RNAO is pleased to respond to the consultation by the Canadian Nuclear Safety Commission (CNSC) on the draft terms of reference of its Potassium Iodide (KI) Pill Working Group. RNAO welcomes the commitment to form a working group to "provide clarity on the existing plans and associated responsible authorities to distribute KI Pills (in the Ingestion Planning Zone, within a 50-km radius) in the event of an emergency at the Pickering Nuclear Generating Station."

RNAO's recommendations focus on improving access to nursing and health care; strengthening our Medicare system; boosting living standards; protecting the environment; and being able to pay for these improvements by making our tax system fairer and more progressive. In the view of nurses, these are public investments that will keep Ontarians healthy and productive.

The full submission is available here, or at the bottom of this document.

Summary of recommendations

1. Provide hospitals with funding earmarked to immediately fill 10,000 RN vacancies.
2. Require all new nursing hires in acute care and cancer care hospitals to be RNs. 
3. Require all first home care assessments be conducted by an RN.
4. Relocate the 4,500 RN care co-ordinators currently in LHINs to primary care.
5. Implement independent RN prescribing in all sectors, inclusive of diagnostic tests by 2019,
   and integrate RN prescribing into the curriculum for baccalaureate nursing by 2020.
6. Ensure RNs are allowed to continue to initiate and perform the controlled act of psychotherapy.
7. Dedicate additional funds to ensure that new and existing NPs in primary care receive compensation equivalent to that received by NPs in hospitals.
8. Remove legislative, regulatory, and practice environment barriers to NPs’ scope of practice
   as follows:
   • Ensure NPs are enabled to act as most responsible providers in hospital.
   • Authorize NPs to perform point-of-care testing.
   • Authorize NPs to order additional forms of energy (e.g., CT, MRI, nuclear medicine procedures, non-invasive EEGs, and ECGs in all situations).
   • Authorize NPs to apply specified forms of energy (e.g., defibrillation).
   • Expand NPs’ authority to certify a death.
   • Authorize NPs to complete Forms 1, 2, 3, 4, 5, 14 and 28 for mental health services under the Mental Health Act.
9. Transform funding models in LTC to account for complexity of resident care needs and quality outcomes. LTC homes that improve residents’ outcomes due to evidence-based care and decrease acuity should retain all funding to reinvest in additional staffing for residents.
10. Mandate the implementation of relevant RNAO BPGs when MOHLTC inspectors find homes are non-compliant.
11. Legislate a minimum of four hours of nursing and personal care per resident per day in
    long-term care.
12. Legislate minimum nursing and personal care staffing and skill mix standards in LTC, accompanied by the necessary funding to support these changes. We call for no less than one attending NP for every 120 residents, and a skill mix of RNs, RPNs, and unregulated care providers consisting of at least 20 per cent RNs, 25 per cent RPNs, and no more than 55 per cent PSWs. This ratio would guarantee LTC residents receive care when they need it from the most appropriate provider.
13. Release funding for the outstanding attending NP in LTC positions. Hold LTC homes accountable for hiring attending NPs in the manner specified by the MOHLTC role description and funding policy.
14. Expedite the implementation of a new program of dental care for low income seniors by increasing funding for dental services in community health centres, Aboriginal health access centres, and public health units. Provide a clear timeline to invest in new public dental services in underserviced areas, including the use of mobile dental buses.
15. Develop and maintain a strategy to make personal health records available to all patients after consulting with patients, families, caregivers, RNs, NPs, and other health providers.
16. Continue to fund RNAO to strengthen its partnerships with Indigenous communities to co-create clinical best practice guidelines and to expand the Indigenous-focused Best Practice Spotlight Organizations to address the health needs of Indigenous persons.
17. Expedite the authorizing and funding of Consumption and Treatment Services (CTS) across the province where they are needed to save lives.
    • Immediately increase access to CTS to all communities in need.
    • Streamline and expedite the CTS application process to increase access to this life-saving health service.
    • Invest sufficient funding in the CTS program to help prevent deaths from overdose. In addition, provide funding and support for the treatment services required by the CTS model because there is now a shortage of treatment, recovery and mental health and addiction services.
18. Develop a climate change plan that, at a minimum, meets Ontario’s legislated GHG reduction targets of 15 per cent below 1990 levels by 2020, 37 per cent by 2030 and 80 per cent by 2050.
19. Take all necessary steps to:
    • Work with federal and municipal partners to ensure dedicated and sustainable revenue sources to pay for ongoing operation and substantial expansion of transit and active transportation in Ontario.
    • Support cost-effective and expeditious delivery of those expansions, implemented by transparent governance and informed expert opinion.
    • Don’t fund transit expansion by selling public assets such as Hydro One.
20. Build a more progressive tax system and don’t cut taxes so Ontario develops the fiscal capacity to deliver all essential health, health care, social, and environmental services.
21. Make polluters pay for the full cost of the pollution they create, including their carbon emissions. Support the national carbon pricing initiative. Increase revenue sources in ways that are fair and equitable, and that encourage environmental and societal responsibility.

RNAO welcomes the opportunity to provide feedback to the College of Nurses of Ontario (CNO) on RN prescribing competencies. RNAO has long advocated for independent RN prescribing. RNs are autonomous health professionals who practise independently and collaboratively within interprofessional teams. With more than 100,000 RNs registered to practise with the CNO, RN prescribing has huge potential to increase access to care across the province.

RNAO welcomes this opportunity offered by the Canadian Nuclear Safety Commission (CNSC) to respond to Ontario Power Generation's (OPG) application to renew its nuclear power reactor operating licence for the Pickering Nuclear Generating Station (Ref. 2018-H-03). OPG is requesting the renewal of its licence from its current expiry date of August 31, 2018 for ten years. OPG plans to end commercial operations at Pickering by December 31, 2024. The issue matters a great deal to nurses because of its health implications and because they are heavily involved in any disaster responses (see the appendix). RNAO urges the CNSC to adopt a precautionary approach that prioritizes human  health.