August 4, 2016
We are preparing a brief for the Accessibility Directorate of Ontario on the barriers that people with disabilities face in the health care system. This is part of the Government’s “pre-consultation” on the Health Care Accessibility Standard that the Wynne Government promised 18 months ago to create under the Accessibility for Ontarians with Disabilities Act (AODA).
We need your stories, and we need them fast! Tell us what barriers and accessibility problems you have encountered when trying to use health care services in Ontario. Don’t just think about doctors and hospitals. Include any accessibility barriers or problems you have had when trying to get any kind of health care services in Ontario, from any kind of health care professional or provider, at any kind of health care facility.
The Accessibility Directorate’s deadline for receiving our brief is August 31, 2016. Let us know by the end of August 12, 2016. Email us at email@example.com
There is no need to share with us personal and private health information. You don’t need to write anything long and detailed. We welcome any feedback, no matter how short.
In this Update, we also let you know what happened on July 26, 2016, when the AODA Alliance took part in the Government’s “pre-consultation” meeting on the Health Care Accessibility Standard. At the end of this Update, we show you the Government’s PowerPoint from that meeting. It gives some insight into the Government’s thinking.
Below we also set out our description of highlights at the Government’s July 26, 2016 “pre-consultation” session. In short:
* The Government initially tried to exclude from the Health Care Accessibility Standard any consideration of built environment barriers in the health care system. It tried excluding these before any work even got started on developing this Standard. we objected to this at this meeting. The Government backed down. It said the health care Standards Development Committee will not be restricted from considering any accessibility standards barriers in the health care system.
* After taking the last two years to discover accessibility barriers in the health care system, the Government had only found a small fraction of the serious obstacles that people with disabilities face.
* the Government’s unnecessary “pre-consultation” duplicates the work that must be done by the Health Care Standards Development Committee, which the Government has delayed appointing for 18 months.
* We learned that some time ago, the Government used public money to hire the KPMG consulting firm to consult on accessibility barriers in the health care system. This appears to be yet another unnecessary delay, for what amounts to have been a “pre-pre-consultation.”
* KPMG did not consult people with disabilities. It certainly didn’t consult the AODA Alliance. We are the community coalition that has led the fight for over half a decade to get the Government to develop a Health Care Accessibility Standard. KPMG only consulted health care providers. Yet people with disabilities are the experts on the barriers they daily face.
* At this meeting, the Government commendably agreed to give us the KPMG report on health care accessibility standard barriers. We will make it public once we get it.
It was no small irony that during a break at this July 26, 2016 “pre-consultation” meeting (which was held on the 26th anniversary of the passage of the Americans with Disabilities Act), AODA Alliance chair David Lepofsky discovered that the public men’s room by the Accessibility Directorate’s office has no accessible Braille signage. That kind of signage is far more commonly found in the U.S. than in Ontario.
A photo of this barrier was tweeted to all members of the Ontario Legislature who are on Twitter, as an “#AODAfail. This was part of our ongoing “Picture Our Barriers” campaign.
In recent revisions to the Customer Service Accessibility Standard, the Wynne Government refused our request to require accessible signage for such public washrooms. The Wynne Government says it is leading by example on accessibility. This is not a good example by which to lead. To learn more about the Government’s refusal to include our proposals in recent revisions to the Customer Service Accessibility Standard.
You can always send your feedback to us on any AODA and accessibility issue at firstname.lastname@example.org
Have you taken part in our “Picture Our Barriers” campaign? If not, please join in! You can get all the information you need about our “Picture Our Barriers” campaign.
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We encourage you to use the Government’s toll-free number for reporting AODA violations. We fought long and hard to get the Government to promise this, and later to deliver on that promise. If you encounter any accessibility problems at any large retail establishments, it will be especially important to report them to the Government via that toll-free number. Call 1-866-515-2025.
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Please also join the campaign for a strong and effective Canadians with Disabilities Act, spearheaded by Barrier-Free Canada. The AODA Alliance is proud to be the Ontario affiliate of Barrier-Free Canada. Sign up for Barrier-Free Canada updates by emailing info@BarrierFreeCanada.org
1. Highlights of the Accessibility Directorate of Ontario’s July 26, 2016 “Pre-Consultation Meeting on the Promised Health Care Accessibility Standard
The Accessibility Directorate of Ontario initially told us at its July 26, 2016 “Pre-Consultation” meeting that built environment barriers were not to be addressed in the promised Health Care Accessibility Standard, since the built environment is now addressed in the Ontario Building Code. The Government had decided this before it even began the AODA’s mandatory process for reaching out to the disability community. The Government’s PowerPoint, set out below, stated:
” What’s out?
