Submission to the Ontario College of Physicians and Surgeons

Catholic Civil Rights League

The Catholic Civil Rights League (CCRL) is pleased to provide this submission to the College of Physicians and Surgeons of Ontario (CPSO) regarding the review of the current policy Physicians and the Ontario Human Rights Code. The CCRL made a previous submission in 2008 prior to the adoption of the current policy. We make this submission on behalf of our membership nationally, particularly for those in Ontario.
Our concern today is similar to that of 6 years ago. We strongly advocate for the protection of the Charter right of freedom of conscience and religion for all Canadians, including physicians in the daily routine of their care to patients and in the overall forming of their individual medical practices. We believe this is key to the maintenance and growth of our social fabric in the province of Ontario and all of Canada. Your policy should reflect a true pluralistic society so as to avoid a climate for discrimination of any kind, including discrimination based on religious and moral beliefs and the exercise of one’s conscience.

The CCRL acknowledges the assertion in the current policy which states that, “There is no hierarchy of rights in the Charter; freedom of religion and conscience, and equality rights are of equal importance.” We also acknowledge that many citizens in Ontario subscribe to a belief in secular humanism, which often demands the relegating of issues informed by religion as private matters, which ought not be expressed or acted on in the public square. We would like to remind the CPSO that the Charter itself does not mention “freedom of religion” independent of “freedom of conscience and religion”, so that the right of one’s freedom of conscience informed by a religion, a philosophical system or otherwise is crucial regardless of society’s current views regarding religion.
The current CPSO policy also states that:

The balancing of rights must be done in context. In relation to freedom of religion specifically, Courts will consider how directly the act in question interferes with a core religious belief. Courts will seek to determine whether the act interferes with the religious belief in a ‘manner that is more than trivial or insubstantial.’ The more indirect the impact on a religious belief, the more likely Courts are to find that the freedom of religion should be limited.

The CCRL submits that issues pertaining to the sanctity of life from conception until natural death are at the core of Catholic beliefs. Such beliefs are also based in reason and medical science. To the Catholic physician, this would impact the providing of prescriptions of birth control pills and abortifacients and the performing of an abortion or its procural unless the mother’s life is in imminent threat. But such understandings go beyond these areas, and touch upon all aspects of medical care, whether for the disabled, the elderly, or those with mental afflictions. We assure the CPSO that under no circumstances would any of the aforementioned practices be considered ‘trivial or insubstantial’.

Secondly, we submit that the College must ensure that a physician’s conscience rights must be observed at first instance, especially given that there are numerous procedures which may cause such physicians, religious or otherwise, difficulty, regardless of their availability under the publicly funded system. In keeping with our mandate to educate the public and defend and promote the Catholic perspective, we at the CCRL submit that a physician must have the right to carry out their duties in line with their respective consciences.

We submit that it would be offensive and a fundamental injustice to human dignity to require people to support, facilitate or participate in what they perceive to be wrongful acts. The more serious the wrongdoing, the graver the injustice and offence that would occur. We urge the College to resist any policy revision to establish the principle that people can be compelled to do what they believe to be wrong – or face the risk of sanction if they refuse. The College should avoid any suggestion that physicians be required to observe a ‘duty to do what is wrong’ in medical practice.

In referring to the ‘balancing of rights’ referred to in the above excerpt from the 2008 policy, the CCRL submits that the current policy attempts to maintain this balance outlined in the Charter rights of conscience and religion and the Ontario Human Rights Code. Using the previous listed examples of practices that would be morally objectionable to a serious Catholic physician, the number of said physicians is minute in comparison to those who would have no objection whatsoever. If a lack of balance exists, it is surely found in the vast difference between physicians who choose to conscientiously dissent versus those who do not. A member of the public in Ontario has ample resources and options available for recourse to a physician to perform publicly funded services, without violating the conscience rights of a physician who may object.

With this submission, we at the CCRL sincerely hope that the September 2008 CPSO policy regarding Physicians and the Ontario Human Rights Code is not altered in a manner that would diminish a physician’s right to freedom of conscious and religion in carrying out his or her duties according to the professional standards and guidelines of the CPSO. The medical profession, as with any grouping of individuals is not truly free to live and free to grow if its members are not able to govern their actions in accordance with their individual consciences whether informed by moral and religious beliefs or otherwise. In no way is this subtractive to the social fabric of our society, rather it greatly contributes to a true pluralist and diverse population. We should be allowed to agree or to disagree at times, always respectful of differences especially when they concern aspects of one’s moral or religious core, in no way trivial, but rather at the basis of a well-developed, civil society.

Submission to the Ontario College of Physicians and Surgeons

Action Life Ottawa

Action Life Ottawa is a non-denominational, non-profit organization dedicated to the defence of human life through education. We believe that all human beings have an equal right to life before and after birth and that society has the duty to uphold and protect that right. Our organization counts 4,000 supporters.

