On November 4, 2024, FSRA hosted a webinar on its Auto Reform Reviews Consultation which includes the Health Service Provider (HSP) Framework Review, the Health Claims for Auto Insurance (HCAI) System Review, and the Statutory Accident Benefits Schedule (SABS) Guidelines Review.
The FSRA Auto Insurance Policy team outlined:
- The three consultation papers that set out options, which fall within FSRA’s statutory authority, to support government auto insurance reforms
- How to ask questions
- How to provide feedback to FSRA
Over 290 attendees participated in the webinar and had the opportunity to ask questions directly to our FSRA team.
FSRA’s Auto Reform Reviews
Date: November 4, 2024
Presenters: Haafiz Alibhai and Shamaila Mian
You can view this video with closed captioning by selecting the “CC” button in the video menu. Note: the closed captioning text is automatically generated and has not been reviewed for accuracy.
Note: the text is automatically generated and has not been reviewed for accuracy.
0:03
Hello everyone and welcome to today's webinar, FISRA's Auto Reform Reviews.
0:08
Before we get started, I'd like to go over a few items so you know how to participate in today's event.
0:14
You have the opportunity to submit text questions to today's presenters by typing your questions into the questions pane of the control panel. You may send your questions at any time during the presentation.
0:24
We will collect these and address them during the Q &A session at the end of today's presentation.
0:29
And now I'd like to introduce Melissa Grover, Senior Manager, Auto Strategy at FISRA.
0:38
Good afternoon. My name is Melissa Grover. Thank you for attending FISRA's webinar on its auto reform review consultations.
0:45
Let's begin by going through today's agenda.
0:49
We'll start by introducing today's speakers, and then following our land acknowledgement, we will discuss FISRA's auto reform reviews.
0:56
Our presenters will provide some background context, summarize the scope of FISRA's three reviews and then get into the substance of the reviews themselves.
1:05
Finally, we will outline FISRA's next steps.
1:09
I'm joined today by my colleagues and your hosts, Shamaila Mian and Hafez Salibai, both of whom are senior policy and technical leads on FISRA's auto policy team.
1:18
As mentioned earlier, we will be answering questions at the end of the presentation.
1:22
If questions are similar, we will group them together and answer them once.
1:26
We will only be answering questions related to the content presented today.
1:30
The recording of today's session will be posted on our website in a few weeks.
1:34
If we are unable to answer your question today, please feel free to reach out to our contact centre through the Contact Us section of our website and they will assign your questions to the appropriate person.
1:45
I hope you find this webinar informative.
1:48
Before we get into FISRA's auto reform reviews, we're going to start with a land acknowledgement.
1:53
It is important to acknowledge the land we are on as the traditional territory of many nations, including the Mississaugas of the Credit, the Anishinaabeg, the Chippewa, the Haudenosaunee, and the Wendat peoples, and is now home to many diverse First Nations, Inuit, and Métis people.
2:09
We acknowledge that Toronto is covered by Treaty 13 of the Mississaugas of the Credit and the Williams treaties signed with multiple Mississaugas and Chihuahua Pans.
2:18
Now I will turn it over to Shemaila to begin our discussions of FSRA's auto reform reviews.
2:24
Thank you, Melissa.
2:26
Before we dive into each of the three separate reviews, I wanted to provide a bit of an overview of the background behind these initiatives.
2:34
As many of you may know, last spring the government requested that FSRA undertake some key auto reform initiatives as part of the spring 2024 budget.
2:45
This request was once again reaffirmed in the fall economic statement that was released last week.
2:52
As part of a broader package of auto reform, the government requested that FISRA undertake a SABS guideline review and consider updating the professional services guideline and the attended care hourly rate guidelines based on our findings.
3:08
Additionally, FISRA was also asked to review the HSB framework and the H-CHI system to find administrative and cost efficiencies to make the systems more modern and efficient.
3:19
Next slide.
3:22
For the scope of these three reviews, so approached by FISRA was to develop three consultation papers with some proposed options and initiatives.
3:32
To develop the options and initiatives set out in the papers, FISRA looked at past findings, past reports.
3:39
We also looked at existing guidelines, current processes and best practices, and most importantly, we did consider previous stakeholder feedback.
3:49
As you are aware, the papers are currently out for public consultation until November 29, with the webinar being conducted today and targeted consultations planned for the rest of this week.
4:01
For ease of reference, the hyperlinks for all three consultation papers are provided in the appendix of this step.
4:08
Next slide, please.
4:11
At this point, we will provide some additional details on each of the three reviews beginning with the SABS guideline review.
4:18
Next slide, please.
4:21
In Ontario, there are over 5 ,000 licensed health service providers, which provide medical and rehab treatment for consumers.
4:28
Medical and rehab costs form a major component of the total cost of auto insurance claims and are vital services to help consumers regain their health after an accident.
4:40
Breaking this down further, the primary drivers behind medical rehab costs are the fees charged by health service providers for goods and services.
4:48
As mentioned earlier, as part of the 2024 budget, the government requested that FISRA undertake a review of two guidelines, the professional services guideline and the attendant care hourly rate guideline.
5:01
To support its statutory objects and to support the government's commitment to auto reform, FISRA agreed to undertake these reviews.
5:09
The SABS guideline review was also expanded to include the minor injury guideline, given And this also addresses health service provider rates and fees.
5:19
The scope of the SABs guideline review was refined further to not only review HSP fees and rates in these three guidelines, but also to propose options that fall within FSRA statutory authority to implement.
