HomeMy WebLinkAboutPolicy 07-10-05
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IN THE MATtER OF AN ARBITRATION
(Under the Ontario Labour Relations Act, J 995)
BETWEEN:
HAMILTON HEALTH SCIENCES
(the "Hospital")
-AND-
ONTARIO NURSES' ASSOCIATION
(the "Union")
AND IN THE MATTER OF the arbitration of policy grievances concerning the administration of
the sick leave benefits plan under the collective agreement between the parties.
BEFORE: G. T. SURDYKOWSKI - Sole Arbitrator
APPEARANCES:
For the Ho:mital: Mark Zega, Counsel; Jane Gooding, Counsel; Cristina Vallonio, Labour
Relations Analyst; Colleen Lynas, Labour Relations Associate; Kelly Corpt Mgr. Heal~ Safety
and Wellness; Mary Gingrich, Disability Associate; Meaghan Hastie, Analyst (Attendance).
For the Union: Kate Hughes, COWlScl; Nicole Butt, ONA COlmsel; CoHeen lonson, Labour
Relations Officer, Pat MacDona1~ Bargaining Unit President and Local Coordinator; Connie
Ross, Local VP and Grievance Chair; B.I. Swanson, Henderson Site Rep.; Cynthia Mascoll;
Chedoke Site Rep.; Gail Molnar, MUNC Site Rep.
HEARlNGS HELD IN HAMILTON, ONTARIO ON JANUARY 17 APRIL 27, 28, MAY 8,9.
'. . .
24, DECEMBER 13,14 AND 18,2006, AND JANUARY 31, FEBRUARY I, 2, 7, 9,13,16,20,
MARCH 6, AUGUST 22,23,2007.
Copyright @ George T. Surdykowski AtbitrationIMediation Inc. 2007
[All rights reserved. Reproduction in whole or in part, in any form. or format; by anyone other than
the parties, or for use in legal proceedings, for not-for-profit educational purposes, or as required
or permitted by Jaw, without express vvritten. consent is prohibited.]
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AWARD #1
"MEDICAL CERTIFICATE OF DISABILITY" FORM ISSUE
I. m1:l!ODUCTION
1. This proceeding concerns two policy grievances. It bas been bifurcated into three phases.
The Award numbers reflect the phase that the particular A ward relates to. I have previously issued
Awards # 1 A (dealing with a preliminary issue in Phase # 1) and #2 (dealing with an Employment
Standards Act issue in Phase #2). This Award deals with the Union's allegation in Phase #1 that
the "Medical Certificate ofDisabiliti' application form for short term sick leave benefits that
employees are required to subm.it is improper. Although the issue is restricted to the short term
disability ("STD'~) requirements it encroaches upon retw1l to work issues.
2. Paragraphs 1-14 of the Introduction in "Award #lA - "Preliminary!' Issue" are an equally
appropriate general introduction to this A ward.
3. However, it bears repeating that prior to the spring of2005 the Hospital's Employee Health
Services ("EHS") Department processed sick leave benefits applications, and obtained information
from employees for that purpose. EHS assessed or "adjudicated;' employee applications for sick
leave benefits and determined in each case whether the employee was entitled to sick benefits.
EHS also sought to facilitate early and safe retum.s to work, with necessary accomm.odations as
required. Although there were (and are) confidentiality protections in place, EHS had to share
certain limited information regarding employees' medical conditions with Hospital management in
order to perform this fimction (see Appendix "AA" and paragraph 53, below).
4. The Hospital decided to outsource the short term disability ("STD") sick leave benefit
application and assessment/adjudication function for operations and efficiency reasons. Cowan
Wright Beauchamp eCowan") was the successful private sector bidder for this contract and took
on the role and tlmctions formerly performed by EHS~ beginning on April 4, 2005 at the General
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site, April 25, 2005 at the McMaster site, May 16~ 2005 at the Henderson site, and June 6, 2005 at
the Chedoke site. The contract between the Hospital and Cowan in that respect (Exhibit #18 - the
"Cowan contract") as produced, with financial details deleted as confidential and irrelevant and
with emphasis added, is attached as Appendix "C" to this Award. I have included it in this A ward
for the sake of compJ.eteness notwithstanding that this contract does nothing to resolve the matters
in issue. A contract between the Hospital and a third party cannot give the third party any greater
rights than the Hospital itself has with respect to bargaining unit employees.
