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The impact of the Goods and Services Tax (GST) and the proposed Harmonized Sales Tax (HST) on Canadian physicians : Brief submitted to the House of Commons Standing Committee on Finance

https://policybase.cma.ca/en/permalink/policy2023
Last Reviewed
2019-03-03
Date
1997-01-21
Topics
Health human resources
Physician practice/ compensation/ forms
  1 document  
Policy Type
Parliamentary submission
Last Reviewed
2019-03-03
Date
1997-01-21
Topics
Health human resources
Physician practice/ compensation/ forms
Text
The Canadian Medical Association (CMA) commends the federal government for its clear and open process, and for encouraging a dialogue in areas of tax policy and economics. Canadians from all walks of life look to the government for strong and constructive leadership in this area. The CMA therefore appreciates the opportunity to present its views to the House of Commons Standing Committee on Finance as it considers Bill C-70 "An Act to amend the Excise Tax Act, the Federal-Provincial Fiscal Arrangements Act, the Income Tax Act, the Debt Servicing and Reduction Account Act and related Acts." The CMA has appeared before the Committee on several occasions when it has considered matters pertaining to federal tax policy in Canada. In addition to our submissions, as part of the government's pre-budget consultation process, the CMA appeared before the Committee when it examined a number of tax policy alternatives to the Goods and Services Tax (GST) in 1994. 1 At that time, the CMA clearly articulated the medical profession's concerns about the need to implement a federal sales tax system that is simplified, fair and equitable for all. The CMA remains strongly committed to the principles that underpin an efficient and effective sales tax system. However, it is of the strong view that there is, on the one hand, a need to review the relationship between sales tax policy and health care policy in Canada, and between the sales tax policy and the physicians as providers of services, on the other. Canada's health care system is a defining characteristic of what makes Canada special. It is no secret that funding for the health care system is under stress and all providers, including physicians, are being asked to shoulder their responsibility in controlling costs and responding to this fiscal challenge. However, physicians have had their costs of providing medical services increased by the federal government through the introduction of the GST. Specifically, the introduction of the GST as it applies to physicians serves as a constant reminder that there still remain some tax policy anomalies - that, without amendment, their consequences will be significantly magnified with the introduction of a proposed harmonized sales tax (HST) on April 1, 1997, as was the case with the introduction of the Quebec Sales Tax (QST) on July 1, 1992. The tax anomaly is a result of the current categorization of medical services as "tax exempt" under the Excise Tax Act. As a consequence, physicians are, on the one hand, in the unenviable position of being denied the ability to claim a GST tax refund (that is, denied the ability to claim input tax credits - ITCs), on the medical supplies (such as medical equipment, medical supplies, rent, utilities) necessary to deliver quality health care, and on the other, cannot pass the tax onto those who purchase such services (i.e., the provincial and territorial governments). Physicians, from coast to coast, are understandably angry that they have been singled out for unfair treatment under the GST, QST and the soon to be implemented HST. II. BACKGROUND The GST was designed to be a " consumer-based tax" where the tax charged for purchases during the "production process" would be refunded - with the consumer, not producer of a good or a service, bearing the full burden of the tax. As a result, self-employed individuals and small businesses are eligible to claim a tax refund of the GST from the federal government on purchases that are required in most commercial activities. It is important to understand that those who can claim a tax refund under the GST in most commercial activities will still be able to do so with the proposed introduction of a harmonized sales tax in Atlantic Canada. The rate is proposed to be set at 15% (7% federal tax, 8% provincial tax). In the case of medical services, the consumer (i.e., the one who purchases such services) is almost always the provincial and territorial governments. Since the provincial and territorial governments do not pay GST (due to their Constitutional exemption), one would have expected the cost of providing medical services to be free of GST. However, this is not the case. It is difficult to reconcile federal health care policies to preserve and protect publicly funded health care with tax policy which singles out and taxes the costs of medical services. Regrettably, physicians find themselves in an untenable situation of "double jeopardy". This is patently unfair and on the basis of the fundamental principles of administering a fair and equitable tax system should be amended accordingly. In an effort to document the impact of the federal government's decision to designate medical services as tax exempt, an independent study by the accounting firm KPMG estimated that physicians' costs increased by $60 million of GST per year. 2 Since 1991, this total is now in excess of $360 million. The recent agreement between the federal government and Atlantic provinces (except Prince Edward Island) to harmonize their sales taxes will make matters significantly worse for physicians as the HST broadens the provincial tax base to essentially that of the GST in those provinces. With no ability to claim a tax refund on the GST they currently pay (and the proposed HST effective April 1, 1997), physicians once again will have to absorb the additional costs associated with the practice of medicine. In assessing the impact of the proposed HST, KPMG has estimated that physicians in New Brunswick, Nova Scotia, and Newfoundland will be out-of-pocket an additional $4.7 million each year because they are not eligible for a tax refund for their purchases. 