Documents for New Doctor Regulations
HOW YOU CAN MAKE YOUR VOICE HEARD
The following are some instructions on what you can do to ensure your voice is heard. It is critical that we
work together to protect all patients’ rights to access integrative medicine. By coordinating our efforts, our
collective voice will be louder and more powerful. Thank you in advance!
- Post a Comment to the CPSO’s CAM Policy Discussion Forum: The College of Physicians and Surgeons of
Ontario (CPSO) has set up a website for consultation on the new Complementary / Alternative Medicine
• Specifically, there is an Online Discussion Forum where both physicians and members of the
public can post their comments on the new CAM policy. Please take the time to write your
feedback to the CPSO, whether it be your thoughts on the draft policy, the points expressed in
the letters provided to you, or your own personal stories about how integrative medicine has
made a difference in your life. The CPSO is supposed to take these comments into consideration
and will be keeping this forum open until March 15, 2021. You can post anonymously, and there
is no maximum number of posts per person.
• Direct Link to the Discussion Forum: http://policyconsult.cpso.on.ca/?page_id=13091
• Link to the CAM Policy Website site up by the CPSO:
- Send & Email a Letter to the Minister of Health, Christine Elliott
• A Template Letter to the Minister of Health has been provided. All you have to do is date, sign,
and include your name and address in the template.
• Alternatively, we encourage you to write your own personal letter to the Minister.
• Address information for Christine Elliott is set out below:
Hon. Christine Elliott, MPP
Minister of Health
10th Floor, Hepburn Block
80 Grosvenor Street,
Toronto, Ontario, M7A 2C4
• In your letter, please note that you are C.C’ing your MPP, the CPSO, and the Canadian Civil
Liberties Association. By noting who you are also sending the letter to, the reader will be more
likely to give it the attention it deserves.
- Send a Letter to the College of Physicians and Surgeons of Ontario (CPSO)
• You can mail a copy of your letter to Dr. Nancy Whitmore, Registrar of the CPSO
Dr. Nancy Whitmore
Registrar & CEO
College of Physicians and Surgeons of Ontario
80 College Street
Toronto, ON M5G 2E2
- Send & Email a copy of Your Minister of Health Letter to your Member of Provincial Parliament (MPP)
• All MPP Contact Information is listed here: https://www.ola.org/en/members/current/contactinformation
• If you do not know your MPP’s name or your riding/electoral district, you can enter your Postal
Code on the Elections Ontario website to find your electoral district and MPP
- Send a copy of your Minister of Health Letter to the Canadian Civil Liberties Association
• The Canadian Civil Liberties Association is a non-profit organization that stands up to power to
keep government and those in authority accountable to the people they represent. It actively
stands up to power by fighting against rights violations, and stands for freedom, equity and a
better future for all people in Canada.
• Addressed to:
Mr. Michael Bryant
Executive Director and General Counsel
Canadian Civil Liberties Association
900 – 90 Eglinton Ave. E.,
Toronto ON M4P 2Y3
- And very importantly – Please spread the word!!!
Whether it be through phone calls, emails, social media, we encourage you to inform others about the
CPSO’s proposed CAM policy changes!
Feel free to circulate this package of information to anyone who might care about protecting their
autonomy to choose between different methods of treatment. Strength in numbers cannot be
underestimated when petitioning government for change.
Hon. Christine Elliott, MPP
Ministry of Health
777 Bay St., 5th Floor
Toronto, ON M7A 2J3
Dear Minister Elliott,
I am writing to you with an urgent request to protect my access to healthcare.
I am a patient who has experienced life-changing benefits from Complementary and Alternative Medicine (CAM). I have recently learned that the College of Physicians and Surgeons of Ontario (CPSO) has proposed revisions to its existing CAM policy which will make it extremely difficult for Integrative Medicine physicians to practice without the fear of being unjustly disciplined by the CPSO. The changes will rob patients of their right to obtain the care that they need and want. It will also stifle innovation in the Ontario healthcare system.
