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Letter to The Honourable David A. Wilson Re: Nova Scotia Bill No. 147 - Regulated Health Professions Network Act


Release Date: 01/04/2013
Staff Reference: Stephen Frank

January 4, 2013

The Honourable David A. Wilson
Minister of Health and Wellness
17th Floor, Barrington Tower
P.O. Box 488
Halifax, Nova Scotia
B3J 2R8

Dear Minister:

Re: Bill No. 147- Regulated Health Professions Network Act

On behalf of the Canadian life and health insurance industry, we would like to offer our comments on Bill 147, the Regulated Health Professions Network Act (the "Bill"). As providers of health and dental benefits, insurers have a significant interest in matters concerning the regulation of health professionals in Nova Scotia. For that reason, we feel it is important to share our thoughts for your consideration.

The CLHIA is a voluntary trade association with member companies that account for 99 per cent of Canada's life and health insurance business. In Nova Scotia, at the end of 2011, the life and health insurance industry provided about 640,000 residents with supplementary health benefit coverage and made payments of roughly $701 million.

We support the government of Nova Scotia's intention of creating a legislative framework to enhance communication and collaboration between health professions in the province. In particular, we view the sharing of best practices by regulated health professionals and the use of joint investigative processes to be positive steps that could enhance the professionalism of health care practitioners in Nova Scotia generally, and provide for greater protection of the public.

We note that section 17 of the Bill provides that two or more health professions can enter into an agreement with respect to their scopes of practice, and section 18 of the Bill provides that a regulated health profession can seek modification of its scope of practice. We would recommend that care be taken in permitting such agreements or modifications. Scopes of practice have been developed and implemented in the governing statutes of regulated health professions and provide necessary clarity to allow members of the Nova Scotia public, as well as other stakeholders, to understand the activities that regulated health professionals may engage in. In addition, scopes of practice are generally relied on to adjudicate health and dental claims by group benefit plan administrators.

Given the foregoing, we would recommend that consideration be given to amending the Act prior to it being brought into force such that: (i) subsection 17(3) provide that the Nova Scotia public must be provided access to any agreement between regulated health professions with respect to their scopes of practice; and (ii) subsection 17(4) of the Bill provide that the public must be provided with a minimum of 60 days to comment on any such agreement. Similarly, we would recommend that subsection 18(4) be revised so that any proposal to modify the scope of practice of a regulated health profession be open to a minimum of 60 days public consultation. While we would like to see greater clarification of section 18 of the Bill generally, these initial changes would provide greater transparency to the public and could have the positive effect of enhancing the public's perception of legislative fairness with respect to the regulation of health professionals in Nova Scotia.

To further enhance transparency and the perception of fairness by the public, we also recommend that the membership of the Nova Scotia Regulated Health Professions Network (the "Corporation") mandate the inclusion of public representatives. The inclusion of the public, particularly representatives of affected stakeholders, can assist in the development of best practices for regulated health professions, which can have the positive effect of enhancing generally the professionalism of regulated health professionals and promoting the protection of the public. The inclusion of the public in the Corporation's membership or on a stakeholder advisory committee would also be consistent with current trends in the regulation of health professionals in other provinces (see for example the Manitoba Bill entitled The Regulated Health Professions Act).

Finally, we note that section 19 of the Bill provides for the establishment of collaborative investigative processes amongst participating members of the Corporation where a complaint affects two or more members. The insurance industry has had experience in working with multiple regulators on related complaints and we view this as a positive development. Greater collaboration between regulated health professions would help promote efficiency in resolving complaints, generally enhance the credibility of health professionals in Nova Scotia and better protect the public.

Thank you for your consideration of these issues. We would be pleased to discuss this with your officials at their convenience or provide any other information. In this regard, please feel free to contact Karen Voin, Director Health and Dental at (416)-359-2020.