OVMA Responses to CVO and Public Consultations
OVMA provides input into consultations issued by the College of Veterinarians of Ontario on an ongoing basis. This process involves analysis of the issue, consultation with the committees involved followed by consultation with the OVMA Board of Directors and the OVMA President. Below are some of the most recent responses to CVO consultations.
CVO Draft Practice Standards on Prescribing, Dispensing, Compounding and Extra-Label Drug Use
Ministry of Health and Long-Term Care Proposal: Changes to Regulations
Ministry of Agriculture, Food and Rural Affairs Proposal: Changes to Regulations
CVO Proposal: By-law Changes
CVO Proposal: Compendium of Veterinary Pharmaceuticals and Specialties
CVO Draft Professional Practice Standard on Telemedicine
May 2017 Updated OVMA Response
CVO Draft Professional Practice Standard on Prescribing (2017) and CVO draft Professional Practice Standard on Dispensing (2017)
CVO Draft Professional Practice Standard on the Veterinary-Client-Patient-Relationship
CVO Draft Professional Practice Standard on Prescribing
CVO Practice Standard on Dispensing
CVO Draft Code of Ethics
OVMA Letter Regarding Companion Animal Mobiles
CVO Draft Professional Practice Standard on Telemedicine
CVO Draft Professional Practice Standard on Delegation
CVO Draft report Ontario Veterinary Stewardship of Antibiotic Use in Food-Producing Animals
CVO Proposal: Accreditation Model
OVMA Responds to CVO’s Consultation on the new Veterinarians Act
In July 2017, the College of Veterinarians of Ontario (CVO) released a comprehensive consultation document outlining a number of proposed changes to the Veterinarians Act. Over the summer, OVMA staff and committees conducted a thorough review of the document, and solicited input on the proposed changes from association members. On Sept. 27, the OVMA Board of Directors met to discuss the document, review input from association members, staff and committees, and formulate a response to CVO.
The Board found many areas where the proposed changes represent an improvement to the current Act. For example, the new Act would:
- Create an updated definition of what constitutes veterinary medicine, which would help to protect the profession from incursions by non-veterinarians.
- Increase the fines imposed on non-veterinarians practicing veterinary medicine without a license.
- Simplify CVO’s investigations processes, which currently involve both CVO’s Complaints Committee and Executive Committee, into one streamlined investigations and resolutions process.
- Enable CVO to dismiss complaints that are frivolous and vexatious at intake, rather than occupying veterinarians’ time and emotional energy to deal with those complaints.
- Formally recognize veterinary technicians as licensed professionals.
There are also some proposals in the consultation document that are very much of concern to OVMA such as:
- Expanding CVO’s public register to include notice of upcoming discipline hearings.
- Mandating a Quality Assurance (QA) Program without providing details as to what that program will entail.
- The proposed ability for the QA Committee to refer veterinarians to the Investigations and Resolutions Committee for investigation.
OVMA has brought these and other areas of concern to CVO’s attention, and will continue to lobby for changes needed to address those concerns in the months ahead.
Review the consultation document, Achieving a Modern Approach to the Regulation of Veterinary Medicine in Ontario.
Review OVMA’s formal response (PDF).
If you have any questions regarding reform to the Veterinarians Act, contact OVMA’s Manager of Government and External Relations Brandi Deimling firstname.lastname@example.org.
OVMA Response to CVO Consultations on Legislative Reform
The College of Veterinarians of Ontario has released several proposals as part of its legislative reform process regarding the Veterinarians Act. After reviewing these proposals, the OVMA Board of Directors has provided feedback to the College. The proposals and responses are listed below:
CVO Proposal: Scope of Practice
CVO Proposal: Objects of the College
CVO Proposal: Accreditation Model
CVO Proposal: Interim Suspensions
CVO Proposal: Notice of Hearings
CVO Proposal: Mandatory Reporting of Dismissal or Resignation Related to Incompetence or Incapacity of a Member
CVO Proposal: Single Complaints Screening Process
CVO Proposal: Mandatory Quality Assurance
CVO Proposal: Public Register
OVMA Response to Proposed Federal Tax Changes
In July 2017, the federal Minister of Finance announced a number of changes that will impact how small businesses are taxed in Canada. Subject to a public consultation until October 2017, this proposal represents some of the most significant developments to the tax code in many years. The changes are being proposed at the same time as new provincial government measures that could affect the ability of small business owners to do business, including changes to Ontario’s labour laws, and an increase in the Ontario minimum wage.