While I recognize that the CPSO is a self-regulating body, it is ultimately accountable to the Ministry of Health. This is why I am writing to you. The CPSO has invited input on the draft policy before March 15, 2021, and I am asking you to assert your input.
There are significant issues with the new draft of the policy that discriminates against physicians using CAM. The policy was drafted by a committee, none of which were physicians who actually practice CAM. To highlight a few of the issues:
- Increased Evidentiary Requirements for Physicians using CAM: The new CAM policy will require physicians to only provide treatments that are supported by evidence and scientific reasoning. This language replaces the more lenient term of “informed by” in the previous policy – which is the same language used in policies in BC, Alberta, Saskatchewan, Nova Scotia and Newfoundland & Labrador. The new policy explicitly outlines a hierarchy of evidence, with randomized control trials being at the top and case-control studies, case reports, and editorials/expert opinions deemed to be of lower quality evidence. Shared clinical experience and positive patient outcomes is not an acceptable form of evidence.
There is one troubling issue with the above requirement: Many natural treatments will never be substantiated by the level of evidence that the new policy requires because they are not patentable. Natural substances/non patentable treatments will rarely obtain the financial backing to allow for costly large-scale clinical trials. No patent, no profit, no proof. CAM physicians often apply therapies that are outside the box to help medically challenging patients, and thus often rely on collective experience and previous patient outcomes to approach such patients.
- Unreasonably burdensome documentation requirements: The new policy requires CAM physicians to document the evidence-based rationale and risk benefit analysis for every single treatment they provide. It is not logistically sustainable in a busy practice and conventional physicians are spared from these requirements. This would act as yet another deterrent to physicians from using CAM and is another example of the discriminatory nature of the policy.
- Omission of Section 5.1 of the Ontario Medicine Act: This provision states that “physicians shall not be found guilty of professional misconduct or incompetence solely on the basis that they practice a therapy that is non-traditional or that departs from the prevailing medical practice.” This Section is included in the current policy yet is entirely omitted from the new policy. This sets a deeply concerning tone for the entire policy.
It would be ideal if conventional medicine had answers for all ailments. Unfortunately, this is not the case. The new policy prevents a conscientious physician from trying his or her best to “problem solve” using all methods available.
If the new policy is adopted, physicians will be prevented from using natural and innovative treatments that have helped thousands of people like me. Irrespective of their safe and effective benefits to patients, natural treatments will always be considered “unproven” and therefore, disallowed. Physicians will inevitably be forced to prescribe only pharmaceutical drugs.
We should be encouraging (not prohibiting!) physicians to explore all safe and effective options for patients. If physicians are forbidden from thinking and acting ‘outside of the box’ for the benefit of their patients, this will silence innovation in the Ontario medical system. We will also risk losing empathetic, innovative physicians to other provinces.
Minister Elliott, I am not asking you to unreasonably intervene with the CPSO’s autonomy. I am simply asking you to uphold an existing Ontario law: Section 5.1 of the Medicine Act.The CPSO’s proposed revision, which would discipline physicians who use treatments that depart from prevailing medicine, is a clear contravention of Section 5.1.
There is also clear case law stating that the majority in a profession ought not to be allowed to stifle the creativity and innovation of the minority (Brett et al. v. Board of Directors of Physiotherapy). The CPSO’s proposed revision is allowing the majority (i.e., conventional practitioners) to stifle the creativity and innovation of the minority (i.e., physicians using complementary and alternative medicine treatments).
Minister Elliot, we need a powerful voice like yours. Please represent my concerns to the CPSO before it is too late. Please urge them to reconsider their draft policy to make it more favourable for CAM physicians (specifically, eliminating increased evidentiary requirements, including the Section 5.1 reference, and including a CAM physician in the policy revision committee) and in turn, for patients like me.
Canadian Civil Liberties Association.
“It is the duty of the Minister to ensure that the health professions are regulated and coordinated in the public interest, that appropriate standards of practice are developed and maintained and that individuals have access to services provided by health professions of their choice and that they are treated with sensitivity and respect in their dealings with health professionals, the College and the Board.” (s.3 of R.H.P.A.)