New Registrar for Transitional Council and New Member of BDDT-N
Andrew Parr has been appointed as the new Registrar of the transitional Council of the College of Naturopaths of Ontario. For the past eight years, Andrew has been Executive Director & CEO of the Registered Massage Therapists’ Association of Ontario.
The Registrar is the chief administrative officer of the Transitional Council, supporting the transitional Council in all its work, including developing and implementing policies, by-laws and regulations that will govern the practice of the health profession.
The government also announced that Mary Welch ND has been appointed a member of both the BDDT-N and Transitional Council.
The OAND warmly welcomes both Andrew and Mary to their new roles, and has offered our support as they work to establish the new College of Naturopaths of Ontario, and a strong new foundation for the profession.
OAND Vision for a Strong New Foundation for the Profession
The final approval of the new Naturopathy Act in 2007, along with the amendment last fall to include prescribing authority moves Naturopathic Doctors into the same regulatory framework as every other health profession. This creates important new opportunities for the profession to become a much more vital force in the health of Ontarians.
The OAND believes the patients of NDs will be best served if NDs can work to the full scope of their training and capability, and with the potential for the naturopathic practice to continue to evolve. If these new rules do not support full scope, or make it difficult for NDs to explore new therapeutic approaches, these opportunities may not be fully realized.
Developing these new rules is the role of the Transitional Council. The Transitional Council, which met for the first time in November, 2009, is responsible for preparing the new regulations that the Ontario government needs to approve for the Naturopathy Act comes into full force to replace the Drugless Practitioner Act. When that happens, the new College of Naturopaths of Ontario will take over responsibility for regulating the profession.
In every health profession, the regulator, educational institution and professional association have different mandates, but a strong and common interest in having a well regulated profession. This is equally true for naturopathic medicine. The mandate of the OAND through the transition process is to be the voice of the profession, advocating on behalf of our members to support the Transitional Council in developing effective new rules. Working together is critical to the success of this effort.
The five guiding principles developed by the OAND to achieve our vision for a strong new foundation for Naturopathic Medicine in Ontario are:
Full Scope
An approach to regulation that supports a dynamic and evolving profession able to practise safely to the full of extent of their training and competence
Naturopathic Principles
An approach to regulation that ensures the profession evolves while preserving the integrity of the naturopathic approach to care.
Primary Care Providers
To establish NDs as primary care providers supported through regulation to achieve their full potential in contributing to patient care.
Integrated
Identify and address potential barriers to NDs being integrated fully into the health care system and valued as partners in collaborative care.
Best Practices
Establish clear and effective new standards of practice that achieve the public interest by building on regulatory best practices of other health care professions and Naturopathic Medicine in other jurisdictions.
The new rules for the profession that are developed in the transition process will shape naturopathic care in the province for many years to come. The OAND, as the voice for the profession, is committed to supporting the success of the transition process.
Prescribing Authority: What it Means for Ontario's NDs
On November 30, the Ontario legislature gave final approval to Bill 179, which includes the amendment to the Naturopathy Act awarding Ontario NDs the controlled act of "prescribing, dispensing, compounding or selling a drug designated in the regulations." Awarding NDs prescribing authority was supported by all three political parties.
This amendment to include prescribing authority means that the Transitional Council for the future College of Naturopaths of Ontario now has the authority to develop advice for the Ontario government on the naturopathic formulary, and associated standards of practice to ensure safe practice. Prescribing authority will come into effect once the regulation of the profession moves under the Naturopathy Act at the end of the transition process. This is now expected to be in 2012.
The Importance of Prescribing Authority for NDs and Patients
Prescribing Authority ensures NDs and patients will have access to traditional substances that have become restricted or may become restricted in the future with the implementation of the NHP regulation, as well as clear authority to compound, dispense and sell these substances. Prescribing authority also creates the potential for NDs to have access to crash cart medications and a limited range of primary care substances.