Concerning the consultation on freedom of conscience, Action Life holds that physicians should not be expected to refer or provide services to which the physician is opposed on conscientious or religious grounds. To force physicians to act against their conscience or religious beliefs would constitute coercion and reduces the role of the physician to that of a technician who must fulfill every patient demand. The physician is not merely a technician providing services to patients. He/she cannot be expected to leave his/her moral integrity at the door. A physician’s ethics are informed as well by medical and scientific knowledge. It is vital that a physician not be forced to refer for abortion or other procedures which the physician finds morally or ethically objectionable. Some of these procedures or services, the physician might find harmful to a patient’s health.

Consider the practice of euthanasia recently legalized in Québec, what does the future hold for physicians in Ontario regarding this practice? Many physicians would be opposed to referring or performing euthanasia if it were legalized. Freedom of conscience and religion must be respected.

Provisions in the Code should protect physicians in Ontario from coercion and discrimination. The Constitution of Canada recognizes freedom of religion and conscience and these rights are protected by the Charter of Rights and Freedoms. The policy of the Canadian Medical Association (CMA) allows physicians to opt out of referrals for abortion. The present policy of the Canadian Medical Association is clear; physicians are under no obligation to provide or refer for abortion. In fact, the CMA’s policy on induced abortion states:

“A physician whose moral or religious beliefs prevent him or her from recommending or performing an abortion should inform the patient of this so that she may consult another physician. No discrimination should be directed against doctors who do not perform or assist at induced abortions. Respect for the right of personal decision in this area must be stressed, particularly for doctors training in obstetrics and gynecology and anesthesia.”

Attacks are mounting on the conscience rights of physicians. In 2007, a letter requesting a change to the CMA referral policy on abortion was sent by The National Abortion Federation an organization representing abortion providers in the U.S. and Canada. The National Abortion Federation was seeking a policy which would force physicians to refer for abortion. It received the following response from Dr. Colin McMillan, then President of the CMA who wrote “The CMA’s policy on induced abortion does not violate our Code of Ethics…Nor does it treat women unfairly or impede their access to critical health care.”

A controversy arose in 2006 when a guest editorial by two professors, published in the Canadian Medical Association Journal of July 4, stated in relation to induced abortion that “Health care professionals who …fail to provide appropriate referrals…are committing malpractice and risk lawsuits and disciplinary proceedings.” In response, the Journal published a letter from the CMA’s Director of Ethics clarifying that the CMA policy on abortion did not require physicians to refer for abortions if doing so would be a violation of their conscience.

The Ontario Medical Association, in response to the College of Physicians and Surgeons of Ontario‘s draft policy in 2008 stated:

“It is the OMA’s position that physicians maintain a right to exercise their own moral judgment and freedom of choice in making decisions regarding medical care and that the CPSO not insert itself into the interpretation of human rights statutes.”

We would agree with the Ontario Medical Association that “…it should never be professional misconduct for an Ontario physician to act in accordance with his or her religious or moral beliefs.” Action Life calls on the College of Physicians and Surgeons to strengthen measures to ensure the right of physicians to practice medicine in accordance with their conscience or religious beliefs.

Thank you for the opportunity to comment on this issue.

Action Life Ottawa

Submission to the College of Physicians and Surgeons of Ontario

ARPA- Association for Reformed Political Action (Canada)

On Tuesday, August 5, ARPA’s legal counsel sent a formal submission to the College of Physicians and Surgeons of Ontario with respect to their policy as it relates to conscience rights and the Ontario Human Rights Code. The College had requested feedback as it underwent consultations while reviewing their policy. At stake is whether doctors have the right  to refuse treatment if they have conscientious objections to the treatment. For example, can a Christian doctor refuse to prescribe birth control pills if that particular doctor thinks that such a prescription is unethical, or is bad medicine? What if the objection is religiously motivated? These are not just hypothetical questions: three doctors in Ottawa recently came under fire for refusing to prescribe the birth control pill. . .  [Full text and submission]

 

Submission to the College of Physicians and Surgeons of Ontario

Evangelical Fellowship of Canada

Re: CPSO Policy #5-08: Physicians and the Human Rights Code

The Evangelical Fellowship of Canada (EFC) appreciates the ability to offer comments on this policy review. The EFC is a national association of denominations, ministry organizations, post-secondary educational institutions including seminaries, colleges and universities, and local churches. Some of our affiliates provide medical and health care in Canada and overseas, and many physicians are members of our affiliated denominations.

Having reviewed to policy, we note that while there is a strong emphasis on the duty not to discriminate in the provision of services, there is a lack of emphasis on the religious freedom and freedom of conscience guarantees and protections offered in Canadian law to individuals and, in this context, physicians.

We endorse the analysis and commentary in the written submission and covering letter of the Christian Medical Dental Society (CMDS) and the Canadian Federation of Catholic Physician Societies. The CMDS is an EFC affiliate, and we commend these documents to you.