5. The "Medical Certificate of Disability" (hereinafter referred to as the "Cowan form"), that
Cowan requires all employees who apply for sick leave benefits to complete was entered into
evidence as Exhibit #22. It is reproduced as Appendix "A" to this Award. The evidence includes
three versions ofthe "Attending Physician's Statement" that the Hospital's EHS Department used
over tbe years for that purpose before the Hospital contracted that function out to Cowan. On the
face of these documents the most recent of these was "updated" in November 2002. For the
purposes of this case, these appear to be substantially the same and I include only the most recent
one as Appendix "AA" for comparison purposes. ,
6. The Union alleges that bargaining unit nurses are being told that they must sign the consent
in the Cowan form and provide aU of the information requested, and that they will be denied
benefits if they do not do so. The Union asserts that the consent being required of employees in
Section B of the Cowan. form is coerced, and is therefore not a true consent, and that the consent
being required is in any event too broad or otherwise improper. The Union also objects to the
reference in Section B of the Cowan form to a maxinuUll. reimbursement of$35.00 to the medical
professional who completes the form. The Union alleges that Section C of the Cowan fonn
requires employees to disclose confidential personal medical information that goes beyond what is
necessary or appropriate for short term sickness benefits purposes, and wbich violates bargaining
unit employees' collective agreement and statutory privacy rights.
7. The Union does not object to the use of a consent and medical information fonn for the
purpose of STD benefits under the collective agreement. It recogni7..es that the Hospital is entitled
to infonnation in that respect. The Union's concern is with the manner and scope oftbe consent,
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and the nature and extent of the confidential medical information that the Cowan form requires
bargaining unit employees to provide. The issue in this case is not the extent of the consent or
medical information that the Hospital can legitimately seek and use in any particular individual
case. The Union acknowledges that a more intrusive investigation of the basis for an application
for SID benefits may be appropriate in a particular individual case. The issue is the more general
one: that is, what consent and medical information can the Hospital require every employee who
seeks SID benefits to provide as a matter of course in the first instance, failing which benefits will
be denied? That is an issue which is appropriately raised in a policy grievance, which is what I
have before me.
8. In addition to vive voce evidence, I have been provided with hundreds of pages of
documentary evidence. Counsel made oral and written submissions, and :filed numerous (48)
Court and arbitration decisions in aid of their submissions. I find it unnecessary to review the
evidence in detail, or to set out the parties' submissions even in summary form. I have reviewed
the collective agreement, the legislation cited to me, and the evidence. I have read all of the
authorities filed, and considered the oral and written submissions. Many of the authorities are of
little or no real assistance, and I do not consider it necessary to analyze or even list them. I will
address the evidence and arguments. and refer to the jurisprudence as I consider appropriate. I
note that unless a different analysis in another jurisdiction is particularly persuasive, I consider it
appropriate to give greater weight to the jurisprudence in the jurisdiction in which the case at hand
is being litigated when there is a divergence of jurisprudential opinion between jurisdictions, and
that is what I have done.
9. I note that there are other separately represented bargaining units at the Hospital. [
understand that the Hospital uses the same Cowan form and services for all of them. During
argument in Phase 3 of the proceeding (i.e. after Phases 1 and 2 had been completed and while J
was in the process of preparing this A ward) an award dated July 10, 2007 issued by Arbitrator
Knopf with .respect to a dispute between the Canadian Union of Public Employees and the Hospital
concerning the Cowan form and Cowan's conduct was brought to my attention. The Knopf Award
in the "CUPE case'; arises out of a mediation/arbitration proceeding held the same day as that
award was issued and concerns a different collective agreement bargaining relationship. It is
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neither binding on me, nor of any particular assistancc. However, I was referred to it and I am
constrained to comment on it in due course, below.