Improving access to health programs and services
New requirements for the built environment where health services are provided”
At this meeting we strongly objected to this. People with disabilities face too many built environment barriers in places where health care services are provided.
The accessibility amendments to the Building Code that went into effect in 2015, while partially helpful, are still clearly inadequate. They leave Ontario well behind on accessibility. They don’t ensure that new buildings and major renovations will be disability-accessible. Moreover, they don’t require any retrofits in any existing building that is undergoing no major renovations. This is so no matter how easy and low-cost those retrofits might be.
Troubling accessibility problems in the brand new Women’s College Hospital in Toronto have been depicted on Twitter in the AODA Alliance’s “Picture Our Barriers” campaign. You can find these tweets by searching on Twitter, looking for the #AODAfail hashtag. These help show why the Health Care Accessibility Standard cannot exclude built environment barriers.
Patients with disabilities cannot get accessible health care services if they cannot even get into and get around places where health care services are provided. We told the Accessibility Directorate of Ontario that the Government should not arbitrarily restrict the future Health Care Standards Development Committee, to be appointed under the AODA, from being able to consider any accessibility barrier that people with disabilities face in Ontario’s health care system.
During the meeting, Ann Hoy, the Assistant Deputy Minister for the Accessibility Directorate, said that if built environment barriers were addressed in the Health Care Accessibility Standard, that accessibility standard would become very big. We responded that this is surely no reason for excluding built environment barriers from that accessibility standard.
In the face of these points, the Accessibility Directorate of Ontario committed at this meeting that the Health Care Standards Development Committee will not be restrained by anything that has gone on during this “pre-consultation” and by any work that has gone on before that. From this, we understand from this that the Government will not try to block the Health Care Standards Development Committee from considering any accessibility barriers in its discussions and recommendations. That Standards Development Committee will be free to address any accessibility barriers that people with disabilities face in the health care system, including built environment barriers. We commend that decision. As well, Assistant Deputy Minister Ann Hoy said that the Accessibility Directorate will not be directing the Standards Development Committee how prescriptive to be.
After all the time the Government spent over the past two years, exploring accessibility barriers in Ontario’s health care system, the Government’s PowerPoint showed that the Government had only found a very small fraction of the areas where people with disabilities actually face barriers. The PowerPoint listed the following barriers:
” What’s in?
• Targeted accessibility training requirements for health care providers
• Improving the interaction between health care providers and persons with disabilities
• Identifying best accessibility practices and patient accommodations
• Accessible prescription drug labels and instructions
• Other focus areas as identified”
The PowerPoint described as barriers to be address: health care providers’ insensitivities towards people with disabilities, and communication barriers when dealing with health care providers. These are all the disability barriers the Government unearthed in Ontario’s health care system, facing people with disabilities, after working on this issue over the past two years. We pointed out at the July 26, 2016 “pre-consultation” meeting, this leaves out a wide range of well-known and critical barriers, including barriers in the built environment in health care facilities, barriers in information technology in the health care system, and barriers in diagnostic equipment in the health care system, just to name a few.
We have been urging the Wynne Government for months to at last appoint the long-overdue Health Care Standards Development Committee. When the Wynne Government finally appoints that Committee, its job will be to consult the public, including people with disabilities, and then to recommend to the Government which accessibility barriers the promised Health Care Accessibility Standard needs to address, what measures it will require, and the time lines for action.
During this “pre-consultation” meeting, the Accessibility Directorate of Ontario spent most of the time asking disability sector representatives to identify the barriers people with disabilities face in the health care system, and what measures should be imposed to fix them. We explained at this meeting that this “pre-consultation” flies in the face of the AODA itself. The AODA gives this responsibility to an independent, armslength Standards Development Committee.
This is an unnecessary duplication of the very work that the Health Care Standards Development Committee will be required to do. The Government’s PowerPoint, set out below, states:
To identify in health care:
• Accessibility gaps and barriers not addressed by other accessibility standards;
• Recommendations and best practices for barrier reduction or prevention; and
• Possible focus areas for a potential accessibility health standard”
At this meeting, we again asked the Government to now appoint that Standards Development Committee, and not to hold its appointment up until this “pre-consultation” is finished. We asked the Accessibility Directorate to promptly make public a list of all the health care accessibility barriers that it hears about during its “pre-consultation”, and that it give this list to the Health Care Standards Development Committee. The Accessibility Directorate of Ontario agreed that it would give that Standards Development Committee the list of barriers in the health care system that it hears about during this “pre-consultation”.
