Summary#
Bill 7, the Health Care is Not for Sale Act (Addressing Unfair Fees Charged to Patients), 2025, would amend the Regulated Health Professions Act, 1991 and the Integrated Community Health Services Centres Act, 2023. Its stated goal is to address unfair fees charged to patients; the bill does not define what makes a fee unfair.
- A discipline panel could find professional misconduct if a regulated health professional, or another person, charged an unfair fee for a service provided by that professional. The panel may order reimbursement and direct a three-month suspension of the professional’s registration.
- Each health profession College’s patient relations program would have to include measures to prevent and deal with unfair fees.
- The Council of a College could make a regulation defining “unfair fee.” The explanatory note says the regulation would need prior approval from the Minister and approval from the Lieutenant Governor in Council.
- The Director could suspend or revoke an integrated community health services centre’s licence if there are reasonable grounds to believe the centre is, or will be, charging unfair fees.
- The Director could not remove services from a centre’s licensed service list unless there are reasonable grounds to believe fees for those services are, or will be, unfair.
What it means for you#
- Patients: If a discipline panel finds that an unfair fee was charged for a regulated professional’s service, it may order the professional to reimburse the patient and direct a three-month suspension. The bill does not create a general process for patients to apply for refunds.
- Regulated health professionals: A fee charged by another person for a service you provided could lead to a professional-misconduct finding. The bill does not set out how responsibility would be assessed.
- Health profession Colleges: Their patient relations programs would have to include measures to prevent and address unfair fees.
- Integrated community health services centres: Their licences could be suspended or revoked over unfair fees. The bill would also limit when the Director can remove services from a centre’s licensed list.
- Patients generally: The bill does not ban all patient fees or set a fee schedule. It also does not clearly create a stand-alone, enforceable right to a particular fee or service.
Money#
No cost estimate is included in the supplied material.
- The bill does not provide an appropriation or state a public spending amount.
- It would require Colleges to add measures to patient relations programs. Staffing and other costs are not estimated.
- A discipline panel could order a patient reimbursed for an unfair fee. The bill does not estimate how often this might happen or the amounts involved.
What is unclear#
- What counts as an “unfair fee” would depend on a later regulation; the bill itself gives no definition or examples.
- The bill does not set out how a patient would raise a concern, how a fee would be investigated, or what evidence or decision process would apply.
- It does not explain how responsibility would be assessed when someone other than the regulated professional charged the fee.
- The full texts of the two Acts were not supplied, so I could not verify how these changes fit with their existing procedures and powers.
- The bill would come into force on Royal Assent, but the supplied material does not say when a regulation defining unfair fees would be made.
Case for#
- The bill appears intended to give regulators tools to respond when patients are charged unfair fees: possible repayment, professional discipline, and licence action against centres.
- Requiring Colleges to address unfair fees in patient relations programs could make preventing and dealing with these fees part of their formal work.
- Protecting services on a centre’s licence from removal, unless there are reasonable grounds to believe their fees are unfair, could help avoid removing services for unrelated reasons.
Case against#
- The central term, “unfair fee,” is left to a later regulation. Until it is defined, patients and providers may not know which fees could lead to discipline or licence action.
- A professional could face a misconduct finding over a fee charged by another person. The bill does not explain how the professional’s knowledge or control would matter.
- A three-month suspension is a serious consequence. The bill does not explain how the panel should account for different circumstances when deciding whether to order it.
- The bill does not set out complaint, investigation, or appeal details, or estimate the resources needed to carry out the new requirements.