II. COWAN'S EXPLA~4nON OF ITS FPRM;
10. As noted above, the Cowan form is reproduced as Appendix "At' to this Award. Exhibit
#45 is typical of the letter that is being sent to employees who seek STD benefits. It reads (witb
dates deleted as irrelevant and as having the potential to identify the employee to whom the
particular letter was sent) as follows:
As you are aware, the hospital has implemented a new process for Short Term Disability
adjudication.
We have determined that the Medical Certificate of Disability win be considered the
satisfactory proof of disability that we require to justifY absences from the workplace as
outlined in the Hospitals of Ontario Disability Incot1le Plan (1992), This will be required for all
absences of 5 shifts or greater. Cowan Wright Beauchamp, will act on behalf of the
hospital to review and assess this infonnation, in consultation with the Family PhYSician, and
advise if there is medical to support the absence. This information will be held in the strictest
coofidence with Cowan Wright .Beauchamp, and no infunnation with respect to diagnosis wilt be
shared with any Hamilton Health Sciences employee, without the expressed consent of the
individual employee in question.
If employees do not CQnsent to Proyjding the Medical Certificate of Disability to the
aooropriate Health l?rokssiQtlaJ. tben we will not be able to establish if proof of disabilitY has been
rnc:=t,. and as a result. the employee will not be paid sick oay benefits.
You have been absent as of_and at this time you stilt remain off You witl need to provide
medical documentation to support that absence. Enclosed you will find a letter fur your doctor
explaining 1he process and a Medical Certificate of Disability whicb your doctor wi II need to
complete. There is a star on that form where you will, need to sign your consent. Please
ensure that Cowan Wright Beauchamp receives the required documentation to support
yoW' absence by ~.JfYOU are unable to provide this documentation. we will not be able to
adiudicate YOU( claim.. sick-DaY benefits may not be in order. and an overpayment recovery would
have to be set up.
Enclosed is a copy of the brochure, which was attached to your pay stub on _, which explains
and outlines the process. Also enclosed is a copy of the Attending Physician Statement that is
required under th.is process. Tfyou have any questions or concerns about this process please contact
(Emphasis added.)
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11. Also in evidence as Exhibit #9, and reproduced as Appendix 44B" to this Award~ is the
"Functional Abilities Form" e'F AF") that the Hospital is using for the purpose assessing
employees when they are ready to return to work from an illness or injury. It is useful to compare
the Cowan form to this F AF as well as the Attending Physician's Statement previously used by
EHS.
12. Helene Santerre is the Cowan representative who drafted the Cowan form in issue, which
she customized for the Hospital's use. She does not deal with the Cowan form on a day-to-day
basis but continues to have oversight responsibility for it. Santerre testified that Cowan ~ s role in
the process is to provide sick leave adjudication and to ensure that employees who apply for short
tenn sick leave benefits obtain appropriate treatment. She says that Cowan can facilitate medical
testing and ,specialist consultations, and provide support to employees and facilitate their return to
work. Although Santerre testified that all of the Cowan employees who perfonn these various
functions are medical health professionals it is clear that that is not the case. On the face of its
proposal to the HospitaJ at least one Cowan employee (Geil) was not a medical health professional
even then, and another non~medica1 health professional (Higgenbotham) subsequently became
. . . .
directly involved. Cowan also seeks to identify s.ic.k claim trends with a view to reducing these
through wellness programs. Santerre conftnns that Cowan ~ s role is to report on the status and
make recommendations about sick benefits claims, and that the Hospital has the final say in that
respect
13. Santerre testified in examination-in-chiefthat when she was drafting the fOUll. she looked at
the 1980 and 1992 HOODIPs, the Hospital's existing policies and the collective agreement.
However, she says that she did not look at the collective agreement to ensure that the Cowan. fonn
was consistent witb it. lndeed when asked in cross-examination whether she (or Cowan) reviewed
the collective agreement (which include the 1980 and 1992 HOODIPs) in order to ensure that the
Cowan form is consistent with it Santerre responded that "we were not asked to do that", which I
take to mean that neither she nor anyone else did so. On the evidence, it is hard to believe that
Santerre, who conceded in cross-examination that she did not review either HOODIP when she
drafted the Cowan form, or anyone else at Cowan paid any attention to the collective agreement.