5:32
For example, increasing threshold limits would be outside the scope of this review.
5:37
That being said, FSRA is interested in hearing about these issues for future reviews and that we can share this feedback with the Ministry of Finance as they are quite interested as well.
5:50
Next slide. So the first guideline that I want, oh apologies, sorry next slide please.
6:09
So the first guideline we looked at as part of the review was the professional services guideline.
6:14
The professional services guideline was issued in September 2003 by FISCO, the legacy regulator.
6:21
It was issued to provide greater uniformity and stabilize costs given it established hourly rates for health service providers.
6:30
Prior to the professional services guideline being put in place, fee setting was left to health service providers and insurers to negotiate.
6:38
The PSG only applies to consumers receiving care that is non-catastrophic or catastrophic.
6:43
Some examples of the care provided under the PSG include Cairo, massage, occupational therapy, podiatry, psychology.
6:53
Those HSPs not listed in the PSG can negotiate their fees with insurers.
6:59
Historically speaking, PSG rates have been indexed in the past in alignment with the consumer price index.
7:06
The last increase to the hourly rates was in 2014, when they were increased by 0.9 percent.
7:14
FISRA doesn't have a legal obligation to review increased the PSG rates and fee nor did FISCO.
7:19
This is also the case for the attendant care guideline alongside the minor injury guideline.
7:25
Before I move on to the options for the professional services guideline, I wanted to flag that we have drafted some consultation questions for each guideline.
7:34
We ask that you keep these in mind and respond to them as you prepare your feedback for That being said, FISRA is also open to obtaining feedback on other options that are within scope and that have not been identified by FISRA in the paper.
7:49
As you can see, this is also referenced in question six above.
7:53
FISRA is proposing four options for the PSG. Option A is to index maximum hourly rates.
8:00
There has been significant stakeholder feedback that increase to the hourly rates is required given the last increase was back in 2014.
8:11
Feedback provided says the increase should also be cumulative to take into account the consumer price indexes from 2014 to 2024.
8:21
Option B is to move to a flat rate fee system.
8:24
and currently there is an hourly rate system.
8:29
So moving to a flat rate fee system would align with different models such as the WSIB model.
8:36
And additionally, flat rates are already used in the PSG for completion of certain forms such as the disability certificate or treatment plan.
8:45
Option C, not to prescribe the rates.
8:48
So this option would allow the sector to have more autonomy if FISRA doesn't set hourly rates.
8:53
FISPAR could introduce such language as reasonable or at-market rates.
8:59
This approach would be consistent with that taken by insurers currently for setting HSP rates for extended health benefits.
9:08
Option D, status quo, maintain existing hourly rates.
9:12
Any increase in the rates may cause premiums to increase.
9:17
So the suggestion is to leave rates as they are for the time being.
9:21
We've just gone through a pandemic and it might be best for rates to stabilize before making any major changes to the insurance system.
9:30
There is also evidence that consumers are currently able to access the care that they need under the existing PSG rate model.
9:40
Next slide, the attendant care hourly rate guideline.
9:46
So this guideline was introduced back in 2010 and it has three levels of care with different rates.
9:53
The attendant care guideline sets out hourly rates and these services are usually provided, attendant care services are provided by PSWs or family members.
10:03
The rate paid is the contingent on who provides the care, but instead the level of care provided.
10:09
So the three levels of care are level one, this is for personal care and this is currently paid out at 1490.
10:16
Level two is for basic supervisory functions.
10:20
This is currently paid out at a rate of $14 an hour.
10:23
And level three, which is attended care for complex care, which is currently paid out at the rate of 21.11 per hour.
10:33
The total number of hours for each day are multiplied by the hourly rate.
10:37
Monthly attended care benefits are limited to $3 ,000 for non-catastrophic claims and 6 ,500 for catastrophic claims. There is no attended care available for make claimants.
10:49
Back in 2016, level one and three rates were increased to line with WSIB rates and level two was increased to line with minimum wage.
10:59
Stakeholder feedback indicates that the rates for all three levels care are now below market rates.
11:07
FISR is proposing three options under this guideline, the first option being option a index all three levels, level one and three, for example, could be increased to align with the CPI, given that there's no there's been no increase since 2016.
11:23
But we're also interested in hearing about other things that these rates could be indexed to level two could be increased from the current $14 to 1720, which is currently minimum wage.
11:36
Any increase to hourly rates would not coincide with increasing maximum monthly attendant care benefits under this review.
11:46
Option B would be to index only level one and level three rates as these are more technical and complex and this work is usually done by PSWs.
11:58
Option C is once again to maintain the status quo and not increase the rates for all three levels.
12:06
Once again, any increase to the intended care rates could cause premiums to increase given they've been increasing since post-pandemic.
12:15
And there's also, once again, no evidence that consumers aren't getting the care that they need under this guideline.
12:23
Next slide, please.
12:26
So the final guideline we've reviewed as part of the SADS guideline review was the Minor Injury Guideline.
12:32
And this covers health practitioners as defined by the staffs.
12:38
This guideline was issued back in 2010 when the concept of minor injury was introduced and it's for the most prevalent and common injuries sustained in an accident.
12:49
The MIG was developed to create a simplified administrative regime with pre-approved funding and block fees for sets of health services.
12:57
The MIG provides 12 weeks of treatment and 2 ,200 in pre-approved benefits.
13:03
An additional 1 ,300 to a maximum of 3 ,300 is available for those that require more treatment.