Examples of the substances that NDs would have trouble accessing and using in clinical practice without prescribing authority include:
1. Write prescriptions for restricted natural substances
(e.g. belladonna obtained from a compounding pharmacy for irritable bowel syndrome)
2. Compound, dispense and sell non-Schedule I natural substances in clinic
(e.g. ephedra for asthma)
3. Order compounding by pharmacy
(e.g. compounded homeopathic preparations for injection)
4. Substances administered by injection or inhalation
(e.g. accessing and compounding parenteral therapy formulations)
5. Federally restricted substances
(e.g. Tryptophan for sleep, L-Carnitine for vascular health)
6. Emergency Kit Medications
(e.g. oxygen, diphenhydramine, salbutamol, epinephrine)
7. Legislative authority for continuing evolution of the profession
(e.g. first line primary care drugs like anti-bacterials, anti-fungals, topical agents)
Why Prescribing Authority Was Awarded
Securing this amendment is a major success for the profession, and the result of an intensive advocacy effort focused on demonstrating that NDs are primary care providers with the training and capability to play an increasingly significant role in addressing many critical issues facing the health care system in Ontario. An essential part of this is for NDs and patients to have secure access to substances integral to naturopathic medicine.
Prescribing authority for NDs was recommended in early 2009 by Ontario's Health Professions Regulatory Advisory Council in their Critical Links report. The need for prescribing authority recognizes the increasing restrictions in the regulation of natural substances, and the importance of preserving scope of practice to compound, dispense and sell. HPRAC also recognizes that NDs have the capability to take on a larger role in primary care with access to basic primary care pharmaceuticals. The report is available on the HPRAC website, click here to access it.
The value of investing in prevention
On February 8, The Conference Board of Canada released a report about the potential impact on national health expenditures if risk factors related to cardiovascular diseases were reduced.
The Conference Board says, "Canada could save $76.4 billion between 2005 and 2020 – an average of about $5 billion a year in health savings – if some of the targets set out by the Canadian Heart Health Strategy and Action Plan (CHHS-AP) are met."
The news release on the report can be viewed by clicking here.
The full report can be viewed by clicking here.
The report focuses on five risk factors:
1. hypertension
2. smoking
3. diet
4. physical activity
5. obesity
Clearly, NDs are already making an important contribution to addressing these risk factors. The OAND will be using this report as part of our efforts to raise awareness among policy makers about the importance of a more central role for NDs in reducing the burden of chronic disease.
Benefits of Naturopathic Care for Firefighters
This paper was drafted to assist Toronto firefighters in advocating for adding naturopathic care to their benefits package. Improved insurance coverage for naturopathic care is an important priority for the OAND. Please let the OAND know about any opportunities you are aware of to further this goal, or if you have any comments on this paper.
An Overview of Implications of GST/HST Exempt Status for NDs
September 17, 2009
Please scroll down for supplementary information and to take the survey!
The Naturopathic profession is likely now in a position to apply for GST-exempt status from the federal government. If the profession becomes GST exempt, it would also be exempt from the harmonized sales tax (HST) in provinces where this exists, or in provinces, like Ontario, where it is being considered.
Once a profession becomes exempt there is no ability to go back, so it is important that the decision is carefully considered. This is why it is vital that you be informed and share your views on this important decision by participating in this OAND member survey. This overview and survey has been developed in collaboration with the CAND and is being sent to NDs in all provinces and territories.
An application of exempt status must have the support of the profession. This brief provides an overview of the implications of exempt status to help you understand the potential benefits and disadvantages for you, your patients, and the profession. At the bottom is a link to a survey for you to offer your response as to whether or not you support exempt status.
More information on the implications of exempt status, including basic financial scenarios, is available on the Members Only section of the OAND website under Government Affairs.
Why Health Professions Are Allowed to be Exempt
Under the federal Excise Tax Act, GST is not intended to apply to health care. Most other health professions are already exempt. The federal government has established a policy that health care providers that are regulated in five or more provinces, or publicly funded, will be recognized professions. Exempt status is not automatic and needs to be formally requested. GST exempt status would also make the profession HST exempt.
While professional services are eligible for exempt status, the products sold in a naturopathic dispensary are not.
How GST Works: A Primer on Consumption Taxes
The GST (and HST) is not just a tax that NDs charge patients on goods and services. The intention is that the tax be collected just once on the final goods or services. As a result, NDs can currently claim back the GST they had to pay in the course of providing those goods and services, such as rent, office supplies, utilities, marketing and legal/accounting services. The HST works the same way as the GST. If the profession became exempt, NDs would continue to have to pay GST/HST, but the Input Tax Credit would be partially lost.
HST: Accounting Implications for ND Practices
Currently, a provincial sales tax that is paid on practice expenses is treated as an allowable business expense for tax purposes, as it cannot be reclaimed. When HST is implemented, all NDs in that province are affected by the fact that HST applies to most of their costs, other than labour. The HST is treated in the same manner as GST and therefore, NDs are allowed to recover the HST paid on business expenses as Input Tax Credits.