3 The medical profession, is not looking for special treatment. What we are asking for is to be treated no differently than other self-employed Canadians and small businesses who have the opportunity to claim ITCs, and to be placed on the same footing with other health care providers who have the ability to recoup GST costs. Physicians, as self-employed individuals are considered small businesses for tax purposes, therefore, it seems entirely reasonable that they should have the same tax rules that apply to other small businesses. This is a question of fundamental fairness. III. POLICY CONTEXT Prior to the introduction of the GST, the federal sales tax (FST) was included in the price of most goods (not services) that were produced in, or imported to, Canada. Therefore, when goods were purchased by consumers, the FST was built into the price. At that time, physicians, and other self-employed Canadians and small businesses, were essentially on a level sales tax playing field. Since 1991, however, the introduction of the GST has tilted the table against physicians. Unless this situation is rectified, with the introduction of the HST, physicians in Atlantic Canada will join those in Quebec who experience additional costs due to the GST and their provincial sales tax using the same rules. (i). The Impact of the GST on Good Tax Policy and Good Health Care Policy When it reviews Bill C-70, the Standing Committee on Finance should look for opportunities where tax policy and health care policy go hand-in-hand. The principle of aligning good health policy with sound tax policy is critical to managing change while serving to lay down a strong foundation for future growth and prosperity. Unfortunately, the current GST policy introduces a series of distortions that have tax policy and health policy working against one another. Tax policies that do not reinforce health policy are bad tax policies. Consider, for example: 1. Under the current system, hospitals (under the "MUSH" formula - Municipalities, Universities, Schools and Hospitals) have been afforded an 83% rebate on GST paid for purchases made while physicians must absorb the full GST cost on their supplies. At a time when health policy initiatives across Canada are attempting to expand community-based practices, the current GST policy (and now harmonized sales tax policy) which taxes supplies in a private clinic setting while rebating much of the tax in a hospital setting acts to discourage the shift in emphasis; 2. Prescription drugs are zero-rated. The objective was to ensure that pharmaceutical firms are no worse off than under the previous federal sales tax regime. Recognizing that medical services can play an equally important role as drugs, it appears inconsistent that the government would choose to have drugs as tax free, and medical services absorbing GST; 3. In the current fiscal climate, the current GST policy, and now the proposed harmonized sales tax in Atlantic Canada, is threatening to harm the important role when it comes to recruitment and retention of physicians across Canada, and in particular, the Atlantic provinces - where they are already experiencing difficulty; and, 4. It is estimated that the 55,000 physicians employ up to 100,000 Canadians. Physicians play an important role in job creation. The disproportionate effects of the GST policy could have an adverse effect on the number of individuals employed by physicians. With these issues at hand, it is apparent that good tax policy and good health policy are themselves not synchronized and are working at cross purposes. At this point, when the Standing Committee is reviewing Bill C-70, it is the time to address this situation based on the fundamental principle of fairness in the tax system, while ensuring that good tax policy reinforces good health care policy. (ii). Not All Health Care Services Are Created Equal under the GST/HST Physicians are not the only group of health care providers whose services are placed under the category of "tax exempt", with the result that they incur increased GST costs. For example, the services of dentists, nurses, physiotherapists, psychologists and chiropractors are categorized as "tax exempt". However, there is an important distinction between whether the services are government funded or not. Health care providers who deliver services privately and which are not publicly funded do have the opportunity to pass along the GST in their costs through their fee structures. For these services that are government funded there are no opportunities for physicians to recover the tax paid for purchases unless a specific rebate has been provided (e.g., hospitals). To date, in negotiations with the medical profession, no provincial/territorial government has agreed to provide funding to reflect the