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14. Santerre also appears not to understand the HOODIP definitions of "total disabiHty" or
"totally disabled". Santerre testified that impairment does not equate to total disability and the
Cowan materials (specifically Exhibit #20) refer to an employee's inability to perfonn the
"essential" duties of her occupation, but both HOODlPs define the eligibility as tbe inability to
perform the ''regular'' duties of the employee's occupation. While Santerre's broad general
statement that a person whose abilities are impaired may not be totally or at all disabled is accurate
as far as it goes, her example of someone witb a broken leg stm being able to perform reception
work and her assertion that an impainnent does not necessarily mean that bargaining unit nurse
cannot perform any of her normal duties demonstrate that Cowan does not appreciate the
distinction between essential and regular duties for SID benefits putpOses under the HOODIPs,
particularly when it comes to nurses. There .is a difference between essential and regular duties.
As a general matter regular duties is a broader category which encompasses but is not limited to
essential duties. Nor is it clear that Santerre appreciates that the Hospital is a highly un.ionized
environment because even if an ill or injured nurse could be assigned to clerical or non..nursing
duties doing so could take her out of the bargaining unit aud conflict with the rights of employees
in another bargaining unit. Perhaps this is why the Hospital has effectively retained full control of
return to work and accommodation issues.
15. Santerre says that the Cowan fonn is similar to (which I take to mean substantially the
same as) forms used by other insurers in.cluding Sun Life, Great~West Life and Manulife use for
the same purpose. (I note that a Manulife medical release form is in evidence (as Exhibit #30), but
I did not allow the Hospital to adduce examples of Sun Life or Great-West Life forms because they
had not been produced in accordance with my production orders. In any event, the mere fact that
an industry nonn has developed does not necessarily mean that the practice is acceptable.)
Santerre identified three uses for tile information obtained from the Cowan fonn: to detennine the
applicant employee's eligibility for ST.D benefits, to ensure that the employee receives proper
treatment, and to identify a return to work date and options. She testified that Cowan uses the
applicable HOODIP parameters to assess an employee's eligibility for SID benefits. It appears
from her testimony that her focus .io. that respect was on the 1992 HOODIP, which is quite
different from the 1980 .J-IOODIP that applies to many of the bargaining unit nurses (see
paragraphs 52 and 56-62, below).
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16. The Union does not o~ject to the personal infonnation sought in Section A of the Cowan
form. Section B is the consent to release infotm.ation part of the fonn. TIle Hospital's Attendance
Awareness Program document (Exhibit #41) speaks In term.s of employees providing "appropriate"
consents to the release of medical information sufficient to allow the Hospital to fulfill its
responsibilities. Santerre testified that the purpose of Section B is to infonn the employee of the
information that .is being requested and that more may be requested, of what Cowan will be doing
with the information, and to preserve the confidentiality of the information. She explained that
Cowan only wants infonnation that is "relative" to the absence in issue, that Cowan seeks
~'restrictions or limitations" infonnaHon for return to work purposes, notwithstanding that she is
aware that the Hospital has a separate return. to work informa.tion form (i.e. the F AF) and process.
Santerre says that Cowan seeks a release for "WSffi" infonnation so that it can coordinate return
to work e.fforts with that agency, and for an "Automobile insurer" [sic) because such an insurer is
the "first payer'~ if a claim arises out of a motor vehicle accident. She says that return to work
information may be shared with supervisors, and "when applicable" the WSIB, an automobile
insurer and the long-term disability insurer. Finally, Cowan decided to include the reference to
maximum reimbursement of$35.00 for completing the form, which Santerre says is in accordance
with OMA and CMA guidelines, so that the doctor will know that he will be reimbursed in that
amount and be aware that the employee will be responsible for any amount in excess of tha.t. This
is an.other illustration of Cowan's failure to review the collective agreement and ensure that the
Cowan form complies with it. Article 12.14 of the Central portion of the agreement clearly
specifies that the Hospital is responsible for the full cost of any medical certificate that is required
of an employee.