13:10
The majority of MEG claimants don't actually hit the threshold of 3 ,500 that's allocated under med rehab benefits.
13:20
So there's two options currently being proposed under the MEG.
13:24
Option A is to index rates in the fee schedule.
13:28
So currently under the MIG, the same rate applies for all practitioners, regardless of who is providing the care.
13:35
The fee schedule, once again, has not increased since 2010.
13:40
And what we're interested in hearing here is what if these rates are increased, what they should be indexed to.
13:47
And there are some questions in that regard on this slide as well.
13:51
Option B, status quo, once again, to maintain fees.
13:54
No significant stakeholder feedback to suggest that increasing the rates in the MIG is a pressing concern for stakeholders.
14:05
The rates in the MIG are generous when compared to other health payer systems.
14:10
For example, a Cairo visit under the MIG is covered at $215, whereas under the WSIB system, it's only covered up to $68.49.
14:23
Next slide, please.
14:25
At this point, I will pass it off to my colleague, Hafiz Alibi, who will provide an update on the HSP Framework Review and the HCI System Review.
14:36
Thank you.
14:39
Thanks, Sharmila.
14:40
I'll now go over the HSP Framework Review.
14:42
I'll begin with some background on FISRA's role in the HSP sector.
14:46
The primary function of a FISRA HSP license is for HSPs to receive direct payments from insurers for services provided to SAP's consumers through the HCI system.
14:56
FISRA's role is focused on oversight of the business and billing practices of licensees.
15:01
Our role does not include overseeing standards of practice or quality of care that is under the regulatory health colleges.
15:08
By licensing HSPs, FISRA can better detect and address fraud like billing fraud and any potential conflicts of interest in the sector.
15:17
FISRA's licensing also addresses issues and manages risks within the sector as they relate to HSPs receiving direct payment from insurers.
15:25
Next slide, please.
15:29
In undertaking its HSP framework review, Fisher is guided by the following principles and outcomes.
15:35
Principle, ensure the HSP framework is accomplishing its intended goals.
15:40
A key outcome of that is realize administrative and cost efficiencies to contribute to having a more modern and efficient HSP framework.
15:48
And this is very important as it sets out scope of our review. Next slide please.
15:55
FISRA has identified initiatives that can provide administrative and cost efficiencies to contribute to having a more modern and efficient HSP framework.
16:03
These initiatives are not mutually exclusive, meaning they are not discrete options, but are intended to be implemented concurrently and or on a staggered timeline.
16:12
These initiatives are already at different stages of implementation and are funded by FISRA.
16:18
FISRA also welcomes stakeholder ideas about other opportunities for administrative and cost efficiencies, not included in what we have identified so far, but which could also make the HSP framework more modern and efficient.
16:31
FISRA is continuing to collect evidence to validate its recommendations and welcomes relevant data from stakeholders.
16:37
This information will help inform FISRA's review and support its decision-making.
16:41
I'll go over the initiatives at this point, which is the first one, initiative A, modernize HSP licensing through FISRA process and system improvements.
16:49
Stakeholder feedback on HSP licensing centered on barriers and challenges and providers keeping their licensing information up to date.
16:57
To address these issues, physical introduce a new software system that will improve the licensing process through internal IT improvements.
17:04
Considerations for this initiative include a new licensing software that will aim to decrease application processing time, lead to faster and more efficient licensing through increased automation and more effective and efficient in identifying fraudulent information.
17:20
HSP licensing will also utilize the decision support portal, or the DSP, which is an artificial intelligence tool to support risk identification in the licensing review process.
17:31
Frizzler will also need to consider its licensing categories and approach when adapting a new system.
17:37
I'll go over to initiative B, modernize supervisory approach with the new HSP supervisory tool.
17:45
Market conducts data is currently spread across multiple sources, which has created inefficiencies and limited the ability to properly identify high-risk HSPs.
17:53
To address these issues, FISRA will introduce a new centralized HSP supervisory tool that will combine multiple data points as well as incorporate risk ratings to help enhance market conducts and analytical capabilities and automate and streamline data.
18:08
Considerations for this initiative include a new tool which will offer greater ability for FISRA to incorporate data into its risk-based supervision, Allow FISRA to be more proactive in the compliance space, and identify fraud and bad actors in the sector.
18:24
Initiative C. Enhance cooperation and collaboration with regulatory health colleges, or RHCs.
18:31
Stakeholders have recommended that FISRA and RHCs should work closer together.
18:35
Building relationships with RHCs was part of FISRA's previous enhancements to HSP licensing and has been an area of current focus.
18:42
VISR is hoping to engage with RHCs to enhance communication and collaboration on compliance issues.
18:49
Considerations for this initiative include sharing of information that will help identify licensees who have sanctions and or suspensions but are still practicing.
18:58
The sharing of information can also help to mitigate redundancy and overlap in the work of both organizations.
19:04
RHCs will also have a better understanding of VISR's work and importance of fraudulent billing.
19:09
VISR will also engage each RHC individually to create an information sharing agreement.
19:14
We have also devised consultation questions related to the HSP framework review, which I will now go over.
19:20
Question number one, what feature should the HSP licensing system focus on to have better user functionality?
19:25
Question number two, are there any concerns or considerations fishers should keep in mind when developing and implementing the new centralized HSP supervisory tool?
19:35
Question number three, what areas of licensing and supervision can regulatory health colleges and FISRA work together to better alleviate issues in the sector.
