The Canadian Medical Association will promote the development of resources to foster academic writing and editing among practicing physicians and physicians-in-training.
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.
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.
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.
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.
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.
The Canadian Medical Association (CMA) is pleased to provide the information below in
response to questions by the Canada Revenue Agency (CRA) for consideration as part of the
development of regulations following the enactment of the Disability Tax Credit Promoters
Restriction Act. This information is in follow up to CMA’s submission to the CRA dated
December 19, 2014, attached for reference.
As explained in the CMA’s submission attached, the CMA strongly encourages the CRA to
include an exemption for “a health care practitioner duly licensed under the applicable
regulatory authority who provides health care and treatment” from the reporting requirements
in the forthcoming regulations enabled by the Disability Tax Credit Promoters Restriction Act.
This exemption is necessary to ensure CRA does not impose duplicative regulatory oversight
of the medical profession, specific to the provision of this uninsured service. As fully explained
in the CMA’s brief, this exemption would not introduce a potential “loophole”.
Issue 1: Organizations Responsible for Physician Regulatory Oversight
The statutory authority for the regulatory oversight of physicians rests with the provincial and
territorial medical regulatory colleges. As explained on page 4 of the CMA’s submission,
medical regulatory colleges have statutory, comprehensive regulatory authority of physicians;
this authority captures: medical licensure, governing standards of practice, professional
oversight, and disciplinary proceedings. Included in this authority is broad regulatory
oversight for fees that physicians may charge for uninsured services, which would capture the
fee charged for the Disability Tax Credit form. The Federation of Medical Regulatory
Authorities of Canada (FMRAC) is the umbrella organization representing provincial and
territorial medical regulatory authorities in Canada and can address how best to contact
individual regulatory colleges.1
Issue 2: CMA’s Code of Ethics
In addition to policies, guidance and oversight by provincial and territorial regulatory
colleges, charging a fee associated with the delivery of an uninsured service, in this case a
fee associated with completing the form associated with the Disability Tax Credit, is captured
by Section 16 of the CMA’s Code of Ethics. Section 16 states: “In determining professional
fees to patients for non-insured services, consider both the nature of the service provided and
the ability of the patient to pay, and be prepared to discuss the fee with the patient.”2
Issue 3: Fee Structure for Uninsured Services
As the CRA does not provide remuneration to physicians for the completion of the Disability
Tax Credit form, the delivery of this service by physicians is an uninsured service. As an
uninsured service there is no set fee level. While provincial and territorial medical associations
Canadian Medical Association 3
May 15, 2015
may provide guidance to physicians within their jurisdiction on uninsured services, which may
be referenced in policies by regulatory colleges, this guidance does not constitute a set fee
schedule. As captured in the CMA’s Code of Ethics referenced above, physicians may
consider patient-specific and other factors in determining a fee for the delivery of an
uninsured service. The CMA encourages CRA to review relevant policies and guidance of
individual provincial and territorial regulatory colleges for a comprehensive understanding of
the oversight of uninsured services.
Closing
Once again, the CMA appreciates the opportunity to provide further information to support
the development of regulations to enable the new authorities of the Disability Tax Credit
Promoters Restriction Act and to ensure that CRA does not impose redundant and duplicative
regulatory oversight of the medical profession.
1 FMRAC’s Executive Director is Dr. Fleur-Ange Lefebvre and can be reached at falefebvre@fmrac.ca
2 CMA’s Code of Ethics may be accessed here: https://www.cma.ca/Assets/assetslibrary/
document/en/advocacy/policyresearch/
CMA_Policy_Code_of_ethics_of_the_Canadian_Medical_Association_Update_2004_PD04-06-e.pdf
In the event that governments fail to resolve the discriminatory effect of the GST on medical practices, that the Canadian Medical Association discuss with its members appropriate methods of passing on these additional costs to their patients.
In the event that governments fail to resolve the discriminatory effect of the GST on medical practices, that the Canadian Medical Association discuss with its members appropriate methods of passing on these additional costs to their patients.
Text
In the event that governments fail to resolve the discriminatory effect of the GST on medical practices, that the Canadian Medical Association discuss with its members appropriate methods of passing on these additional costs to their patients.
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.
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.
