Accessibility for Ontarians with Disabilities Act Alliance Update
United for a Barrier-Free Society for All People with Disabilities
Send Us Your Feedback on the Initial or Draft Recommendations for What the Promised Health Care Accessibility Standard Should Include that Were Prepared by the Government-Appointed Health Care Standards Development Committee
May 10, 2021
It is more important than ever for the Ontario Government to remove and prevent the many disability barriers that impede patients with disabilities in Ontario’s health care system. If anything, the COVID-19 pandemic and the Government’s response to it have made those barriers worse. That flies in the face of the Accessibility for Ontarians with Disabilities Act (AODA), which requires the Ontario Government to lead our health care system and our entire society to become accessible to over 2.6 million Ontarians with disabilities by 2025.
We now seek your feedback once again on the barriers that people with disabilities face in Ontario’s health care system. Last week, on Friday, May 7, 2021, the Ford Government belatedly and at last posted online for public comment the initial or draft recommendations in this area that were prepared by the Government—appointed advisory Health Care Standards Development Committee. We are going to write a brief to that Committee, giving it our feedback on their recommendations. We aim for that Committee’s final recommendations to be as strong and effective as possible. We need your input.
We have posted the Health Care Standards Development Committee’s initial or draft recommendations on the AODA Alliance website at https://www.aodaalliance.org/wp-content/uploads/2021/05/Health-Care-SDC-Initial-Report-As-Submitted.doc. The Government also has them posted, at least for now, on its website, with the link set out below.
Please give The Committee’s recommendations a read, and send us your thoughts. What do you like about them? Are they missing anything that should be added? Are they strong and comprehensive enough?
We welcome and invite your feedback to help us as we work on our brief. Send your thoughts to us at [email protected]
Of course, you are also strongly encouraged to send your feedback and recommendations directly to the Health Care Standards Development Committee. You have up until August 11, 2021 to do that. The contact information for the Health Care Standards Development Committee is set out below, in the Government’s announcement.
If you want helpful background on the barriers people with disabilities face in the health care system,, including what the AODA Alliance has recommended in the past to the Health Care Standards Development Committee (based on feedback from our supporters), take a look at these resources:
- The AODA Alliance’s February 25, 2020 Framework that it submitted to the Health Care Standards Development Committee on what the promised Health Care Accessibility Standard should include. We developed that Framework in consultation with our supporters, after getting input from multiple sources.
- The captioned November 26, 2019 online video by AODA Alliance Chair David Lepofsky where he describes many of the disability barriers in the health care system that the Health Care Accessibility Standard needs to remove and prevent. This video has been viewed over 1,000 times.
- The more recent April 27, 2021 captioned video by AODA Alliance Chair David Lepofsky on one specific and frightening barrier that people with disabilities, face, namely Ontario’s disability-discriminatory critical care triage protocol, which was created in case hospitals must ration life-saving critical care due to COVID-19 overloads.
- The saga of the AODA Alliance’s non-partisan campaign that it has waged for over a decade to get the Ontario Government to enact a strong and effective health Care Accessibility Standard under the AODA, documented on the AODA Alliance’s health care web page.
There has been a series of inexcusable Government delays in getting to this important interim stage on the road to the enactment of a strong and effective Health Care Accessibility Standard in Ontario. As a result of our five or more years of advocacy up to that point, on February 13, 2015, the Ontario cabinet minister then responsible for the AODA, Eric Hoskins, announced that the Government of Ontario would develop and enact a Health Care Accessibility Standard under the AODA. That was six years ago.
Under the AODA, the first step required for the government to develop an accessibility standard is for the Minister responsible for the AODA to appoint an advisory committee (a “Standards Development Committee”) to make recommendations on what the specific accessibility standard should include. That Standards Development Committee is required to include representatives from the disability community as well as representatives from the obligated sector, such as health or education.