17. With respect to Section C, Santerre testified that requests for diagnoses are "nonnal in the
field". Although she agreed in cross-examination that Cowan doesn't necessarily need to have
diagnosis, treatment or medication infonnation to verify SID benefits eligibility and that an
employer only needs to know an employee's functional limitations, not the diagnosis (which she
says is not communicated to the Hospital in any event), Santerre nevertheless maintained that
Cowan requires the primary diagnosis and symptoms in order to perform its adjudication function.
She says the primary diagnosis and symptoms reveal the nature of the illness andpennits Cowan
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to assess the reasonableness of the duration of the absence. It is difficult to reconcile Santerre's
assertion that Cowan requires diagnosis and symptoms information to perfonn its adjudicative
function and to assess the reasonableness of the duration of the absence with her need to know
admissions in cross-examination. Not only did she agree with Union counsel that Cowan doesn)t
necessarily require diagnosis, treatment or medication information in order to verify (which I
consider indistinguishable from adjudicate) SID benefits eligibility, she frankly acknowledged
that an employer does not require diagnosis information. Ifth.e employer) in this case the Hospital,
does not require the infonnation, it is not entitled to it unless the collective agreement so provides
(an issue that I will return to below). Since a thi.rd party agent like Cowan stands in the shoes of
the Hospital neither is it entitled to it Notwithstanding this, Santerre maintained that such
information, "current findings" and a prognosis are "useful" for return to work purposes and to
assess the appropriateness of the treatment, which Santerre was quick to say was not for the
pwpose of questioning the doctor but to permit Cowan to facilitate or make treatment suggestions.
Santerre says that Cowan seeks a secondary diagnosis and symptoms because that could be what is
preventing the employee from returning to work. In cross-examination, Santerre agreed that the
Section C information is unnecessary because of the Hospital's own. .FAF return to work form and
process, but she continued to insist that Cowan nevertheless requires that information in order to
provide disability management and to facilitate and assist in the employee I s medical treatment.
Indeed, Santerre testified in cross-examination that the focus of Section C is on return to work
issues, and agreed that the Hospital' s own F AF provides all of the return to work infonnation that
an employer needs. It is clear from the evidence that the Hospital maintains complete control over
all aspects of the return to work and accommodation process notwithstanding the provisions in. .its
contract with Cowan in that respect
18. Santerre explained that the attending physician is in the best position to assess an
employee's medical status, and that the physician's role is to diagnose and treat the employee, and
provide functional abilities information, but not to determine whether the employee is totally
di.sabled for employment and benefits purposes. In cross-examination, SantelTe agreed that the
attending physician would be in a better position to do so if slbe were provided with a job
deSCription and demands analysis (which the Hospital has for all bargaining unit positions), but she
al.50 said that doctors have a Iim.ited amount of time to spend on these issues and often are not used
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to or comfortable deaHng with them. Santerre says that Cowan's role is to adjudicate the claim for
benefits, to ensure that th.e employee is receiving appropriate treatment, and to discern return to
work options. It appears from Santerre's evidence that Cowan is seeking the type and amount of
confidential medical information because its view is that a bargaining unit nurse is not totally
disabled for SID benefits purposes if she can do tbe essential or perhaps even. any of her normal
duties. This is the wrong test under either of the HOODIPs (see paragraph 52; below)
fiI. WHAT CONFIDENTIAL MEDICAL ~O:RMATlON CAN AN_ E~LQ~...B
REQUIRE
General Principles
19. At least two questions typically arise in medical information cases: what is appropriate as a
m.atter of general practice and policy, and what is appropriate in a particular case? These
grievances directly raise the general practice and policy issue. But they also engage the question
of the particular case as the counterpoint. That is, a question that arises is whether the sort of
invasive inquiry that may be appropriate in a particular individual case is also appropriate in the
first instance in every case.
