It’s Quintuplets! ORA Members Sweep Award Nominations

Do consider supporting your fellow ORA members when you cast your ballot (by Aug 31) for the annual OBIA & PIA Awards of Excellence. There’s lots to choose from!

All five of the companies nominated in the Rehab Company of the Year category are ORA members, so you can’t go wrong voting for Abilities Rehab, Brainworks, Essentially YouFunctionAbility or Wright Rehab.

Colleen Boyce, (Bayshore), Sheila MacDonaldKindrey Rowland (Orangeville, ORA members all, are nominated in the category of Healthcare Provider of the Year category.

Jennifer Jones (Abilities Rehab), Jodi Harendorf (Neuro-Rehab Services Inc.), Laura MacPhee (Rehab Results) and Maureen Palmer, are nominated in the Case Manager of Year category.

Happy voting!

Help Distribute Important Survey of Individuals with Brain Injuries

The ORA is asking its members to assist in disseminating a survey to individuals with brain injuries sustained in motor vehicle collisions to obtain information about their experience with auto insurance claims.

Please see the attached letters from student researchers at McMaster University and Acquired Brain Injury Survivor Solutions (ABISS), an advocacy group.

ABISS MCMASTER.TBI Insurance Study Approval 2020

Letter & Survey for Participants

Letter to Organizations & Professionals Assisting with Survey Distribution.

This research has received ethics approval through McMaster University from the Hamilton Integrated Research Ethics Board. The researchers include:

  • Principal Investigator, Dr. Lyn Turkstra, Department of Rehabilitation Science, McMaster University
  • Research Supervisor, Sheila MacDonald, Assistant Professor (Adjunct), Department of Rehabilitation Science, McMaster University
  • Student Investigators: Laura Brooks, Yvette Hou, Daniella Reid, Aileen Zhou

Clinicians distributing the survey are asked to ensure objectivity and privacy by observing the following:

  • Allow the person to complete the survey in their private (non-therapy) time
  • Do not discuss, assist with, or document survey completion in clinical notes and records (reporting, chart notes, emails etc.).

If you have questions or need more information about the study itself, please contact student investigator Laura Brooks by email at [email protected], or call Dr. Turkstra at 905.525.9140 Extension 28648.

The goal of this research project is to help better understand the experiences that those with brain injury following a motor vehicle collision have with their auto insurance claims.

Data from surveys like is so badly needed to support our advocacy for changes. Please do what you can to support this initiative.

With thanks,

Laurie Davis 

Executive Director, ORA


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ORA ED Laurie Davis shares thoughts on COVID-19 and Auto Accident Survivors

“We have people who are seriously and catastrophically injured who are in their own homes or in community settings and they are vulnerable”

How COVID-19 is probably affecting your auto claimants

ORA Pandemic Issues Letter to FSRA

ORA Pandemic Issues Letter to FSRA PDF

Sent via email

March 26, 2020
Dear Ann and Stuart,
The ORA is very gratified by the deferral of the AIR filing. Thank you for any contributions you may have made to that announcement.
Along with all healthcare providers we’ve been asked to do our part and help mitigate the impact of this pandemic on our most vulnerable populations and on our acute care sector. We are ready and anxious to do so. Help us do our part.
The ORA has been holding weekly consultations with our members to hear what their experiences and questions are during this pandemic. Below I’ve outlined the issues and requests for FSRA’s guidance and assistance that have emerged thus far. We appreciate that some may be out of scope for FSRA and would, in these cases, be grateful for suggestions or introductions as to where to redirect.

Suspension of Non-Essential Regulated Health Provider (RHP) Services by Ontario’s Chief Medical Officer of Health in the on March 19, 2020.
Early communications from some RHP members’ Colleges indicate that this directive is being interpreted to relate to in-person services though the wording of the directive is not clear. Though health care facilities and home care services have subsequently been deemed essential in Ontario we are concerned that insurers may be confused and are consequently denying approvals for services that may be safely delivered virtually and/or in-person in cases where that may be deemed essential.
A further concern is that while some services may not be considered essential in the early days of this pandemic its highly likely they may become essential in coming weeks


To read the whole letter please see link to PDF above

ORA Requests Fee Deferral in AIR Filling & FSRA Guidance for Pandemic Related Issues

