ID
2024-011
ID
2024-011
Type
Policy
Sector
Auto Insurance
Status
Public comment closed
Date
Comment Due Date
Thank you for providing your feedback on FSRA’s proposed auto reforms.
The request for submissions is now closed.
We appreciate the comments and questions received to date. Your feedback will help to inform our framework; stay up to date on our newsroom. Follow us on LinkedIn and subscribe to our mailing list for quick updates.
Ontario’s Financial Services Regulator (FSRA) is conducting a review of the health service provider guidelines and frameworks. This will help make the auto insurance system more modern, efficient, and ensure consumers injured in auto accidents continue to get the care they need. As part of this review, FSRA is now consulting on three papers that set out options, which fall within FSRA’s statutory authority, to support government auto insurance reforms.
The consultation papers include:
- The Health Service Provider (HSP) Framework Review and The Health Claims for Auto Insurance (HCAI) System Review which set out administrative and cost-efficient options to modernize the system and make it more efficient.
- The Statutory Accident Benefits Schedule (SABS) Guidelines Review which sets out options for the Professional Services Guideline (PSG), the Attendant Care Hourly Rate Guideline (ACHRG), and the Minor Injury Guideline (MIG).
The consultation is now open and will close on November 29, 2024. Stakeholder input will be used to help inform FSRA’s auto reform review findings and recommendations to government.
Learn more:
- Health Service Provider (HSP) Framework Review
- Statutory Accident Benefits Schedule (SABS) Guidelines Review
- Health Claims for Auto Insurance (HCAI) System Review
FSRA continues to work on behalf of all stakeholders, including consumers, to ensure financial safety, fairness, and choice for everyone.
Learn more at www.fsrao.ca.
Before we begin, please make sure you do not include any personal or private financial information. If your inquiry does require this information be shared with us, please call us at 1-800-668-0128 or email us at [email protected] for instructions.
By submitting your content, you agree to have your materials posted on our engagement portal, used in reports and other materials prepared by Financial Services Regulatory Authority of Ontario (FSRA) that may be shared with the public. Content is moderated so that all posts are respectful and professional. The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31, applies to all online content.
The content in these submissions reflects feedback from stakeholders and has not been verified or validated by FSRA. FSRA does not endorse or guarantee the accuracy of the statements made.
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| Sector | Comment | Date posted Sort ascending |
|---|---|---|
[2024-011] Group submission
Over 500 stakeholders submitted the attached statement to FSRA. The second attachment includes the names of these stakeholders and any additional comments they provided. |
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| Auto Insurance | [2024-011] Giuseppina Marra - Desjardins Group
Hello, On behalf of Desjardins Group, please find attached our comments regarding the consultation on auto reform. We'd like to thank the FSRAO for the present given opportunity . Shall you require any additional information, please feel free to contact the undersigned. Regards, Sarah Bouhenni Administrative assistant Regulatory Affairs, Desjardins Group |
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[2024-011] Dianna Pasic - Ontario Chiropractic Association
Please see the attached letter sent on behalf of Ms. Caroline Brereton. |
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[2024-011] Janak Soni - SGI CANADA & Coahcman Insurance Company
Please find attached a document that summarises the feedback on the below listed FSRA Consultation Papers related to Ontario Accident Benefits.• Statutory Accident Benefits Schedule (SABS) Guidelines Review • Health Claims for Auto Insurance (HCAI) System Review • Health Service Provider (HSP) Framework Review |
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[2024-011] Consumer Advisory Panel - FSRA |
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| Auto Insurance | [2024-011] FAIR Association of victims for Accident Insurance Reform
Please see attached comments regarding the FSRA Consultation on auto reforms from FAIR Association of victims for Accident Insurance Reform.Thank you |
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| Health Service Providers | [2024-011] Kindree Alkins - Bayshore Healthcare
Please find attached Bayshore's submission with respect to consultation on the Professional Services Guidelines (PSG), Attendant Care (AC) and Framework review. Thank you for your time and consideration. |
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| Health Service Providers | [2024-011] Brian Fehst - College of Kinesiologists of Ontario
From College of Kinesiologists of Ontario (Professional Regulator), submitted respectfully for consideration. |
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| Licensing | [2024-011] Caitlin Reid on behalf of Brian O'Riordan - College of Audiologists & Speech Language Pathologists of Ontario
Please find CASLPO's submission re. FSRA's Consultation on Auto Reforms (ID: 2024-011) attached. Should you have any questions or wish to discuss further, please contact Margaret Drent, Deputy Registrar |
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| Health Service Providers | [2024-011] Ruth Abrahamson - Medico-Legal Society of Toronto
Attached, please find the MLST Response to Financial Services Regulatory Authority of Ontario (FSRA) –Guidelines ReviewThank you! Medico-Legal Society of Toronto (MLST) |
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[2024-011] Brian Zeiler-Kligman
Please find attached a submission on behalf of Lifemark Health Group. Thank you for the opportunity to provide these comments. |
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| Cross Sector | [2024-011] Danielle Wilkinson - Equite Association
Please see the attached submissions on behalf of Equite Association. |
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| Auto Insurance | [2024-011] Neenah Navasero & Simon Oomen-Hurst - Neenah Navasero Neurorehabilitation
Please find our submission attached detailing our concerns and comments regarding auto reform.Thank you for your consideration. |
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| Auto Insurance | [2024-011] Matt Di Maio - Ontario Trial Lawyers Association (OTLA)
Please find OTLA's submissions attached - HCAI, HSP and SABS. |
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| Auto Insurance | [2024-011] Kelly Gauthier & Tara Payne - Forest City Counselling Services |
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[2024-011] Justin Dela Pena - Ontario Association of Social Workers
Thank you for the opportunity to provide feedback. Attached is OASW's Submission. |
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| Auto Insurance | [2024-011] Co-operators |
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[2024-011] Brian Zeiler-Kligman
On behalf of Lifemark Health Group, please find attached a supplemental submission outlining issues to be addressed in future reforms. |
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| Auto Insurance | [2024-011] Wendy Sarsons & Jacquie Levy - Action Potential Rehabilitation
Following the Auto-Reform Webinar, Action Potential Rehabilitation would like to address the following points: 1. PSG / HCP fees need to be increased to improve access to care and fairly compensate providers. • Option A should be considered and the indexation should be cumulative in line with changes to the Consumer Price Index (CPI). • The increase should be cumulative from the last increase in 2014 to present (2024). • The rate increase should be implemented immediately and not staggered. • The fee guidelines should be reviewed annually and adjusted accordingly with the CPI. 2. The rate distinction between non-CAT and CAT categories should be eliminated. • Compensation for an hour of provider time should be the same regardless of injury status. • With this, the overall funds available for non-CAT and CAT files should continue to be different. • Different rates result in complicated scenarios when clients move from non-CAT to CAT status or when they settle and move to private rates. • There should be only 1 fee rate for an hour of service that fairly compensates providers. 3. MIG fees should also be increased to match CPI - OR – in this case, a flat rate comparable to market value should be implemented. 4. The Block System for MIG files should be removed. • The hard deadlines create a ‘use it or loss it’ mindset while scheduling and treating. • When there are holidays, illness, or other reasons that care is unable to be provided, clients lose access to this block of funding. • OCF23 should be revised to allow treatment that can be scheduled according to need rather than using an arbitrary funding formula. 5. The definition of ‘overhead’ costs needs to be re-evaluated. • Many of our treatment plans are being partially approved as codes like Service Planning are deemed an ‘administrative fee’ or as ‘not applicable to provider indicated’. • Service planning includes contacting physicians, other HCP’s, and family members to coordinate care. The date cannot be controlled by the provider. • According to College guidelines, dates for billing need to correspond to when the service was provided. • As a result, service planning cannot be batched together with treatment, if it did not occur on the same date. 6. Travel Time costs to be reviewed. • Our Physiotherapy practice treats clients with very complex needs who are unable to travel to a clinic for services. • Our providers should be compensated for the additional time it takes to travel to these complex clients where barriers are in place preventing them from taking public or other forms of transit. 7. The requirement to exhaust Extended Health Benefits (EHB) prior to accessing the AB Insurance needs to be eliminated. • Having to exhaust a claimant’s EHB causes issues with compliance, delays payment to the provider and puts the provider in the middle between the MVA insurer and the claimant. • In the past, we have not been fully reimbursed for services as the AB insurer refuses to pay and the client refuses to submit against their EHB. These are all significant concerns with the current system and we hope that FSRA will give them serious consideration to ensure better access to care for clients. |
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| Property and Casualty and General Insurance | [2024-011] John Taylor - Ontario Mutual Insurance Association
Please find attached OMIA's Submissions.
