Ontarians suffering from injury related to motor vehicle accidents (MVA) continue to be subjected to excessive wait times to receive the care that they require.
This issue is being raised and discussed with Ministry officials as part ongoing policy discussions with respect to signing authority for treatment of MVA related injuries.
The current regulatory framework establishes that a “Health Practitioner” be the lead on any treatment plan that is submitted for the recovery care in the case of an MVA.
However, the definition of “Health Practitioner” is not comprehensive or reflective of the Regulated Health Professions (RHP’s) that are able not only to treat conditions but also to diagnose health conditions. Specifically, members of the College of Traditional Chinese Medicine Practitioners and Acupuncturists of Ontario (CTCMPAO) are currently excluded from the definition of “Health Practitioner.”
The argument for allowing Registered Traditional Chinese Medicine Practitioners (R.TCMP.’s) and Registered Acupuncturists (R.Ac.’s) to be included within this definition is based, in part, on 2013-14 advisories from the CTCMPAO. The advisories cited that regulatory change had been made subsequent to a request from FSCO and as a result, both OCF-18 and WSIB treatment forms would include R.TCMP.’s and R.Ac.’s as those listed under the Statutory Accident Benefits Schedule (SABS) as a “Health Practitioner” eligible to sign off on MVA treatment plans (OCF-18 forms).
It appears that, although the regulatory change was made, physical alterations to the regulation were either lost or never incorporated/posted into regulatory documents. Subsequent digitalization of treatment forms also left R.TCMP.’s and R.Ac.’s out of the SABS list of “Healthcare Provider”.
In addition to the exclusion from the definition of “Health Practitioner”, R.TCMP.’s and R.Ac.’s are also omitted from the listed “Health Care Profession or Provider” appendix within the Professional Services Guideline (which is a guideline under SABS).
As a result of exclusion from the SABS list:
• Access to care is being delayed or in some cases denied MVA patients who view the signature requirement as an impediment.
• Delays of a week or more are common in obtaining signatures result in postponed treatment and slower recovery.
• Red tape is adding costs rather than value: R.TCMP.’s and R.Ac.’s report being charged an average of $114 – for a signature.
• R.TCMP.’s and R.Ac.’s are often not reimbursed for appropriate costs of care as inconsistencies arise due to the exclusion from the Rates & Fees appendix.
It is noteworthy that, under their scope of practice, members of the CTCMPAO (R.TCMP.’s and R.Ac.’s) can both diagnose injury and illness as well as prescribe treatment. Further, under direction of the Government of Ontario, the CTCMPAO is currently in the final stages of establishing a Doctor title for Traditional Chinese Medicine (Dr. TCM). These facts strongly support this RHP’s inclusion within the definition of Health Practitioner able to sign the OCF-18 and OCF-23. As other RHPs listed in the Statutory Accident Benefits Schedule (SABS) for the purpose of submitting the OCF-18 and OCF-23 forms, R.TCMP.’s and R.Ac.’s are held to standards of competence and accountability by their regulatory college (the CTCMPAO).
As the government has consistently emphasized, Ontario’s auto insurance system should balance patient access to care, cost-effectiveness and accountability. The exclusion of R.TCMP.’s and R.Ac.’s from signing the OCF-18 and OCF-23 does not support these objectives as it creates unnecessary delay and duplication, adds costs and creates barriers to timely patient recovery.
For more information, please contact:
Katrina Dollano, Vice-President, TCMO: katrina.dollano@tcmo.ca
Heather Kenny, President, TCMO: heather.kenny@tcmo.ca