OPSEU/SEFPO

OPSEU response to the proposed amendment to Regulation 566 under the Health Protection and Promotion Act 

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Regulation 566: removing professional qualifications requirements in public health

On October 26, the Ministry of Health and Long-Term Care released 11 proposed amendments to regulations made under the Health Protection and Promotion Act, with the goal to “modernize them and ensure public health programs and services remain current to protect the health of Ontarians.”

Under Regulation 566 – regarding qualifications of Boards of Health staff – the government has proposed the removal of “existing public health professional qualifications requirements for business administrators, public health inspectors, public health dentists, dental hygienists and public health nutritionists” as part of an effort to “provide Boards of Health with autonomy with respect to hiring staff with the proper qualifications and include updated requirements.”

OPSEU is deeply concerned by the government’s effort to remove qualifications in the public health sector, and questions the government’s motives for proposing these amendments.

The Standards Modernization process

As part of the Patients First overhaul of Ontario’s public health care system – or what the Ministry of Health and Long-Term Care (MOHLTC) has described as “broader health system transformation efforts,” the MOHLTC launched a review of the Ontario Public Health Standards (OPHS) and Ontario Public Health Organizational Standards (Organizational Standards) – what they have termed collectively as “Standards Modernization.” The Standards Modernization process is meant to provide an opportunity to “define public health’s role and contributions” within the broader health system changes that are happening.

Background

In 2008, the Ministry released the OPHS, and in 2011 the Organizational Standards. The OPHS and 27 incorporated protocols are guidelines issued by the Minister under the Health Protection and Promotion Act (HPPA); these establish the minimum requirements for fundamental public health programs and services to be delivered by Ontario’s 36 boards of health. The Organizational Standards established the minimum management and governance requirements for all boards of health and public health units and are operationalized via the Public Health Funding and Accountability Agreement.

In 2015, the Standards Modernization process began, with an Executive Steering Committee (ESC) established to provide leadership, oversight and guidance for this process. Based on input from a host of sub-committees (all strategically guided by the ESC), the ESC was tasked with recommending a set of “renewed program and organizational standards” to the MOHLTC for final review and decision-making.

But in the Standards Modernization process outlined here, it does not appear that Regulation 566 was part of the discussions held, including in the consultative process with representatives of Public Health Units. It is distressing that this was left off the table, seemingly until the last minute.

While limited information about the MOHLTC’s future plans makes it extremely difficult to provide feedback, we wish to focus on three areas of concern in light of the information currently available to us.

1. That the removal of professional qualifications under Regulation 566 is an attempt to cut costs by allowing Boards of Health to hire less qualified staff, with no regard for public health and safety.
2. That the Standards Modernization process – in line with the broader health system transformations – is an attempt to facilitate the downloading of public health services.  
3. That in light of the recommendations of the Minister’s Expert Panel in Public Health, Standards Modernization is part of a much larger plan to restructure public health units in the image of LHINs (as brokers of services, but not direct providers of services), or perhaps even to integrate public health completely under the umbrella of the LHINs.

Issue #1: Cutting costs, lowering qualifications

According to Roselle Martino, Assistant Deputy Minister in the Population and Public Health Division of the MOHLTC, “high quality public health professionals remain the foundation of our public health system.”

So why does Regulation 566 remove existing public health professional qualifications requirements?

According to the Public Health Agency of Canada, there are core competencies in the public health sector. These core competencies are the essential knowledge, skills and attitudes necessary for the practice of public health; they transcend the boundaries of specific disciplines and are independent of program and topic.