Economic and fiscal implications of Canada's aging population. Ottawa, 2012. 2 Office of the Auditor General of Ontario. 2012 annual report. 2012. http://www.auditor.on.ca/en/reports_en/en12/2012ar_en.pdf. Accessed 01/30/13. 3 Statistics Canada. Population projections for Canada, provinces and territories 2009 to 2036. June 2010. 91-520-X 4 Alzheimer's Society Ontario. Facts about dementia. http://www.alzheimer.ca/en/on/About-dementia/Dementias/What-is-dementia/Facts-about-dementia. Accessed 01/30/13. 5 Canadian Medical Association. Toward a Dementia Strategy for Canada. Ottawa, 2013. http://www.cma.ca/submissions-to-government Accessed 01/30/13. 6 Ontario Association of Non-Profit Homes and Services for Seniors. Proposals for the Ontario Budget. Fiscal Year 2012-13. March 2012. 7 David Walker. Caring for our aging population and addressing alternate level of care. Report Submitted to the Minister of Health and Long-Term Care. June 30, 2011. Toronto. 8 Long Term Care Innovation Expert Panel. Why not now? A bold, five-year strategy for innovating Ontario's system of care for older adults. March 2012. http://www.oltca.com/axiom/DailyNews/2012/June/LTCIEPFullREport_web_jun6.pdf. Accessed 01/30/13. 9 For an example of an integrated continuum of post-acute care model see CARP, One Patient: CARP's Care Continuum. http://www.carp.ca/wp-content/uploads/2013/01/One-Patient-Brief-Updated-Oct-18.pdf. Accessed 01/30/13. 10 Canadian Life and Health Insurance Association. Improving the accessibility, quality and sustainability of long-term care in Canada. CLHIA Report on Long-Term Care Policy. June 2012. 11 Wait Time Alliance. Time out! Report card on wait times in Canada. 2011. http://www.waittimealliance.ca/media/2011reportcard/WTA2011-reportcard_e.pdf. Accessed 01/30/13. 12 Correspondence with officials from Bruyère Continuing Care in Ottawa. January 2013. 13 Canadian Institute for Health Information. Health care in Canada, 2011 2011. . 14 Rapport du Vérificateur général du Québec à l'Assemblée nationale pour l'année 2012-2013. 15 Office of the Auditor General of Ontario. 2012 annual report. 2012. 16 The .59 per cent decrease in bed ratio is presented as Scenario 2 in Lazurko, M. and Hearn, B. Canadian Continuing Care Scenarios 1999-2041, KPMG Final Project Report to FPT Advisory Committee on Health Services, Ottawa. 2000. Presented in Canadian Healthcare Association, New Directions for Facility-Based Long-Term Care. 2009. http://www.cha.ca/wp-content/uploads/2012/11/CHA_LTC_9-22-09_eng.pdf. Accessed 01/30/13. 17 Canadian Institute for Health Information, Health Care in Canada, 2011.