We learned at this meeting that the Government had earlier hired the KPMG consulting firm to hold a consultation to find out what accessibility barriers face people with disabilities in the health care system. This amounts to an unnecessary “pre-pre-consultation”. The Government had a report from KPMG over one year ago, in the 2015 summer.
We asked the Government to now give us a copy of the KPMG report. Assistant Deputy Minister Ann Hoy agreed to give it to us and anyone at the meeting who wants it. We made it clear that we want it now, and that we will make it public. We and others will want to study it as they prepare their input into this “Pre-Consultation”. With The Government has not yet sent us that report.
We asked whom KPMG consulted on the accessibility barriers that people with disabilities face in the health care system. The Accessibility Directorate told us that KPMG consulted health care providers, but not people with disabilities. We responded that it was wrong for the Government to delay the appointment of the Health Care Standards Development Committee, in order to hire KPMG, and for KPMG to then not consult people with disabilities.
When the Government passed the AODA 11 years ago, it commendably emphasized the central role that people with disabilities must play in the development of accessibility standards. People with disabilities are the experts on the barriers they daily face.
It is a sad irony that KPMG had never consulted the AODA Alliance. We are the organization that came up with the idea of developing a Health Care Accessibility Standard, and that has led the fight for over half a decade to get the Government to develop it.
The Accessibility Directorate asked us which barriers should be a priority. We explained that the Health Care Accessibility Standard must ensure that health care services become fully accessible. We cannot set priorities in advance, such as choosing that accommodating one kind of disability takes priority over another. Every disability must be accommodated. We cannot say that it is less important to get in the building than to get onto the diagnostic table.
We add a final point arising from the Government’s PowerPoint, but not discussed at the meeting itself. The Government’s PowerPoint says:
“KPMG research findings from Summer, 2015 indicated that Ontario is comparable to or better than other jurisdictions in addressing accessibility in the healthcare sector.”
This raises three concerns: First, why are we first hearing this in the 2016 summer, if KPMG finished that “pre-pre-consultation” work in the 2015 summer? How long has the Government delayed since receiving the KPMG report, before it started its current “pre-consultation”?
Second, what value can there be in KPMG’s findings about accessibility in Ontario’s health care system, when it did not ask people with disabilities about the accessibility barriers they face in Ontario’s health care system?
Third, what value is there in a finding that Ontario is comparable to or better than other jurisdictions? The AODA requires Ontario’s health care system to become fully accessible. If all other jurisdictions have poor accessibility, it would be no answer that Ontario’s is just as poor, or perhaps slightly less poor, than other jurisdictions?
2. Text of Accessibility Directorate of Ontario PowerPoint Presentation for the July 26, 2016 “Pre-Consultation” on the Health Care Accessibility Standard
Possible Focus Areas for a Potential New Accessibility Standard for Health Care
Pre-Consultation July 26 and August 10, 2016
Accessibility Directorate of Ontario
Ministry of Health and Long-Term Care
- In response to the Moran Report in February 2015, the government committed to exploring how to remove barriers in individual sectors, starting with the health care sector.
- The review emphasized that the health care sector is serving patients with temporary or permanent disabilities at all times, which sets it apart from other businesses and organizations.
- The review highlighted stakeholder concerns that barriers in health care may not be addressed by current obligations and suggested a targeted approach to developing new requirements.
- On June 3, 2015, “The Path to 2025: Ontario’s Accessibility Action Plan” was released, and included a government commitment “to review barriers in the delivery of health care as a first step toward illuminating barriers that will be overcome through education, outreach and new standards.”
Preliminary Research Findings
- KPMG research findings from Summer, 2015 indicated that Ontario is comparable to or better than other jurisdictions in addressing accessibility in the healthcare sector.