19:44
Question number four, what are the key implementation considerations that must be taken into account for each initiative?
19:50
For example, timing, communication, education, et cetera.
19:53
Question number five, how can FISRA help to ensure the prioritized initiatives and changes are communicated to HSPs and other stakeholders?
20:01
And question number six, are there any considerations which we have missed that should be considered as part of the HSP review and or the proposed initiatives?
20:09
Next slide, please.
20:13
will now go over the HCI system review. Next slide.
20:17
I'll begin with some background on HCI.
20:20
HCI automates the exchange of health claim information between HSPs and insurance companies.
20:26
HCI's primary role is for insurers to receive specified documents on their behalf to confirm that the documents are completed and make the documents available for access by insurers to whom they are addressed. HCI is not a financial or billing system.
20:39
It does not manage the exchange of funds between parties, nor does it process payments.
20:44
Both licensed and unlicensed HSPs must use HCI to submit forms and invoices.
20:50
The purpose of HCI is to facilitate the efficient and cost-effective transmission of claimant and health provider information between insurers and healthcare providers related to claims under this apps, and facilitate the collection of aggregated and anonymized information related to the delivery of healthcare services made under this apps.
21:08
HSPs with FISRA licenses can bill insurers directly, whereas unlicensed HSPs would bill their patient, submit a copy of the invoice to HCI, and provide a copy of the HCI submitted invoice directly to their patient so the patient may be reimbursed by the insurer.
21:26
In undertaking its HCI system review, FISRA is guided by the following principles and outcomes.
21:32
Principle, ensure the HCI system is accomplishing its intended goals.
21:37
Outcome, realize administrative and cost efficiencies to contribute to having a more modern and efficient HCI system.
21:44
Again, this is very important as it sets up the scope of our review.
21:47
Next slide please.
21:51
FISRA has identified the following initiatives that can provide administrative and cost efficiencies to contribute to having a more modern and efficient HCI system.
21:58
These initiatives are not mutually exclusive, meaning they are not discrete options, but are intended to be implemented concurrently and or in a staggered timeline.
22:06
These initiatives are already at different stages of implementation and are funded by FISRA.
22:11
The HCI system is fully funded by the insurance industry so the initiatives are intended, are anticipated to be implemented at no cost HSPs.
22:19
FISRA also welcomes stakeholder ideas about other opportunities for administrative and cost efficiencies, not included in what we have identified so far, but which could also make the HCI system more modern and efficient.
22:30
FISRA is continuing to collect evidence to validate its recommendations and welcomes relevant data from stakeholders.
22:36
This information will help inform visitors' review and support in decision-making.
22:40
I'll now go over the different initiatives.
22:43
Initiative A, prioritize increasing the number of forms transmitted through HCI.
22:47
Increasing the number of forms transmitted through HCI can improve administrative and cost efficiencies.
22:52
Considerations for this initiative include reducing the time spent manually completing paper-based forms.
22:57
Currently, HSPs electronically submit OCF forms through HCI.
23:02
All other forms are non-standardized and manually submitted to insurers.
23:05
Standardizing the forms and using the HCI system to submit them can decrease administrative and cost efficiencies.
23:12
The outcomes we hope to achieve is for HSPs to more easily track and submit documents, and the insurers will be able to better monitor and adjudicate claims.
23:22
This may incentivize HSPs to become licensed to experience the benefits of direct billing through AHQI.
23:28
And again, increasing claims-related data collected at industry level will support better supervision and better monitor of trends of fraudulent activity and behavior.
23:39
Initiative B, prioritize revising forms.
23:42
The OCS currently process in AHQI have not been revised in over 10 years.
23:46
It should be reviewed with a view to simplify and make more user friendly to improve administrative efficiencies.
23:53
Considerations for this initiative include Plain language, easy-to-understand forms, simplifying questions, reviewing codes, looking at pre-populating fields and drop-down menus, fields that capture HSP's work effort.
24:07
Outcomes we hope to achieve include plain and simple language will increase understanding for businesses who do not typically interact with auto claimants and are not familiar with the H-GUY system.
24:17
Some forms may need to be updated to align with proposed government auto reforms, for example the changes to the first payer.
24:23
Initiative C, prioritize data-related initiatives.
24:26
Enhance data security, including accuracy, completeness, and consistency, and support administrative and cost efficiencies, including optimized care plans and reduced costs across the system.
24:38
Data reports developed with a view to identifying patterns of questionable behavior and or practices that might require further analysis of investigation and better monitoring and identification of consumer harms.
24:50
Future state possibilities of this initiative may include less manual data entry and increased automation in terms of sharing of data.
24:58
Outcomes we hope to achieve include data-related initiatives would be effective if the number of forms processed through HCI were increased giving a fuller picture of accident benefit claims.
25:08
Useful analysis could help reduce fraud and abuse in the system and produce evidence-based health outcome data and deter suspicious activities.
25:18
Initiative D, prioritize other initiatives.
25:21
Initiatives to improve HCI's functionality and reporting can yield administrative and cost efficiencies by facilitating better communication and collaboration between HSPs and insurers.
25:31
Consideration for this initiative include priorities given to initiatives that improve HCI system's operational effectiveness, including enhanced educational technical support to improve uptake and reduce errors, improve system quality and create pathways in H-GUIDE for assessors who are performing assessments for independent examinations.
25:53
Outcomes we hope to achieve would be more effective collaboration and reduce errors which can help improve consumer experience.