additional costs associated with the introduction of the GST. Their position has been that this is a "federal" matter. This becomes important when one considers that under the Canadian Constitution one level of government cannot tax another, and the provincial governments are not prepared to absorb the cost of the GST. It is critical to point out that since doctors receive 99% of their professional earnings from the government health insurance plans, 4 they have absolutely no other option when it comes to recovering the GST - they must absorb it! In summary, while a number of health care services are categorized as tax exempt, it must be emphasized that some providers "are more equal than others" under the GST - contrary to other health care providers, physicians do not have the ability to claim ITCs. This distinction becomes readily apparent when one considers the sources of (private and/or public) funding for such services. IV. THE SEARCH FOR A SOLUTION Like many others in Canadian society, physicians work hard to provide quality health care to their patients within what is almost exclusively a publicly-financed system for medical services. Physicians are no different from Canadians in that they, too, are consumers (and purchasers). As consumers, physicians pay their fair share of taxes to support the wide range of valued government services. By the same token, as providers of health care, physicians have not accepted, nor should they accept, a perpetuation of the fundamental injustices built into the current GST, QST and proposed HST arrangements. To date, the CMA has made representations to two Ministers of Finance and their Department Officials. We have discussed several ways to address a situation that is not sustainable, with no resolution to date. We look to this Committee and the federal government for a fair solution to this unresolved issue. V. RECOMMENDATION This unfair and discriminatory situation can be resolved. There is a solution that can serve to reinforce good economic policy with good health care policy in Canada. An amendment to the Excise Tax Act, the legislation which governs the GST (and proposed HST) can make an unfair situation fair to all Canadian physicians. In its recent submission to the Standing Committee as part of the 1997 pre-budget consultation process, the CMA recommended "that medical services be zero-rated, in order to achieve a fair and equitable GST policy for physicians." In order to achieve this objective all health care services, including medical services, funded by the provinces could be zero-rated. This recommendation serves to place physicians on a level playing field with other self-employed Canadians and small businesses. In addition, from a health care perspective, this would treat medical services in the same manner as that of prescription drugs. This is a reasonable proposition, as in many instances, medical treatments and drug regimens go hand-in-hand. Furthermore, this recommendation would ensure that medical services under the GST and proposed HST would be no worse off than other goods or services that provincial governments' purchase and where suppliers can claim a tax refund (i.e., ITCs). While the recommendation is an important statement in principle of what is required to address the current inequities under the GST, and soon to be HST, the CMA offers a more specific recommendation to the Standing Committee as to how the principles can be operationalized within the context of Bill C-70 and the Excise Tax Act. The CMA respectfully recommends the following: 1. "THAT HEALTH CARE SERVICES FUNDED BY THE PROVINCES BE ZERO-RATED." CMA has been advised that this would be accomplished by amending Bill C-70 as follows: (1). Section 5 of Part II of Schedule V to the Excise Tax Act is replaced by the following: 5. "A supply (other than a zero-rated supply) made by a medical practitioner of a consultative, diagnostic, treatment or other health care service rendered to an individual (other than a surgical or dental service that is performed for cosmetic purposes and not for medical or reconstructive purposes)." (2). Section 9 of Part II of Schedule V to the Excise Tax Act is repealed. (3). Part II of Schedule VI to the Excise Tax Act is amended by adding the following after section 40: 41. A supply of any property or service but only if, and to the extent that, the consideration for the supply is payable or reimbursed by the government under a plan established under an Act of the legislature of the province to provide for health care services for all insured persons of the province. VI. SUMMARY By adopting the recommendation above, the federal government would fulfil, at least two over-arching policy objectives, they are: 1. Strengthening the relationship between good economic policy and good health policy in Canada; and, 2. Applying the fundamental principles that underpin our taxation system (fairness, efficiency, effectiveness), in all cases. ________________________ 1 the Goods and Services Tax: Fairness for Physicians, Presentation to the House of Commons Standing Committee on Finance, Ottawa, Ontario, March 15, 1994. The Canadian Medical Association. 2 Review of the Impact of the Goods and Services Tax on Canadian Physicians, KPMG, June, 1992. 3 Review of the Impact of a Provincial Value Added Tax on Physicians in New Brunswick, Nova Scotia, and Newfoundland and Labrador, KPMG, August, 1996. 4 National Health Expenditures, 1975-1994, Health Canada, January 1996.
Documents
Less detail

