‘Zombie’ Attendant Care Issue Raises it Ugly Head

Dear members,

Many of you will already be aware of the emergent Attendant Care benefit issue that has surfaced in recent weeks. I have been in close contact with attendant/PSW care provider members to collectively compare notes and strategize. A joint letter sent to FSRA yesterday in collaboration with OSOT is shown below. It should provide a decent summary of the issue.

I may have missed some AC providers in the somewhat flurried outreach. Please do let me know if I’ve missed you, and I’ll be sure to loop you in going forward. Thanks to Darcy Merkur for his legal insight and support and to all those members who’ve lent a hand to date.

Watch this space for updates and resources (template letters to insurers etc.).

ORA & OSOT letter to FSRA no name (pdf)

It’s (still) all about FSRA & Fairness

Read full submission here: ORA Comments on Proposed UDAP Rule


The Ontario Rehab Alliance (ORA) welcomes this opportunity to comment on the proposed changes to Rule 2020-002, Unfair or Deceptive Practices Act.

We were pleased to be able to provide initial input to the proposed rule change last fall as part of FSRA’s Health Service Providers Stakeholder Advisory Committee and have reviewed the comments and FSRA’s response to these in the subsequent public consultation ‘the Original notice’.

We have restricted our comments and questions in this document to those aspects which we believe may require further consideration or explanation.


Once again, the ORA would like to acknowledge our thanks for this opportunity to contribute to the consultation process. We would be pleased to provide any further clarification or information.

Respectfully submitted by,

Laurie Davis, Executive Director

Ontario Rehab Alliance



<a href=’https://www.freepik.com/photos/background’>Background photo created by suksao – www.freepik.com</a>

FSRA Priorities Submission

Submitted: October 26, 2020

The Ontario Rehab Alliance (ORA) is highly supportive of FSRA’s stated priorities for 2021-22. This submission will comment primarily on broad-strokes intentions and hoped-for outcomes.

At the Cross Sectoral level, we believe that all four priorities: Protect the Public Interest, Enable Innovation, Modernize Systems and Processes, and Transition to Principles Based Regulation may be harnessed to drive improvement to the auto insurance sector.

The ORA has made a number of previous submissions, along with other HSP associations, that reference our keen support for modernized systems and processes, and have offered multiple examples and specific suggestions of how and where we see the greatest need for these. As Principles-Based Regulation is a new form in Ontario’s regulatory environment we find it challenging to forecast how this transition might change our operations or the experience of our injured clients, so have focused our remarks elsewhere.

Read the rest in the attached PDF submission

ORA Commentary 2021-22 Priorities