Some two years later, in or around 2017, the government appointed the advisory Health Care Standards Development Committee to develop recommendations on what should be included in the promised Health Care Accessibility Standard. It should not have taken the previous Kathleen Wynne Government some two years just to appoint an advisory committee.
Under the AODA, a Standards Development Committee is first required to develop initial or draft recommendations for the government. These initial or draft recommendations on what the accessibility standard in issue should include are to be submitted to the Minister. Under s. 10(1) of the AODA, upon receiving initial or draft recommendations from a Standards Development Committee, the minister is required to make those initial or draft recommendations public for at least 45 days, including posting them on the internet. The public is to be invited to give feedback on those initial or draft recommendations. That is the interim stage we have now reached.
That public feedback is to then be given to the Standards Development Committee. After that public feedback is received, the Standards Development Committee meets to review the feedback and to finalize its recommendations for the government on what the accessibility standard in issue should include.
Once finalized, the Standards Development Committee then is required to submit its final recommendations to the Minister. Section 10(1) of the AODA requires the Minister to make those final recommendations public upon receiving them. Thereafter, the government can enact some, all, or none of what the Standards Development Committee recommended.
Here we are, some four years after the Health Care Standards Development Committee was appointed, and we are now just getting to the stage of being able to review their initial or draft recommendations. This illustrates why progress towards an accessible Ontario has been so painfully slow.
The delays in the health care context are certainly not the sole fault of the previous Wynne Government. The Ford Government left the Health Care Standards Development Committee frozen and unable to work for over a year after it took office. Precious time was lost.
After it finally got back to work, the Health Care Standards Development Committee submitted its initial or draft recommendations to the Ford Government by the end of last December, over five months ago. Yet the Ford Government only made them public last Friday. Section 10 of the AODA required the Government to make them public upon receiving them.
Had the Government made these initial or draft recommendations public upon receiving them, the public consultation could have wrapped up by now. The Health Care Standards Development Committee could have now been going back to work, drawing on that public input to finalize its recommendations. Instead, that Committee won’t be able to resume its work until some time this fall, depending on the extent of further Government delays. More time is wasted due to the Government.
Will the Ford Government’s delays on disability accessibility ever stop? There have now been 830 days, or over 2 and a quarter years, since the Ford Government received the ground-breaking final report of the Independent Review of the implementation of the Accessibility for Ontarians with Disabilities Act by former Ontario Lieutenant Governor David Onley. The Government has announced no effective plan of new action to implement that report. That makes even worse the serious problems facing Ontarians with disabilities during the COVID-19 crisis. The Ontario Government only has 1,332 days left until 2025, the deadline by which the Government must have led Ontario to become fully accessible to people with disabilities.
The Ford Government’s May 7, 2021 Announcement on the Health Care Standards Development Committee’s Initial or Draft Recommendations
In Ontario, the Accessibility for Ontarians with Disabilities Act, 2005 outlines the legislated process for the development of new accessibility standards through Standards Development Committees.
Standards Development Committees are responsible for developing and reviewing accessibility standards in Ontario. These accessibility standards help move Ontario forward on its journey to create a more accessible and inclusive province.
The Health Care Standards Development Committee was tasked with developing recommendations for proposed accessibility health care standards for hospitals. The Committee is a group of representatives comprised of people with disabilities, disability organizations and health sector experts.
The Initial Recommendations Report of the Health Care Standards Development Committee is now available for public comment.
The Report will be posted online for a period of 65 business days. Members of the public can submit feedback until August 11, 2021.
The initial report contains 22 recommendations that the committee developed and on which it voted.
As these recommendations may impact you or your community, we would encourage you to participate in this process. We would also encourage you to share this information broadly with your networks.
A survey has been developed to seek public feedback and is linked from the consultation page together with the report itself.
Written submissions can also be sent in by email to
Members of the public or interested organizations can also reach out to the Accessibility for Ontarians with Disabilities Division by email at
for any questions.
Assistant Deputy Minister (A)