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The Ontario Caregiver Coalition is a not-for-profit organization that advocates on behalf of unpaid caregivers who volunteer their time and resources to care for loved ones who face physical and mental challenges because of illness or injury.


The relationships of care and concern between family, friends, and those they care for are central to the wellbeing of both caregivers and care recipients. These relationships must be respected and protected. The healthcare system would fall prey to unbearable pressure absent the significant involvement of unpaid family and friends who support those who live with chronic conditions or who are too ill to manage on their own.


The Coalition commends the Government for attempting to deal with the crisis in our hospitals.  However, we are concerned that Bill 7, referred to as the More Beds Better Care Act, 2022, is deeply flawed, and may have unintended consequences.


The Government of Ontario is reminded that caregivers have been under enormous strain, exacerbated by the pandemic, due to the lack of meaningful home and community care supports. They have been facing impossible choices. Reforms must reflect the essential nature of caregiving and reduce these strains. 


We acknowledge that the Bill specifically prohibits the transfer of Alternate Care Patients to Long Term Care Homes without their consent. However, as we outline below, we are concerned that in practice, residents will be transferred without meaningful consent. This will place significant additional burdens on families, undermining the wellbeing of those needing care, their caregivers, and the health system in general. We therefore urge the government to amend or withdraw Bill 7.


The provisions of the Bill that essentially permit a long-term care home eligibility assessment to be conducted on a patient without consent are simply not appropriate in a free and democratic society, even following reasonable attempts to engage the patient. This is particularly problematic where a patient lacks a substitute decision maker and is vulnerable owing to poor health and possibly poor cognition. It positions hospital administrators to exercise undue influence on vulnerable individuals and obtain uninformed consent to transfer to a long-term care facility far away from loved ones and caregivers. The ends do not justify the means.


The Coalition proposes an amendment to the Bill to encourage hospital administrators to suggest a long-term care assessment to a patient coupled with a prohibition against the exercise of undue influence and a requirement to have an advocate present when a vulnerable patient lacks a substitute decision maker. The advocate would very often be an unpaid caregiver (generally a friend of or a member of the patient’s family) and consent to the assessment would still be required.


Another amendment would prohibit the charging of fees when consent to a transfer is withheld by a patient.  There would be a specific provision against the use of financial threats to force a decision upon such a patient or the patient’s substitute decision make who, again, will very often be an unpaid caregiver and friend or member of the patient’s family.


The Coalition appreciates the Government’s sense of urgency, on the one hand, but suggests that undue haste may well compromise the quality of the response.  It is important to take a holistic view of the system, which would include better support for unpaid caregivers to facilitate ALC transfers to the home, and reinforce home care, which the bill lacks with its singular focus on long-term care. We urge the Government to move forward with such an approach as quickly as possible since Bill 7 does nothing to provide the additional supports that caregivers and their loved ones need.


The Coalition acknowledges the commitment made by the Government to activate long term care respite programs to provide temporary relief to someone taking care of a loved one at home.  We thank the Minister of Long-Term Care for making this commitment  to the Legislative Assembly on August 23 during the second reading debate of Bill 7. We look forward to seeing this implemented rapidly.


But more needs to be done.  Public policy must leverage the valuable support system provided by unpaid caregivers through innovative programs such as directed care, increased homecare, and revitalized mental health services.



Yours truly,




Samuel Schwisberg                                                     Lauren Bates



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