The rate of HST will vary by province. Currently, HST in Nova Scotia, Newfoundland and New Brunswick is 13%. Effective July 1, 2010, the proposed HST for Ontario will be 13% and for British Columbia will be 12%.
Examples of property/services currently exempt from Ontario PST that will attract 13% HST (once implemented)
- Management company fees paid for administrative services
- Certain professional fees and membership dues
- Certain educational courses and seminars
- Commercial real estate rentals, leases, sales
- Other services including: accounting services, legal services, advertising services, janitorial services, dry cleaning services, monitoring and security services, magazine subscriptions
Process for Securing Exempt Status
Becoming GST exempt requires an amendment of the Excise Tax Act to add NDs to the list of exempt health care professions. The Federal Minister of Finance is responsible for bringing forward this amendment. However, before a request can be put to the Federal Minister of Finance, the profession must be able to demonstrate that there is widespread support from members for the GST/HST exemption.
Potential Implications of NDs becoming GST Exempt
There are important impacts for practitioners, patients and the profession if NDs achieve GST and HST exempt status. The extent and degree to which these impacts are positive or negative will vary from practice to practice, therefore, it is important for each ND to consider the impact on their own practice and patient fees. With GST exempt status, the GST/HST paid would be an allowable business expense for tax purposes.
GST exempt status does not apply to products dispensed by NDs therefore GST/HST must be charged on products sold. It may be possible for NDs to receive input tax credits for the portion of their business dedicated to product sales.
Make an Informed Decision
Each ND will have to make their own assessment of how GST/HST exempt status will affect their practice. You may want to review this impact with your accountant to help determine the potential overall implications for your practice and your patients. If you require additional information before responding to the survey question, sample financial scenarios focusing on the direct financial implications of exempt status and additional materials are available below.
The OAND is surveying all members to determine your view on this important issue. Please click on the link below to respond to the survey. Your reply is required by Thursday, October 1, 2009.
Click here for OAND Member Survey
Ontario Medical Review: May 2009 - Ontario harmonized sales tax
Dentists GST exempt rules
Canada Revenue Agency GST Memoranda: Health Care Services
Canada Revenue Agency GST taxable - exempt supplies
The Regulated Health Professions Statute Law Amendment Act, 2009 and Prescribing Authority for NDs
May 11, 2009
The Ontario government introduced a wide-ranging omnibus bill today, the Regulated Health Professions Statute Law Amendment Act, intended to introduce fundamental changes to the regulation of health professions in Ontario. A primary objective of the legislation is to implement many of the recommendations made by the Health Professions Regulatory Advisory Council (HPRAC) in their January 2009 Critical Links report.
The legislation does not include prescribing authority for NDs. As explained below, this omission was unintentional. The OAND has received assurances that the legislation will be amended to correct this. The OAND efforts over the coming months will be focused on ensuring these assurances are successfully translated into acceptable changes to the legislation by being fully engaged in the legislative process. Final approval of the legislation being introduced today is not expected until Fall. We may need to have members involved in our strategy to achieve prescribing authority and we will let you know how and when once we have a chance to analyze the details of the legislation.
When the legislation was initially drafted, prescribing authority for NDs was not included despite being strongly recommended by HPRAC. The OAND had already planned a series of proactive meetings in April with key provincial government decision-makers and at these meetings we were able to determine that it was an inadvertent omission not to include NDs in the initial version of the legislation.
In these meetings, we reiterated the importance of prescribing authority to NDs and their patients, and secured a commitment from the office of the Minister of Health and Long-Term Care that prescribing authority would be included as an amendment put forward by the government during the upcoming review of the legislation by Standing Committee. It is because of this commitment that the bill introduced today includes a section on the Naturopathy Act that provides a place-holder for these forthcoming changes. Amendments during the legislative process are normal. Major changes to the Naturopathy Act were secured through Standing Committee as a result of a focused advocacy effort.
Key background notes used in briefing the government can be found in the Members-Only section of the OAND website. We ask that you not share these documents publicly. The OAND will be continuing efforts over the duration of the review of this legislation to ensure there is a full understanding of the importance of this issue. This includes the recent information package sent to all MPPs (also available in the Members-Only section of the website) and ongoing meetings with key staff and politicians from all parties.
The OAND will be carefully reviewing the legislation introduced today and will share our broader analysis with all members as soon as this review is completed.
Given the sensitivity and importance of efforts to secure prescribing authority, we ask that you coordinate with the OAND before talking about this legislation with your MPP or with the media.