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| Cross Sector | [2024-011] Danielle Russell - Canadian Defence Lawyers
Submitted on behalf of Canadian Defence Lawyers |
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| Auto Insurance | [2024-011] Lisa McGowan - Private Practice
When I initially started as a private practitioner I incorporated as I was unsure of how my practice would play out. Unfortunately, it would be more cost effective for me to be a private practitioner and dissolve my corporation. Through HCAI there is a seamless way to go from Sole practitioner to a corporation, but there is no way to go from corporation to sole practitioner. This needs to be addressed as the fees and hassles associated with opening a new HCAI account as a sole practitioner is unnecessary. |
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| Auto Insurance | [2024-011] Lisa Bauer - Knorr and Associates Inc
I am writing to you as the owner of Knorr and Associates Inc., a company that employs registered nurses, (RN's), occupational therapists (OTs), speech-language pathologists (SLPs), kinesiologists, and rehabilitation support workers. With over 30 years of experience in this industry, I bring valuable insight into the challenges faced by health care providers, particularly regarding compensation under the Professional Services Guideline (PSG) rates.The PSG hourly rates have not been adjusted since 2014, despite the Consumer Price Index (CPI) increasing by 28% over the same period. In contrast, insurance companies have been allowed to raise their rates by 28–34% during this time. This disparity is inequitable, especially considering the critical role health care providers play in delivering essential services to motor vehicle accident (MVA) clients. The PSG rates are intended to be all-inclusive, covering not only professional wages but also the significant overhead costs that have dramatically escalated in the last decade. For comparison, rates paid by other payer systems are significantly higher, highlighting the need for a review and adjustment of the PSG rates. Additionally, MVA rehabilitation work requires a broader scope of expertise and a higher, more expensive skill set than other health care contexts. This complexity necessitates ongoing professional development and training, further increasing costs. Moreover, the Financial Services Regulatory Authority (FSRA) licensing system adds another layer of administrative and financial burden unique to this sector, on top of the compliance requirements set by our respective colleges. It is deeply concerning that health care providers, whose roles are more essential than ever due to earlier hospital discharges, have not received a rate adjustment in over a decade. What other profession has faced such stagnation in compensation while being expected to absorb rising costs and increased responsibilities? I respectfully urge the government to revisit and adjust the outdated PSG rates to reflect the increased cost of living, overhead expenses, and the high demands placed on health care providers in the MVA rehabilitation sector. Fair compensation is not only a matter of equity but also essential to sustaining the vital work we do. Thank you for your time and consideration. |
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| Auto Insurance | [2024-011] Laurie Davis - Ontario Rehab Alliance
To Whom It May Concern,Please see attached for the Ontario Rehab Alliance's (ORA) submissions regarding the consultation on Auto Reform. We have prepared a response for each of the three consultation papers. We welcome the opportunity to discuss our responses further and can be reached at the contact details listed on our submission papers. Sincerely, Laurie Davis Executive Director Ontario Rehab Alliance |
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| Auto Insurance | [2024-011] Rosemary Alexander - Swanson & Associates
I am a nurse case manager and have worked with catastrophically injured clients due to motor vehicle accidents for the past 30 years. I would like to address several important points1. Why is it that registered nurses and regulated social workers can not sign their own treatment plans? Why must these be co-signed by OT, PT, etc. 2. Having worked in this field prior to the implementation of HCAI and OCF18s, I believe these systems have not improved service delivery. I find it perplexing that a system cannot be established, similar to that of extended health benefit carriers, where clients can simply submit invoices, receive direct deposits, and enable pharmacies to bill directly. 3. I agree with many others who have submitted comments here regarding the rates for services, both the zero increase in 10 years, and how far below these are from rates covered elsewhere. Case in point, in Ottawa, most, if not all the excellent psychologist and psychology offices are no longer offering services to HCAI clients. This has made it extremely hard as a case manager to find appropriate and timely care, causing increased suffering and longer recovery for those who need it most and their families, who end up bearing these burdens and become broken themselves. I have seen many colleagues leave this field to find work with better pay with less hassle of paperwork, where their professional contributions are valued and their recommendations for client needs are not continually questioned. There are some excellent adjusters out there, who have found a way to work the system to the client’s benefit and to work with the therapist to find solutions, when the system has put up barriers rather than bridges for their recovery. Those who have the power to do good within a complex system, and find ways of doing so. But more and more, the policy is being used as a barrier, the forms to simplify the lives of the insurance rather than the life of the claimant and the power to deny and delay is too much in the hand of those who have never met or understood the claimant in need or the recovery processes. All along, our work as case managers, to fill the gaps, to coordinate the care, to work within this system, has become more complicated, requiring more line-by-line rationale and advocacy. And then we are told we will not be paid for this “cost of doing business”. The climate for claimants is not that of care and support for which they thought they were paying for benefits. It is more difficult than it should be, it is more difficult than it needs to be. We need to find a way to compensate and treat professionals properly, find ways of making the service more accessible and usable for those who work in it and need it. |
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| Auto Insurance | [2024-011] Abilities OT - Abilities Rehabilitation Services
Please see our attached letter in response to the request for consultation. Thank you. |
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| Health Service Providers | [2024-011] ronald david kaplan - kaplan and levitt
It is my pleasure to submit three separate documents to you on behalf of the Ontario Psychological Association in response to the three FSRA consultation papers. Thank you for this opportunity to provide our input. Please feel free to contact me if you would like any further information or clarification. Ron Kaplan, Ph. D., C. Psych. |
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[2024-011] Ruth Wilcock - Ontario Brain Injury Association
Please find attached a letter from the Ontario Brain Injury Association (OBIA). We appreciate the opportunity to provide input on the Financial Services Regulatory Authority of Ontario’s (FSRA) review of the health service provider guidelines and frameworks.We asked our constituents for feedback on the proposed changes by FSRA, and we are including their responses. The following comments and statements have been shared by some of our constituents, offering valuable insights into the challenges and impacts of brain injury recovery within this context. For full transparency, OBIA committed to forwarding all feedback to FSRA without filtering or alteration. Please note that these submissions reflect the personal experiences and viewpoints of the contributors. |
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| Auto Insurance | [2024-011] Angie Cunningham - Lawlor Therapy Support Services INc
Please see my letter attached detailing the concerns and comments that I have as provider of Rehabilitation Support Services. Thank you for your consideration |
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| Property and Casualty and General Insurance | [2024-011] Amanda Dean - Insurance Bureau of Canada
Please see attached IBC's submission in response to the Statutory Accident Benefits Schedule (SABS) Guidelines Review. If you have any questions, please do not hesitate to reach out. Thank you. Amanda Dean |
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| Property and Casualty and General Insurance | [2024-011] Amanda Dean - Insurance Bureau of Canada
Please see attached IBC's submission in response to the Health Service Provider (HSP) Framework Review. If you have any questions, please do not hesitate to reach out. Thank you. Amanda Dean |
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| Auto Insurance | [2024-011] Ralph Palumbo on behalf of the Access to Justice Group
Attached is the submission by the Access to Justice Group to FSRA's consultations on the Attendant care Guideline. Regards, Ralph Palumbo |
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| Health Service Providers | [2024-011] GREG MORE - Rehab First Inc.
