Operating an Independent Health Facility

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Operating an Independent Health Facility

• Introduction to Independent Health Facilities

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Diagnostic imaging is an integral pillar of
Canadas healthcare industry professionals in
this field are responsible for the diagnosis of
thousands of medical conditions each day.
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In Ontario, Independent Health Facilities (IHF)
such as radiology clinics, X-ray labs, and
mammography centers are licensed by the Ministry
of Health.
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Ministry of Health and Long-Term Care proposed
regulatory changes that are aimed at giving the
Ministry the option of issuing Independent Health
Facility (IHF) licences to so-called
Community-Based Speciality Clinics.
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Overview of IHFs

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Created Under the Independent Health Facilities
Act (Ontario)

• Perform procedures that are funded by the Ontario
  Health Insurance Plan
• The IHFA permits the Minister of Health and
  Long-Term Care to fund these procedures in
  non-hospital premises.

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IHFs maybe

• Diagnostic facilities that provide specific
  classes of diagnostic imaging, pulmonary
  functions or sleep study tests or
• Care facilities that provide surgical and other
  therapeutic procedures such as dialysis,
  abortion, laser dermatologic surgery and
  ophthalmic, vascular, plastic and gynaecological
  surgery.

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• The IHFA is explicitly stated not to apply to
  certain health facilities, persons, places and
  services.
• There are over 1000 IHFs licensed in Ontario.
• The largest category of services provided in IHFs
  are diagnostic radiology and ultrasound services

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The IHFA prohibits anyone from charging facility
fees.
Facility Fees are defined under the IHFA as

• (a) a charge, fee or payment for or in respect of
  a service or operating cost that,
• supports, assists and is a necessary adjunct, or
  any of them, to an insured service, and
• is not part of the insured service, or
• (b) a charge, fee or payment for or in respect of
  a service or class of services designated by the
  Minister under the Act.

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Corporate Structure
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Community-Based Specialty Clinics established as
not-for-profit entities.

• A Licence may be held by either an individual or
  corporation, but may not be held by a corporation
  that operates a public hospital.
• A partnership is not permitted to hold a Licence.

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The Licensing Regime
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A Licence must be obtained from the Director of
Independent Health Facilities

• Submission of a proposal in response to a request
  for proposals issued by the Ministry for the
  establishment and operation of an IHF.
• The IHFA permits the Director to issue a Licence
  if in his or her opinion
• (i) The proposal meets the specified criteria in
  the RFP
• (ii) The quality and standards of the facility or
  the services to be provided in the facility will
  comply with the regulations made under the IHFA
• (iii) the licensee will operate the IHF
  competently and with honesty and integrity and
• (iv) the licensee will establish and maintain a
  system to ensure the monitoring of the results of
  the services provided in the IHF.

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• Licences may be transferred or an IHF may
  relocate only upon the consent of the Director.
• The Director may request any information he or
  she deems necessary in order to decide whether to
  approve a relocation.
• Licences are issued for a maximum of five (5)
  years, but may be renewed upon expiration.

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The IHFA permits the Director to revoke, suspend
or refuse to renew a Licence where, among other
things

• (a) The licensee or any member of the licensees
  staff is in contravention of the IHFA or its
  regulations
• (b) There is a breach of a limitation or
  condition of the Licence
• (c) Any person has made a false statement in the
  proposal submitted to the Director in respect of
  the IHF
• (d) Any person has made a false statement in the
  application for renewal of the Licence or in any
  report, document or other information required
  under the IHFA

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There are reasonable grounds to believe that

• The IHF is not being or will not be operated in
  accordance with the law and with honesty and
  integrity
• The IHF is not being or will not be operated in a
  responsible manner in accordance with the IHFA or
  any other Act or regulation that applies to the
  IHF
• The IHF is being operated or will be operated in
  a manner that is prejudicial to the health,
  safety or welfare of any person

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• (f) The licensee has ceased operating the IHF for
  a period of at least six (6) months and is not
  taking reasonable steps to prepare the facility
  to re-open.
• The Director may order an immediate suspension of
  a Licence if he or she has reasonable grounds to
  believe the IHF

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Monitoring
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Inspections

• The IHFA permits the Minister to appoint
  inspectors and authorizes the Director to direct
  such inspectors.
• It is necessary to ensure that the IHFA and the
  limits and conditions of the Licence are being
  complied with.

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Assessments

• An assessor appointed under the authority of the
  IHFA carries out assessments of the quality and
  standards of the services provided in an IHF.
• The Director is under no obligation to notify the
  licensee that an assessment will be carried out.

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Quality Advisor

• The General Regulation under the IHFA mandates
  that an IHF must appoint a quality advisor to
  advise the licensee with respect to the quality
  and standards of services provided in an IHF.
• The quality advisor must be a health
  professional who provides services in or in
  connection with the IHF and must have adequate
  training that enables him or her to advise the
  licensee.

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• The largest category of services provided in IHFs
  are diagnostic radiology including diagnostic
  imaging centers.
• It is an integral pillar of Canadas healthcare
  industry professionals in this field are
  responsible for the diagnosis of thousands of
  medical conditions each day.
• Doctors may have hands-on training to help
  patients manage illness, and investors may have
  the capital to acquire a medical facility. But
  very few people understand the bureaucratic
  process associated with transferring IHF licenses.

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• Defining your vision and goals is key to ensuring
  successful results.
• Whether youre looking to grow your radiology
  practice or require funding for nuclear medicine
  research, a simple needs analysis can help you
  understand what you want for your business.

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THANK YOU