26:00
We've also devised consultation questions related to the H-GUIDE system review, which I will now go over.
26:05
Question number one, which initiative should be prioritized and why?
26:09
Are there significant benefits or drawbacks, including potential stakeholder impacts, missing from the analysis that should be included?
26:16
Are there any considerations which have not been included that should be included?
26:20
What are the key implementation considerations that must be taken into account for each initiative? For example, timing, communication, education.
26:28
Our question number five, are there any other opportunities for administrative and cost efficiencies that Frister should consider to make the HCI system more modern and efficient that are not included in the list of initiatives presented? Next slide, please.
26:42
At this point, I will pass it back to Melissa.
26:50
Thanks to my line of office.
26:51
So, FISRA is interested in receiving stakeholder feedback on its auto reform reviews.
26:56
As my colleagues mentioned, we encourage you to share any relevant data or evidence so that it may be considered as part of the auto reform reviews.
27:03
We also welcome your ideas about other opportunities not included in the consultation papers.
27:10
Feedback can be submitted via the online consultation portal on FISRA's website.
27:14
The consultation itself closes on Friday, November 29th, 2024, and after the consultation period closes, FISRA will begin developing its recommendations to government, which will be delivered to government by March 2025.
27:31
So this concludes the formal presentation.
27:33
Thank you for attending today's session.
27:35
We will now take some time to respond to questions we've received through the chat.
27:39
Shemaila and Hafiz will be joined by our FISRA colleagues, Kevin Liu, technical lead from the Fisher's Market Contact Team, and Jason Harris, the Director and Deputy General Counsel from Fisher's Legal and Enforcement Team.
27:51
Several questions have already come in.
27:53
If you have any questions, you can still enter them using the Q &A icon on your screen.
27:57
And as a reminder, we will group similar questions and answer them once.
28:01
We will only be answering questions related to the content presented today.
28:05
The recording of today's session will be posted on our website in a few weeks.
28:09
As mentioned earlier, if we're unable to respond to your question, please reach out to our contact center through the contact us section of our website and they will assign it to the appropriate person method.
28:18
Okay, so the first question, I think is for you, Shemaila.
28:22
How did FISRA come up with the options set out in its SABS guideline review?
28:26
Okay, so the consultation paper is part of FISRA's review of the SABS guideline and sets out proposed options that A, fall within FISRA's statutory authority to implement and B, advance the government's commitment to improve Ontario's auto insurance system.
28:44
The paper's contents and options were developed by synthesizing past findings, reviewing past reports, reviewing existing guidelines, processes, additionally leveraging previous stakeholder feedback.
28:59
Additionally, we also invite stakeholders to share feedback and other possible options with us through the online consultation portal.
29:09
Thank you. Let's see.
29:14
The next question, I think you can answer as well, is what is FISRA going to do with the feedback it gets from the consultation?
29:22
So FISRA will, once the consultation closes on November 29th, FISRA will use the input received to refine FISRA's findings and recommendations.
29:35
FISRA plans to develop its final recommendations and we'll share those with the government in early 2025.
29:43
FSRA will then initiate work on final recommendation implementation beginning spring-summer 2025.
29:52
Thank you.
29:59
That's another question for you, Shyamala.
30:01
Did you indicate that FSRA doesn't have the ability to revise the PSG rates?
30:05
Is this an MOF responsibility?
30:08
No, PSG rates amending them do fall within the scope of the review.
30:16
It was expanding the list of HSPs in the PSG that we're not able to expand at this point because they don't fall within the context of this review, which is focused on rates and fees.
30:30
Thank you.
30:32
Hafiz, this is a question for you.
30:34
Has there been any new or ongoing investigation into the impact of HSB fee guidance on, maybe you and Shemaila can both answer, into the impact of HSB fee guidance on the quality of care or patient or client experience?
30:52
So from the perspective of the fee guidance, there hasn't been an impact in terms of what we've heard.
30:58
Like there is many motor vehicle accident victims have been able to get the care that they need.
31:08
And that's something that we've had stakeholder input on.
31:12
So it hasn't decreased access.
31:15
Thank you.
31:16
Can you also speak to whether FISRA will update the codes for HCI?
31:20
Some codes don't represent the work HSPs perform or are no longer relevant.
31:26
Sure, so in initiative B, prioritizing, revising forms, that may include reviewing codes, but it should be noted that revising forms may not address all the inaccurate or misuse of codes.
31:38
It depends on what our review is.
31:41
However, if we're looking at examples of expanding treatments or services by HSTs, that's something that will work with stakeholders, such as HSTs to ensure the treatment codes are up to date and obsolete codes are removed from future use and new codes are proposed for new types of treatments.
31:58
Thank you.
32:04
Can you also speak to whether any other options, other than those proposed in the stack we've presented today, be considered?
32:14
So other options, again, we are open to feedback from different stakeholders, and we will be having targeted stakeholder consultation this week.
32:23
So we are looking at receiving feedback from our stakeholders and including it into our review.
32:29
Thank you.
32:31
Can you speak to when the effective date for the auto reform will be? So in terms of an effective date, again we are going through consultations.
32:44
We're looking at, you know, we have to see what's the outcome of the review.
32:49
So FISRA plans to develop its recommendations in early 2025 and share those recommendations and findings with government around March 2025, and then also it tends to review recommendations publicly in advance of beginning to implement any of them.
33:05
So again, we're starting to just collect all the information and again, share it with government in early 2025 and looking at reaching out to the industry in 2025, spring 2025.