ORA Pandemic Issues Letter to FSRA

Letter to MPP Cho re FSRA Licensing Fee Deferal

Ann MacKenzie, Senior Manager, Policy Interpretation
Stuart Wilkinson, Director, Policy Auto & P/C

Copied to:
Tim Bzowey, Executive Vice President, Auto/insurance Products, FSRA
Cobi Lechem, Senior Policy Advisor, Office of the Minister of Finance
Barbara Sulzenko-Laurie, VP Policy Development, Insurance Bureau of Canada
Sent via email


March 26, 2020

Dear Ann and Stuart,
The ORA is very gratified by the deferral of the AIR filing. Thank you for any contributions you may have made to that announcement.
Along with all healthcare providers we’ve been asked to do our part and help mitigate the impact of this pandemic on our most vulnerable populations and on our acute care sector. We are ready and anxious to do so. Help us do our part.

The ORA has been holding weekly consultations with our members to hear what their experiences and questions are during this pandemic. Below I’ve outlined the issues and requests for FSRA’s guidance and assistance that have emerged thus far. We appreciate that some may be out of scope for FSRA and would, in these cases, be grateful for suggestions or introductions as to where to redirect.

—Click the links above to view the entire letter. —




ICBC’s bold change to auto insurance

BC’s newly announced no-fault care-based auto injuries benefits include a minor injury cap of $5,500 for pain and suffering, an increase in accident benefits to $300,000 and up to 7.5 million for catastrophic injuries. And a premium rate reduction of 20% for drivers.

Might Ontario be contemplating something similar with the yet-to-be-unveiled Care not Cash model?


Read all about it:

The story behind ICBC’s bold change to auto insurance

ORA Input to CPSO Third Party Reports Policy Consult

ORA Input to CPSO Third Party Reports Policy Consult PDF

DATE: January 31, 2020
TO: College of Physicians and Surgeons Consultation
RE: Third Party Reports

The Ontario Rehab Alliance appreciates this opportunity to comment on the proposed policy, and thanks the College for reaching out to us with the invitation. Our comments are as follows:

RE # 29. Physicians must state any findings or opinions contained in a report in a way that is objective and free from personal bias; and # 30. Physicians must not include comments unrelated to the physician’s professional opinion, or that are extraneous to the requesting party’s stated objectives.

Comment: We commend the intention to ensure objectivity but believe that goal might be best accomplished by extending the policy to address the larger issue of physician objectivity and the conflicts of interest that arise when a physician routinely and frequently undertakes IME assignments from an insurer. Objectivity and/or the perception of objectivity may be compromised where such patterns exist and significant income from such assignments is involved. We suggest that the policy could address such circumstances by requiring disclosure and transparency regarding such

Scope of Expertise & Knowledge
RE # 37. In situations where a physician is asked to answer questions, or provide an opinion that is beyond their expertise or experience, or which requires access to information they do not have, physicians are advised to discuss the matter with the requesting party, and explain that they may not be able to answer every question asked, or provide the opinion sought.

a. If the party will not amend their request, or is otherwise unresponsive to the concerns expressed, physicians
i. restrict their statements to matters that are within their area(s) of expertise and about which they have sufficient information, and
ii. indicate clearly the reasons for which they are unable to fulfill all the elements of the third party’s request.

Comment: We commend the intention of this policy. If the intention is to ensure that limitations of scope and expertise are respected and acknowledged, this policy would be most effective if it restricted physicians from taking on assignments beyond their expertise or experience, or which require access to information they do not have.

With thanks, again, for this opportunity to contribute.


Laurie Davis, Executive Director

Lack of Knowledge About Auto Insurance Continues to Hurt Ontario Drivers

An annual survey on Ontario Auto Insurance reveals that Ontario drivers are becoming slightly more aware of optional coverage, but drivers continue to be insufficiently protected particularly when it comes to medical benefits and income replacement benefits.

Link to the article on Exchange Magazine:

The third annual survey from Deutschmann Law looked at optional coverage, the deductible for general damages and included questions regarding close calls, auto safety features and roundabouts.

The survey reveals that 10 years after the introduction of optional benefit coverage, 30% of drivers are still unaware of the opportunity to purchase optional coverage. This has increased from 25% of drivers in 2017.

In 2010 accident victims had their medical and rehab benefits reduced from the basic coverage of $100,000.00 for everyone, to $3,500.00 for almost 80% of accident victims with the option to purchase additional coverage for medical and income benefits.