Please find attached Rehab First's submission |
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| Health Service Providers | [2024-011] Sarah Hutchison - Ontario Physiotherapy Association
Dear Mr. Glen Padassery, Please see the attached submission from the Ontario Physiotherapy Association in response to the consultation on auto reforms (2024-011). We thank you for the opportunity to provide this feedback and hope to engage in ongoing collaborative efforts around auto sector reformations. |
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| Health Service Providers | [2024-011] Alice - Rmt
It's unbelievable that the insurance company should be allowed to pay such low fees to the people treating their clients, yet they pay absornomical fees for reports.$3500 goes now where these days. Especially with Ontario health care system. There is such a delay and so many non knowledgeable physicians what do not know how to treat accident patients, physically, mentally or full in reports or keep good notes. I treat so many clients that went thru the MIG with not good results and I get them feeling better in a few treatments. |
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| Auto Insurance | [2024-011] Joanna Liang - Geronimo Occupational Therapy
Healthcare providers are not being reimbursed for their time while operating under the current HSP rates, which have been stagnant since 2014. It is important to highlight that Ontario's minimum wage has increased just over 56% since 2014; however, current HSP rates remain the same. It is imperative that these rates be reviewed to take into consideration the current economy. |
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| Auto Insurance | [2024-011] Amanda Dean - Insurance Bureau of Canada
Good Afternoon,Please see the Insurance Bureau of Canada's submission on the Health Claims for Auto Insurance System Review. If you have any questions on any of our commentary please don't hesitate to reach out. Amanda Dean, Vice-President, Ontario & Atlantic Canada Insurance Bureau of Canada |
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| Health Service Providers | [2024-011] Eric Jackson - London Chiropractic and Massage
• Inadequate Reimbursement Rates: Current fee schedules often do not adequately compensate healthcare providers for the time, expertise, and resources required to treat complex MVA injuries. This can lead to financial strain on clinics and potentially limit access to care for patients.• Complex and Time-Consuming Administrative Processes: The administrative burden associated with MVA claims can be overwhelming. Lengthy claim processing times, complex documentation requirements, and frequent communication with insurance companies divert valuable time and resources away from patient care. • Delayed Payments: Delayed or denied claims from insurance companies can cause significant financial hardship for healthcare providers. This can lead to cash flow problems and difficulties in maintaining staff and operations. • Patient Complexity: MVA injuries often involve complex conditions that require specialized care and ongoing treatment. The complexity of these cases can increase the time and resources required to provide adequate care. To streamline claims processing and reduce administrative burdens, FSRA should consider the following: • Simplified Claim Forms: Develop standardized, user-friendly claim forms that minimize the amount of paperwork required. • Automated Claim Processing: Implement automated systems to expedite claim processing and reduce manual intervention. • Clear and Timely Communication: Improve communication between healthcare providers, insurers, and the FSRA to minimize delays and misunderstandings. • Faster Payment Processing: Implement measures to expedite payment processing, such as electronic funds transfer and streamlined payment systems. • Standardized Fee Schedules: Develop clear and consistent fee schedules that accurately reflect the complexity and value of healthcare services provided to MVA patients. To ensure fair compensation for healthcare services, the SABS guidelines should be updated to: • Increase Reimbursement Rates: Adjust fee schedules to reflect the increased costs of providing care, including inflation and technological advancements. • Expand Coverage: Expand coverage to include a wider range of treatments and therapies, such as physiotherapy, chiropractic care, and massage therapy. • Streamline the Appeal Process: Simplify the appeal process for denied claims to reduce delays and administrative burdens. • Regular Review and Updates: Establish a mechanism for regular review and updating of the SABS guidelines to ensure they remain relevant and responsive to the evolving needs of MVA patients. To ensure continued access to quality healthcare services, FSRA should: • Promote Collaboration: Foster collaboration between healthcare providers, insurers, and government agencies to facilitate efficient and effective care delivery. • Support Patient Choice: Allow patients to choose their healthcare providers, ensuring access to a diverse range of services and expertise. • Monitor Access to Care: Regularly monitor access to care for MVA patients and take steps to address any barriers or disparities. • Invest in Healthcare Infrastructure: Support investments in healthcare infrastructure, such as clinics and hospitals, to ensure adequate capacity to meet the needs of MVA patients. By addressing these concerns and implementing these recommendations, FSRA can help ensure that MVA patients have timely access to high-quality care and that healthcare providers are adequately compensated for their services. |
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| Auto Insurance | [2024-011] Dave Gaylor - Acquired Brain Injury Survivor Solutions (ABISS)
ABISSAcquired Brain Injury Survivor Solutions PO Box 1650 Wingham, Ontario N0G 2W0 abiss.ca November 26, 2024 Financial Services Regulatory Authority of Ontario 25 Sheppard Avenue West, Suite 100 Toronto, Ontario M2N 6S6 RE: Auto Insurance Reform Consultation Paper – Statutory Accident Benefits Schedule (SABS) Guidelines Review (PSG) ABISS is a non-profit, entirely volunteer group of brain injury survivors. While we were initially formed as a social/support group by our speech language pathologist, we soon became involved in advocacy and a desire to improve the outcomes for others who were facing the same difficulties that we had. We have been advocating for auto insurance fairness and reform since 2017 and have conducted research, collaborated with other groups, met with FSRA, MPP’s, and other stakeholders. Although all of our stories are unique we share the devastation of brain injury, the challenge of rehabilitation, and the even more painful hurdles of managing the auto insurance system. It’s a combative/adversarial system run by insurance companies who are profit driven and seemingly disinterested in your recovery. Most of us want nothing more than to put our lives back on track after facing a traumatic, life-changing injury. We want to do the physiotherapy, see the specialists, the counsellors, whatever is recommended but when you must be a claimant with your auto insurer you are not treated with respect or an effort to help but rather with suspicion. 1. Independent Insurer Examinations The first problem is the relentless number of independent insurer examinations. The boxes of medical records you have from qualified experts, accountable to their respective licensing bodies, detailing the severity of your injuries and recommended care seem to be disregarded in your claim and you have to be retested over and over again by insurance company representatives. These tests are often long distances from home, requiring travel and sometimes overnight stays. The test administrator’s job is to prove that you do not have the disabilities that your doctors and therapists have said you have. Everything is geared towards the insurance company having to pay the least amount of money and everything is a trial. There is no consideration for the exhaustion, confusion and stress that is being felt by the person with an injury. For people with brain injuries like ourselves, this is particularly difficult due to pain, fatigue, cognitive and communication challenge, overwhelm, anxiety and disruption from our regular routines. Independent lawyer and psychologist examinations Privacy? The emotional impact of dealing with severe injury is very consequential. After leaving the hospital along with trying to physically recover you may be facing the loss of your job, your memory, your balance, your communication skills, your marriage or even your personality. Having to be interrogated by lawyers and psychologists about things that have no bearing on the cause of your injury puts severe strain on you emotionally. Many are asked intimate details about themselves or their family members all in an effort to dredge up other reasons for our difficulties than our diagnosed brain injuries. We have seen people interrogated about their divorces, a sibling’s dementia, menopause, the loss of a child, a parent’s stroke, or other traumatic events, all to discount the brain injury. This is an invasion of your privacy that, even without the trauma of a brain injury, would be an affront. Our right to privacy apparently does not apply to the insurance companies and there are no boundaries as to what they can ask you. Your entire family doctor records are copied and shared with a team of professionals and if you deny consent they deny treatment. 2. Adding Insult to Injury When you are facing the possibility of the loss of your job, your social life, or school, and you and family are struggling with the emotional damage brought on by your injuries, you are facing a long road to rebuilding your life, which is not going to look like your old one. You should not also face being interrogated as you literally struggle to hold everything together. Once your emergency care is finished you are forced to enter the nightmare of having to constantly prove that you are not faking your injuries by an industry driven by profit alone. We have no choice but to pay for insurance but that support does not go both ways as insurers have a choice not to pay. Even after running the gauntlet to have care approved, it’s often denied. 3. Catastrophic - Non-Catastrophic Whether or not an injury is catastrophic has a huge bearing on how much coverage you are entitled to. There are several problems with the catastrophic designation. First, the initial severity indicators such as the Glasgow Coma Scale Score or evidence of CT and MRI scan findings are inadequate determinants of brain injury and its potential lifelong effects. Second, a quick one day evaluation by insurer hired health professionals in a clinic setting is an unfair and inaccurate measure of the long term impact of a brain injury on your daily functioning, independence, social participation, physical wellbeing, need for supports, and ability to return to work or school. Catastrophic Determination should be based on the ongoing evaluations of your treating healthcare team or at least an objective multidisciplinary team with community based (not hospital) expertise. 