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Canadian Medical Association Submission on Bill S-209, An Act to Amend the Criminal Code (prize fights)

https://policybase.cma.ca/en/permalink/policy10708
Date
2013-04-15
Topics
Health care and patient safety
  1 document  
Policy Type
Parliamentary submission
Date
2013-04-15
Topics
Health care and patient safety
Text
In 2010, physician delegates to the CMA's annual General Council voted in favour of a ban on mixed martial arts prize fighting matches in Canada. The CMA's complete policy on head injury and sport, the central concern of physicians with respect to mixed martial arts, is attached as an appendix to this brief. A key recommendation in this policy is that physicians discourage participation in sports in which intentional trauma to the head and body is the objective of the sport, as is the case with mixed martial arts (MMA). Background MMA prize fighting, like commercial boxing, is distinct from healthy sport because the basic tenet is to win by deliberately incapacitating one's opponent through violent bodily assault. Professional fighters train in different martial arts disciplines in order to develop the widest possible set of fighting techniques. Blows delivered by hands, feet, elbows and knees are entirely permissible.1 "Bouts" are won in a number of ways that include deliberate head injury such as knockout (KO) and technical knockout (TKO). Physician and referee stoppage are recognized as a necessary option for the declaration of a winner in order to prevent continued violence.4; 5 Despite the introduction of rules and regulations meant to ensure fighter safety, MMA is a violent sport with a high risk of injury. Publications seem to indicate that the overall injury rate in professional MMA competitions ranges approximately from 23 to 28 injuries per 100 fight participations, which is similar to that found in other combat sports involving striking, including boxing.1; 5; 7 Organizers support the rules because they realize that prize fighting can't be sustained as a business if the fighters are unable to return to the ring. The injuries vary in severity but include many types of head injury: ocular injuries, such as rupture of the bony orbit or of the eye itself; facial injuries including fractures; spine injuries; concussion; and tympanic membrane ruptures.2, 6, 7 Most sanctioned matches end in a submission, judge's decision or referee/physician stoppage, as opposed to KO or TKO. It is important to note that the overall risk of critical injury, defined as a persistent acquired brain injury, permanent blindness, permanent functional loss of limb or paralysis, appears to be low. The ability of referees to intercede and for fighters to voluntarily concede victory to their opponents, as well as the presence of physicians at the ringside, are all thought to play a role in minimizing the risk of critical injury.7 The risk of traumatic brain injury and concussion nevertheless remains one of the chief concerns with respect to MMA. KO rates are thought to be lower in professional MMA events than in similar boxing competitions, but it is not clear why. It is well known that knockouts are the result of brain injury4 and at least one study reported that blunt trauma to the head was a common reason for match stoppage. One study reported a severe concussion rate of 16.5 per 100 fighter participations (3.3% of all matches). 6 Regrettably, as in other combat sports, long-term follow-up of players is insufficient to measure how often head injury leads to permanent brain damage.1, 3 Issues Insufficient research Whether you defend or condemn MMA, the true nature and rate of severe brain injuries is speculative.6 Similarly, the absence of longitudinal studies means that the true long-term health implications of MMA fighting can only be surmised. Risk factors for injury Unsurprisingly, losing fighters are at a considerably greater risk for sustaining injury. It is notable that fighters losing by KO or TKO appear to have a higher overall incidence of injury.4 An increased duration of fighting is associated with an increased incidence of injury.3, 5 However, it remains unclear how age and fight experience contribute to the risk for sustaining injury.2, 3, 4 It appears that fighters with head injury continue to fight and sustain further injury, head injury being more clearly associated with injury than are either inexperience or age. Current situation Despite the sport's growing popularity, professional MMA competitions are currently illegal in Canada. Indeed, section 83(2) of the Criminal Code of Canada states that only boxing matches, where only fists are used, are legal. However, the governments of Nova Scotia, Quebec, Ontario, Manitoba and Northwest Territories have regulated/licensed MMA through athletic governing commissions, effectively circumventing the Criminal Code. The legality of the sport in New Brunswick, Alberta and British Columbia currently varies by municipality. CMA Recommendations The CMA recommends that Section 83(2) of the Criminal Code, the ban on mixed martial arts, be maintained in its current form. The CMA recommends that the federal government undertake further research on head injuries and concussion in Canada, including expanding current surveillance tools for the incidence of these injuries. References 1. Bledsoe, G. H. (2009). Mixed martial arts. In R. Kordi, N. Maffulli, R. R. Wroble, & W. A. Angus (Eds.), Combat Sports Medicine (1st ed., pp. 323-330). London: Springer. 2. Buse, G. J. (2006). No holds barred sport fighting: A 10 year review of mixed martial arts competition. British Journal of Sports Medicine, 40(2),169-172. 3. Bledsoe, G. H., Hsu, E. B., Grabowski, J. G., Brill, J. D., & Li, G. (2006). Incidence of injury in professional mixed martial arts competitions. Journal of Sports Science and Medicine, 5(Combat Sports Special Issue), 136-142. 4. Walrod, B. (2011). Current review of injuries sustained in mixed martial arts competition. Current Sports Medicine Reports, 10(5), 288-289. 5. Unified Fighting Championship. (n.d.). Unified rules and other important regulations of mixed martial arts. Retrieved May 28, 2012, from http://www.ufc.com/discover/sport/rules-and-regulations 6. Ngai, K. M., Levy, F., & Hsu, E. B. (2008). Injury trends in sanctioned mixed martial arts competition: A 5-year review from 2002 to 2007. British Journal of Sports Medicine, 42(8), 686-689. 7. Scoggin III, J. F., Brusovanik, G., Pi, M., Izuka, B., Pang, P., Tokomura, S. et al. (2010). Assessment of injuries sustained in mixed martial arts competition. American Journal of Orthopedics, 39(5), 247-251.