While people are aware of the availability of optional coverage, only 8% have purchased additional coverage. Of those, increased liability coverage was the most popular (71%) followed by increased medical coverage (50%) and then increased weekly income benefits (16%).

Though 75% of people were aware of a deductible that applies for property damage, only 52% were aware of a deductible for pain and suffering damages. The deductible is currently $38,818.97. However only 10% of those surveyed felt that the deductible is over $10,000.00. That means that where an injured party is awarded $50,000.00 for pain and suffering then the at fault insurer will only have to pay $11,181.03.

Only 25% of respondents feel there should be a deductible for pain and suffering damages.

The deductible for pain and suffering damages increases by the CPI rate annually, further eroding damages payable to innocent victims. Contrast that to rate payable by the insurer for income benefits (maximum $400.00 weekly) which has stayed stable since 1990, unless optional coverage is purchased.

“Our third annual survey shows that consumers in Ontario are not sufficiently informed about auto insurance including the availability of enhanced medical and income benefits and the erosion of damages when they are involved in an accident. There needs to be better education so consumers can make more informed decisions about their insurance and avoid becoming a victim twice – at the time of the accident and then realizing how their benefits do not sufficiently deal with their needs,” says Rob Deutschmann.
For those respondents that have been involved in a “close call” while driving, 87% identified that there was another vehicle involved and 11% with a bicycle or pedestrian. 45% identified speed as the biggest cause while 38% identified distracted driving and 25% identified improper turns.

The independent survey, conducted in September 2019, was administered by Metroline Research Group on behalf of Deutschmann Law. Over 800 Ontario licensed drivers between the age of 18 -74 participated. All were identified as decision-makers regarding their auto insurance policy.

ORA Response to FSRA Priorities

On behalf of the Ontario Rehab Alliance I am pleased to have an opportunity to respond to FSRA’s published Priorities and Budget.

Six Months In

The ORA commends FSRA for the Stakeholder Engagement efforts it’s made since its inception.

  • Striking the ad hoc Industry Advisory Group (IAG) of Health Service Providers to provide input to Fee Rule decision making. As a participant, the ORA was impressed with the degree of transparency, information sharing and interest in learning more about the HSP sector.
  • Establishing the Stakeholder Advisory (SAC) Committee for HSPs. We have several comments with respect to this:
    • Timeframes within which the SAC has been asked to frame comments have been very constrained, making it difficult for association representatives to properly accommodate their own governance processes (consulting with members and Board’s). More time between meetings with FSRA management and its Board would also enhance the capacity of SAC members to discuss and develop clarity on points of convergence and divergence and therefore offer FSRA enriched feedback.
    • SAC members and their deliberations would benefit from access to more data about the sector, such as proportion of HSPs with Regulated Health Professional (RHP) ownership, breakdown by RHP and other relevant factors.

The ORA has kept its members up to date on the transition from FSCO, however many HSPs who do not belong to this or other active associations, are unaware of the transition to a new regulator.

We also commend FSRA for early efforts in Burden Reduction.

  • The Draft version of the 2020 Annual Information Return shared with association representatives will be considerably less burdensome to complete.

2019/2020 Priorities

Supporting Auto Insurance Reform

The ORA was pleased to participate in Auto Insurance Reform consultations this summer and early fall. We are keenly interested to learn more about the intended policy directions government is heading in and stay involved on issues of greatest significance to Health Service Providers, such as:

  • Increased optionality and the potential impact on mandatory accident benefit levels and consumer risk of being inadequately insured if seriously injured
  • Reducing HSP fees which would reduce access to treatment as HSPs will continue to leave the sector
  • Compromising consumer choice by expansion of preferred provider arrangements
  • Accountability mechanisms to fair and effective insurer claims management practices, particularly as FSRA moves towards a principles-based approach

In addition to the legislatively established Auto Insurance system, consumers, claimants and HSPs are also impacted by a parallel reality of ‘ghost’ regulations created by patterns of insurer practices that can create obstacles to access for consumers/claimants and considerable costs for HSPs. For instance, our members report an increase in the frequency of non-payment for approved and delivered services; the reason given by insurers is the exhaustion of med/rehab benefits. Insurers are mandated to manage and dispense these funds, yet they are not held accountable for not doing so, and HSPs have no regulatory means by which to hold them accountable.