4. David versus Goliath We hear all the time from the government about what they are doing to fix the problems with the auto insurance industry, yet still do not see an interest in solving the main issue that we have been trying to highlight, which, is support for the person with traumatic injuries. The claim of fraud prevention must not be used as a scapegoat for putting legitimate claimants’ health and welfare at risk by denying or making extremely difficult the coverage they receive. There is a lack of accountability for the practices of insurance companies. Auto insurers who create unfair barriers to care cause suffering to injured auto insurance claimants, who through no fault of their own need to seek compensation. The insurance industry has the privilege of providing a service that people must subscribe to if they wish to drive a car. They have been well paid to provide this service and they must be held accountable for doing that. 5. Research Reveals Unfair Insurance Practices for Brain Injury Survivors Across the Province ABISS participated in a study conducted by McMaster University entitled, Survey of Auto Insurance Claims Process for Individuals with Communication Disorders After Traumatic Brain Injury (Hou et al., 2023). The published paper is attached and highlights many of the consumer challenges we have underscored above. FSRA has always indicated that a main priority has been improving outcomes for consumers of the products they regulate. It is in fact the first priority in your recent publication on 2025—2026 statement of priorities and budget, reproduced below: 1. Strengthen Stakeholder Relations and Improve Consumer-focused Outcomes: To effectively carry out its mandate, FSRA will improve relationships with its stakeholders, with an emphasis on improving outcomes for consumers. This includes understanding and advancing the voice of all consumers, enabling innovation in FSRA’s regulated sectors, and ensuring FSRA is accessible, supportive and responsive to stakeholders. We created a list of recommendations for insurers based on our research. We strongly recommend that the attached study and recommendations be reviewed and considered in achieving this stated priority. We are also aware of the important submission made recently to you regarding auto insurance reform by the Ontario Brain Injury Association (OBIA) and are fully supportive of the points made there. Thank you to the Financial Services Regulatory Authority for reaching out for feedback and we trust you will fully consider this submission in your efforts to improve consumer-focused outcomes. Yours sincerely, Jackie Cribb Dave Gaylor Sheila MacDonald Sheila OReilly Deanna Pelino Ashley Tindall Julie Wynen Members of ABISS |
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| Health Service Providers | [2024-011] Anthony Grande
Please find attached my submission- Here’s a copy of my consultation document and my impressions of Ontario auto insurance.Ontario’s auto insurance premiums will never decrease unless the system itself is re-evaluated with a LEAN approach. - which isn’t happening. - this is not a claims volume issue, it is bureaucracy gone wild. The current structure is overly complex and costly, only benefiting insurers who must justifiably pass administrative expenses onto consumers with a profit margin. These systemic costs — healthcare licensing, dueling assessments, LAT, HCAI, and complex invoice processing due to work benefit coordination — increase system burden and limit new insurance market entrants, leading to consolidation, and an increased government reliance on existing insurers. When individuals seek benefits after an accident, the inadequate Minor Injury Guideline (MIG) often restricts availability of appropriate care. With about 80% of claims forced into the MIG, this misclassification leads to delays and inadequate treatment. While these cases drag on, often for years, they grow in liability and injuries that could have been resolved with sufficient care are left to worsen. Many cases are removed from MIG status after extended LAT disputes, by which point the original injuries have often become chronic, adding indefinite costs to the system. These costs are then passed onto consumers, compounding annually, ensuring that premiums continue to rise. This system that makes claims worse and where costs are pushed years down the road also affects ratemaking. Rates are submitted yearly, fails when the system itself creates additional costs by prolonging or exacerbating injuries. In essence, premiums are inflated not just by the injuries resulting from accidents but by the delays and frustrations caused by the claims process itself. As it stands, only existing insurers benefit from the system’s complexity, which strengthens their hold on the market and provides justification for continual price increases. Much like the challenges seen with the landlord-tenant board, system participants are ultimately bearing the cost of a poorly designed system. The current Canada Post strike has also highlighted another flaw in this system, HCAI has no electronic payment delivery method unlike every other claims submission portal. Thank you. Best regards, Anthony |
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| Auto Insurance | [2024-011] Aimee Hayes - Hayes Dietetic Professional Corporation
I have been working in the Auto Insurance industry as a business owner and healthcare provider for over 20 years. I have experienced several industry and legislative changes throughout the years but have never been more concerned with the state of the industry as I am today. We are seeing many highly skilled health professionals leave the industry due to poor wages, highly complex patient care and high administrative burden. From my perspective, I would prioritize the following:1. Increase compensation rates under the Professional Fee Guidelines Compensation rates under the Professional Fee Guidelines have not increased in a decade, while inflation has increased significantly. Inflation is cited as the reason for the increase in insurer premiums (despite reduced claims). The same logic should apply to health care provider rates. Highly skilled healthcare professionals are leaving the industry due to poor wages combined with increased administrative costs. Include Registered Dietitians in the Professional Fee Guidelines. Registered Dietitians are an integral part of a rehabilitation team. They play a critical role in optimizing recovery and improving outcomes. Registered Dietitians are governed by the College of Dietitians of Ontario, regulated by the Regulated Health Professionals Act. Registered Dietitians are currently listed in the Professional Fee Guidelines. This results in confusion about fair compensation rates between insurers and providers. Without this clarification, insurers often default to “unregulated rates” which is grossly insufficient and essentially denies access to this important treatment. Eliminate Health Service Provider Licensing Healthcare professionals are regulated by their respective Colleges. The Health Service Provider Licensing framework adds significant financial and administrative burden. It is redundant and the resources should be reallocated to more effective fraud reduction strategies. |
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| Health Service Providers | [2024-011] Amber Kosubovich - Waterdown Physiotherapy
I participated in the webinar and read over the documents. The fee schedule needs to be updated immediately to reflect increasing costs. Many clinics are not registering with FSRA or taking patients injured in an MVA due to the complexity of the cases, the burden of paperwork and the cost of registration. Clinics should be directed to immediately stop billing extended health benefits prior to billing through HCAI for SABS patients. Those patients may need those benefits for other non-MVA related treatments and should not be penalized in this way. Other documents such as OCF 1 & OCF 3 should be able to be uploaded through HCAI. There should not be "preferred providers" with auto insurance companies. This does not promote patient choice. Patients often feel obligated to go where their adjuster is recommending. The blocks in the MIG are not always appropriate. It should be based on per session fees within the allotment for the MIG, which needs to be raised from $3500. This allows for better planning rather than trying to have more visits at the beginning which is not always beneficial or possible. |
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[2024-011] Sue Bremner
The letter from obia speaks to the struggles I had with funding. I didn’t understand fully that I had a brain injury and the things I was experiencing. It took a team of people who worked with me and helped me improve and develop tools and systems in order to function. I was so overwhelmed by the process and the repeated need for paperwork. The financial thresholds were impeding my care. A Brain injury is so difficult to experience. The thresholds just made it harder to receive care in a timely organized manner. |
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| Auto Insurance | [2024-011] Elaine McKinnon - Encompass Neuropsychological Services
I worked within the MVA injury sector for over 2 decades. I am very discouraged by what I have seen as a systematic dismantling of effective, coordinated patient care. This has been manifested as repeated denials of treatment, which is disruptive to recovery and sets patients back in terms of their overall psychological adjustment after their injuries. There have been denials of team meetings where the coordination of treatment between professionals ensured optimal care plans. Of particular concern are the arbitrary caps on assessment fees and treatment fee guidelines that have not increased in a decade. What industry would expect professionals to work for the same rate over 10 years, while the costs of providing such care increase every year? This strategy has effectively driven out the most experienced practitioners who have the most to offer patients in their recovery. Moreover, this has reduced choice and access to appropriate care for claimants. It is also frankly disingenuous; insurance companies have no rightful claim to putting the well-being and recovery of their claimants as a priority given such practices. I have left the insurance sector for the reasons above. A review of the Health Service Provider framework is certainly overdue. Insurance companies need to be held more accountable to the consumers in Ontario. They must also be guided to deal fairly with health service providers by providing fee guidelines that are in keeping with the current marketplace for such services (with annual reviews and adjustments) and to support treatment pathways that have known benefits to injured parties so as to optimize recovery. |
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| Health Service Providers | [2024-011] jack Jack Shapiro - Speech Therapy Centres of Canada Ltd
Subject: Urgent Need for Updates to the FSRA GuidelinesAs Speech-Language Pathologists who work with individuals who have sustained injuries in motor vehicle accidents, we are aware of the critical need for updates to the Professional Services Guideline. These updates are not only necessary but also long overdue. The rates suggested by the Financial Services Regulatory Authority (FSRA) have become untenable. Over the past 20 years, inflation has not been considered, making it impossible to offer services at the current rates. Without adjustments, the quality and availability of care are at risk, impacting both professionals and clients. It is imperative to remove specific rates from the Professional Services Guideline. Allowing professionals to charge market rates will ensure that services remain viable. This approach empowers clients to assess the reasonableness of fees and choose providers based on value and quality of care. Thank you for taking the time to consider our feedback. We hope these crucial updates will be implemented, ensuring better outcomes for professionals and the individuals we serve. |
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| Health Service Providers | [2024-011] Aaron Lightstone - Music Therapy Toronto
