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Dear College of Physicians & Surgeons of Ontario: thank you for the opportunity to comment on your Confidentiality of Personal Health Information Policy. I am pleased with the policy’s repeated appeal to practitioners to employ “professional and humane” standards in their work; also, the policy encourages doctors to ask the patient about disclosure whenever it becomes an issue.
As a member of the clergy, I am often stymied in my attempts to find out who of my parishioners are in hospital and have asked for my presence for that occasion or habitually in the past. While I am aware that the CPSO probably is not the body which determines hospital policy, I think the College can set the standard & lead the rest of the healthcare community by adopting a policy which would ask the patient if they would like their clergy informed of their situation: to be truly humane to the patient should encompass seeking any help or consolation that their religion can offer, I would think.
Please include somewhere in your policy that physicians & surgeons are encouraged to ask the patient if any clergy should be notified of the patient’s condition.
The policy should have a section specifically addressing social media and patient confidentiality. Social media is ubiquitous in the workplace and has become a standard tool for communication – even though it may not be the right one. CPSO should address this issue by name with clear directives.
No consent should be required for transmission of information when patients abuse or divert restricted drugs. Similarly when they steal prescription forms and forge prescriptions, alter prescriptions or engage in double doctoring. This town has recently had another death of a young person from a drug overdose. There are increasing numbers of reports about illegal dealers. The authorities and courts appear to be surprisingly lenient.
Patients are accessing genetic studies or undergoing high tech testing ( eg whole body MRI’s) . The implications of the results are not clear but the patient comes to the physician’s office with results and perhaps concerns. These results could influence, for eg. insurance eligibility/costs if disclosed despite the fact that their clinical relevance is uncertain. Should physicians warn patients beforehand about their receiving this information and including it in the patient’s record? How should this be handled?
Present policy is adequate
Apparently if I try to access my own health information on our hospital record system this is now considered to be a breach of privacy. In the old days this would be considered illogical. I guess the rules of logic have changed. Good thing Mr. Spock is not alive to witness this.
The current policy appears quite complete. Why are you undertaking a policy review? If it is politically motivated caution should be taken not to compromise a good policy for political ends.
Current policy is straight forward and I have no concerns.
Clarify the “circle of care” between institutions.
A critically ill patient receives initial treatment at a community hospital and is later transferred to a tertiary centre.
Up to which point is the referral physician in that ” circle” for eg receiving patient updates.
The referral physician clearly has an obligation to forward results received from investigations done
prior to transfer, but it is less clear based on my personal experience up to which point they may receive updates.
Just the age of valid consent of children and minors should be very clear and distinct
College of Physicians and Surgeons of SaskatchewanDear CPSO,
Please find below the 3 responses from the CPSS Senior Team:
• This document is based almost entirely on Ontario legislation. I identify nothing in it that is inaccurate, but I also do not have much familiarity with the legislation.
To the extent that it identifies issues that are not legislation-specific, I identify no concerns.
• I agree. I have not noted anything of concern, but also did not review the referenced Ontario legislation.
• I have no comments to add.
I feel that the policy should explicitly state that where there are concerns about prescription substance use disorder or diversion, information can be share among relevant Health Care Professionals to ensure the safety of patients and the community
The policy appears sensible and comprehensive.
Information and Privacy Commissioner of OntarioResponse in PDF format.
The policy is good as it stands
There should be clarification about revealing health information to insurance companies as physicians should reveal health information for the best interest of their patients and not for the benefit of the insurance companies.