If you have any questions or comments about the legislation or the government affairs work being undertaken by the OAND, please contact:
Alison Dantas, CEO, 416-233-2001, ext. 23 or Michael Heitshu, Director of Policy, 416-233-2001 ext. 27.
The following letter and information package on the importance of prescribing authority was sent to all MPPs on May 5, 2009.
The following are key background papers used in briefing key government officials:
Maintaining Access to Substances
Overview of Parenteral Therapy
Naturopathic Profession Responds to Ontario Consultation on Prescribing Rights
March 4, 2009
The OAND submission to the Ministry of Health and Long-Term Care in response to Health Professions Regulatory Advisory Council’s (HPRAC) report Critical Links is here.
The OAND shared the draft submission and collaborated in the development of a joint response with the BDDT-N, CCNM and CAND. The joint response is here.
Responses from members to the OAND survey on HPRAC’s recommendations was invaluable in developing the OAND response. 97% of NDs who responded to the survey supported HPRAC’s recommendations for prescribing rights including basic primary care drugs, and had detailed suggestions on the proposed substances that should be included in the ND formulary.
In our response, the OAND expresses the profession’s support for the broad direction and approach of HPRAC’s continuing efforts to improve the regulation of health professions in Ontario to enhance patient care and better utilize health human resources through improved collaboration.
The OAND also strongly supports HPRAC’s Central Response in support of prescribing authority for NDs. The OAND appreciates HPRAC’s understanding that NDs should be awarded the controlled act of prescribing, dispensing, selling and compounding drugs in order to ensure that NDs can maintain access to restricted natural substances, and play a larger role in improving access to primary care across Ontario. HPRAC recognizes that NDs have the competencies required to prescribe and that this will improve access to care for Ontarians who chose NDs for their primary care. The OAND response does express concern about the absence of an HPRAC recommendation on “crash cart” drugs for NDs and asks that these be included in the prescribing rights for the profession.
Ensuring that all health professions are able to make their full contribution to the health care system will improve patient care, respect patient choice of care provider, improve access to safe and effective care, and improve the effectiveness of inter-professional teams. Effective collaboration, in turn, requires each profession to be able to practise to their full scope of practice, in keeping with their training and competence.
At a time when the provincial government is concerned about access to primary care, the OAND has used this consultation as an opportunity to emphasize that NDs are well poised as primary care providers to increase their contribution to the health care system and patient care, particularly with full access to all therapeutic substances that are integral to naturopathic medicine.
The Ontario process for evaluating the prescribing rights for NDs has not had the intense media focus compared to British Columbia. Almost all of the efforts of the OAND has been focused on working with HPRAC, the provincial government and other health sector stakeholders to build an understanding of the merits of prescribing rights for NDs. This has been a very productive approach to date and as a result the OAND has not been seeking media attention on this topic in Ontario.
Please contact Michael Heitshu, Director of Policy, at 416-233-2001 ext. 27 or policy@oand.org with any questions or comments.
HPRAC Recommends Larger Role for NDs in Primary Care
Full Scope of Practice for Naturopathic Doctors:
Prescribing, Dispensing, Selling and Compounding
February 2, 2009
Ontario’s Naturopathic Doctors (NDs) are a highly trained and provincially regulated health profession. The regulation of the profession is in transition from the Drugless Practitioners Act to the Regulated Health Professions Act. This transition is expected to be completed in the next two years. As part of this transition, NDs require the controlled act of prescribing, dispensing, selling and compounding a drug in order to maintain patient care they are currently able to provide, and take on an expanded role in improving access to primary health care.
The Health Professions Regulatory Advisory Council (HPRAC), which advises the Ontario Ministry of Health and Long-Term Care, has a clear vision of the importance of all regulated health professions being able to make their maximum contribution by working to the full scope of their training and capability. They envision a health care system:
“…where all health professions can function to the fullest extent of their training and capability as part of an integrated and collaborative health care team is key to improving access to seamless, effective, patient-centred care. To deliver this kind of care, health care professionals must be able to practice to the maximum extent of their respective scopes of practice.”
HPRAC supports full scope of practice for NDs, including the limited ability to prescribe drugs. HPRAC’s January 2009 report, Critical Links: Transforming and Supporting Patient Care, recommends that NDs be able to prescribe restricted natural substances that are integral to Naturopathic Medicine, as well as specific pharmaceuticals that would allow NDs to play a larger role in primary care.