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Canadian Medical Association Submission on Motion 315 (Income Inequality)

https://policybase.cma.ca/en/permalink/policy10715
Date
2013-04-25
Topics
Physician practice/ compensation/ forms
  1 document  
Policy Type
Parliamentary submission
Date
2013-04-25
Topics
Physician practice/ compensation/ forms
Text
The Canadian Medical Association is pleased to present its views to the House of Commons Standing Committee on Finance regarding income inequality in Canada. The Canadian Medical Association represents 78,000 physicians in Canada; its mission is to serve and unite the physicians of Canada and to be the national advocate, in partnership with the people of Canada, for the highest standards of health and health care. Income inequality is a growing problem in Canada. According to a Conference Board of Canada report, high income Canadians have seen their share of income increase since 1990 while the poorest and even the middle-income groups have lost income share. In 2010 the top quintile of earners accounted for 39.1% of Canadian income while the bottom quintile only accounted for 7.3%. These numbers led to a ranking for Canada of 12 out of 17 among other high income countries in terms of income inequality.1 Research by the Organization for Economic Co-operation and Development has largely confirmed these results.2 Part 2: Why Income Inequality Matters to Canadian Physicians The issue of income inequality is an important one for Canada's physicians. As physicians, we are not the experts in housing, in early childhood development, income equality and so on. But we are the experts in recognizing the impact of these factors on the health of our patients. Hundreds of research papers have confirmed that people in the lowest socio-economic groups carry the greatest burden of illness.3 In 2001, people in the neighbourhoods with the highest 20% income lived about three years longer than those in the poorest 20% neighbourhoods.4 Mental health is affected as well. Suicide rates in the lowest income neighbourhoods are almost twice as high as in the wealthiest neighbourhoods.5 Studies suggest that adverse socio-economic conditions in childhood can be a greater predictor of cardiovascular disease and diabetes in adults than later life circumstances and behavioural choices.6 Finally, the countries reporting the highest population health status are those with the greatest income equality, not the greatest wealth.7 These differences in health outcomes have an impact on the health care system. Most major diseases including heart disease and mental illness follow a social gradient with those in lowest socio-economic groups having the greatest burden of illness.8 Those within the lowest socio-economic status groups are 1.4 times more likely to have a chronic disease, and 1.9 times more likely to be hospitalized for care of that disease.9 Income plays a role in access to appropriate health care as well. Individuals living in lower income neighbourhoods, younger adults and men are less likely to have primary care physicians than their counterparts.10 Women and men from low-income neighbourhoods are more likely to report difficulties making appointments with their family doctors for urgent non-emergent health problems. They were also more likely to report unmet health care needs.11 People with lower socio-economic status are more likely to be hospitalized for ambulatory care sensitive conditions and mental health12, admissions which could potentially be avoided with appropriate primary care.13 Those with higher socio-economic status are more likely to have access to and utilize specialist services.14 Utilization of diagnostic imaging services is greater among those in higher socio-economic groups.15 Access to preventive and screening programs such as pap smears and mammography are lower among disadvantaged groups.16 It is not just access to insured services that is a problem. Researchers have reported that those in the lowest income groups are three times less likely to fill prescriptions, and 60% less able to get needed tests because of cost.17 Services such as physiotherapy and occupational therapy to name two are often not covered unless they are provided in-hospital or to people on certain disability support programs.18 Access to psychologists is largely limited to people who can pay for them, through private insurance or out of their own pockets.19 Similar access challenges exist for long-term care, home care and end-of-life care. There is a financial cost to this disparity. According to a 2011 report, low-income residents in Saskatoon alone consume an additional $179 million in health care costs than middle income earners.20 A 2010 study by CIHI found increased costs for avoidable hospitalizations for ambulatory care sensitive conditions were $89 million for males and $71 million for females with an additional $248 million in extra costs related to excess hospitalizations for mental health reasons.21 The societal cost of poor health extends beyond the cost to the health care system: healthier people lose fewer days of work and contribute to overall