National multidisciplinary knowledge-sharing network for precision medicine research

https://policybase.cma.ca/en/permalink/policy11619
Last Reviewed
2018-03-03
Date
2015-08-26
Topics
Ethics and medical professionalism
Physician practice/ compensation/ forms
Resolution
GC15-43
The Canadian Medical Association supports the development of a national multidisciplinary knowledge-sharing network for precision medicine research.
Policy Type
Policy resolution
Last Reviewed
2018-03-03
Date
2015-08-26
Topics
Ethics and medical professionalism
Physician practice/ compensation/ forms
Resolution
GC15-43
The Canadian Medical Association supports the development of a national multidisciplinary knowledge-sharing network for precision medicine research.
Text
The Canadian Medical Association supports the development of a national multidisciplinary knowledge-sharing network for precision medicine research.
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Precision medicine into clinical care

https://policybase.cma.ca/en/permalink/policy11663
Last Reviewed
2018-03-03
Date
2015-08-26
Topics
Health systems, system funding and performance
Physician practice/ compensation/ forms
Resolution
GC15-84
The Canadian Medical Association supports the development of a national strategy to integrate precision medicine into clinical care.
Policy Type
Policy resolution
Last Reviewed
2018-03-03
Date
2015-08-26
Topics
Health systems, system funding and performance
Physician practice/ compensation/ forms
Resolution
GC15-84
The Canadian Medical Association supports the development of a national strategy to integrate precision medicine into clinical care.
Text
The Canadian Medical Association supports the development of a national strategy to integrate precision medicine into clinical care.
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Goods and Services tax (GST)

https://policybase.cma.ca/en/permalink/policy670
Last Reviewed
2017-03-04
Date
1997-08-20
Topics
Physician practice/ compensation/ forms
Resolution
GC97-9
That General Council support the continuation of an aggressive strategy at the federal level aimed at establishing equitable application of federal GST/HST tax policy.
Policy Type
Policy resolution
Last Reviewed
2017-03-04
Date
1997-08-20
Topics
Physician practice/ compensation/ forms
Resolution
GC97-9
That General Council support the continuation of an aggressive strategy at the federal level aimed at establishing equitable application of federal GST/HST tax policy.
Text
That General Council support the continuation of an aggressive strategy at the federal level aimed at establishing equitable application of federal GST/HST tax policy.
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Around-the-clock services for frail and elderly Canadians living in the community.

https://policybase.cma.ca/en/permalink/policy11600
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-20
The Canadian Medical Association supports improved training, resource allocation and incentives to help primary care physicians develop robust, around-the-clock services for frail and elderly Canadians living in the community.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-20
The Canadian Medical Association supports improved training, resource allocation and incentives to help primary care physicians develop robust, around-the-clock services for frail and elderly Canadians living in the community.
Text
The Canadian Medical Association supports improved training, resource allocation and incentives to help primary care physicians develop robust, around-the-clock services for frail and elderly Canadians living in the community.
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Tax incentives and/or other financial supports for caregivers

https://policybase.cma.ca/en/permalink/policy11609
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-29
The Canadian Medical Association recommends that tax incentives and/or other financial supports for caregivers be available for all family members, without a requirement for co-habitation.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-29
The Canadian Medical Association recommends that tax incentives and/or other financial supports for caregivers be available for all family members, without a requirement for co-habitation.
Text
The Canadian Medical Association recommends that tax incentives and/or other financial supports for caregivers be available for all family members, without a requirement for co-habitation.
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Systems-thinking approach across all stages of the medical career life cycle

https://policybase.cma.ca/en/permalink/policy11623
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-45
The Canadian Medical Association will advocate for incorporation of a systems-thinking approach across all stages of the medical career life cycle.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-45
The Canadian Medical Association will advocate for incorporation of a systems-thinking approach across all stages of the medical career life cycle.
Text
The Canadian Medical Association will advocate for incorporation of a systems-thinking approach across all stages of the medical career life cycle.
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Gradual transition toward retirement

https://policybase.cma.ca/en/permalink/policy11626
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-46
The Canadian Medical Association supports physicians who choose a gradual transition toward retirement.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-46
The Canadian Medical Association supports physicians who choose a gradual transition toward retirement.
Text
The Canadian Medical Association supports physicians who choose a gradual transition toward retirement.
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Academic writing and editing among practicing physicians and physicians-in-training

