An important component to any government relations activity is officially providing a submission to the government on a particular topic or issue.
This gives the government an “on-the-record” account of a particular organization’s response.
ONA submits reports to the provincial government and to committees of the Legislative Assembly of Ontario on a range of topics to influence change and create dialogue. From the annual budget cycle to changes to health-care services and practices, ONA provides a front-line nurses’ voice on the issue.
ONA’s Submission on Initiation of Psychotherapy by Registered Nurses and Registered Practical Nurses (Proposed Amendments to Regulation 275/94 (General) under the Nursing Act, 1991) (November 15, 2019)
ONA’s Submission on RN Prescribing (Proposed regulatory amendments to Ontario Regulation 275/94 (General), Part III (Controlled Acts) and Part V (Delegation) under the Nursing Act, 1991)(November 15, 2019)
ONA’s Submission on Bill 124 – Protecting a Sustainable Public Sector for Future Generations Act, 2019 (November 4, 2019)
ONA’s Submission on New Patient Care Models for Emergency Health Services (Proposed Amendments to Regulation 257/00 under the Ambulance Act and Regulations 552 under Health Insurance Act) (October 4, 2019)
ONA’s Submission on Proposed Changes to the Employment Standards Act, 2000 in respect of Overtime Averaging in Unionized Workplaces (August 2, 2019)
ONA’s Submission on Public Sector Compensation to the Ontario Treasury Board (May 23, 2019)
ONA’s Submission on Bill 100: Protecting What Matters Most Act (Budget Measures) 2019 to the Standing Committee on Finance and Economic Affairs (May 7, 2019)
ONA’s Submission on the Proposed Pay Transparency Reporting Requirements to the Ministry of Labour (April 5, 2019)
ONA’s Submission on Bill 74, The People’s Health Care Act 2019 to the Standing Committee on Social Policy (April 1, 2019)
ONA’s Submission on 2019 Pre-Budget Consultations to the Standing Committee on Finance and Economic Affairs (January 29, 2019)
ONA’s Submission on Bill 47, Making Ontario Open for Business Act, 2018 (November 15, 2018)
ONA’s Submission on Proposed Funding Framework from Target Benefit Multi-Employer Pension Plans (May 4, 2018)
ONA recommends the Ministry of Finance abandon its proposed new funding rules for MEPPs. Rather, we recommend the Ministry work with the MEPP industry to develop a framework that will ensure the long-term viability of target benefit MEPPs, so that they can continue to provide meaningful pensions to the hundreds of thousands of Ontarians who participate in them.
ONA’s Submission on Bill 31, Plan for Care and Opportunity Act (Budget Measures), 2018 (April 26, 2018)
In summary, ONA is asking the Standing Committee to put forward amendments that would include the original retroactive date for the new inclusion of direct care nurses in the PTSD presumption, the inclusion of healthcare professionals in the PTSD presumption, and directing healthcare employers to prepare and to submit PTSD prevention plans for direct care nurses. Finally, ONA is asking that coverage of Canadian Blood Services under HLDAA be delayed for one year.
ONA’s Submission on Bill 3 – Pay Transparency Act (April 18, 2018)
In ONA’s submission, eliminating the gender pay gap is an achievable and necessary goal for the province of Ontario. ONA supports the recommendations made by the Equal Pay Coalition. ONA strongly supports recognizing equal pay as a human right as a starting point to any action taken by the government. Approaching the gender wage gap from a human rights lens is critical to adopting actions that will not merely do lip service to this problem, but will engage meaningful steps to eliminate the gap. As the Act will be one of the primary legislative tools for enforcing and achieving pay equity, ONA supports revisions to the Act that expand its application and improve the reporting requirements and enforcement, permitting equal access and benefit to legislation in place to address equal pay issues.
Ensuring women’s work is properly valued and paid the same as their male counterparts is not just a women’s issue; it’s an issue that affects all of society. We are optimistic that this new initiative by the government will result in meaningful action to eliminate the wage gap. Until then, ONA will continue the fight on behalf of its members and all women in this province.