economic productivity.22 According to data in the U.K., those living in the most disadvantaged neighbourhoods experience almost 20 years less disability-free life than those in the highest income neighbourhoods. These individuals will become disabled before they are eligible for old age services, striking two blows to the economy: they will no longer be able to contribute through productive work, and their disability will consume a great deal of health care services.23 The reasons for this inequitable access are multifaceted and include patient specific barriers as well as challenges within the health care system itself. CMA recognizes the need for physicians to work to address the system related barriers. However, one of the biggest challenges for patients themselves remains economic. Having a low-income can prevent access through lack of transportation options, an inability to get time off work, and the inability to pay for services that are not covered by government insurance. Health equity is increasingly recognized as a necessary means by which we will make gains in the health status of all Canadians and retain a sustainable publicly funded health care system. Addressing inequalities in health is a pillar of CMA's Health Care Transformation initiative. Part 3: Ensuring adequate income for all Canadians "The rates of family and child poverty are unacceptably high taking into account Canada's high quality of living standard." 2010 Report of the Committee on Human Resources, Skills and Social Development and the Status of Persons with Disability One reason income is so critical to individual health is that it is so closely linked to many of the other social determinants of health. These include but are not limited to: education, employment, early childhood development, housing, social exclusion, and physical environment. The CMA and its members are concerned that adequate consideration during the decision-making process is not being given to the social and economic determinants of health, factors such as income and housing that have a major impact on health outcomes. Recent decisions such as changes to the qualifying age for Old Age Security, and new rules for Employment Insurance, among others, will have far reaching consequences on the income of individuals, especially those in vulnerable populations. We remind the government that every action that has a negative effect on health will lead to more costs to society down the road. One method to ensure that these unintentional consequences do not occur is to consider the health impact of decisions as part of the policy development and decision-making process. A Health Impact Assessment (HIA) is a systematic process for making evidence-based judgments on the health impacts of any given policy and to identify and recommend strategies to protect and promote health. The HIA is used in several countries, including Australia, New Zealand, the United Kingdom, and increasingly the United States. The HIA can ensure that government departments consider the health impacts of their policies and programs by anticipating possible unintended consequences and taking appropriate corrective action. The use of HIA will allow the federal government to demonstrate leadership in health care in Canada and provide greater accountability to all Canadians. The CMA recommends that: 1. The federal government recognize the importance of the social and economic determinants of health to the health of Canadians and the demands on the health care system; and 2. The federal government requires a health impact assessment as part of Cabinet decision-making. We are hearing about the need to address the poverty and income security of Canadians from stakeholders across the country. We have conducted a series of town halls with Canadians asking them questions about how the social and economic conditions of their communities affect their health. From Winnipeg, to Hamilton to Charlottetown we have heard how poverty and a lack of income is undermining Canadians' health. This public response is not surprising. According to the Conference Board of Canada, more than one in seven children in Canada live in poverty.24 This poverty will severely limit the ability of these children to achieve good health in the future. There are systemic barriers that contribute to this poverty. The annual welfare income in Canada varies between $3,247 for a single person to $21,213 for a couple with two children. The 'best' of Canadian programs provides an income within only 80% of the poverty line. The lowest income is barely 30% of that needed to 'achieve' poverty.25 It is not just people on social assistance, however, that are facing poverty. Data from 2008 indicates that one in three (33%) of children living in poverty had a parent that was employed. Based a review conducted in 2010, one in 10 workers still earned less than $10 an hour in 2009, with 19% paid less than $12. The same study found that roughly 400,000 full-time adult workers, aged 25+, were making less than $10/hr. and therefore paid less than poverty line wages.26 Some physicians are working directly with patients to try and address