1. The records retention requirements, while understandable from a legal perspective, can be very unwieldy... I left my private family practice decades ago, at a time when it was still common to leave the records in the hands of the physician taking over the practice (we were later advised to retain the originals ourselves... but where???). While I had a written agreement with the new physician & with my associates that I would be informed if any of those records were later transferred elsewhere, that has never occurred (and would be a significant administrative responsibility given the time duration involved)... meanwhile I did specialty training, worked for nearly two decades at a mental health clinic, and then transitioned into a private solo practice from which I am soon to retire. Yet it will be another year before I am technically no longer responsible for the records of any children born within the family practice I left in 1997... and I have no control over the records in the physical custody of the agency I last worked for, and for which I am technically responsible for some years yet. Not to mention that if I were to die, my (non-medical) executors would be mystified at how to deal with my estate's ongoing responsibilities in this regard. Somehow the logistics of this medical records policy need a 're-think'. 

2. 'Responsibilities without resources' is a recipe for physician stress. I feel for the commenter who described trying to meet these responsibilities when closing a practice under significant personal duress. And how, in practical terms, are we required to prepare for our own potential sudden death or incapacitation? (... recognizing that most estate trustees and helpful family members/friends are not health care professionals and are not familiar with nor able to carry out some of the tasks involved)

Consider the following, as a 'companion' to the policy & associated 'Advice to Physicians':

(a) A simple, practical checklist, organized according to suggested timelines, for a closure that can be planned in advance (as suggested by another commenter, include any advice on dealing with one's professional on-line presence - website, directories, social media, etc.)
(b) A similar checklist for unexpected closure - taking into account varying situations such as physician illness / incapacity, loss of licence to practise, sudden death, etc.
(c) Development of a roster of professional persons who could be hired by physicians themselves, or by their POA (if the physician is incapacitated), or by estate trustees, who could provide hands-on assistance to ensure that closure duties are completed in conformity with CPSO requirements.

I would also like to see clarification that the College be required to maintain privacy of a retired physician's personal contact information... which in some cases is a matter of safety for the physician & their family. if a member of the public has a legitimate need to contact a physician who no longer has a practice address, that should be directed through the College (who would keep the physician's contact info confidential).

Note: Some content has been edited in accordance with our posting guidelines.

Good morning,

As a mature member of the public, I have reviewed the background documents including discussion page comments.

The doctor who provides discussion comments on September 12, 2024 stated very clearly his experience as a recently retired doctor.

Policy 2019 version paragraph 7 content states record retention 2 years.  Is that an appropriate duration for some patient records?

Because planning versus an abrupt end of practice are both very complicated, the CPSO and other physician professional organizations should try to ensure basic physician education including this topic as associated with the steps in establishing their professional business corporation as well as periodic updates.

The unexpected end of practice due to illness, accident, other tragic ending brings additional complications for the practice as well as the patients.

In the ideal practice as in [redacted], the Family Health Team model, in which I have been a patient since 2003, very likely has physician support and guidelines on this topic while much does rely on the individual doctor member.

Note also that in [redacted], Dr. [redacted] at [redacted] public health leads a model public health unit. They were ready to schedule on line fall vaccine appointments by October 15 with first COVID vaccine appointments starting October 21. [redacted] residents have had access to this option for public health services during the pandemic - a model for the province.

Perhaps improved periodic annual communication with patients at appointments or other contacts to ensure current personal information for contact is current.

I support any provincial plans to increase number of students entering medical school by significant numbers and making this and other administrative responsibilities as basic and simple for graduating doctors in Ontario.

College of Nurses of Ontario (CNO)

CNO had the opportunity to review the Consent to Treatment and Closing a Medical Practice draft policies posted on your consultation page. We greatly appreciate the opportunity to review and provide feedback on the draft policies and practice supports. Overall, both draft policies are clearly written, easy to understand and relevant. The accountabilities set out in the policies are helpful for articulating the practice expectations of the profession.