https://policybase.cma.ca/en/permalink/policy11627
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Health systems, system funding and performance
Resolution
GC15-47
The Canadian Medical Association will promote the development of resources to foster academic writing and editing among practicing physicians and physicians-in-training.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Health systems, system funding and performance
Resolution
GC15-47
The Canadian Medical Association will promote the development of resources to foster academic writing and editing among practicing physicians and physicians-in-training.
Text
The Canadian Medical Association will promote the development of resources to foster academic writing and editing among practicing physicians and physicians-in-training.
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The Pan-Canadian Joint Consortium for School Health

https://policybase.cma.ca/en/permalink/policy11632
Date
2015-08-26
Topics
Health systems, system funding and performance
Physician practice/ compensation/ forms
Resolution
GC15-60
The Canadian Medical Association supports the Pan-Canadian Joint Consortium for School Health.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Health systems, system funding and performance
Physician practice/ compensation/ forms
Resolution
GC15-60
The Canadian Medical Association supports the Pan-Canadian Joint Consortium for School Health.
Text
The Canadian Medical Association supports the Pan-Canadian Joint Consortium for School Health.
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Governments undertaking unilateral action

https://policybase.cma.ca/en/permalink/policy11641
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-97
The Canadian Medical Association stands against governments undertaking unilateral action in lieu of a negotiated agreement with physicians.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-97
The Canadian Medical Association stands against governments undertaking unilateral action in lieu of a negotiated agreement with physicians.
Text
The Canadian Medical Association stands against governments undertaking unilateral action in lieu of a negotiated agreement with physicians.
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Ontario Medical Association’s request for the inclusion of a binding dispute resolution mechanism

https://policybase.cma.ca/en/permalink/policy11642
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-98
The Canadian Medical Association supports the Ontario Medical Association’s request for the inclusion of a binding dispute resolution mechanism in its contract negotiations with the Government of Ontario.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-98
The Canadian Medical Association supports the Ontario Medical Association’s request for the inclusion of a binding dispute resolution mechanism in its contract negotiations with the Government of Ontario.
Text
The Canadian Medical Association supports the Ontario Medical Association’s request for the inclusion of a binding dispute resolution mechanism in its contract negotiations with the Government of Ontario.
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The medical profession’s critical role in supporting immunization

https://policybase.cma.ca/en/permalink/policy11643
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Population health/ health equity/ public health
Resolution
GC15-63
The Canadian Medical Association will provide information and tools to physicians to promote the medical profession’s critical role in supporting immunization.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Population health/ health equity/ public health
Resolution
GC15-63
The Canadian Medical Association will provide information and tools to physicians to promote the medical profession’s critical role in supporting immunization.
Text
The Canadian Medical Association will provide information and tools to physicians to promote the medical profession’s critical role in supporting immunization.
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Generalist approach across the medical career life cycle

https://policybase.cma.ca/en/permalink/policy11644
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-64
The Canadian Medical Association will advocate for a generalist approach across the medical career life cycle.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-64
The Canadian Medical Association will advocate for a generalist approach across the medical career life cycle.
Text
The Canadian Medical Association will advocate for a generalist approach across the medical career life cycle.
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Arm’s- length, anonymous pre-accreditation survey

https://policybase.cma.ca/en/permalink/policy11647
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-67
The Canadian Medical Association affirms its support for the continued use of the arm’s- length, anonymous pre-accreditation survey as an integral component of the national system of accreditation for postgraduate medical education.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-67
The Canadian Medical Association affirms its support for the continued use of the arm’s- length, anonymous pre-accreditation survey as an integral component of the national system of accreditation for postgraduate medical education.
Text
The Canadian Medical Association affirms its support for the continued use of the arm’s- length, anonymous pre-accreditation survey as an integral component of the national system of accreditation for postgraduate medical education.
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Workplace guidelines for physicians who have or develop disabilities or disease

https://policybase.cma.ca/en/permalink/policy11655
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-75
The Canadian Medical Association will develop workplace guidelines for physicians who have or develop disabilities or disease.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Ethics and medical professionalism
Resolution
GC15-75
The Canadian Medical Association will develop workplace guidelines for physicians who have or develop disabilities or disease.
Text
The Canadian Medical Association will develop workplace guidelines for physicians who have or develop disabilities or disease.
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A unified voice when advocating on issues of common interest