- However, KPMG’s work also identified common accessibility barriers within the health care sector, including the following which will be discussed in more detail later:
- Interaction with health care providers
- Communication and Administrative
Guiding Principles for Pre-Consultation
- Accessibility vs. Access – address barriers to accessibility that persons with disabilities may experience when receiving health care services, not access to specific programs or services
- Align with Existing Accessibility Standards – consider the complex statutory and regulatory environment in which the heath care sector functions and seek to address specific regulatory gaps, rather than duplicate or overlap existing accessibility requirements
- Implementation – recommendations can be implemented in the health care sector in the short-term and scaled up over the long-term
A Potential New Health Care Standard
– in Context of AODA Standards
- Addresses the provision of goods or services or facilities (Note: new regulation amendment provides for the inclusion of “facilities” such as venues/conferences)
- Addresses ways to prevent and remove barriers to public transportation
Information and Communications
- How organizations create, provide and receive information and communications in ways that are accessible for people with disabilities
Current standards under AODA continued
- How organizations can make accessibility a regular part of their employment practices
Design of Public Spaces
- Addresses accessibility barriers for the exterior built environment (e.g. trails, sidewalks and outdoor play spaces)
What’s In Focus?
- Targeted accessibility training requirements for health care providers
- Improving the interaction between health care providers and persons with disabilities
- Identifying best accessibility practices and patient accommodations
- Accessible prescription drug labels and instructions
- Other focus areas as identified
- Improving access to health programs and services
- New requirements for the built environment where health services are provided
Barrier # 1
Interactions with Health Care Providers
Barrier: Patients with disabilities may experience insensitivities when interacting with a health care provider. This may lead to mistrust or misdiagnosis, resulting in poorer health outcomes.
Example: Health care providers who prefer to communicate with caregivers or family, leading patients with disabilities to feel ignored or miss important information.
Questions re: Barriers in Interactions with Health Care Providers
- What key accessibility barriers do persons with disabilities experience when interacting with a health care provider?
- As a patient/person with a disability, what could health care providers do to improve their awareness and consideration of accessibility barriers?
- As a health care provider, what additional resources would assist your awareness and ability to accommodate the needs of persons with disabilities?
- How can a health care standard help health care providers and patients be confident that their key messages have been heard and understood?
Barrier # 2
Barrier: Patients with disabilities may face a variety of communication barriers in navigating Ontario’s health sector. This may lead to fragmented or unequal care.
Example: Patients with disabilities may miss appointments because of inaccessible notifications (e.g. mailed letters)
Example: Patients with disabilities may experience difficulty reading or understanding a prescription drug label (e.g. font on label is too small).
Questions re: Communication Barriers
- What communication barriers do persons with disabilities face when accessing health care services?
- As a patient / person with a disability, what could health care providers do to reduce communication barriers?
- As a health care provider, what additional resources would allow you to better accommodate accessibility needs and reduce communication barriers?
Questions re: Other Barriers
- As a patient / person with a disability, what other accessibility barriers have you experienced in accessing health care services?
- As a health care provider, what other accessibility barriers have you experienced in providing health care services to people with disabilities?
- How could these barriers be addressed through a new accessibility standard for health care?
- The development of a potential new accessibility standard is an ongoing, collaborative process.
- These initial, pre-consultations are intended to inform an overall framework for a potential new accessibility standard for health care.
Your feedback as part of this process will help improve Ontario’s understanding of barriers and how they could be addressed in the standards development process.
- Invited organizations who have members who wish to express their lived experiences of inaccessibility – August 23 and 25, 2016
- Survey is open until August 31:
Other Inquiries: firstname.lastname@example.org
Opportunity for public comment will be provided during standards development process, once the Standards Development Committee has submitted an initial proposed standard to the Minister
- Purpose: An accessible Ontario by 2025 through the development and enforcement of proactive standards in key areas of daily living.
- First jurisdiction in Canada with legislation that sets out a clear goal and timeframe for accessibility by 2025.
- First jurisdiction in the world to require public, private and not-for-profit sector organizations to train their staff on accessibility.
- First jurisdiction in the world to move to a modern regulatory regime that mandates accessibility reporting from organizations.
- Applies to all organizations in Ontario with one or more employees (public/private/not-for-profit).
- Requirements are being phased in through to 2021 based on organizational type and employee count.
Ministry of Health and Long-Term Care: Patient First Strategy
- Access – Improve access – providing access to the right care
- Connect Services – delivering better and coordinated and integrated care in the community, closer to home
- Inform – Support people and patients – providing the education, information and transparency they need to make the right decisions about their health
- Protect our universal public health care system – making decisions based on value and quality, to sustain the system for generations to come