33:18
Thank you.
33:19
So I think that answers another one of the questions that one of the attendees had about whether FISRA will share the outcomes of its reviews and whether stakeholders will know what FISRA's recommendations are.
33:29
But maybe you could speak to that again, specifically that question.
33:38
So again, we're looking to share with the government in early, in March 2025, present our findings and then look to share the recommendation publicly in advance of any sort of implementation.
33:55
So again, we're looking at maybe around spring 2025 to share that information book.
34:00
Great. Thank you very much.
34:02
Shyamala, how will FISRA mitigate potential rate hikes if we propose to adjust the current rates for PSG, attendant care, hourly rate guideline, and MIG to align with market rates?
34:14
Okay.
34:15
So should FISRA choose to adjust the rates and fees found in either the PSG and the attended care guideline or the MIG or all three, FISRA will consult with actuaries and consider the implications of any potential cost adjustments, including whether it's appropriate to take a phased or staggered approach to possible increases.
34:42
Can you also speak to whether increasing caps will be addressed in any upcoming reviews or consultations and whether there's a plan for that?
34:50
Sorry, increasing?
34:52
Increasing the benefit limits for MIG, non-MIG, etc.
34:56
Okay, yep.
34:57
So although an important issue, threshold limits are found in the SAVs and thus fall outside of FISRA's statutory authority to implement, and unfortunately outside the scope of this review, which is focused on rates and fees.
35:09
FISRA does acknowledge that there is an interdependence, that threshold limits and HSP fees and rates play in the ability to service claims.
35:18
The challenge for FISRA is that even though these issues are interlinked, they're governed by different authorities.
35:26
For example, some may be found in legislation, regulation, whereas the rates are found in guidelines.
35:32
That being said, once again, stakeholder feedback, which is outside the scope of this review, including threshold limits, will be considered for future FISRA reviews and or will be shared with the Ministry of Finance if amendments to this apps or insurance act are required.
35:49
Thank you very much.
35:51
There is a question about the consultation website about whether or not there's an email or address or contact person for submitting feedback.
35:59
And then I can say that there's an option about submitting comment.
36:05
The webpage has a button that says, submit a comment, upload a file, ask a question, yes.
36:10
Responses or feedback is supposed to be uploaded through that button.
36:13
So, thank you very much for that question.
36:17
Hafiz, can you speak to when licensing upgrades will be operational and whether stakeholders will have a chance to test any new licensing system before it's implemented?
36:31
So, in terms of timelines, so, again, timelines are not – they're not set yet.
36:40
So, right now what's happening is that these projects are in progress and we are looking at engaging stakeholders when we start to implement, especially during testing of the new software.
36:54
But at this moment, this is, we're still reviewing the details of the project.
36:59
It's part of its implementation approach and transition and launch of the actual system improvements are still to be determined.
37:10
Thank you very much.
37:11
So there's a question about regulatory health colleges They have varying compliance roles, and this may be a question for you, Officer, for Kevin.
37:22
If FISRA revokes an HSP license, how will that impact their license with their regulatory health college?
37:33
So again, FISRA's role in HSP licensing is just limited to monitoring a regular entity's business conduct with oversight just on business and billing practices.
37:42
So again, I know that on the market conduct end, there is some information sharing on a high level about sanctioned practitioners.
37:51
I'll pass it over to Kevin to answer a little bit more about that.
37:55
Yeah, we're still in the development of our 2024 to 26 supervisory plan.
38:01
We're looking to publish that in the coming months.
38:05
Part of one of our initiatives is to review members of the regulatory health colleges who's had their certificate of registration suspended or revoked, for example, and I invite the attendees to look out and review that supervisor plan once it becomes published. Thanks Kevin.
38:30
So we have received some questions that address issues out of scope for the auto reforms reviews that we're discussing today and as mentioned we're only going to answer questions that relate to today's presentation content.
38:43
Hafiz, can you speak to what FISRA is doing currently to reduce fraud in the HSB sector?
38:49
So again, FISRA's market conduct team does employ a risk-based approach when performing reviews.
38:54
So HSBs are selected for reviews based on available data such as complaints or past sanctions.
38:59
So this approach aids to address instances of fraud in the sector.
39:03
Another initiative that FISRA has been actively engaged in is to address problems in the sector, such as the fraud reporting service rules and guidance, which was just recently out for consultation. So there are certain initiatives that are currently underway. Great.
39:20
So we'll give it a little bit longer to see if there are any other questions, but we have just one other relevant or question within scope in the queue for you, Shemaila.
39:32
Will this review consider the current status that requires STABs patients to utilize the personal extended health benefits prior to auto insurance?
39:42
That is something that we are considering as we develop the options and we finalize our recommendations as well.
39:49
They interchange between that.
39:51
Great, thank you very much.
39:54
Okay, so I don't see any other questions about today's presentation.
39:59
Thank you for, oh.
40:01
Nope, I think that, yeah.
40:03
I don't see any other questions related to today's presentation.
40:08
Thank you very much, everybody, for engaging with us about this important work, and thank you for taking the time to be with us today.
40:14
So we welcome your feedback on FISRA's auto reform reviews.
40:17
Please submit your feedback through the consultation portal on FISRA's website using the Submit Here button.
40:22
The consultation period closes Friday, November 29th.
40:25
I'd like to remind you again today's webinar was recorded, the recording will be available on FISRA's website in the following weeks.