the income inadequacy which is undermining their health. Physicians from Health Providers Against Poverty in Ontario have developed a tool for physicians to use in screening their patients for poverty and linking them with provincial/territorial and/or federal programs that might help mitigate the health effects of their poverty. This group is also involved in training health care providers to support this work. While this program and others like it are serving as a 'band aid' solution for some living in poverty, the CMA feels that physicians and their patients should not be placed in this position. As part of its study on income inequality, the CMA encourages the Finance Committee to review two recent reports from Parliamentary committees on the same topic. The first and most recent is the report of the House of Commons Committee on Human Resources, Skills and Social Development and the Status of Persons with Disability, Federal Poverty Reduction Plan: Working in Partnership Towards Reducing Poverty in Canada.27 The second is the report of the Senate Committee on Social Affairs, Science and Technology In From the Margins: A Call to Action on Poverty, Housing and Homelessness.28 The Committee on Human Resources, Skills and Social Development and the Status of Persons with Disability, noted that the federal government's efforts to address poverty among Canadian seniors "is generally recognized as one of Canada's most notable achievements of the past 30 years." The report of the Senate Committee made a number of significant observations, two bear repeating: * "[W]hen all the programs are working, when the individual gets all possible income and social supports, the resulting income too often still maintains people in poverty, rather than lifting them into a life of full participation in the economic and social life of their communities." * "[A]t their worst, the existing policies and programs entrap people in poverty, creating unintended perverse effects which make it virtually impossible for too many people to escape reliance on income security programs and even homeless shelters." The public policy debate on addressing income inequality in Canada is not new. For instance, the 1971 report of the Special Senate Committee on Poverty recommended that a guaranteed annual income financed and administered by the federal government be established. In consideration of this concept, from 1974 to 1979, the Governments of Canada and Manitoba funded the Manitoba Basic Guarantee Annual Income Experiment (referred to as "Mincome"). While this was initially designed to be a labour market study, the results were also relevant from a health perspective. A recent study of this data concluded that hospitalizations declined by 8.5 per cent for the Mincome subjects.29 The CMA recommends that: 3. The federal government gives top priority to the development of strategies to minimize poverty in Canada. Part 4: Addressing access barriers in the health sector Access to services not covered by provincial health plans remain a large barrier for Canadians. Those with low incomes are less likely to be able to access needed pharmaceuticals and services due to this barrier. One in 10 Canadians can not afford the medications that they are prescribed.30 This further exacerbates the income inequality that exists. While we urge the federal government to take action on reducing poverty among Canadians, at the minimum action needs to be taken to ensure universal access to needed medical care. The CMA recommends that: 4. Governments, in consultation with the life and health insurance industry and the public, establish a program of comprehensive prescription drug coverage to be administered through reimbursement of provincial/territorial and private prescription drug plans to ensure that all Canadians have access to medically necessary drug therapies; 5. Governments examine methods to ensure that low-income Canadians have greater access to needed medical interventions such as rehabilitation services, mental health, home care, and end-of-life care; and 6. Governments explore options to provide funding for long-term care services for all Canadians. This could include public insurance schemes or registered savings plans allowing Canadians to save for their future long-term care needs. Finally, there is a need to recognize the effect on income related to providing care to family members who are ill. Many Canadians take time off work to care for their children or parents. Without adequate long-term care resources and supports for home care, Canadians may be forced to take a leave from the workforce to provide this unpaid care. Research suggests that more than one third of parents (38.4%) who care for children with a disability are required to work fewer hours to care for their children.31 While the 2011 federal budget provided some relief in the form of a Family Caregiver Tax Credit of up to $300, it is not enough. A 2004 Canadian study placed the value of a caregiver's time at market rates from $5,221 to $13,374 depending on the community of residence.32 This is a significant amount of unpaid work and may further add to income