OCSA Statement on Bill 175 Proceeding to Committee During COVID-19
OCSA Analysis and Statement on Bill 175
The province had actively engaged the Ontario Community Support Association (OCSA) on the development of a new legislative framework for the home and community care sector, which led to the introduction of Bill 175 and the associated proposed regulation summary on February 25, 2020. OCSA had been supportive of the approach for developing Bill 175 and the province’s plan to modernize the sector. However, COVID19 has halted sector consultations on Bill 175 and the proposed regulations.
In the past number of months, the sector has been solely focused on responding to the COVID-19 pandemic by supporting and delivering services that enable frail seniors and adult with physical disabilities safely isolate and stay healthy during COVID-19. This is why OCSA believes that there is no need to hastily move the bill through the legislative process until further engagement with the sector. At present, OCSA strongly believes that the timing is not right to move forward with this legislation.
COVID-19 has had a great impact on the health sector and has fundamentally changed how services are delivered across the entire health sector. The passing of Bill 175 should be delayed until the COVID-19 pandemic has passed, which would enable the sector to better understand and incorporate key learnings from the pandemic response.
OCSA is calling on government to consult the sector about the lessons learned from COVID-19 in order to ensure a successful transformation of the home and community care sector for clients, providers and front-line staff. Our support of this legislation and associated regulations is contingent on open and transparent collaboration between government, the home and community care sector and other stakeholders. The recent pandemic is a great opportunity for us to learn, adapt and create resilient and sustainable systems for the future. We must make the most of this opportunity.
Summary of OCSA’s Analysis of Bill 175 and the Proposed Regulatory Framework
for the Modernization of the Home and Community Care Sector
At present, the Home Care and Community Services Act, 1994 (HCCSA) and associated regulations govern the home and community care sector. Much of the clinical and service delivery requirements in home and community care are set out in legislation and regulation as opposed to regulation and policy as is the case in other health sectors. Bill 175 proposes to repeal the HCCSA and establish the Connecting Care Act, 2019 (CCA), associated regulations and policy as the oversight framework to govern the sector. This proposal would shift the clinical and service delivery requirements from legislation to regulation and policy.
Overall, OCSA supports adopting a more patient focused regulatory system for the sector. Bill 175 moves away from rigid legislation that directs clinical services – such as service maximums and the need for client assessments –towards services that are more current and reflective of client need.
Summary of Recommendations
Bill 175
- Require Ontario Health Board meetings to be open to the public.
- Carry over the exemption from the Public Vehicles Act for transportation services funded by the Ministry of Health.
Bill 175
- Enshrine the principle that client fees should not be a barrier to accessing care in regulation.
- Develop a provincial framework for care coordination in order to ensure quality and consistency.
- Leverage existing care coordination resources to enhance front-line care and focus care coordination on those who need it most.
- Develop a clear and consistent policy framework to ensure an equitable and client focused approach to address the removal of service maximums.
- Offer support and resources for organizations, especially small organizations, that would be impacted by their designation as Health Information Custodians.
- Prescribe through regulation qualification standards and requirements for being a home and community care health service provider.
- Establish procurement guidelines for contracting services which include a preference for not-for-profit providers with a history of high-quality service.
- Do not proceed with the addition of public hospitals as a location of service for home and community care until comprehensive engagement with both the home and community care sector and the hospital sector is completed.
- Consult extensively with the sector before moving forward on the development of new regulations for residential congregate care settings.
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OCSA has partnered with Cowan Benefits™ as our preferred group benefits partner to help member organizations explore flexible, sustainable employee benefits solutions tailored to the community support and not-for-profit sectors. As the OASSIS program transitions, Cowan will provide OCSA members with expert guidance, dedicated support and flexible group benefits options designed to balance affordability, stability and employee wellbeing. Whether organizations are looking for comparable coverage, greater flexibility or a longer-term benefits strategy, Cowan will work with them to identify solutions that meet their needs and support a smooth transition.
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