Message likely easier to read in the attached PDF. But it is copied here as well. ___________________________________________________________________________________ I am a Registered Psychotherapist and Neurologic Music Therapist with 26 years of clinical experience. For the past eleven years, I have worked as a Health Service Provider (HSP) in the auto-insurance sector. Thank you for the opportunity to share my observations on the challenges within this system which urgently requires attention and reform. 1) Professional Rates It is unacceptable that most health professionals working in this sector have not been allowed to increase their rates in over 10 years. While most of us have our rates firmly set by the Professional Services Guideline (PSG), some of us—like myself as a Registered Psychotherapist (RP) —are subject to the discretion of individual adjusters. The need to negotiate a new rate ( and create different versions of individual practitioners with different rates in HCAI, is an unreasonable administrative burden). This creates inconsistencies and inequities: • Some/most adjusters approve treatment plans at my current rate. • Other adjusters insist on arbitrary rate reductions (e.g., $0.08/hour, $15/hour, or even insisting that I work for less than half my standard rate, if they are to approve the treatment plan). This untenable situation is exacerbated by unprecedented inflation and post-pandemic burnout in the healthcare sector. For a regulatory body like FSRA to enforce stagnant professional rates for a decade is unsustainable and deters qualified professionals from remaining in this field, which ultimately impacts patient outcomes. 2) Insurance Maximum Payouts for Medical Rehabilitation Over the past decade, costs associated with medical rehabilitation ( other than professional fees) have risen, yet: • Maximum payouts for claimants ($1 million or $2 million, depending on coverage) remain unchanged. • HSP professional fees have been stagnant. • Insurance companies, however, have been allowed to raise premiums by 34.5%. This double standard is glaring. In 2018, the Conservative government promised system reforms and premium reductions. However, the changes merely allowed optional reductions in catastrophic coverage limits (e.g., from $2 million to $1 million), shifting risk to consumers who were often unaware of the potential long-term costs of rehabilitation. Insurance companies have teams of actuaries and access to extensive data, while consumers lack this expertise. This underscores why regulators must prioritize the interests of consumers over corporate profits. 3) Inadequacy of Catastrophic and Non-Catastrophic Categories The distinction between catastrophic (CAT) and non-catastrophic (non-CAT) injuries does not align with the lived experiences of many patients: • The $65,000 non-CAT threshold is inadequate for many patients (who don’t meet the CAT criteria) requiring extensive rehabilitation. • A significant gap exists between $65,000 and $1 million. Patients frequently exhaust their non-CAT coverage before being designated as catastrophic, leading to delays in essential care. Many patients don’t meet the criteria for CAT, but exhaust their med-rehab benefits long before their rehabilitation is complete. Why is there not a middle category with $300K of med rehab available? Additionally, PSG rates differ for CAT and non-CAT cases. This is counterintuitive: • In my 26 years, I have never encountered another healthcare sector where hourly professional rates vary based on injury severity. • HSPs should be compensated for more complex CAT cases, but this happens because we incur more billable hours when working on CAT cases. Greater compensation for more complex cases comes from more time spent on those cases. Paying HSPs less for non-CAT cases creates a disincentive to working on those cases. If the distinction in rates is maintained however then, the non-CAT funding cap urgently needs a substantial increase, and PSG rates should be immediately and substantially adjusted to attract qualified HSPs to this sector. 4) Inefficiencies of the HCAI Platform The HCAI platform is outdated, inefficient, and poorly designed, and very awkward to use. This places unreasonable administrative burdens on providers, claimants, and adjusters. Key issues include: • Claimants and providers cannot sign OCF-18s directly within the platform, requiring time-consuming external processes. • Providers have no way to view remaining claimant rehab funds, leading to wasted resources when treatment plans are submitted on exhausted accounts. • There is no direct communication channel (e.g., a messaging system) between adjusters and HSPs within HCAI, which could reduce delays and errors. Modern technology offers solutions that HCAI has failed to adopt. A redesigned platform could: 1. Allow claimants to log in, review, and sign OCF-18s electronically. 2. Enable team members and claimants to see how much of a claimant’s rehabilitation funds remain. This is especially important with non-CAT cases. 3. Facilitate secure messaging between adjusters and providers (similar to how the CRA portal works and communicates with tax payers) and providers and claimants. 5) Barriers to Accessing Qualified Providers HCAI inefficiencies, below-market PSG rates, and administrative hurdles deter excellent providers from working in the auto-insurance sector. This limits access for claimants and prolongs wait times, particularly for essential independent evaluations, which of course then had an adverse impact on patient outcomes or at least delays the rehabilitation process thus increasing health care costs. For example, one of my pediatric clients with significant injuries has been waiting eight months for a neuropsychological assessment required for catastrophic designation. This delay, caused by a lack of available providers, has halted critical treatments. The entire treatment team is waiting for a CAT assessment to take place so that treatment can resume. The adjuster has been looking for a neuropsych assessor to do the assessment for 8 months. 6) Challenges in Treatment Plan Approvals and Redundant Regulatory Burden I am a Registered Psychotherapist and certified Neurologic Music Therapist (NMT) with advanced training (including a masters’ degree) and 26 years of clinical experience. I frequently encounter adjusters who: • Admit to knowing little or nothing about NMT. • Approve treatment plans inconsistently or delay them by sending plans for Independent Examinations (IEs). They say that they cant approve a treatment plan when they know nothing about the treatment program ( despite the fact that I always provide them with a substantial introductory and information package). This is unjustifiable when treatment plans are referred by regulated professionals (e.g., PTs, OTs, SLPs, MDs) and supported by the patient and their team. Adjusters without medical or rehabilitation training should not have the authority to veto plans for evidence-based, regulated therapies like NMT. As a Registered Psychotherapist my ethical and professional conduct is already regulated by the CRPO, the other HSP on the treatment team who referred the patient to my services are PTs, SLPs, OTs and MDs, who are also regulated by their regulatory colleges. If any of us are acting improperly or unethically our regulatory colleges are ready to receive complaints and to follow up with appropriate discipline. Why do the insurance companies need another layer of expensive regulation ( money that could be better directed to patient care) ? This often results in significant delays to patients accessing needed rehabilitation services. Delays in accessing necessary treatments negatively impact patient recovery and further strain the system. This additional layer of regulation is costly, redundant, and detracts from patient care. Further, it seems that individual adjusters are given the authority and great discretion to interpret FSRA rules and regulations and their company policies. For example, I have submitted a treatment plan to an insurance company and it is approved with no problems, then an other plan for a different client at the same company is submitted for a client with a similar degree of injury ( but a different adjuster) who insists that my treatment plan will only be approved to match a rate that is in the PSG ( even though RPs are not listed in the PSG). There was a period two years ago when I sent several treatment plans to the same company. I was told that the plans would be approved if I worked for half of my regular rate, which I can not do, so my treatment was not available to those patients. Those patients might have had the plans approved with no issue had they been with a different insurer. This presents a huge equity issue for consumers, as most will choose insurance based on cost and costumer service during the purchasing process. Auto-insurance consumers in Ontario have no possible way to vet insurance companies on what is the most important metric. If someone is seriously injured and needs med-rehab did they choose an insurance company that will provide for their needs, or did they choose a company that puts up barriers to accessing their care. Sometimes this seems to vary from one company to the next but to make matters worse this sometime seems to vary from one adjuster to the next within the same company. This is the most important consideration in choosing insurance and Ontarians have no way to vet their insurance purchase in this regard. Conclusion The auto-insurance- health care- rehabilitation system urgently needs reforms to address: 1. Fair professional compensation. 2. Adequate rehabilitation funding for both CAT and non-CAT cases. 3. An additional injury category to bridge the huge gap between CAT and non-CAT cases. 4. The redundant regulatory burden that FSRA (and insurance companies – through unnecessary IEs) impose on HSPs that is already covered by our regulatory colleges. 5. Modernization, rebuilding of HCAI to reduce inefficiencies. 6. Barriers preventing timely access to qualified providers. 7. The unjustified and arbitrary power of adjusters to delay or deny evidence-based treatment plans, and to have large discrepancies between adjusters in how the rules are applied and interpreted. Thank you for considering this feedback. I hope FSRA will prioritize the needs of claimants and health service providers in these critical reforms. Sincerely, Aaron Lightstone MMT, RP, MTA, NMT-F Registered Psychotherapist and Certified Neurologic Music Therapist Music Therapy Toronto |
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| Auto Insurance | [2024-011] Kylie James - Koru Nutrition