The proposals seek to eliminate or restrict some ways that business owners can save on taxes, including:
- Sharing income with family members
- Saving passive investment income in a corporation
- Converting a corporation’s income into capital gains
The proposed change likely to have the greatest potential impact on veterinarians is a new policy regarding the holding of a passive investment portfolio inside a private corporation. Currently, one of the benefits of a private corporation is the ability to defer income tax. Corporate income tax rates, which are lower than personal rates, facilitate the accumulation of earnings within the corporation that can be invested in a passive portfolio. The corporation can reinvest these tax-deferred funds to earn income, with potentially significant compounding effects. Professionals and business owners use this tax deferral opportunity as a way to save for retirement or for the corporation to save for future growth or investment. The government’s proposal aims to tax these passive investments at the same rate as investments held outside the corporation.
OVMA is seriously concerned about this proposed change, as well as the timing of the consultation about all of the proposed tax changes. Announced in the middle of the summer with a short consultation window, changes such as the ones proposed should be carefully considered and subject to a broader consultation involving all small business owners in Canada.
OVMA has written to the federal Minister of Finance to express OVMA’s concerns regarding the proposed policy changes, and encourages members to write directly to their MPs to share these concerns.
If you have any questions, contact OVMA’s Manager of Government and External Relations Brandi Deimling at email@example.com.
Changes to Ontario’s Labour Legislation
In addition to changes to Ontario’s minimum wage, in 2017 the provincial government also included comprehensive reform to labour legislation in Ontario. When the legislative package was unveiled, several of the changes were analyzed for their impact on the veterinary profession in Ontario.
According to OVMA’s data, on many of the proposals, veterinarians and clinic staff tend to already receive the benefits that the government has introduced as minimums. This is because the government’s reforms are intended to better protect what the government deems “vulnerable workers”, meaning those who are under or precariously employed. Therefore, most of the changes relate to temporary help agencies, seasonal employees and unionized environments. That said, changes of this magnitude can still affect all workers and employers in the province.
Below is a summary of the changes that could have an impact on Ontario’s veterinarians. Since the legislation only passed in November, the Ministry of Labour is still developing further details for the public’s information. OVMA will provide updated information to members as it becomes available.
Minimum wage in Ontario is increasing to $14 as of Jan. 1, 2018, and it will increase to $15 in 2019. Learn more about OVMA's advice on implementing these changes in your clinic, or contact Darren Osborne (firstname.lastname@example.org) or Chris Doherty (email@example.com).
Employees who have been with the same employer for at least five years will now be entitled to three weeks of vacation time, which is in line with the national average. According to two recent OVMA studies (the Ontario Non-DVM Wage Report, and the Ontario Report on Compensation and Benefits for Associate Veterinarians), the majority of DVM and non-DVM staff in Ontario who have been employed for five years or more already receive at least three weeks of paid vacation time. Therefore, while this is a significant change in the province, it should have a minimal impact on the profession.
Personal Emergency Leave
Before this legislation was passed, only employees of companies with more than 50 employees were entitled to Personal Emergency Leave (PEL). The legislative changes now mean that employees at any workplace, regardless of size, are entitled to 10 days of PEL, two of which must be paid. PEL can be taken for a variety of reasons, including illness of an employee, death/illness of an employee’s family member, etc. An employer may no longer require a doctor’s note for an employee to prove illness. This is in response to concerns addressed by Ontario’s medical professionals, as the requirement for a doctor’s note further clogs emergency rooms and doctors’ offices with mildly-ill patients, while exposing other patients to infection and illnesses.