ONA’s Response to Aging with Confidence: Ontario’s Action Plan for Seniors (March 20, 2018)
ONA’s Submission on the Ministry of Labour’s “Safe At Work Ontario” Strategy for its 2018/2019 Health Care Sector Plan (February 14, 2018)
ONA’s Submission to the Ministry of Labour on Proposed Voluntary Occupational Health and Safety Management System Accreditation and Employer Recognition Program for Ontario Workplaces (January 26, 2018)
ONA’s Submission on Workplace Safety and Insurance Board Rate Framework Consultations (January 15, 2018)
ONA’s Submission on Bill 177 – Stronger, Fairer Ontario Act (Budget Measures), 2017
Schedule 45 – Workplace Safety and Insurance Act, 1997 to the Standing Committee on Finance and Economic Affairs (December 7, 2017)
ONA’s Submission on Bill 160 – Strengthening Quality and Accountability for Patients Act, 2017 to the Standing Committee on General Government (November 20, 2017)
ONA Feedback – Report of the Minister’s Expert Panel on Public Health (November 2, 2017)
ONA’s feedback states, in part: The Expert Panel did not consult with the public health sector and its stakeholders. It did not provide rationale for its recommendations, nor did it release any materials that it relied on to support its recommendations. This has been a hasty process without the necessary engagement and research to achieve any consensus in the sector regarding the problem to be addressed nor the solution(s) required. For these reasons, ONA is unable to support the Expert Panel recommendations.
ONA’s SECOND Submission on Bill 148 to the Standing Committee on Finance and Economic Affairs (November 2, 2017)
ONA’s second submission states, in part: “The Fair Workplaces, Better Jobs Act is a step in the right direction but there is more work to be done. ONA advocates for amendments that will address some shortcomings in the proposed legislation as drafted.” ONA’s suggested amendments are related to First Contract Arbitration, Successor Rights and Consolidation of Bargaining Units.
ONA’s Submission on Bill 148 to the Standing Committee on Finance and Economic Affairs (July 18, 2017)
ONA’s Submission on proposed Operational Policy: “Traumatic or Chronic Mental Stress (Accidents on or after January 1, 2018)”, Document Number: 15-03-14 to the Workplace Safety and Insurance Board (WSIB) Consultation Secretariat
ONA’s Submission on Amendments to the Workplace Safety and Insurance Act proposed under Schedule 33 of Bill 127 Stronger, Healthier Ontario Act (Budget Measures), 2017 to the Standing Committee on Finance and Economic Affairs
ONA’s Submission on Bill 87 – Protecting Patients Act, 2017 (Schedule 4) to the Standing Committee on the Legislative Assembly
ONA’s Input on the Standards for Public Health Programs and Services – Is this the Demise of PHNs and the Delivery of Public Health Programs?
ONA’s Input to Minister’s Expert Panel on Public Health
ONA’s Submission on the Ministry of Labour’s “Safe At Work Ontario” Strategy for its 2017/2018 Health Care Sector Plan
Submission to the Standing Committee on Finance and Economic Affairs on Bill 70 – Building Ontario Up for Everyone Act (Budget Measures), 2016 (Schedule 16 – Occupational Health and Safety Act)
Our submission states, in part: “We are deeply disappointed with Bill 70 (Schedule 16) given the productive, collaborative relationship we thought we were building with the MOHLTC and MOL, as well as employers, in our collective violence prevention efforts. After raising this concern on Bill 70 to the Deputy Minister of Labour, she has identified that ONA will be consulted after this bill has passed, a bill that we believe will cause a fundamental upheaval of Ontario’s health and safety system.”
ONA’s Response to Bill 41 – The Patients First Act 2016
Our submission states, in part: The primary issue for ONA is gaining a solid understanding of how the structural transition proposed in Bill 41 will actually result in administrative and management savings that can be reinvested in frontline care as the Minister insists is at the core of the transition.
ONA’s Response to the Ontario Changing Workplaces Review Interim Report
Presentation to the Standing Committee on General Government on Bill 201- The Election Finances Statute Law Amendment Act, 2016
Submission to the Ministry of Labour on Code of Practice and Workplace Violence and Harassment: Understanding the Law Guideline Drafts Consultation
ONA’s submission states, in part: There is wide acknowledgement that workplace harassment, including sexual harassment, is a hazard that can be a precursor to escalating behaviour that can become violence in its most extreme form. The memory of ONA member Lori Dupont, and the lessons learned from her inquest, must not be lost. The amendments place too much onus on vulnerable victims. And aside from being unenforceable, the draft Code of Practice and the Guide are in need of key amendments to ensure employers properly treat harassment, including sexual harassment, as a workplace hazard covered by the OHSA.
