Policy and Political Action

Policy & Political Action

RNAO comments on proposed amendments to O. Reg. 79/10 under the Long-Term Care Homes Act, 2007

The Registered Nurses' Association of Ontario (RNAO) is the professional association representing registered nurses (RN), nurse practitioners (NP), and nursing students in all settings and roles across Ontario. Since 1925, RNAO has advocated for healthy public policy, promoted excellence in nursing practice, increased nurses' contributions to shaping the health system, and influenced decisions that affect nurses and the public they serve. It is the strong, credible voice leading the nursing profession to influence and promote healthy public policy.

RNAO welcomes this opportunity to provide feedback to the Ministry of Health and Long-Term Care (MOHLTC) on the proposed amendments to Ontario Regulation (O. Reg.) 79/10 under the Long-Term Care Homes Act, 2007 (LTCHA) in support of legislative changes made under Bill 160, Strengthening Quality and Accountability for Patients Act, 2017, Schedule 5 to allow for administrative penalties, as posted to Ontario's Regulatory Registry on Feb. 28, 2018. RNAO had previously commented on Bill 160 when it was brought before the Ontario legislature in the fall of 2017. Our written submission and speaking notes can be accessed on our website.

General comments

The focus on compliance in LTC homes does not foster a supportive, innovative practice environment. There are over 330 areas of regulation in O. Reg. 79/10 that compliance inspectors assess. Overall, LTC homes meet compliance in inspections. But LTC homes that meet and exceed expectations are not recognized for the excellent work that they do, because inspection reports only identify areas of non-compliance.
RNAO recommends that inspection reports identify both areas of compliance and non-compliance. Recognizing areas of best practice and excellence will encourage LTC staff and administrators to improve care and build on the positive work they are doing.

Summary of RNAO Recommendations

Recommendation 1. Balance inspection reports by requiring that they report both on areas of compliance and areas of non-compliance.
Recommendation 2. Do not introduce any fees for subsequent inspections required to determine compliance.
Recommendation 3. Use RNAO's LTC Best Practices Program throughout the stages of non-compliance to support LTC homes to achieve and maintain compliance, before administrative monetary penalties are imposed. Fines should only be used as a last measure. In particular, we recommend that:

  1. Compliance inspectors should recommend in the inspection report that homes work with RNAO's LTC Best Practices Program and coordinators to achieve compliance at the written notification stage and the voluntary plan of correction stage; and
  2. When issued with a compliance order, LTC homes should be mandated to use RNAO's LTC Best Practices Program and coordinators to assist in the preparation and execution of a plan to achieve compliance.


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