inequalities. Expanding the tax credit available to these individuals would help but there is a need to provide further supports to family caregivers. The CMA recommends that: 7. The federal government expands the relief programs for informal caregivers to provide guaranteed access to respite services for people dealing with emergency situations, as well as increase the Family Caregiver Tax Credit to better reflect the annual cost of family caregivers' time at market rates. Part 5: Conclusion Once again, we commend the Standing Committee on Finance for agreeing to study this important issue. Canada's physicians see the examples of income inequality in their practices on a daily basis. Tackling this important social issue will contribute to not only reducing the burden of disease in Canada but to providing Canadians with the necessary financial resources to achieve good health. Summary of Recommendations Recommendation 1 The federal government recognizes the importance of the social and economic determinants of health to the health of Canadians and the demands on the health care system Recommendation 2 The federal government requires a health impact assessment as part of Cabinet decision-making. Recommendation 3 The federal government gives top priority to the development of strategies to minimize poverty in Canada. Recommendation 4 Governments, in consultation with the life and health insurance industry and the public, establish a program of comprehensive prescription drug coverage to be administered through reimbursement of provincial/territorial and private prescription drug plans to ensure that all Canadians have access to medically necessary drug therapies. Recommendation 5 Governments examine methods to ensure that low-income Canadians have greater access to needed medical interventions such as rehabilitation services, mental health, home care, and end-of-life care; and Recommendation 6 Governments explore options to provide funding for long-term care services for all Canadians. This could include public insurance schemes or registered savings plans allowing Canadians to save for their future long-term care needs. Recommendation 7 The federal government expand the relief programs for informal caregivers to provide guaranteed access to respite services for people dealing with emergency situations, as well as increase the Family Caregiver Tax Credit to better reflect the annual cost of family caregivers' time at market rates. References 1 Conference Board of Canada. How Canada Performs: Income Inequality. Ottawa (ON); 2013. Available: http://www.conferenceboard.ca/hcp/details/society/income-inequality.aspx (accessed 2013 Apr 11). 2 Organisation for Economic Co-operation and Development. Divided We Stand: Why Inequality Keeps Rising: An Overview of Growing Income Inequalities in OECD Countries: Main Findings. Paris (FR); 2011. Available: http://www.oecd.org/els/soc/49499779.pdf (accessed 2013 Apr 11). 3 Dunn JR. The Health Determinants Partnership Making Connections Project: Are Widening Income Inequalities Making Canada Less Healthy? Toronto (ON); 2002. Available: http://www.opha.on.ca/our_voice/collaborations/makeconnxn/HDP-proj-full.pdf (accessed 2011 March 15) 4 Wilkins R, Berthelot JM and Ng E. Trends in Mortality by Neighbourhood Income in Urban Canada from 1971 to 1996. Statistics Canada, Ottawa (ON); 2002. Health Reports 13 [Supplement]: pp. 45-71 5 Marmot, M. Fair Society Healthy Lives: The Marmot Review: Executive Summary. London (UK): 2010. Available: http://www.marmotreview.org/AssetLibrary/pdfs/Reports/FairSocietyHealthyLivesExecSummary.pdf (accessed 2011 Jan 25); Mikkonen J, Raphael D. Social Determinants of Health: The Canadian Facts. Toronto (ON); 2010. Available: http://www.thecanadianfacts.org/The_Canadian_Facts.pdf (accessed 2011 Jan 14) 6 Raphael D. Addressing The Social Determinants of Health In Canada: Bridging The Gap Between Research Findings and Public Policy. Policy Options. March 2003 pp.35-40. 7 Hofrichter R ed. Tackling Health Inequities Through Public Health Practice: A Handbook for Action. The National Association of County and City Health Officials & The Ingham County Health Department. Lansing (USA); 2006. Available: http://www.acphd.org/axbycz/admin/datareports/ood_naccho_handbook.pdf accessed (2012 Mar 16). 8 Dunn, James R. (2002) The Health Determinants Partnership... 9 Canadian Population Health Initiative. 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Canadian Medical Association Submission on Bill C-462 Disability Tax Credit Promoters Restrictions Act

https://policybase.cma.ca/en/permalink/policy10812
Date
2013-05-22
Topics
Physician practice/ compensation/ forms
  1 document  
Policy Type
Parliamentary submission
Date
2013-05-22
Topics
Physician practice/ compensation/ forms
Text