40:32
As always, you can reach out to FISRA's contact centre if you have any other additional questions we didn't answer.
40:37
We hope you found this session on FISRA's auto reform reviews informative.
Questions & Answers
Scope and outcomes of review
| Question | Response |
|---|---|
|
How did FSRA come up with the options set out in the SABS Guideline Review? |
The consultation paper is part of FSRA’s review of the SABS Guidelines and sets out options that:
We invite stakeholders to share feedback on other possible options with us through the online consultation portal. |
|
I believe it was stated that many claimants do not exhaust the full $3500 med/rehab limit under the MIG. Can you please elaborate on the number/percentage that exhaust the full $3500, and what the understood reasons are for anyone not utilizing the full amount (full recovery, EHC paying full amount, no claim made, etc)? And how was this data obtained? |
FSRA has received stakeholder feedback that suggests most consumers are able to obtain the care they need from health service providers under the existing fees/rates found in the Professional Services Guideline (PSG), Attendant Care Hourly Rate Guideline (ACHRG) and the Minor Injury Guideline (MIG).
FSRA is interested in reviewing any information/data stakeholders may have about access to care issues that appear to result from existing Guideline fees/rates, or from any other barriers to access. |
|
"Did the first speaker indicate that FSRA does not have the ability to revise the PSG rates? Is this a MoF responsibility?" |
Reviewing the rates/fees found in the Professional Services Guidance falls within FSRA’s statutory authority. |
|
The scope of this 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. |
|
When you were listing professional providers I did not hear you say Physiotherapists - are they included in this review? |
The fees/rates set out for physiotherapists in the Professional Services Guideline and Minor Injury Guideline are within scope and are captured by this review. |
|
Although an important issue, threshold limits are found in the SABS and fall outside of FSRA’s statutory authority to implement and outside the scope of this review which is focused on fees/rates.
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. |
|
Will any other options other than those proposed in this deck be considered? |
FSRA is interested in hearing from stakeholders on other options/initiatives that were not outlined but that should be considered. Please provide your feedback on other possible options by submitting them through the consultation portal by November 29, 2024. |
|
"Is there also a review of the profits of auto insurers? The costs to provide healthcare and cost of living for healthcare providers has increased substantially since 2014 and without increased wages, we risk losing healthcare providers to other sectors. There continues to be reductions in benefits to consumers, and limits on healthcare wages. Will the profits of auto insurers be reviewed? |
Reviewing the profits of insurers is outside the scope of the SABS Guideline Review, which deals with health service provider rates/fees. |
|
Will this review consider the current status that requires SABS patients to utilize personal extended health benefits prior to auto insurance? |
The government has proposed changes to make auto insurance the first payor instead of extended health benefit plans. If passed, these changes would come into effect July 1, 2026.
The impact of first payor changes on HSP rates/fees was considered as part of the SABS Guideline Review and will continue to be considered as FSRA drafts its recommendations. |
|
Desired outcomes seem to focus on efficiency and cost saving. This focus does not appear to align fully with FSRA's stated role "We protect the rights of consumers in Ontario by promoting high standards of business conduct and transparency within the financial services we regulate". Where does this mandate fit in this review? |
As FSRA undertook the SABS Guideline Review and developed the proposed options we were guided by the following principles: maintain the care that consumers receive and ensure the continued availability of services.
These principles are very closely related to and support the Government’s identified outcomes for these reforms which is to ensure those injured receive the care they need and that HSPs are compensated appropriately. |
Med/rehab claims
| Question | Response |
|---|---|
|
Any sense as to what percentage med/rehab costs are to total insurance expenses or percentage of overall insurance premiums? |
In 2023, a total of $11.6 billion was spent on auto insurance claim costs. Accident benefits (i.e. medical/rehabilitation, attendant care, income replacement) made up 22.5% ($2.6 billion) of the total auto insurance claim costs spent by insurers.
|
Access to care
| Question | Response |
|---|---|
|
FSRA has received stakeholder feedback that suggests most consumers are able to obtain the care they need from health service providers under the existing fees/rates found in the Professional Services Guideline (PSG), Attendant Care Hourly Rate Guideline (ACHRG) and the Minor Injury Guideline (MIG).
FSRA is interested in reviewing any information/data stakeholders may have about access to care issues that appear to result from existing Guideline fees/rates, or from any other barriers to access. |
|
Thanks for the opportunity to ask a question. It appears that a number of conclusions have been made that are subject to this review that were made prior to today. Have you considered opening your fact finding process to stakeholders working on behalf of injured people? For example during the talk there was a statement that there was “no evidence” that injured people were unable to access benefits in the current system. Should have FSRA had an appropriate response from a well-rounded stakeholder group, FSRA could have received a good deal of evidence of injured people being unable to access benefits as a result of the current system issues including but not limited to attendant care rates below minimum wage. |
The consultation paper and the proposed options/initiatives set out in the paper and webinar presentation were developed using a variety of different sources. For example, the paper’s contents synthesize past findings/ reports, review existing guidelines/ processes, and leverage previous stakeholder feedback.
FSRA has also scheduled targeted consultations with a variety of different stakeholder groups to obtain diverse and varying viewpoints. |
|
"What evidence do you want to see of how the low rates for Attendant Care in the Guidelines have resulted in the inability to obtain care? There have been several news stories on this. Would you like to meet with clients and actual individuals who are experiencing this? Do you want names? What ""evidence"" are you looking for? |
FSRA is interested in reviewing any information/data stakeholders may have about access to care issues that appear to result from existing fees/rates for attendant care, or from any other barriers to access. |
Implementation
| Question | Response |
|---|---|
|
When will the proposed reform changes be officially approved? And when can we expect specific implementation guidelines for carriers & brokers to be released? |
FSRA plans to develop its final recommendations and will share those with the government in early 2025.
