Email letter to Tiffany Kautz, Accreditation Canada, from the ISDCO

April 3, 2024

I am writing on behalf of the Independent Surgical & Diagnostic Clinics of Ontario (ISDCO), the provincial industry association representing the interests of the ISHSC sector.  

First off, congratulations on Accreditation Canada (AC) for now officially taking on the role of the new QA oversight organization for the sector.  As was communicated to us in the recent videoconference facilitated by the Ministry, we understand that AC will shortly be distributing a new set of QA standards to ICHSCs.  

Our association has been giving a lot of thought to the communications rollout to the clinic sector.  We believe that there will be a need to convey both information and a certain amount of reassurance.  A number of sector participants have expressed concern that institutional standards will be imposed on the community-based clinic sector.  

In order to help address these concerns, the ISDCO would like to work with you in holding one or more virtual (or live) events, in which information (and reassurance) can be given.  We would suggest holding a webinar very shortly after the release of the new QA standards.  Moreover, our annual conference in the fall is always well attended by the clinic sector.  As a result, we would invite AC to be a presenter at the upcoming annual conference.  These events are traditionally held in a convention centre in the north part of the GTA.     

Tiffany, please feel free to reach out to me, or to our executive director, Stephanie Bolton.

Best regards,
Jason Hartman, President, True North Imaging and Director, Independent Surgical & Diagnostics Clinics of Ontario

Concerns Regarding Regulatory Amendments Submitted

 The Ministry has made regulatory amendments under the ICHSCA to support strengthened quality assurance, safety and inspections within the integrated community health service centres sector (ICHSCs).  The ISDCO has heard the concerns expressed by clinic operators regarding aspects of these proposed changes that we believe may have negative and unintended consequences for the entire ICHSC sector.  The ISDCO made a submission to the Ministry to express the areas of our concern.  

Ontario Preparing for Clinic Expansion

Ontario is preparing for the next step in its expansion of private clinics that can offer publicly funded tests and procedures. Learn More.

Survey Results

The ISDCO conducted a provincial survey of community clinic operators during the first half of November 2023.  The responses to this survey suggest that clinic operators are concerned about the financial health and the sustainability of the sector.  The health and human resource crisis is expected to have a material impact on the ability of the sector to continue to perform its ‘share’ of provincial healthcare services.  Clinic operators expect to have to match significant wage increases to be given to hospital-based staff [who already enjoy the benefits of participation in the HOOPP pension plan], or else risk losing staff.  OHIP underfunded technical fee compensation concerns also remain an issue. 

These compensation issues are now exacerbated by COVID-19 loan repayment obligations and the need to replace aging fleets of medical equipment.  

These survey results suggest that funding initiatives from the Government may be necessary to ensure the sustainability of the clinic sector and to better balance the “playing field” with hospital-based providers.

Attached is the full submission.

Full Survey Results.

Submission to OBSP

Connecting more women to Breast Cancer Screening earlier has the province lowering age eligibility to receive publicly funded mammograms to include those aged 40-49 beginning fall 2024. However, there are a number of material factors such as equipment capabilities and human resources that are likely to undermine the ability of service providers to meet the Government’s goals. Recommended solutions  will assure community-based OBSP sites are able to meet their service responsibilities in the coming years.

Legislative Foundation Changed

As of September 25, 2023, the Integrated Community Health Services Centres Act, 2023 (ICHSCA) and its regulations has come into effect. The ICHSCA repeals and replaces the Independent Health Facilities Act (IHFA). Independent Health facilities will now be known as independent community surgical and diagnostic centres.

Not since the creation of the legislation creating the Independent Health Facilities Act in 1990 has the IHF industry had to address changes that are as significant as those to be faced in the coming months.