I have been working in the mva industry for the last 24 years and over the most recent couple of years grown extremely frustrated with the regulatory demands, excessive admin tasks and the increasing non repsonsivess from adjusters as well as the increasing financial demands with running a business with no increase in fees to help offset this. I run a nutriton company and I have deititians, naturopath doctors and homepaths that are all regulated health professionals but despite the documentation and evidence that I show to the adjuster they continue to drop the rates to non regulated fee rates which is sometimes only a 1/4 of what there standard and regulated hourly rate is and identified by their regulated colleges. The adjuster refers to the FSCO fee guidlines which our extremely outdated and do not include our specific regulated heath profesionals. I am finding I am spending an excessive amount of time following up on adjusters to review these partial approvals and when they do not ammend the fees we often can not proceed with treatment and the client is left without receiving the service or the burden is taking on the by the laywers/client to protect the outstanding amount. I have seen clients deteriorate, adapt maladpative coping strategies, and mental health worsens when there are delays in care or they do not receive the services they require. This can result in seocnday health complications arising (that could have easily been avoided if treatment/fees were approved). In turn this places increase stress and demands on an already burdened OHIP health care system. I have also been tracking approvals and denials on hcai and the denial rates have significantly increased over time. Not only that the denials for the time for plan service and reduced/denied travel time which makes our ability to provide quality care to individuals with various and often complex cogntiive, physical and emtional issues challenging. Plan service is the time we need to coordinate with the rehab team, educate rehab supprt workers of the client goals, brain storm challenging situations with the tretament team, call the adjuster, and get support from other treatment team providers and their expertise (strategies from SLP on how to best communicate with the client). In regards to nutrition specifi plan service tis includes ordering supplements, creating meal plans, recipes, and supplement schedules, liaise with family members on meal prep/nutrition goals, make recommednations for other health professionals or specialists, create handouts and resources for the clients to refer back to etc. This can all take signicficant amount of time. Adjusters often indciate that "plan servcie" should be part of our tretament time but as part of the audits they have advised us that the client needs to sign in and out of our treatment sessions so if we include for example devloping a meal plan oustide of the direct time with the client but bill it as direct client time then this looks like we are engaged in faudulent billing. So not sure what we are actually supposed to do. Given that there is a code for plan service on HCAI the autosector obviously acknowledges that clinicians do need non direct client time to work effectibely with their clients. Also given the recent postal strikes setting up payments electronically from insurance companies to the rehab companies and health professionals is also well over due. Thanks Kylie James Clinic Director |
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| Health Service Providers | [2024-011] Eric Jackson - London Chiropractic & Massage
• Inadequate Reimbursement Rates: Current fee schedules often do not adequately compensate healthcare providers for the time, expertise, and resources required to treat complex MVA injuries. This can lead to financial strain on clinics and potentially limit access to care for patients.• Complex and Time-Consuming Administrative Processes: The administrative burden associated with MVA claims can be overwhelming. Lengthy claim processing times, complex documentation requirements, and frequent communication with insurance companies divert valuable time and resources away from patient care. • Delayed Payments: Delayed or denied claims from insurance companies can cause significant financial hardship for healthcare providers. This can lead to cash flow problems and difficulties in maintaining staff and operations. • Patient Complexity: MVA injuries often involve complex conditions that require specialized care and ongoing treatment. The complexity of these cases can increase the time and resources required to provide adequate care. To streamline claims processing and reduce administrative burdens, FSRA should consider the following: • Simplified Claim Forms: Develop standardized, user-friendly claim forms that minimize the amount of paperwork required. • Automated Claim Processing: Implement automated systems to expedite claim processing and reduce manual intervention. • Clear and Timely Communication: Improve communication between healthcare providers, insurers, and the FSRA to minimize delays and misunderstandings. • Faster Payment Processing: Implement measures to expedite payment processing, such as electronic funds transfer and streamlined payment systems. • Standardized Fee Schedules: Develop clear and consistent fee schedules that accurately reflect the complexity and value of healthcare services provided to MVA patients. To ensure fair compensation for healthcare services, the SABS guidelines should be updated to: • Increase Reimbursement Rates: Adjust fee schedules to reflect the increased costs of providing care, including inflation and technological advancements. • Expand Coverage: Expand coverage to include a wider range of treatments and therapies, such as physiotherapy, chiropractic care, and massage therapy. • Streamline the Appeal Process: Simplify the appeal process for denied claims to reduce delays and administrative burdens. • Regular Review and Updates: Establish a mechanism for regular review and updating of the SABS guidelines to ensure they remain relevant and responsive to the evolving needs of MVA patients. To ensure continued access to quality healthcare services, FSRA should: • Promote Collaboration: Foster collaboration between healthcare providers, insurers, and government agencies to facilitate efficient and effective care delivery. • Support Patient Choice: Allow patients to choose their healthcare providers, ensuring access to a diverse range of services and expertise. • Monitor Access to Care: Regularly monitor access to care for MVA patients and take steps to address any barriers or disparities. • Invest in Healthcare Infrastructure: Support investments in healthcare infrastructure, such as clinics and hospitals, to ensure adequate capacity to meet the needs of MVA patients. By addressing these concerns and implementing these recommendations, FSRA can help ensure that MVA patients have timely access to high-quality care and that healthcare providers are adequately compensated for their services. |
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| Auto Insurance | [2024-011] Ninette Ibanez
Attached is my submission from a consumer’s perspective.As a general observation, the scope of FSRA’s consultation papers is focused only on the health practitioners’ business administration/operations, (i) creating cost burdens and resource challenges diverting from the appropriate care to injured accident consumers and (ii) reducing the pool size of available healthcare practitioners because the administrative burdens are disincentives. My submission raises the claim handling landscape as a prime contributor to a failed consumer outcome: that (Ontarian) consumers injured in auto accidents receive the care they need. The claim handling landscape foments barriers to consumers when accessing the benefits of the insurance policies they paid for. The substantial lack of recognition and acknowledgment by the industry, government and regulators results in continuing unfairness to vulnerable consumers injured in auto accidents. |
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| Auto Insurance | [2024-011] melanie flitt - Concept Physio
I believe PSG rates should be indexed (option A) based on the CPI. PSG fees should be reviewed every other year. I believed that the current PSG fee schedule is affecting consumers access to care as clinics are less likely to work with auto insurance clients with compensation well below what they are charging clients privately or through EHB. I have had difficulty referring clients to other clinics for this reason. I believe that PT and OT should be paid at the same rate as SLP providers. Why are SLP receiving almost 12% more for services when these allied health providers hold Masters degrees? |
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| Auto Insurance | [2024-011] Kim Teggelove - Aspirerehab.ca
The fees chedule should be updated to reflect the current costs of care, ensuring that highly qualified providers are interested in working within the auto insurance sector. Access to skilled and qualified care is especially critical for individuals living with complex brain injuries (who often sustained their injuries in motor vehicle collisions), as their recovery often requires specialized expertise and comprehensive support. Ensuring providers are fairly compensated will attract more qualified providers to the field, allowing consumers to get the high level of care necessary to regain independence and improve their quality of life. Establishing a mechanism to periodically review and adjust fees will help ensure that the system keeps pace with inflation and evolving care needs. |
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| Health Service Providers | [2024-011] Bobi Tychynski Shimoda - S.L. Hunter Speechworks
Hi there,I am writing to offer my commentary on the lack of increases in the fee schedule for allied health providers. Our Professional Association (OSLA/CASLPA) sets fee guidelines and the current FSCO SLP rate is nearly $100/hour less than our fee guideline allows for. Companies are barely able to survive in this climate and we are seeing many experienced practicianers leaving the field for more sustainable income streams. If this continues, this will compromise client care as the more experienced and skilled clinicians will have reduced motivation to work in this environment, based on the high costs of living, particularly in Ontario. Thanks -Bobi |
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[2024-011] Kayla Colling
As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue. First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. The Professional Service Guideline Fee Guideline is no longer compatible with market rates for professional services, causing many to leave the industry. Moreover, Regulated Professionals such as Social Workers and Psychotherapists are not currently listed, resulting in reduced rates for services at the insurer’s discretion. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. The $65,000.00 cap for non-catastrophically impaired clients does not suffice for serious injuries. Oftentimes this funding is exhausted within a year and there is a 1-year gap before an application can be submitted for catastrophic determination. The catastrophic determination cap should return to $2,000,000.00 as prior to 2016, again, the current amount of funding does not suffice to rehabilitate and support individuals with catastrophic injuries. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and real-time feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. Thank you for taking the time to consider this feedback. I am hopeful that these important updates will be implemented, ensuring better outcomes for both professionals and those we serve. |
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| Health Service Providers | [2024-011] Laura Paulin - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Vino Xavier - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Stacey Bergman - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Ramann Gill - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Pooja Joshi - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have. Thank you for your consideration. |
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| Health Service Providers | [2024-011] Lindsay Gaspar - Personal Injury Occupational Therapy
Please see my letter attached detailing the concerns and comments that I have.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Maike McCaskell - Personal Injury Occupational Therapy
Please see my letter attached detailing concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Lisa Martin - Personal Injury Occupational Therapy
Please see my letter attached detailing concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Karen Forse - Personal Injury Occupational Therapy
Please see my letter attached detailing concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Arvinder Gaya - Personal Injury Occupational Therapy
Please see my letter attached detailing concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Health Service Providers | [2024-011] Amaresh Parikshya - Personal Injury Occupational Therapy
Please see my letter attached detailing concerns and comments that I have as an occupational therapist.Thank you for your consideration. |
