The Council on Aging of Ottawa (COA) serves as a leading community voice for Ottawa’s older adults. As a bilingual and inclusive Council, we work to advance the wellbeing of Ottawa’s older adults. We have been following the debates around Ontario’s proposal on Bill 135, Convenient Care at Home Act, 2023 (Bill 135) intending to amend the Connecting Care Act, 2019, to establish Ontario Health atHome.
We recognize that consolidation can have positive impacts if it allows for standardized approaches and for the proper allocation of resources based on needs and local realities. Providing high-quality care for patients and their families should be at the centre of any decisions pertaining to the health system, but the current proposal is not clear on how this change will support the needs of Ontarians.
While we understand the government’s intention to streamline and improve efficiency by centralizing support and consolidating resources, the COA is concerned by some of the potential consequences of the proposed bill. We urge the government to acknowledge and address our concerns – concerns shared by several community organizations – before moving forward.
Minister Access to Personal Health Information
We understand that the personal health information of service users can now be shared with the Minister for the purpose of monitoring, assessing, and evaluating home and community care services. The Personal Health Information Protection Act (PHIPA) has been in force across Ontario since 2004 and we strongly believe that individuals’ right to consent to the release of health information and the preservation of confidentiality of health records should continue to be protected. These rights need protection and must be enshrined in Bill 135. We would recommend the addition of language to better define what type of information (for example, aggregate data) can be shared and under which circumstances.
Removal of Liability for Ontario Health atHome
It appears that this new service organization does not have liability for the care it would be providing. This is deeply troubling as it would leave no recourse for patients if an injury due to the Agency’s care were to occur. The newly created Crown Agency needs to remain accountable to the public and the public must have their interests protected by the Crown Agency. As a publicly funded organization, Ontario Health atHome needs to be liable. We urge the government to ensure robust mechanisms for accountability are in place to protect the interests of older adults and their families.
Accountability and Governance
By having a CEO who is not an officer of the service organization and having a Board of Directors appointed by the Minister, the COA is concerned about accountability. Bill 135 should include a firm commitment to ensure that there is adequate representation on the Board from a wide cross-section of consumers and cultures, including older adults and their representatives.
Risk to the Public Healthcare System
The proposed amalgamation has the potential to allow for increased privatization of home care by for-profit companies and to undermine the integrity of the public healthcare system by diverting resources and control away from the local level. We are concerned that this could lead to a reduction in the quality of care and lead to a two-tier system. We implore the government to carefully assess and mitigate the risks to the public system and ensure that the well-being of older adults remains a top priority.
Ontario Health atHome as a Service Provider
The proposed bill is unclear about the nature of the Ontario Health atHome organization. The language refers to “service provision” (Section 27:6, Pg. 4) while the amendments state that: “the regulations may provide that the Service Organization is deemed not to be a health service provider or to have been funded by the Agency under section 21 for the purposes of any provision of this Act or its regulations or any other Act or regulations” (Section 1:1(3), pg. 1). This could lead to potentially different approaches across regions and inequities in service provision. We recommend clarifying the information as well as adopting a consistent approach across the province.
Minister Designation of Additional Ontario Health Teams (OHT)
We worry that this opens the door to corporate provision of health care. Regional Offices of Ontario Health should be the lead when it comes to supporting existing Ontario Health Teams as well as planning and implementing additional OHTs, in collaboration with health care service providers, rather than those at the political level.
We understand the need for administrative efficiency, but it should not come at the expense of the well-being and quality of care for Ontarians. Centralization may lead to a one-size-fits-all approach, which could negatively impact the quality of care for patients, including older adults, Ontarians living in remote and rural communities, and marginalized populations. We encourage the government to consider the importance of maintaining localized expertise and flexibility in service delivery.
We trust that the government will ensure that the procurement processes will consider factors such as demonstrated capacity to provide services to the home care sector with service standards and audit oversight functions built into the contract award process.
We hope that our concerns will be considered as the bill progresses through the legislative process and that government will continue to engage with care providers and community partners to ensure the success of this transition.
Thank you for your attention to this critical matter.
Sincerely,
Trèva Cousineau
President, Board of Directors
and
Brian Malcolmson and Dr. John Joanisse
Co-Chairs, Health Issues Committee