https://policybase.cma.ca/en/permalink/policy11657
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-78
The Canadian Medical Association will work with the Royal College of Physicians and Surgeons of Canada and College of Family Physicians of Canada to provide a unified voice when advocating on issues of common interest.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-78
The Canadian Medical Association will work with the Royal College of Physicians and Surgeons of Canada and College of Family Physicians of Canada to provide a unified voice when advocating on issues of common interest.
Text
The Canadian Medical Association will work with the Royal College of Physicians and Surgeons of Canada and College of Family Physicians of Canada to provide a unified voice when advocating on issues of common interest.
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Increased knowledge amongst physicians in the practice of trauma-informed care

https://policybase.cma.ca/en/permalink/policy11667
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-88
The Canadian Medical Association promotes increased knowledge amongst physicians in the practice of trauma-informed care.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Health human resources
Physician practice/ compensation/ forms
Resolution
GC15-88
The Canadian Medical Association promotes increased knowledge amongst physicians in the practice of trauma-informed care.
Text
The Canadian Medical Association promotes increased knowledge amongst physicians in the practice of trauma-informed care.
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Evaluating federal forms used by physicians

https://policybase.cma.ca/en/permalink/policy11672
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-93
The Canadian Medical Association will create a working group to evaluate federal forms used by physicians.
Policy Type
Policy resolution
Date
2015-08-26
Topics
Physician practice/ compensation/ forms
Resolution
GC15-93
The Canadian Medical Association will create a working group to evaluate federal forms used by physicians.
Text
The Canadian Medical Association will create a working group to evaluate federal forms used by physicians.
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Guiding principles for physicians recommending mobile health applications to patients