Christianity has a long history of fostering and promoting medical care. It was and continues to be a distinctive of the Christian tradition, as documented by Gary Ferngren in his book Medicine and Health Care in Early Christianity (Johns Hopkins, 2009). Integrity of belief and practice is a core element of the Christian faith and respect for religious freedom is critical to the ability of individuals and groups to live out their faith in an integral way before God and in the service of others.

Evangelical Fellowship of Canada

 

Submission to the College of Physicians and Surgeons of Ontario

General Practice Section, Ontario Medical Association

Re: Human Rights Code Policy

Dear College of Physicians and Surgeons of Ontario,

The Section on General and Family Practice appreciates the opportunity to provide  comment on the College’s Physicians and the Ontario Human Rights Code policy that is currently being reviewed.

This policy provides important guidance to physicians on sensitive matters and has generated a great deal of interest and discussion amongst our members since it has come up for review. Overall, the Section feels that the policy in its current form seems to strike a reasonable balance between the moral and religious beliefs of physicians and the legal obligations and professional expectations related to the medical services they provide and has served the profession well since it was approved in 2008.

Essentially, the Section feels that we as physicians are professionals. We communicate with our patients on the complex issues they bring to us and we use our best judgement in making decisions around care together with our patients. The system and communities that we work in have well established networks with our other provider colleagues that enable us to provide the care our patients require when that need falls outside of our ability to provide that care as individual physicians.

Since this policy has come up for review, there have been significant concerns raised amongst our members that tighter guidelines will be placed upon physicians requiring them to provide types of care that conflict with their own personal morals and beliefs. This has led to a number of concerns being raised as to the possible outcomes related to any potential changes to this policy that would be more onerous on physicians. Questions that have come to our attention from our members include the following.

  • Are we slowly heading to a system where individuals looking to enter the medical profession will be required to leave their moral and religious beliefs behind when they accept entry?
  • What about more remote areas of practice? Will more prescriptive policies drive physicians to feel that they will have no choice but to practice in more urban settings?
  • What happens if a physician becomes fearful for safety in their office due to the extreme nature of a particular patient’s behaviour or uncomfortable with a patient who refuses to respect the rules of a physician’s office that may or may not be related to an underlying medical condition? Will the physician lose the ability to end the doctor-patient relationship?
  • Will a stricter policy make it more difficult to manage inappropriate patient demands such as those for narcotic pain medications as it may be construed by some patients as a denial based on discrimination.

College policies can have far-reaching impact above and beyond regulation of physicians in practice. As such, they need to be carefully thought out. A more strict approach to Physicians and the Human Rights Code could lead to situations where well qualified students are, in a sense, denied entry into medical school because of a potential inability to honour their personal, socially accepted religious beliefs due to patient demand. The Section believes it is important to ensure that the public continues to have access to care from the best and brightest minds and we are concerned that quality could suffer if we only accept medical students who are willing to compromise their personal values. At the same time, the Section is well aware of recent items in the media that might compel the College to consider changes to the current policy that would place more onerous expectations upon physicians to personally provide any and all treatment even when it is in direct conflict with their own personal morals and beliefs. However, the Section is not aware that there has been a pattern of complaints that relate to this matter that would document a more significant underlying or systemic problem in this area. As such, it would seem that the policy in its current form is adequate.

An area that was identified as a potential area to be improved upon is in regards to the definition of “disability” within the context of this policy. Mental illness has been raised as an example of a medical condition or disability that has a wide range of expression. It is felt that there may be some room to better define disability or provide some guidance to allow for the use of professional judgement when it comes to disability and a physician’s ability to safely and appropriately provide care in their work environment.

Finally, a significant area for consideration has been raised about the importance of having clarity in regards to complaints being dealt with through the Ontario Human Rights Commission and the role of the College. Physicians are always exposed to the risk that the decisions they make will be challenged by a complaint to the OHRC. If there is a complaint against a physician to the OHRC, this should be allowed to run its course without necessitating involvement of the College. The College should not become involved in additional areas outside of its jurisdiction. For complaints that come to both the OHRC and the College, the College policy should clarify when the College steps aside and waits to assess whether issues of professional conduct remain after the OHRC has made its decision.

The Section feels that the policy in its current form seems to give appropriate guidance to physicians in regards to our legal obligations and our professional expectations but also does not place physicians in an unreasonable position of being forced to provide certain care if it conflicts with their own moral and religious beliefs. The ability for physicians to say “no” without retribution must be preserved as long as those decisions are not based on discrimination. In the rare instance that an individual physician’s professional conduct is felt to clearly fall outside of what is deemed to be reasonable, then the policy in its current form has sufficient substance to be able to deal with those individual situations.

The Section understands that this request for feedback is a preliminary consultation that is meant to assist the College as it begins its work to update this policy so we look forward to the opportunity to review the outcome of this work and once again provide input when it is recirculated for further comment.

General Practice Section
Ontario Medical Association