FSRA intends to begin to initiate work on implementing its final recommendations in spring/summer 2025. |
|
"The timelines seem really tight for the entire insurance ecosystem to be able to be ready for the July 2026 launch. Is MOF open to pushing back the effective date?" |
FSRA will consider your feedback on implementation timelines related to its auto reform reviews as it develops its final recommendations.
The Ministry of Finance is leading auto reforms related to SABS optionality and first payor. Changes to SABS benefit optionality have passed and will be effective July 1, 2026. Changes to first payor, if passed, would also be effective July 1, 2026. |
|
sorry to clarify are these proposed changes separate and distinct from changes coming for July 2026? |
The options proposed during FSRA’s auto reform webinar relate to the fees/rates set out in three SABS Guidelines and are within FSRA’s authority to implement.
The Ministry of Finance is leading auto reforms related to SABS optionality and first payor. Changes to SABS benefit optionality have passed and will be effective July 1, 2026. Changes to first payor, if passed, would also be effective July 1, 2026. |
|
How will FSRA mitigate potential rate hikes should FSRA propose to adjust the current rates for PSG, ACHRG and MIG to align with market rates? |
FSRA is considering implications of any potential fee/rate adjustments, as well as mitigations such as a phased or staggered approach. |
Stakeholder feedback
| Question | Response |
|---|---|
|
Can you explain exactly how to provide feedback on these reviews? Do we just submit a comment on the notice on the website? |
Please submit your feedback on these reviews by visiting Consultation on auto reforms. You can submit your feedback by using the yellow submit a comment button at the bottom of this webpage or alternatively by e-mailing it to the [email protected]. |
|
What will FSRA do with the feedback it receives from stakeholders? |
Stakeholder input will be used to inform FSRA’s auto reform review findings and recommendations and to advance the government’s commitments to improve Ontario’s auto insurance system.
FSRA plans to develop its final recommendations and will share those with the government in early 2025.
FSRA intends to begin to initiate work on implementing its final recommendations in spring/summer 2025. |
|
Will FSRA share the outcome of its Reviews? How will stakeholders know what FSRA’s recommendations are? |
FSRA plans to develop its recommendations in early 2025 and share its review recommendations and findings with the government by March 2025.
FSRA also intends to share its review recommendations publicly in advance of initiating work on the final recommendations beginning in Spring/Summer 2025. |
| Question | Response |
|---|---|
|
When will the licensing upgrades be operational? Will stakeholders have a chance to test the system before its implemented? |
FSRA is still reviewing details of the project as part of its implementation approach. Transition and launch are still to be determined.
HSP licensing will also utilize Decision Support Portal (“DSP”). The DSP is an Artificial Intelligence (“AI”) tool to support risk identification in the licensing review process which eliminates the manual search process used during the suitability assessment review. |
|
Regulatory Health Colleges have varying compliance roles. If FSRA revokes a licence of a HSP, how will that impact their licence with their Regulatory Health College? |
FSRA’s role in HSP licensing is limited to monitoring regulated entities’ business conduct, with oversight specifically pertaining to licensees’ business and billing practices.
FSRA is not responsible for overseeing standards of practice and quality of care provided by regulated health professionals, which falls under the supervision of the Regulatory Health Colleges. |
|
What is FSRA doing currently to reduce fraud in the HSP sector? |
FSRA’s Market Conduct team employs a risk-based approach when performing reviews. HSPs are selected for reviews based on available data, such as complaints or past sanctions. This approach aids to address instances of fraud in the sector.
FSRA also has initiatives underway to address fraud in the sector, such as the Fraud Reporting Service Rule and Guidance consultation. |
| Question | Response |
|---|---|
|
Will FSRA update the codes for HCAI? Some codes do not represent the work HSPs perform or are not relevant? |
Initiative B “Prioritize Revising Forms” may include reviewing codes. However, it should be noted that revising forms may not resolve issues with inaccurate/ misuse of codes.
This initiative could include working with stakeholders to ensure treatment codes are up to date, obsolete codes are removed from future use, and new codes are proposed for new types of treatments.
Decisions on updating codes will depend on the outcome of this review. |
|
Can you please provide some more detail on the additions of "fields that capture HSP’s work effort" under HCAI reforms? |
“Initiative B: Prioritize Revising Forms” proposes form changes that include (among others) fields that capture health service providers work effort (e.g., pages read, sessions conducted). For example, standardization of the reporting of time spent providing therapeutic services. |
|
Can you clarify who CURRENTLY has access to HCAI systems? Is there opportunity to expand access to other parties, parties who could help service consumers faster and better when it comes to claims handling and progress status updates on claims? |
Insurers and health care providers have access to HCAI system for business-to-business transmission of information pertaining to SABS claims.
The suggestion to expand HCAI access to other parties is reflected in the HCAI consultation paper and will be considered when FSRA publishes its final recommendation report to the Ministry of Finance. |
|
You mentioned a "synthesis of past reports and findings about HCAI" Is that synthesis available and if so, where? |
Please refer to the HCAI System Review consultation paper. The consultation paper was developed based on synthesized past findings and reports, in addition to other stakeholder feedback. |