https://policybase.cma.ca/en/permalink/policy11521
Date
2015-05-30
Topics
Health information and e-health
Physician practice/ compensation/ forms
  1 document  
Policy Type
Policy document
Date
2015-05-30
Topics
Health information and e-health
Physician practice/ compensation/ forms
Text
GUIDING PRINCIPLES FOR PHYSICIANS RECOMMENDING MOBILE HEALTH APPLICATIONS TO PATIENTS This document is designed to provide basic information for physicians about how to assess a mobile health application for recommendation to a patient in the management of that patient's health, health care, and health care information. These guiding principles build on the Canadian Medical Association's (CMA) Physician Guidelines for Online Communication with Patients.1 Background * Mobile health applications, distinct from regulated medical devices, may be defined as an application on a mobile device that is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease. The functions of these applications may include: o The ability to store and track information about an individual or group's health or the social determinants thereof; o Periodic educational information, reminders, or motivational guidance; o GPS location information to direct or alert patients; o Standardized checklists or questionnaires.2 * Mobile health applications can enhance health outcomes while mitigating health care costs because of their potential to improve a patient's access to information and care providers.3 * Mobile health applications are most commonly used on a smart phone and/or tablet. Some may also interface with medical devices. * The use of mobile health applications reflects an emerging trend towards personalized medicine and patient involvement in the management of their health information. By 2016, 142 million health apps will have been downloaded.4 According to some industry estimates, by 2018, 50 percent of the more than 3.4 billion smartphone and tablet users worldwide will have downloaded at least one mobile health application.5 * While mobile health application downloads are increasing, there is little information about usage and adherence by patients. It is believed that many patients cease to use a mobile health application soon after downloading it. * Distributers of mobile health applications do not currently assess content provided by mobile health applications for accuracy, comprehensiveness, reliability, timeliness, or conformity to clinical practice guidelines.6 However, mobile applications may be subjected to certain standards to ensure critical technical requirements such as accessibility, reachability, adaptability, operational reliability, and universality. * Increasingly there are independent websites providing reviews of medical apps and checklists for health care professionals. However, the quality criteria used by these sites, potential conflicts of interest, and the scope and number of mobile apps assessed are not always declared by these groups. To date, randomized controlled trials are not usually employed to assess the effectiveness of mobile health applications. Some believe that the rigorousness of this type of assessment may impede the timeliness of a mobile health application's availability.7 * Some examples of the uses of mobile health applications include tracking fitness activities to supplement a healthy lifestyle; supported self-management of health and health information; post-procedure follow up; viewing of test results; and the virtualization of interaction between patients and providers, such as remote patient monitoring for chronic disease management. Some mobile health applications may be linked to a patient profile or patient portal associated with a professional or recognized association or medical society or health care organization. * Some mobile health applications may be an extension of an electronic medical records (EMR) platform. Guiding principles * The objective of recommending a mobile health application to a patient must be to enhance the safety and/or effectiveness of patient care or otherwise for the purpose of health promotion. * A mobile health application is one approach in health service delivery. Mobile health applications should complement, rather than replace, the relationship between a physician and patient. * No one mobile health application is appropriate for every patient. Physicians may wish to understand a patient's abilities, comfort level, access to technology, and the context of the application of care before recommending a mobile health application. * Should a physician recommend a mobile health application to a patient, it is the responsibility of the physician to do so in a way that adheres to legislation and regulation (if existing) and/or professional obligations. * If the mobile health application will be used to monitor the patient's condition in an ongoing manner, the physician may wish to discuss with the patient what they should watch for and the steps they should take in response to information provided. * Physicians are encouraged to share information about applications they have found effective with colleagues. * Physicians who require additional information about the competencies associated with eHealth and the use of health information technologies may wish to consult The Royal College of Physicians and Surgeons of Canada's (RCPSC) framework of medical competencies, CanMEDS.8 * Physicians may wish to enter into and document a consent discussion with their patient, which can include the electronic management of health information or information printed out from electronic management platforms like mobile health applications. This agreement may include a one-time conveyance of information and recommendations to cover the elements common to many mobile health applications, such as the general risk to privacy associated with storing health information on a mobile device. Characteristics of a safe and effective mobile health application A mobile health application does not need to have all of the following characteristics to be safe and effective. However, the more of the following characteristics a mobile health application has, the likelier it will be appropriate for recommendation to a patient: 1. Endorsement by a professional or recognized association or medical society or health care organization As recommended by the Canadian Medical Protective Association (CMPA), it is best to select mobile health applications that have been created or endorsed by a professional or recognized association or medical society.9 Some health care organizations, such as hospitals, may also develop or endorse applications for use in their clinical environments. There may also be mobile health applications associated with an EMR platform used by an organization or practice. Finally, some mobile health applications may have been subject to a peer review process distinct from endorsement by an association or organization. 