Domestic or Sexual Violence Leave
A new domestic and sexual violence leave is being established with this legislation. Employees who have been employed for at least 13 consecutive weeks are entitled to a leave of absence if they or their children are the victim of domestic or sexual violence. The legislation provides up to 10 individual days for medical appointments, etc., of which the first five days are paid. The employee can also access up to 15 weeks of leave for reasons that can take more time, such as moving, etc. The new legislation also requires employers to put mechanisms in place to protect the confidentiality of records they receive or produce in relation to an employee taking domestic or sexual violence leave.
Public Holiday Pay Calculation
The new legislation simplifies the calculation used to determine an employee’s public holiday pay. Previously subject to a complex calculation, the new calculation is simpler and allows an employee who would normally have worked the public holiday to receive their average wage.
Ministry of Labour Holiday Pay Calculator
Alignment with Federal EI Changes
The federal government has recently made changes to Canada’s Employment Insurance (EI) policies. In order to implement the new EI benefits, Ontario has updated its existing leave policies as follows:
- Pregnancy and Parental Leave: combined, up to 18 months leave can be taken for new parents, up from the current one year. Benefits remain the same and are spread out over a longer period.
- Critical Illness Leave: with the new changes, an employee is entitled to take up to 17 weeks of leave in a 52-week period to provide care or support to a critically ill adult family member and up to 37 weeks to provide care or support to a critically ill child who is a family member.
- Family Medical Leave: the legislation increases Family Medical Leave from up to eight weeks in a 26-week period to up to 28 weeks in a 52-week period.
As part of the government’s efforts to protect vulnerable workers, the new legislation contains language to protect workers when they are asked to stay at home and be “on call”, essentially waiting for a call from an employer to come into work—a call that may or may not come. This is common in retail and restaurant sectors.
Given the use of the term “on call”, OVMA wrote to the Minister of Labour in July 2017, saying “this is clearly a different scenario than in the veterinary profession, where a veterinarian is not being exploited, but is simply available to clients over the phone in the event of an emergency. OVMA wishes to clarify the roles played by veterinarians when being “on-call”, and would like to emphasize that this regular activity should not be captured in the Ministry’s definition of being on-call and should not be subject to the provision that an on-call employee should not receive three hours’ pay if s/he is not called in.”
The new on-call provision is slated to take effect in 2019, so details are not yet available. OVMA will continue to work with the province to ensure that the regulatory requirements of the profession are respected and recognized in the new legislation.
View more information about the changes.
OVMA Endorses CVMA’s Position Statement on Onychectomy
At its meeting in April, OVMA’s Board of Directors endorsed the Canadian Veterinary Medical Association’s (CVMA) statement on Partial Digital Amputation (PDA), which opposes elective and non-therapeutic PDA, commonly known as declawing. The endorsement of CVMA’s statement means that OVMA also opposes PDA and the Association discourages its members from performing the procedure, except for medically necessary reasons. The primary role of the veterinary profession is to look out for the best interests of animals and provide a voice for those who do not have one of their own. OVMA has long been opposed to other medically unnecessary cosmetic alteration of animals such as canine ear cropping and tail docking. Instead of performing the procedure, OVMA encourages its members to discuss alternatives to PDA with clients.
For more information on OVMA’s new position and for guidance in discussing it with clients, see this one page summary (PDF) and the full position statement (PDF).
New Guidelines to Help Horse Rescue Organizations
The “Ontario Care Guidelines for Equine Rescue, Retirement and Adoption/Rehoming Facilities” (PDF) was released March 3, 2017 to help provide support and important information on care standards for those involved in equine rescue, retirement and adoption/rehoming facilities. It was developed by a working committee called the Ontario Equine Welfare Information Group, which includes representation from Equestrian Canada, Equine Guelph, Ontario Association of Equine Practitioners (OAEP), Ontario Equestrian Federation (OEF), Ontario Harness Horse Association (OHHA), Ontario Horse Racing Industry Association/Ontario Racing, Ontario Veterinary College, Ontario Veterinary Medical Association (OVMA), Whispering Hearts Horse Rescue, and the Ontario Ministry of Agriculture, Food and Rural Affairs.