Submission to the Standing Committee on Justice and Human Rights on Bill C-14, An Act to Amend the Criminal Code and to make related amendments to other Acts (medical assistance in dying)
ONA’s submission states in part: Bill C-14 will have significant impact on ONA’s members. It contemplates that nurse practitioners may provide medically assisted dying and recognizes that other health practitioners, including registered nurses, may aid in providing medically assisted dying.
ONA’s Submission on Bill 163, Supporting Ontario’s First Responders Act (Posttraumatic Stress Disorder), 2016 to the Standing Committee on Social Policy
ONA’s submission states in part: ONA must express our disappointment with the government for excluding front-line nurses from coverage under Bill 163, ignoring both the growing experience of nurses with extremely violent and traumatic incidents in their workplace and the findings in the literature showing that the traumatic experiences that nurses face at work are closely linked with PTSD. ONA is calling on the government to adopt the model used in Manitoba’s recent presumptive legislation – the leading province on presumptive legislation regarding PTSD.
ONA’s Submission on Bill 119, Health Information Protection Act, 2015 to the Standing Committee on Justice Policy
ONA’s submission states, in part: ONA’s primary concerns with respect to Bill 119’s proposed amendments to the PHIPA are:
- It creates new reporting obligations to regulatory bodies (e.g. College of Nurses) that are inconsistent with the Regulated Health Professions Act, 1991.
- It increases the maximum fine for breaches of the PHIPA by natural persons from $50,000 to $100,000.
- It removes the existing 6-month limitation period leaving no limitation period. We propose the standard 2-year limitation period.
ONA’s Submission on Home and Community Care in Ontario Response to the Minister’s Discussion Paper
ONA’s submission states in part: ONA generally supports the transition of home care services from CCACs to LHINs, ensuring the stability of home care services. However, we have raised some very serious concerns regarding the fragmented approach to care for patients and their families under the existing model of CCACs.
ONA’s Submission on the Ontario Ministry of Labour’s Safe at Work Policy 2016/17
ONA’s submission states, in part:
- Hold CEOs/Boards/Directors and managers/supervisors accountable through effective enforcement.
- Strengthen the health care sector plan to provide clear and concise enforcement direction.
- Revise the MOL Policies and Procedures manual section on workplace violence to remove any direction that could limit an inspector’s ability to fully enforce the OHSA and regulations.
- If you want to make a meaningful change, support inspectors to enforce the OHSA and its regulations.
- Change the language in the Critical Injury regulation to include an event of workplace violence that places life in jeopardy, etc.
- Require through legislation/regulation minimum criteria for employers to be held accountable to perform comprehensive risk assessments and training and allow inspectors flexibility to assess if these measures were sufficient.
Supplemental Submissions to the Ontario Changing Workplaces Review Sectoral Bargaining in the Health Care Sector
ONA’s Submission to the Health Professions Regulatory Advisory Council on RN Independent Prescribing
ONA’s submission states, in part: Expanding the scope of RN practice in Ontario will not only leverage the existing workforce to improve health service delivery, it will also improve recruitment and retention of the RN workforce and labour mobility. RNs seeking greater career challenges could volunteer to pioneer this expanded scope offered in Ontario instead of leaving the province for these types of opportunities. Independent prescribing gives RNs more autonomy over their practice and patient care, improves role clarity and enhances interprofessional collaboration.
ONA’s Submission to the Standing Committee on Social Policy: On Bill 132, An Act to amend Various Statutes with respect to sexual violence, sexual harassment, domestic violence and related matters
ONA’s submission states, in part: ONA is calling for a single comprehensive OHSA definition of harassment/violence invoking duties to prevent and respond to incidents at all points in the continuum as follows. In the alternative and at minimum:
- The definitions of workplace violence must also be amended to include psychological injury;
- The definition of occupational Illness should also be expanded to include physical and psychological illness resulting from incidents of harassment and/or violence including sexual harassment and sexual violence.
