Enforcement Framework for Accessibility in Healthcare


Currently, there are still no AODA healthcare standards. However, an AODA standards development committee drafted recommendations of guidelines that AODA healthcare standards should include. These guidelines include an enforcement framework for accessibility in healthcare.

The committee’s mandate from the Ontario government requires recommendations focused on the hospital setting. However, patients and healthcare workers with disabilities also face barriers in other parts of the healthcare system, including:

  • Doctors’ offices
  • Walk-in clinics
  • Wellness centres
  • Pharmacies
  • Labs
  • Nursing homes
  • Outpatient rehabilitation centres
  • Health regulatory colleges

Therefore, enforcement frameworks to ensure accessibility should also apply to all these settings.

Enforcement Framework for Accessibility in Healthcare

The committee reports that many hospitals are not complying with accessibility requirements under the Integrated Accessibility Standards Regulation (IASR). Therefore, the committee recommends that the government should strengthen its existing enforcement framework, and create an additional framework to enforce accessibility in healthcare.

Under the current framework, the government assesses compliance based on reports that organizations submit about their own accessibility. In other words, organizations assess themselves. The committee recommends that the reporting process should include more incentives for organizations to complete these reports accurately, such as:

  • More examples of compliance and non-compliance, to support staff in understanding the report
  • Reminders of fines for organizations that do not comply

In addition, the committee recommends mandated on-site inspections, so that the government can verify that hospitals are complying with the law. Both the report and inspection should assess hospitals’ patient relation processes, to verify that they are:

Furthermore, hospitals should also create plans to remove or prevent the accessibility barriers that are documented within their complaint processes, feedback processes, or independent evaluations. Hospitals should post their plans within the Ministry for Seniors and Accessibility’s publicly searchable database. As a result, patients and visitors can know which hospitals are most committed to compliance. Moreover, funding that hospitals receive from the government should be based on whether they have created and followed such accessibility plans. Similarly, funding should also depend on how well hospitals make improvements recommended during the reporting or inspection processes.

Finally, hospitals should have accessible websites, as required under the Information and Communications Standards. These websites should include information about the hospital’s accessible services, such as:

New Enforcement Framework for Hospitals

In addition to enhancing existing frameworks under the IASR, the government should also create a new enforcement framework specifically supporting the healthcare standards. The government should create and establish this framework over the next three (3) years. Moreover, the government should develop the framework while consulting with:

Under this framework, hospitals would work with the Ministry for Seniors and Accessibility to set accessibility goals. These goals would help hospitals decide which accessibility issues to address first. Goals would also include timelines and penalties for non-compliance with the IASR or with a hospital’s own accessibility plan, under the existing framework. Penalties could be fines, or other consequences. However, each hospital would receive clear guidance about what constitutes compliance, and the consequences of non-compliance.

The government should post the framework online, in English and French, and in accessible formats. Furthermore, the government should review and update the framework every three to six (3-6) years. The results of the review should also be publicly available online. In addition, hospitals should post their accessibility plans on the Ministry of Seniors and Accessibility’s publicly searchable database. After every government review of the framework, hospitals should also post their progress toward achieving their goals. In this way, the public can assess how well each hospital is identifying and removing barriers to accessibility.




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