NDs are one of only three health professions that provide primary health care for patients in the province, along with medical doctors and nurse practitioners. In fact, NDs have been regulated in Ontario since 1925. Science-based, safe and effective, patient-centred care are at the heart of all ND care.
NDs have the high level of training required to prescribe medicine. The minimum seven years of training includes pre-med studies plus a four-year program from an accredited Naturopathic College with extensive training and testing in pharmacology.
Naturopathic Doctors require the ability to prescribe therapeutic natural substances that are integral to Naturopathic Medicine but are currently on restricted schedules because they are not suitable for consumer self-selection. Examples include some vitamins, minerals and amino acids in higher dosages or administered by injection, as well as restricted botanical medicines and bio-identical hormones. NDs are the experts in the use of these substances. Loss of access would severely impact patient care and take away patient choice.
NDs will also be able to improve patient care by having access to key drugs used in primary care. For example, prescribing authority would allow NDs to immediately treat a diagnosed case of strep throat with antibiotics as indicated by best practices, improving patient care and patient safety while reducing pressure on other providers and emergency rooms. Being able to practise to their full scope will also make NDs more effective members of inter-professional teams.
Prescribing authority will not change the fundamental approach to Naturopathic Medicine to treat the whole person, with a focus on identifying the underlying causes of a health concern, rather than just treating symptoms.
Ensuring that all health professions are able to make their full contribution will improve patient care, respect patient choice of care provider, improve access to safe and effective care, and improve the effectiveness of inter-professional teams.
Regulation
Bill 171
The OAND presented their submission to the Standing Committee on Social Policy on the needed improvements to Bill 171 which is the omnibus bill that includes the Naturopathy and Homeopathy Act. Our presentation and written submission are now available online. Simply click on the links below:
Prescribing Selling Dispensing Compound
More Protection, Choice and Improved Healthcare for Ontarians: OAND Comments on Health System Improvement Bill
Toronto (December 12, 2006) Ontarians can expect better access to high quality healthcare when the Health System Improvement Act comes into effect, according to the organization representing Ontario’s Naturopathic Doctors (NDs). The changes introduced in this bill will improve the regulation of NDs, offering important support and protection for Ontarians who choose complementary healthcare. More
To view the OAND's backgrounder, A Snapshot of Naturopathic Medicine in Ontario, click here.
Bill 171, the Health System Improvement Act, had first reading on December 12, and has now been posted on the Ontario Legislature website. This website has a webpage dedicated to the Bill, including the legislation itself, statements from the Minister and opposition, background information and related resources, including the press release from the OAND.
www.ontla.on.ca/library/bills/382/171382.htm
Bill 171 is an omnibus Bill, addressing a wide range of issues, including the Naturopathy and Homeopathy Act found in Schedule P which proposes improved regulation for Naturopathic Doctors. The Bill itself can be found here:
www.ontla.on.ca/documents/Bills/38_Parliament/session2/b171.pdf
For a decade, the OAND has lobbied each successive provincial government to improve the regulation of the naturopathic profession.
We are now very close to achieving that objective: on April 27, 2006, the Health Professions Regulatory Advisory Committee (HPRAC) advised Ontario’s Minister of Health and Long-Term Care that Naturopathic Doctors and the practice of Naturopathic Medicine should be regulated under the Regulated Health Professions Act.
Read the HPRAC report, Regulation of Health Professions in Ontario: New Directions here.
What is the benefit of improved regulation?
Improved regulation should have significant benefits for current and prospective patients of Naturopathic Doctors, Ontario Naturopathic Doctors and for Ontario’s healthcare system as a whole.
Read the OAND's letter to current and prospective patients of Naturopathic Doctors here.
Research
Want to find out what the public thinks about Naturopathic Medicine? Click here.
Fully 40 percent of Ontarians – or 5,000,000 potential patients – say they are likely to
see a Naturopathic Doctor (ND) in the next few years, according to recent public opinion research done for the Coalition for Naturopathic Medicine.
The study was conducted by Innovative Research Group through random-digit dialing telephone interviews among a representative sample of 602 English-speaking Ontarians, 18 years of age or older. The interviews were conducted between March 17th and March 23rd, 2006. Up to eight call-backs were made in the case of non-response. Using data from Statistics Canada, the results were weighted according to region, age and gender to ensure a sample representative of the entire Ontario adult population. In the end, the maximum margin of error obtained for a sample of 602 respondents is ± 4.0%, 19 times out of 20.
To view the full polling questionnaire and response data, click here.