- The language under section 52 should be expanded to include psychological illness from harassment and violence.
ONA’s Submission to the Gender Wage Gap Strategy Steering Committee
ONA’s submission states, in part: Eliminating the gap is an achievable and necessary goal for the province of Ontario. ONA supports all the recommendations made by the Equal Pay Coalition. ONA strongly supports recognizing equal pay as a human right as a starting point to any action taken by the government. Approaching the gender wage gap from a human rights lens is critical to adopting actions that will not merely do lip service to this problem, but will engage meaningful steps to eliminate the gap.
ONA’s Submission to the Standing Committee on Justice Policy: Bill 109, Employment and Labour Statute Law Amendment Act, 2015
ONA’s submission states, in part: It is crystal clear to ONA that the Standing Committee should vote to strike out Schedule 2 and restore the existing workplace democracy where employees are able to make their own decisions about representation as part of the restructuring process.
ONA’s Submission to the Ministry of Health and Long Term Care on Proposed Amendments to Regulation 965 under the Public Hospitals Act
ONA’s submission states, in part: The purpose of the Quality of Care Information Protection Act (QCIPA) relates to improving quality of care by encouraging frank discussions and allowing healthcare professionals to disclose information to the Quality of Care Committee in a safe environment. QCIPA, and the related Personal Health Information Protection Act (PHIPA) were introduced in Bill 31 in 2004 to create what was referred to as “a protective zone” at the time the legislation was introduced. It is ONA’s submission that the purpose and intent in introducing the Quality of Care Information Protection Act (QCIPA) must be carefully considered to ensure that any proposed amendments to QCIPA and other regulations under the Public Hospitals Act do not undermine this important purpose.
ONA’s response to amendments under Ontario Regulation 570 to the Health Protection and Amendment Act
ONA’s position states, in part: “…these amendments will reduce dental screening in schools and will have a significant impact on low-income families who are unable to see a dentist.”
Submission to the Ontario Ministry of Labour on the Changing Workplaces Review
ONA’s recommendations state, in part, “To mandate working conditions that enhance dignity and respect for all working people; to encourage and promote unionization; and to improve the labour relations process.”
Submission to the Ministry of Health and Long-Term Care Health System Accountability and Performance Division Implementation Branch on Consultation on Proposed Amendments to Regulation 386/99 under the Home Care and Community Services Act, 1994 relating to the Provision of Community Services Proposal Number: 15-HLT014
ONA’s submission states, in part: While we support more nursing hours in home care, we have two main concerns with the amendments. 1. We believe Care Coordinators should determine hours of nursing service based on patient need not service maximums. We also believe the proposed nursing service maximums are proportionately higher for RPNs than for RNs and this is not the appropriate nursing classification for patients with complex and unpredictable needs. 2. We believe Care Coordinators should be the professional in CCACs who has the discretion to provide more than the nursing service maximums to clients in the extraordinary circumstances as outlined in the proposed amendments.”
Submission by the Ontario Nurses’ Association (ONA) to the Ontario Health and Long-Term Care Minister’s Task Force on the Prevention of Sexual Abuse of Patients
ONA’s submission states, in part: The Task Force’s recommendations and any legislative changes will have a broad impact not only on physicians, but on nurses and other regulated health professionals across Ontario. Any recommendations and legislative changes must take into account the rights of regulated health professionals, including the very different contextual factors that are relevant to an assessment of sexual abuse in professions outside of medicine.
Submission to the Ontario Roundtable on Violence Against Women and the Select Committee on Sexual Harassment and Violence
ONA’s submission states, in part: We applaud the Premier’s commitment to eliminating misogyny and its appearance in the form of harassment, including sexual harassment, in our workplaces. And we appreciate the Minister of Labour’s commitment to recognizing injuries from workplace mental stress. But we also believe the key to success will begin with this government examining its own agencies and law, with expeditious legislative amendment and changes in Ministry of Labour and and WSIB policy and practice. The government, particularly the Ministries of Labour and Health and Long- Term Care, need to lead by example. We look forward to a day when our members can go to work secure in the knowledge that they will be free from harassment, including sexual harassment and violence in our workplaces.