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| Auto Insurance | [2024-011] Sandra Weaver - Innovative OT
As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue. First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. The Professional Service Guideline Fee Guideline is no longer compatible with market rates for professional services, causing many to leave the industry. Moreover, Regulated Professionals such as Social Workers and Psychotherapists are not currently listed, resulting in reduced rates for services at the insurer’s discretion. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. The $65,000.00 cap for non-catastrophically impaired clients does not suffice for serious injuries. Oftentimes this funding is exhausted within a year and there is a 1-year gap before an application can be submitted for catastrophic determination. The catastrophic determination cap should return to $2,000,000.00 as prior to 2016, again, the current amount of funding does not suffice to rehabilitate and support individuals with catastrophic injuries. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and real-time feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. Thank you for taking the time to consider this feedback. I am hopeful that these important updates will be implemented, ensuring better outcomes for both professionals and those we serve. |
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| Cross Sector | [2024-011] Stephanie Anglin - Innovative Occupational Therapy Services
As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue. First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. The Professional Service Guideline Fee Guideline is no longer compatible with market rates for professional services, causing many to leave the industry. Moreover, Regulated Professionals such as Social Workers and Psychotherapists are not currently listed, resulting in reduced rates for services at the insurer’s discretion. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. The $65,000.00 cap for non-catastrophically impaired clients does not suffice for serious injuries. Oftentimes this funding is exhausted within a year and there is a 1-year gap before an application can be submitted for catastrophic determination and as such I advocate for the amount to be increased to improve the health outcomes of people involved in motor vehicle accidents. The catastrophic determination cap should return to $2,000,000.00 as prior to 2016, again, the current amount of funding does not suffice to rehabilitate and support individuals with catastrophic injuries. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and real-time feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. Thank you for taking the time to consider this feedback. I am hopeful that these important updates will be implemented, ensuring better outcomes for both professionals and those we serve. |
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| Health Service Providers | [2024-011] Nick Gurevich - FunctionAbility Rehabilitation Services
Please find attached my submission with respect to consultation on the PSG. |
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[2024-011] Tyler Jensen - Ontario Bar Association
Please accept the enclosed as the Ontario Bar Association's submission. |
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| Auto Insurance | [2024-011] Lisa Carter
I am an OT that has been working in the auto sector for over 15 years. I find it shocking that we have not had a rate change in over 10 years, in addition to removing mileage from providers several years ago. There is a massive shortage of OTs in this sector and we are doing very important work that can impact the lives of these accident survivors. We are using our own cars and gas to visit clients in the community. Adjusters are often denying OCF 18 form fees, indirect treatment time and shortening our recommended service time that is making our service delivery very difficult- as we have need to follow COTO guidelines and they are often not giving us time to do it. Many companies are moving away from auto as it becomes increasingly difficult to navigate- leaving the sector short staffed in general for OTs. Clients are having to wait longer for services as a result. Please consider increasing our rates- as ALL other sectors have had increases as per inflation over 10 years. Thank you. |
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| Auto Insurance | [2024-011] Neha Hasan Gill - Rehab First Inc.
As a professional working with individuals who have sustained serious injuries in motor vehicle accidents for the last ten years, I see firsthand the need for updates to the Form 1 Assessment, and the Professional Services Guideline. These changes are not only necessary but long overdue. Specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Restricted rates in PSG, that are outdated and not in line with inflation and cost of living, are driving health are professionals out of this industry. We face a concerning shortage which is resulting in delays of the required treatment for our severely injured clients. This risks prolonging clients' recovery process and placing an increased burden on the publicly funded healthcare system. |
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| Auto Insurance | [2024-011] SEN HOONG PHANG - Propel Physiotherapy
Hello, Over the course of my career as a Registered Physiotherapist, I have observed clinics, clinicians, and support persons move away from providing treatment to people who have been involved in a motor-vehicle injury. This ultimately limits the access to care that people in Ontario have and increases the wait times to be seen by institutions still servicing these types injuries. Ultimately, the fee schedule from FSRA for people involved in MVAs must be updated to reflect the current landscape and economy. |
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| Health Service Providers | [2024-011] Wanda Chen Registered Physiotherapist - Freedom In Movement Physiotherapy and Wellness
The College of Physiotherapists of Ontario ensures the standard of practice of physiotherapists in Ontario. There is no need for another regulator to overlook the quality of service physiotherapists provide for motor vehicle accident injuries. If a physiotherapist is not practicing according to the standard of practice, he or she should be reported to the College, which is equipped and mandated to protect the public with necessary procedures to ensure the standard of practice is followed. The expensive funding for independent assessments to double-check on physiotherapists' work and recommendations should be redirected to patient care. Sometimes patients need more time to recover and slowly transition back to working and normal daily chores. With proper support, patients can get stronger over time and avoid chronic pain or pain resurfacing. |
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| Auto Insurance | [2024-011] Jackie Sinkeldam - Eramosa Physiotherapy Associates
I listened to the most recent webinar. Following this webinar I have several follow up questions or comments:1. HCP fees need to be adjusted. They have not been reviewed since 2014. How do good quality clinics pay their HCP, when at the same time all other pay overhead is increasing. Why would we continue to see clients from this sector? The proposal to leave the fees the same should NOT be considered. We continue to loose HCP to "boutique clinics" that do not have this extra layer of paperwork. If the goal is to have great clinical care, the fees need to account for the extra time spent on paperwork so that we can appropriately compensation everyone involved. 2. It was suggested that clients ARE able to access HCP. I disagree. We are in 8 cities. MANY clinics in each city that we are in have opted out of HCAI because of HCAI fees and paperwork. We continue to service these clients after an automobile incident, however; evaluate whether it is worth the admin burden. The clinics that do NEED referrals are often the ones that continue, and not always the clinics with great clinical care. So Auto clients are NOT always getting the best care possible 3. When is the billing to Extended Health Insurance being dropped? This adds another layer of complexity 4. If FRSA is there to decrease fraudulent billing, is there data to suggest that they are finding fraudulent billing? Our audits are always a burden, and find minor admin issues, and not fraudulent billing. If there are resources to answer any of my questions, please send to my email thank you. |
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| Auto Insurance | [2024-011] The Injury Advocates
Please see attached discussion documents from The Injury Advocates. |
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| Auto Insurance | [2024-011] Miranda Mo - Miranda Mo & Associates
Summary of recommendations for the Consultation on auto reforms: As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue. First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and realtime feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. Thank you for taking the time to consider our feedback. We are hopeful that these important updates will be implemented, ensuring better outcomes for both professionals and those we serve. |
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| Health Service Providers | [2024-011] Kate Skeggs - Balance Rehabilitation
Summary of recommendations for the Consultation on auto reforms: As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue. First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and realtime feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. |
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[2024-011] Graeme Mitson - N/A
I support the suggestions made in the Injury Advocates document. |
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| Health Service Providers | [2024-011] Anthony Grande
Please find attached a submission: simply put Ontario’s auto insurance premiums will never decrease in the long term because the system is overly complex and costly to manage. High administrative expenses are always passed along to consumers with a markup and as a result benefit insurers high administrative costs for dispute resolution, invoicing and redundant licensing make it difficult for new companies to enter the market, leading to fewer players and increased consolidation. This reduced competition makes the government more dependent on existing insurers. Ontario and many Canadian Markets are dealing with increased consolidation as a result of these barriers to entry.When people try to access benefits after an accident, the hurdles and red tape involved can lead to greater frustration and even worsen injuries over time. Treatable injuries often become chronic due to delays and disputes, adding indefinite costs to the system that are difficult to control or predict. These added expenses are then passed on to consumers, always at a profit margin, ensuring that rates keep climbing. In the end, insurers are the only ones benefiting from this complexity, it strengthens their hold on the market and allows them to continually increase prices due to always increasing administrative costs. |
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| Auto Insurance | [2024-011] Sindhuja Ramasamy - greater toronto adjusters