2. Usability There are a number of usability factors than can complicate the use of mobile applications, including interface and design deficiencies, technological restrictions, and device and infrastructure malfunction. Many developers will release periodic updates and software patches to enhance the stability and usability of their applications. Therefore, it would be prudent for the physician recommending the mobile health application to also recommend to the patient that they determine if the application has been updated within the last year. Physicians considering recommending a mobile health application to a patient may wish to ask about the patient's level of comfort with mobile health technologies, their degree of computer literacy, whether or not the patient owns a mobile device capable of running the application, and whether or not the patient is able to bear potential one-time or ongoing costs associated with use of the application. Physicians may consider testing the application themselves beforehand to understand whether its functionality and interface make it easy to use. 3. Reliability of information Physicians considering recommending a mobile health application may wish to understand how the patient intends to use the information, and/or review the information with the patient to understand whether it is current and appropriate. Information presented by the mobile health application should be appropriately referenced and time-stamped with the last update by the application developer. 4. Privacy and security There are inherent security risks when a patient uses mobile health applications or enters sensitive information into their mobile device. Mobile devices can be stolen, and the terms of use for mobile health applications may include provisions for the sharing of information with the application developer and other third-parties, identified or un-identified, for commercial purposes. In 2014, the Officer of the Information and Privacy Commissioner of Alberta assessed approximately 1200 mobile applications and found nearly one-third of them required access to personal information beyond what should be required relative to their functionality and purpose, and that basic privacy information was not always made available.10 Physicians entering into and documenting a consent discussion with their patients may wish to include the electronic management of health information in the scope of these discussions, and make a notation of the discussion in the patient's health record. If physicians have not entered into and documented a general consent discussion, they may wish to indicate to the patient that there are security risks associated with mobile health applications, and recommend that the patient avail themselves of existing security features on their device. Physicians may wish to recommend to the patient that they determine whether a privacy policy has been made available which discloses how data is collected by the application and used by the developer, or a privacy impact assessment, which demonstrates the risks associated with the use of the application. Some mobile health applications may feature additional levels of authentication for use, such as an additional password or encryption protocols. If all other factors between applications are equal, physicians may wish to recommend that patients use mobile health applications adhering to this higher standard of security. 5. Avoids conflict-of-interest Physicians may wish to recommend that patients learn more about the company or organization responsible for the development of the application and their mandate. There is a risk of secondary gains by mobile health application developers and providers where information about patients and/or usage is gathered and sold to third parties. A standardized conflict of interest statement may be made available through the mobile health application or on the developer's website. If so, physicians may wish to refer the patient to this resource. Physicians who develop mobile applications for commercial gain or have a stake in those who develop applications for commercial gain may risk a complaint being made to the College on the basis that the physician engaged in unprofessional conduct if they recommend mobile health applications to their patients in the course of patient care. 6. Does not contribute to fragmentation of health information Some mobile health applications may link directly to an EMR, patient portal, or government data repository. These data resources may be standardized, linked, and cross-referenced. However, health information entered into an application may also be stored on a mobile device and/or the patient's home computer, or developers of mobile health applications may store information collected by their application separately. While there may be short-term benefits to using a particular mobile health application, the range of applications and developers may contribute to the overall fragmentation of health information. If all other factors between applications are considered equal, physicians may wish to recommend mobile health applications which contribute to robust existing data repositories, especially an existing EMR. 7. Demonstrates its impact on patient health outcomes While not all mobile health applications will have an appropriate scale of use and not all developers will have the capacity to collect and analyze data, physicians may wish to recommend mobile health applications that have undergone validation testing to demonstrate impact of use on patient health outcomes. If mobile health applications are claiming a direct therapeutic impact on patient populations, physicians may wish to recommend that their patients seek out or request resources to validate this claim. References 1 Canadian Medical Association. Physician guidelines for online communication with patients. Ottawa: The Association; 2005. Available: http://policybase.cma.ca/dbtw-wpd/PolicyPDF/PD05-03.pdf?_ga=1.32127742.1313872127.1393248073 2 US Food and Drug Administration, Center for Devices and Radiological Health, Center for Biologics Evaluation and Research. Mobile medical applications: guidance for industry and Food and Drug Administration staff. Rockville (MD): The Administration; 2015. Available: www.fda.gov/downloads/MedicalDevices/.../UCM263366.pdf 3 Canada Health Infoway. Mobile health computing between clinicians and patients. White paper. Toronto: The Infoway; 2014 Apr. Available: www.infoway-inforoute.ca/index.php/resources/video-gallery/doc_download/2081-mobile-health-computing-between-clinicians-and-patients-white-paper-full-report 4 iHealthBeat. 44M mobile health apps will be downloaded in 2012, report predicts. Available: www.ihealthbeat.org/articles/2011/12/1/44m-mobile-health-apps-will-be-downloaded-in-2012-report-predicts 5 Jahns R-G. 500m people will be using healthcare mobile applications in 2015. Research2guidance. Available: www.research2guidance.com/500m-people-will -be-using-healthcare-mobile-applications-in-2015/ 6 Lyver, M. Standards: a call to action. Future Practice. 2013 Nov. Available: www.cma.ca/Assets/assets-library/document/en/about-us/FP-November2013-e.pdf 7 Rich P. Medical apps: current status. Future Practice 2013 Nov. Available: www.cma.ca/Assets/assets-library/document/en/about-us/FP-November2013-e.pdf 8 Royal College of Physicians and Surgeons of Canada. The CanMEDS 2015 eHealth Expert Working Group report. Ottawa: The College; 2014. Available: www.royalcollege.ca/portal/page/portal/rc/common/documents/canmeds/framework/ehealth_ewg_report_e.pdf 9 Canadian Medical Protective Association. Managing information to delivery safer care. Ottawa: The Association; 2013. Available: https://oplfrpd5.cmpa-acpm.ca/en/duties-and-responsibilities/-/asset_publisher/bFaUiyQG069N/content/managing-information-to-deliver-safer-care 10 Office of the Information and Privacy Commissioner of Alberta. Global privacy sweep rasies concerns about mobile apps [news release]. Available: www.oipc.ab.ca/downloads/documentloader.ashx?id=3482
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