The Canadian Medical Association (CMA) is pleased to present this brief to the House of Commons Standing Committee on Finance regarding Bill C-462 Disability Tax Credit Promoters Restrictions Act. The Canadian Medical Association represents 78,000 physicians in Canada; its mission is to serve and unite the physicians of Canada and to be the national advocate, in partnership with the people of Canada, for the highest standards of health and health care. The CMA is pleased that the House of Commons has made Bill C-462 a priority. This bill is an important step toward addressing the unintended consequences that have emerged from the Disability Tax Credit since 2005. Part 2: Issues to be addressed In 2005, the Disability Tax Credit was expanded to allow individuals to back-file for up to 10 years. While this was a welcome tax measure for individuals with disabilities, the CMA has been urging the Canada Revenue Agency to address the numerous unintended consequences that have emerged. Central among these has been the emergence of a "cottage industry" of third-party companies engaged in a number of over-reaching tactics. The practices of these companies have included aggressive promotional activities to seek and encourage individuals to file the Disability Tax Credit. The primary driver behind these tactics is profit; some companies are charging fees of up to 40 per cent of an individual's refund when the tax credit is approved. Further to targeting a vulnerable population, these activities have yielded an increase in the quantity of Disability Tax Credit forms in physician offices and contributed to red tape in the health sector. In some cases, third parties have placed physicians in an adversarial position with their patients. We are pleased that this bill attempts to address the concerns we have raised. The CMA supports Bill C-462 as a necessary measure to address the issues that have emerged since the changes to the Disability Tax Credit in 2005. However, to avoid additional unintended consequences, the CMA recommends that the Finance Committee address three issues prior to advancing Bill C-462. First, as currently written, Bill C-462 proposes to apply the same requirements to physicians as to third-party companies if physicians apply a fee for form completion, a typical practice for uninsured physician services. Such fees are subject to guidelines and oversight by provincial and territorial medical regulatory colleges (see Appendix 1: CMA Policy on Third Party Forms: The Physician Role). The CMA recommends that the Finance Committee: * Amend the definition of "promoters" under section 2 to exclude "a health care practitioner duly licensed under the applicable regulatory authority who provides health care and treatment." * If the committee imports the term "person" from the Income Tax Act, then the applicable section of Bill C-462 should be amended to specify that, for the purposes of the act, "Person does not include a health care practitioner duly licensed under the applicable regulatory authority who provides health care and treatment." Second, the CMA is concerned that one of the reasons individuals may be engaging the services of third-party companies is a lack of awareness of the purpose and benefits of the Disability Tax Credit. Additional efforts are required to ensure that the Disability Tax Credit form (Form T2201) be more informative and user-friendly for patients. Form T2201 should explain more clearly to patients the reason behind the tax credit, and explicitly indicate there is no need to use third-party companies to submit the claim to the CRA. The CMA recommends that the Finance Committee: * Recommend that the Canada Revenue Agency undertake additional efforts to ensure that the Disability Tax Credit form is more informative, accessible and user-friendly for patients. Finally, the CMA recommends that a privacy assessment be undertaken before the bill moves forward in the legislative process. It appears that, as written, Bill C-462 would authorize the inter-departmental sharing of personal information. The CMA raises this issue for consideration because protecting the privacy of patient information is a key duty of a physician under the CMA Code of Ethics. Part 3: Closing The CMA encourages the Finance Committee to address these issues to ensure that Bill C-462 resolves existing problems with the Disability Tax Credit while not introducing new ones. The CMA appreciates the opportunity to provide input to the Finance Committee's study of this bill and, with the amendments outlined herein, supports its passage. Summary of Recommendations Recommendation 1 The definition of "promoters" under section 2 of Bill C-462 should be amended to exclude "a health care practitioner duly licensed under the applicable regulatory authority who provides health care and treatment." Recommendation 2 If the Committee imports the definition of "persons" from the Income Tax Act, the applicable section of Bill C-462 should be amended to specify that, for the purposes of the act, "Person does not include a health care practitioner duly licensed under the applicable regulatory authority who provides health care and treatment." Recommendation 3 The Canada Revenue Agency should undertake additional efforts to ensure that the Disability Tax Credit form is informative, accessible and user-friendly. Recommendation 4 Prior to advancing in the legislative process, Bill C-462 should undergo a privacy assessment.
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