MB is an outlier!
The following correspondence was sent to the Government of Manitoba (Minister of Health and official health critic), the College of Physicians and Surgeons of Manitoba, Health Canada and few other key stakeholders on January 29, 2021.
My concern is that as wait times go up, and resources become scarce, especially post COVID, the system will turn a blind eye to private clinics charging patients for otherwise publicly insured services.
Since I wrote the letter I have learned that Shared Health has operates a community outpatient ultrasound clinic on Jefferson Avenue which is both publicly funded and administered. This is progress but MB Health appears to still have an ideological bent against publicly funded funded services in private settings.
MB is one of only two provinces, the other being Newfoundland and Labrador, that does not fund diagnostic ultrasound (US) services in private settings (e.g. possible to combine with currently publicly funded community based x-ray and other laboratory services).
The majority of MB hospital based US services are for elective studies which could easily be provided in more patient convenient community locations with ample free parking (e.g. Grant Park Mall). The provision of US services in MB is currently anchored in an archaic service delivery model which is not based on what is best for the “patient”.
MB’s health policies have resulted in Manitobans being charged for routine elective US services being provided outside of hospitals.
Winnipeg’s "Prota Clinic" offers a variety of services including accepting physician referrals for echocardiograms (i.e. an ultrasound of the heart) and general ultrasound scans and are charging Manitobans $650 and $550, respectively (website accessed on January 22, 2021 and telephone confirmation, by myself, on January 22, 2021 that they were still offering these services for the fees posted). [ https://protaclinic.ca/echocardiograms-ultrasounds/ ]
For comparison, and as per the Manitoba Physician’s Manual (April 1, 2020), both of these services are on the MB schedule of insured services with typical professional fees being, $143 for routine echocardiography and $47.55 for a representative general ultrasound procedure (i.e. complete abdomen) with an additional $44.45 added if the diagnostic imaging physician performs the full exam for the latter (MB Fee Schedule codes 9729, 7309 and 7365 respectively). These values are considerably less than what Prota Clinic is charging patients.
It appears that the provision of such services could be considered uninsured under the Health Insurance Act, Excluded Services Regulations, as the services are being provided in a facility not approved by the Minister as per Section 17,( i.e. if the facility was “approved” by the minister they would be publicly funded).
Excluded Services Regulation
17 Diagnostic examination or treatment by means of non-radiation emitting medical imaging devices, including ultrasound, unless provided in a hospital as an in-patient or out-patient service, or in a facility approved by the minister. This exclusion does not apply to the ultrasonography of the eye for which a fee is set out in the Payments for Insured Medical Services Regulation under the Act. (bold added)
In addition, independent health facilities are under the purview of The College of Physicians and Surgeons of Manitoba (CPSM) “Manitoba Quality Assurance Program” (MANQAP) - Non-Hospital Medical and Surgical Facilities Accreditation Program - Diagnostic Imaging (DI) Standards. Under MANQAP’s DI standards there is no specific discussion of echocardiology, versus general US, standards and it would be prudent for MB Health to confirm that there is acceptable quality assurance oversight for such.
In my opinion, charging patients for routine, otherwise publicly funded services is not in keeping with the spirit, if not the letter, of the Canada Health Act.
In addition, and again in my opinion, charging patients for routine, otherwise publicly funded services, may be subject to provisions of Section 95 of The Health Services Insurance Act (Fees in excess of benefits prohibited). i.e.:
95(1) A medical practitioner, whether or not he has made an election under section 91 which is in effect, who renders medical services, and any person rendering other health services to which this Act applies by reason of an order made under section 71, shall not charge to or collect from an insured person, in respect of those medical services or other health services, a fee in excess of the benefits payable in respect thereof under this Act and the regulations.
I will leave it to the CPSM to determine if physicians participating in this venture are abiding by their professional and ethical obligations and if MANQAP is providing appropriate oversight for the DI services that Prota Clinic is providing.
In short, Manitobans deserve better. On the surface of it this appears to be a policy of privatizing the provision of routine, otherwise publicly funded, health care.
I respectfully await your responses to the raised concerns.