Dear FSRA Team,I hope this message finds you well. My name is Sindy Ramasamy, and I have been working in the insurance industry, specifically in claims, for almost 8 years. With my experience in the field, I have observed various challenges that drivers, insurers, and regulators face, especially as the automotive landscape continues to evolve with the rise of electric vehicles, ride-sharing, and technological advancements. In light of these developments, I would like to propose several changes to Ontario's auto insurance policies, which may also be beneficial for consideration in provinces like Alberta, New Brunswick, and Nova Scotia. These changes would help modernize the insurance offerings to better serve today’s drivers and meet the demands of an evolving marketplace. Key Proposals for Auto Insurance Policy Updates: Expanded Coverage for Electric Vehicles (EVs): Battery and Charging Station Coverage: Given the increasing adoption of electric vehicles, policies should explicitly cover risks related to EV batteries, home charging stations, and potential malfunctions. Fuel Reimbursement (Electric Equivalent): With the growth of electric cars like Teslas, “Loss of Use” coverage should be updated to include fuel reimbursement, or its electric equivalent, during repairs. Ride-Sharing Endorsements: Comprehensive Ride-Sharing Coverage: As more drivers rely on ride-sharing platforms such as Uber and Lyft, a dedicated endorsement should be developed to provide clear coverage across all stages of a ride (e.g., waiting for passengers, driving to pickups, and transporting passengers). EV-Specific Policies for Ride-Sharing: As many ride-share drivers now use electric vehicles, tailored policies addressing the higher costs of repairs and availability of parts for EVs should be considered. Loss of Use Coverage Updates: Expanded Options for Alternative Transportation: Loss of Use coverage should include modern transportation alternatives, such as ride-sharing services and public transportation, in addition to traditional rental vehicles. Higher Cap for EV Rentals: Recognizing that renting an EV can be more expensive than conventional vehicles, policies should adjust their rental car reimbursement limits accordingly. Telematics-Based Insurance: Usage-Based Insurance (UBI): More widespread adoption of telematics could allow for premiums based on driving behavior, rewarding safe driving and reducing costs for infrequent drivers. Data Privacy Protection: With telematics comes the need for clear rules on data privacy to ensure that the personal information collected is used responsibly and transparently. Autonomous and Semi-Autonomous Vehicle Coverage: Liability in Autonomous Mode: Policies should clearly define how liability is allocated when vehicles are in semi-autonomous or fully autonomous modes, particularly when accidents occur. Product Liability for Manufacturers: As vehicle technology evolves, it may become necessary to further clarify the division of liability between drivers, manufacturers, and software providers when autonomous systems are involved in accidents. Climate-Related Coverage: Enhanced Coverage for Severe Weather Events: As severe weather events become more frequent due to climate change, policies should expand coverage for flood damage, hailstorms, and other weather-related risks. Eco-Friendly Vehicle Incentives: Introducing premium discounts for hybrid and electric vehicle owners would help encourage environmentally conscious driving behaviors. Cross-Provincial Standardization: Harmonized Coverage Across Provinces: Since many Canadians travel or move between provinces, aligning policy standards across jurisdictions would provide greater consistency and fairness in coverage, especially for frequent travelers. Cybersecurity for Connected Vehicles: Cyber Attack Coverage: As vehicles become more connected, the potential for cyber-attacks increases. Policies should address the risks associated with cybersecurity threats, including data breaches or malicious attacks that could impair vehicle performance. Digitization and Simplification of Claims: Fully Digital Claims Process: Insurers should provide a streamlined digital claims process, allowing for virtual inspections, real-time updates, and faster settlements. AI-Powered Claims Handling: Leveraging AI to assess damage and expedite claims for minor accidents would improve the efficiency of claims handling and provide a better customer experience. These proposals aim to ensure that Ontario's auto insurance policies are aligned with current trends in technology, transportation, and environmental considerations. I believe these updates would benefit both consumers and insurers, offering a more comprehensive, equitable, and modern approach to auto insurance. Thank you for your time and consideration. I would be more than happy to discuss these suggestions in further detail or participate in any consultations regarding potential changes to auto insurance policies. Sincerely, Sindy Ramasamy, ACIP, CRM |
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| Auto Insurance | [2024-011] Sarah Palmer
As a professional working with individuals who have sustained serious injuries in motor vehicle accidents, I see firsthand the need for updates to the Form 1 Assessment, Professional Services Guideline, HCAI System, and Minor Injury Guideline. These changes are not only necessary but long overdue.First, specific rates should be removed from both the Form 1 Assessment and the Professional Services Guideline, allowing professionals to charge market rates. While the Form 1 can prescribe a certain number of minutes for various services, no fixed dollar amounts should be tied to them. Clients can assess whether fees are reasonable and to choose their preferred provider based on value and quality of care. Second, the Minor Injury Guideline (MIG) cap should be increased to $15,000 and indexed to inflation. This would ensure that individuals receive adequate funding for necessary treatments, ultimately reducing reliance on the public healthcare system. Third, the HCAI system must be modernized. Key features like autofill, real-time error checking, and automation for recurring claims would help minimize mistakes and expedite submissions. A built-in messaging system would facilitate direct communication between providers and insurers, and real-time feedback tools—similar to those used by TELUS Health—could resolve issues quickly. Additionally, there should be a system to provide clear adjudication feedback, improving transparency and reducing delays. Thank you for taking the time to consider our feedback. We are hopeful that these important updates will be implemented, ensuring better outcomes for both professionals and those we serve. |
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| Auto Insurance | [2024-011] Lucy Lee - Cohen Highley LLP
I am a lawyer who works regularly with SABS providers. The professional guideline should reflect market rates of service providers. The idea of SABS was to place an injured person in a position to recover as quickly as possible. In light of the complications of HCAI, we lost many psychologists. Social workers have stepped into the gap. However, due to their unregulated status and the insurers complete control over the amount they will pay, insured individuals are going without emotional and psychological treatment. This lack of treatment can result in chronic conditions developing, adjustment disorder, depression etc. We are losing experienced social workers because they are being paid, at time, half of the market rate set out by their college. The other medical professionals have not had a raise in 10 years. They should also receive an increase. The cap for non-mig, non-cat should also be raised accordingly.I am happy to discuss. |
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| Auto Insurance | [2024-011] Bhavesh
The fees for health care is not justified, they are so much underpaid and never keep up with inflation or expertise . Why are this health care worker underpaid ! Why aren’t we doing anything to pay them well and also the funding option is limited - in other province for $$ they spend for car insurance and benefit are completely different then what we get here in ontario |
| Sector | Question and response |
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| Cross Sector | Question: is there an email address to submit responses instead of this portal. I can't seem to get the web page to work well. FSRA response: Comments can be submitted to FSRA's contact center by emailing us at [email protected]; however, please note that by submitting your content, you agree to have your materials posted on our engagement portal, used in reports and other materials prepared by Financial Services Regulatory Authority of Ontario (FSRA) that may be shared with the public. Content is moderated so that all posts are respectful and professional. The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31, applies to all online content. |
| Health Service Providers | Question: Is there an email address to submit a comment if we do not want to post online? FSRA response: Comments can be submitted to FSRA's contact center by emailing us at [email protected]; however, please note that by submitting your content, you agree to have your materials posted on our engagement portal, used in reports and other materials prepared by Financial Services Regulatory Authority of Ontario (FSRA) that may be shared with the public. Content is moderated so that all posts are respectful and professional. The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c.F.31, applies to all online content. |
| Health Service Providers | Question: Hello, FSRA response: The scope of the SABS Guideline review is limited to HSP rates and fees set out in the following three SABS Guidelines:
Stakeholder feedback which is outside the scope of this review will be considered for future FSRA reviews and/or will be shared with the Ministry of Finance. |
| Health Service Providers | Question: It has been over a decade since the fees for providers under MVA's have changed I am wondering when the government will update to current rates. My second question is why they change the rates for Cat and no-cat rates. No health care provider changes their treatment for a person based on fees. There really should not be a difference between categories and Health care providers fees. I do understand the need for designation when if comes to the max allowed from insurers but as a health care provider I do not feel it is truly meeting your mandate for fairness for consumers. I have been working in this industry for over a decade and am seeing the stress for consumers from insurers after an automobile accident increase. The percentage of denials has increased and the IE's no longer seem impartial. What is being done on a government level to protect the consumers from this trend. . I would also like to know what is being done to help provide service to Rural Ontarians with insurance. Service is lacking and providers are required to travel and denials for that are high. FSRA response: Thank you for your questions. FSRA's current review of the SABS Guidelines seeks stakeholder feedback on options related to the fees/rates paid to health service providers. The consultation paper sets out proposed options for the Professional Services Guideline, Attendant Care Hourly Rate Guideline, and the Minor Injury Guideline, as well as questions stakeholders are invited to answer. FSRA is also conducting reviews of the Health Service Provider Framework and of the Health Claims for Auto Insurance System. We welcome your feedback on FSRA's auto reform reviews. Please note that the consultation closes on Friday, November 29. |
| Auto Insurance | Question: Do you review and approve comments before publishing? I submitted a comment and document over the weekend, which has not appeared yet on the list. FSRA response: We confirm receipt of your submission to FSRA's consultation on auto reforms. Thank you. |
| Auto Insurance | Question: On November 28 I filed a submission on behalf of the Access to Justice Group. I would like to confirm that the submission has been received. IF it has not been received I will re-submit the document. Thanks. Ralph FSRA response: We confirm receipt of the submission from the Access to Justice Group. Thank you. |