The guidelines provide information on nutritional management for thin or starving horses, body condition scoring, working with an equine veterinarian to identify and manage the most common issues these horses may face, and other helpful information. They also incorporate the standards from the Canadian Code of Practice for the Care and Handling of Equines and self-assessment guides to ensure compliance to the standards of welfare.
Lyme Disease Update
In 2014, we reached out to the Minister of Health and Long-Term Care to encourage the provincial government to get more involved in Lyme disease prevention. This included advocating for a Lyme disease strategy that would include consultations with human and animal health experts with an aim to prevent, recognize, diagnose and treat Lyme disease in humans.
This past summer, the Ministry of Health contacted OVMA with an invitation to establish the Ministry’s Lyme disease Stakeholder Reference Group. Attendees included the Minister of Health and representatives from a wide array of stakeholders, including public health officials, the Ontario Medical Association, hunters, trail users, veterinary technicians, and groups representing Lyme patients.
The group committed to working together to advance Lyme prevention, diagnosis and treatment. In addition, there was an acknowledgement from the Minister that the human health sector has much work to do to better understand Lyme disease in humans. In addition, there was recognition of the need for more research and diagnostic tools in human health. OVMA will continue to work with stakeholders to advance Lyme disease prevention and treatment.
OVMA Works with Municipalities to Improve Local Bylaws
An OVMA member approached us about his concerns that a proposed local bylaw in the Town of Georgina to regulate kennels, duplicated some CVO regulations and did not properly serve the animals the legislation aimed to protect.
We investigated the matter and worked with the municipality to improve the bylaw to ensure there were no redundant regulations. The final bylaw included improvements that will better ensure oversight where it's needed, which will result in improved animal welfare.
The City of Mississauga also contacted us seeking expertise on animal welfare issues as the City embarked on redeveloping its bylaws that regulate standards for outdoor pets. We were asked help City Council as it considered its proposed amendments. We connected the City with a local member who has a background in animal welfare, who presented to City Council on several occasions to help them agree to a fair and balanced bylaw.
Ontario Animal Health Network
The Ontario Animal Health Network (OAHN) is a program funded by the federal and provincial government, and administered by the Animal Health Lab (AHL). Its long-term goal is to establish a province-wide disease surveillance program that will be integrated into daily veterinary medicine.
OAHN Network is pleased to release the first companion animal quarterly disease report, and wildlife disease report. The report contains important information about the recent canine respiratory outbreaks, and an emerging zoonotic disease to southern Ontario, echinococcus multilocularis.
Reports can be accessed via the OAHN website in the veterinarian only log in area (sign up in one easy step).
Those wishing to receive regular reports to their inbox should email firstname.lastname@example.org.
Recent issues OVMA has successfully advocated for on behalf of Ontario veterinarians:
Lobbied CVO to implement a minimum guideline for pain management in companion animals. Now, at OVMA’s urging, CVO requires that pain control be used where the potential for pain exists, and that withholding proper therapy is not a justifiable means of reducing treatment costs.
Lobbied CVO to amend its interpretation of Regulation 1093 (Veterinarians Act), in order to allow the implementation of wellness plans, allowing clients to pay a low monthly fee for a year’s worth of veterinary care.
Worked with CVO to update its formerly outdated advertising policies. Previous policy did not allow veterinary clinics to use adjectives such as “caring”. In addition, OVMA was opposed to the College’s previous policies that resulted in clinics being held responsible for positive client reviews on third-party websites.
Persuaded CVO to reverse plans to drastically increase their fees for professional incorporation. In 2014, CVO intended to raise fees for the administration of the professional corporations program, above the cost of operating the program. OVMA lobbied CVO to keep its fees for the program in line with the cost of its operation.
Partnered with veterinary clinics in Durham Region to create a low-cost feline spay and neuter program for pet owners on social assistance. This program included municipal government participation which required lobbying local municipal councils and mayors to encourage participation.