HPRAC Consultation on Podiatry and ChiropodyRelease Date: 03/20/2015 Staff Reference: Karen Voin
March 20, 2015
Subject: Second consultation - Chiropody and Podiatry Review
On behalf of the Canadian life and health insurance industry, we appreciate the opportunity to provide additional comments regarding the regulation of chiropody and podiatry in Ontario. In Ontario, at the end of 2013, the life and health insurance industry provided some 9.3 million Ontario residents with supplementary health benefit coverage and made payments of $10.1 billion, of which roughly $468 million was for paramedical and other healthcare goods and services, which includes the services provided by Chiropodists and Podiatrists.
Overall, we are supportive of the changes being proposed by the College of Chiropodists of Ontario. In our July 4, 2014 initial response to HPRAC, we recommended that HPRAC consider the development of one restricted title and scope of practice for Podiatrists and Chiropodists. It is our understanding that this recommendation is consistent with the proposal by the College of Chiropodists of Ontario. Since the services of both professions are often included as part of a group benefit plan, we also suggest that in order to minimize confusion with plan members who currently may need to seek OHIP coverage for services provided by a Podiatrist (but not Chiropodist) prior to accessing coverage under their benefit plan, that a consistent funding model be considered.
As an industry, we are supportive of change that assists in protection of the public and minimizing confusion. The proposed changes are a positive step towards those goals. However, these changes only address some of the concerns related to foot care in Ontario. We remain concerned that in the absence of legislation related to the prescribing and dispensing of orthotics and orthopaedic shoes whether by a Chiropodist, Podiatrist, or other individual, that consumer protection issues will remain. While we recognize this goes beyond the current consultation, this is a significant concern for the industry and is related. To assist with consumer protection, we continue to recommend that accepted definitions, guidelines and criteria related to the prescribing and dispensing of orthotics and orthopaedic shoes and common to all health care providers be considered to ensure treatments are provided with the best interests of the patient in mind.
The industry encourages the Ontario government to continue to work with all health care providers and concerned stakeholders to have in place sound governance practices, including with respect to complaints handling and disciplinary procedures. As this consultation continues to progress, we welcome the opportunity to remain involved and assist where appropriate.
Original signed by
Director, Health and Dental Policy