Similarly, the impact and importance of LAT decisions must be taken into consideration. Though not intended to be precedent-setting, LAT decisions in favour of any one insurer are quickly acted upon by others. Conversely, LAT decisions in favor of HSP (e.g.  psychotherapist rates) are not generally adopted by insurers.

Developing Fraud & Abuse Strategy

Data shared at the Ministry of Finance’s Cost Reduction Working Group this fall shows that while the average Accident Benefits Claim cost has been decreasing the past few years, costs related to property damage are increasing. We therefore suggest that fraud and abuse strategies focus the areas of rising costs, such as:

  • Towing and storage
  • Repairs and rentals

The ORA would like to see the elimination of the double standard that continues to question costs associated with human body repair while the corresponding costs on the auto body side are not similarly examined.

Reviewing HSP Regulation

HSP Licensing through FSCO, when implemented in 2014, was to be a cornerstone of fraud reduction efforts on the accident benefits med-rehab side, yet efficacy to date has not been fully established.

We strongly encourage FSRA to establish one or more task specific (as opposed to standing) technical committees to assist with various aspects of the review such as: degrees of regulatory oversight for various classes of HSP, governance distillation and distribution to HSPs, transition and transformation of HCAI, etc..

2020/21 Priorities

4.1           Empower & Protect Insurance Consumers

With respect to auto insurance, we urge FSRA to consider that consumers at point-of-policy- purchase become claimants when they are injured. Empowering consumers if translated to mean increased optionality of Accident Benefits must then also mean educating them sufficiently on the possibility of injury and associated costs so that they are sufficiently protected if injured. The costs of not doing so will be evident in the hallways of hospitals and the demands on strained health and social services.

4.3          Develop a Comprehensive Auto Insurance and Data Analytics Strategy

We support the transition of HCAI to the regulator and its transformation to a system better designed to support users, the regulator, and policy makers.

We urge FSRA to strike one or more stakeholder technical committees to establish useful, functional outcome measures and metrics to shape data gathering activities, tools and analytics to support a principles-based approach to regulation and service delivery standards.

4.2 Support and Implement Auto Reform

See comments under 2019/20 Priorities, above.

2020/21 Budget

HSP licensing fees should be held at the current levels until burden reduction strategies for the HSP regulatory regime have been fully developed and implemented, so that associated costs for a presumably leaner and lighter regulatory regime can be properly established.

Other Comments

The Ontario Rehab Alliance wishes to play a key role in assisting the government to reduce hallway medicine. Our members are primarily small and medium sized businesses located throughout the province, with a focus on the treatment of serious injuries. Our work across the healthcare continuum gives us a wide-angle lens and a capacity to drill down into an understanding of the role that accessible and appropriate rehabilitation services play in keeping Ontarians and their healthcare systems at optimally functional levels.

Laurie Davis, Executive Director

Fall Economic Statement Falls Back & Good News re FSRA’s SAC

Dear members,

The Ford Government’s Fall Economic Statement makes clear intentions to continue its Auto Insurance Reform agenda by potentially altering mandatory coverages. While last spring’s Budget suggested there wouldn’t be tinkering with current AB levels it now seems tinkering may be the form of “increased choice” as we heard discussed in consultations over the past months.  The previous government slashed away at AB limits and we’d hope these days were behind us. As hope is not enough, we will continue to advocate to ensure that greater flexibility of coverage doesn’t compromise the needs of the seriously injured. I’ve extracted from the full statement [link] the key points for Health Service Providers, below. Italics are mine. Action to reduce system costs that drive up auto insurance premiums for drivers, includes:

  • Increasing consumer choice by allowing drivers to decide for themselves what coverage they need;
  • Enhancing competition by supporting innovation and reducing barriers for new and existing companies to compete in Ontario; and
  • Fighting fraud and taking costs out of the system by working with the Financial Services Regulatory Authority of Ontario (FSRA) to prevent bad actors in the system, replace inefficient processes and reduce fees

The good news is that we continue to be invited to consult. I am very pleased to have been selected to join FSRA’s Health Service Providers Stakeholder Advisory Committee. We meet with FRSA Management this coming Tuesday.Back at the ORA ranch we are working on HSP rates data and strategy and I will be reaching out shortly to the members who will be supporting our work on non-regulated rates.

Laurie Davis, Executive Director