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it does not seem cost effective to audit and do site visits for small fertility clinics that just do IUI -as they do not have an IVF lab and do not do surgical procedures. IUI is just a easy office procedure (like a pap smear) that requires a lab tech and incubator. Surely the college does not want to audit every doctor office that does pap smears! I feel the college should spend its energy on IVF clinics to start with and then consider a portion of the audit for smaller fertility clinics that only provide the IUI service.
I fully agree with the proposed changes. Any such procedures should be inspected by the College. I would add to the list many others, such as acupuncture done by MDs, etc.
this is a timely initiative which I fully support.
I suggest that the CPSO also gets involved in other out of hospital procedural places such as those offering endoscopy
I agree completely
I fully support this, and agree that other endoscopic clinics should be monitored.
I believe it is essential to have college oversight of fertility services regardless of whether anesthesia or sedation are used on the premises.
I support the proposed amendment.
What does a small iud clinic do. Wash sperm and draw except for infection control which necessary in any office what are you looking for a waste of time and another expense and road block
This is a much needed oversight of all fertility services, which I strongly support.
I frequently hear of questionable practices in fertility services and think they need more accountability.
These are desperate vulnerable patients who should receive only evidence based treatments and not be asked to spend large amounts on unproven treatments.
College should not be given those kinds of Powers. This should be under the Royal College only. It should not be in their jurisdiction to enter premises as they will.
As a Child Psychiatrist my comments relate to the product of these services – otherwise known as a person (initially described as “a child”).
1. ABSOLUTELY there should be an “audit trail” (e.g. like with the handling of narcotics or forensic evidence)of where the gametes (sperm or ova) came from and where they went!!
2. This information should be AVAILABLE TO THE PERSON resulting from this procedure – i.e. stored for 18-58 years, under the usual privacy protections.
3. To minimize errors or malfeasance (people deliberately misusing these procedures for multiple reasons – i.e. doctor uses his own sperm to inseminate dozens of females)- there should be periodic checks (trust – and verify)on these certifications.
4. The DNA of DNA manipulators should be documented to further reduce opportunities for manipulation.
5. Explicit notes need to be documented for any “material” disposed of – when, how etc.
Measures like this will help minimize life long concerns for these (medically assisted created) people.
This is a big unnecessary part of my practice.
re the inspection of facilities and operative procedures there is no discussion re the qualities and experience that the INSPECTOR must have. There should be a statement that defines necessary background history of the inspector to limit bias and ignorance.
I both support and not support this proposed change in inspection.
Has the College defined what they are inspecting for? If it is protection of the patient from useless therapies being advised to them, then that may make sense. But if it is to flex their muscles and impose further limitations to clinics being able to run professionally, cost-effectively and ethically then it is not a good idea. Who are the inspectors going to be? Hopefully they are people who are trained in the industry and understand the nuances of how things are done to accommodate patients demands and wishes and may not always be “best science”.
The other question is why are not other types of clinics being inspected under similar guidelines? Cardiology clinics? Etc.
I assume the cost recovery aspect of such inspections proposed means that the cost of these inspections are born by the clinic being inspected?
In the past, fertility clinics have been inspected by inspectors that have no experience in the area and have no regard for the cost of changes they demand at the end of the inspection. Will this continue with this new “inspection” process proposed here?
I fully support this regulation change as fertility clinics need to be held to a high standard. Also agree with the others in that other clinics such as endoscopy clinics need to be inspected on a regular basis as well.
Agree that the CPSO should have authority to inspect these premises. The cost of this should be covered by the government as part of implementing their new policy change as opposed to increasing fees for CPSO in the future .
I agree with physician comments submitted on this subject.
Especially, comment # 9 submitted by a children’s psychiatrist.
The news about [name omitted] in the media not the first time he has been presented in the media as a specialist with questionable adherence to best medical practice and ethics.
I am a member of the public, I have received email invitations in the past to provide opportunity for comments.
I read and consider the specific document and proposed changes then flag the email message until closer to the deadline.
In Guelph, I am grateful for my fine family doctor who has been a member of an early and successful family health team.
You are very welcome.
Please note that I found it very difficult to access the comments page-making this easier will increase feedback!
Suggest a minor change so as to capture all practices related to infertility care (changes in bold);
44.(1)(b.1) any act that is performed in connection with,
i. in vitro fertilization,
ii. intra-uterine or vaginal insemination,
iii. fertility preservation for medical purposes
Ministry of Health and Long-Term CareResponse in PDF format.
PAROResponse in PDF format.
Ontario Trial Lawyers Association Response in PDF format.
College of Physicians and Surgeons of SaskatchewanThe senior staff at the College of Physicians and Surgeons of Saskatchewan have reviewed the proposed policy and do not have any comment at this time.
Responsible as opposed destructive audit has always been a welcome process in the medical community dating back to 1976 !
However as more OP procedures such as Endometrial Ablation,hysteroscopy etc will follow the European endeavours it behoves us to be more vigilant of the standards of care and qualifications of the providers as recently reflected in the “Liposuction debate”1.
However the College will be well advised to have a Standard test for their Reviewers to asses their Prejudices including Racial Bias…some have reported poor outcomes due to such biased individuals who feel “inflated with authority”,they also should have some comeback & feed back to make the process equitable .
After all lets not create another witch hunt!
Absolutely stunned majority of physicians support this. More regulation more cost no increase in compensation. I had an IHF licence and sold it to get out of onerous documentation. A surgeon can offer major surgery without oversight but if I do donor insemination for a same sex couple I need to be monitored. Seriously this will just reduce access and hurt patients. I am the only Fertility provider within 500 km. Great if you live in one of the major cities terrible for everyone else. CFAS came out with policy statement that only REI s should offer ovulation induction. A self serving guideline that has no basis in common sense. Royal college training standards state all OB/gyn need to be proficient in ovulation induction and the use of gonadotropins. infertilty treatment is out of reach for average Canadian let’s make it more so. CPSO Can audit any doctor this new program will make doctor(patient) pay for.