20. Both subjectively and objectively, personal medical infonnation is confidential personal
information. The confidentiality of the doctor/patient relationship and personal medical
information is universally and legislatively recognized as one of the most significant privacy rights
in modern Canadian society. There appears to be a general societal notion that the right to privacy
is a basic human right, particularly in a modern democratic society. But employer and employee
rights in that respect do not arise out of the air. It is far from clear that there is a common law right
to privacy (althougb there is some American jurisprudence that seems to suggest there is - see~ for
example, Holloman v. Lift Ins. Co. o/Virginia, 192 S.C. 454, 7 S.E. 2d 169, 127 A.L.R 110), but I
think it unnecessary to digress into that discussion (particularly when the parties did not do so).
Although the right to privacy is not a right listed in the Canadian Charter of Rights and Freedoms
or the Human Rights Code~ there is privacy protection legislation that addresses and reflects the
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prevailing societal notions of privacy rights with respect to personal health infonnanon. This
legislation "occupies the field" and overtakes any common law notion of a right to privacy. The
Personal Health lnformation Protection Act, 2004 (the "PHIP A"; see Appendix "D'\ attached) is a
comprehensive piece of health care privacy legislation. The Occupational Health and Safety Act
(the "OHSA") contains a medical information privacy provision which prevails over the .PHlP A
(section 63(6); see Appendix "E", attached).
21. There is nothing in the mere existence of an employment relationship that gives the
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employer any inherent right to compel its employees to compromise their legitimate right to keep
personal medical information confidential. An employer only has a right to an employee's
confidential medical information to the extent that legislation or a collective agreement or other
contract of employment specifically so provides, or that is demonstrably required and permitted by
law for the particular purpose. Except where required or permitted by law an employer cannot
seek and a doctor cannot give out any patient medical information without the patient's freely
given infonned specific authorization and consent. But there are few if any things that are
confidenti.aJ for all purposes or in all circumstances and the privacy right that attaches to
confidential medical information is not absolute. The dispute between the parties reveals the
tension between an employer's right to or legitimate need for information in order to properly
manage its business and the workplace, and to meet its statutory and collective agreement
obligations, and an employee's right to personal privacy.
22. The law that applies to privacy issues includes the "law" that the parties to a collective
agreement of .individual contract of employment create for themselves. Of course this party
created law must fit within the mandatory parameters created by legislation. There is some
legislation that parties cannot contract out of (the Labour Relations Act. 1995 and the Employment
Standards Act, for example), and there is legislation that the parties can contract out of (the
Arbitration Act, for example). Parties cannot contract out of the PIDP A or the OHSA.
23. Most modem collective agreements contain sick leave benefit provisions. A fundamental
principle that underlies every collective agreement is that bargaining unit employees are under an
obligation to regularly attend work as scheduled in accordance with the collective agreement, and
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to provide notice of and a legitimate excuse for absences from work. Employees are entitled to be
paid for work pe1formed in accordance witb the collective agreement. In the absence of collective
agreement provisions employees are not entitled to be paid if they do not attend work. Employer
paid leave benefits, including STD benefits, are all contractual. Paid leaves of absence, whether
the absence is due to iJlness or injury, or othervvise are only available to the extent that the
collective agreement so provides, and then only on the negotiated terms that the agreement
stipulates.
24. The onus is on the employee to establish entitlement to collective agreement paid sick
leave benefits. This generally means that the onus is on the employee to establish that an absence
is legitimate in the sense that she is genuinely unable to report for work due to iJlness or injury. As
a general matter, the employer is entitled to sufficient "proof' of the employee's assertion that shc
is unable to attend work due to illness or injury and entitled to benefits. Also as a general matter,
even if there are no paid benefits available, or the employee elects to forgo them, the employer is
entitled to notice of the fact and expected duration of an absence for the legitimate business
purposes of work force management and a.bsenteeism control purposes. Both tbe employee and
the employer have a legitimate interest in and an obligation to facilitate as early a return to work as
possible, with accommodation as appropriate where reasonably available. The employer also has a
legitimate interest in investigating suspicious absences and information provided by an employee
in that respect. Of course alJ of this begs the question: what is sufficient "proof' in that respect?
What information is the employer entitled to and what infonnation must the employee provide?
25. As a matter of general p.rinciple in that latter respect, what is required is sufficient reliable
infonnation to satisfy a reasonable objective employer that the employee was in fact absent from
work due to illness or injury, and to any benefits claimed (see, Arbitrator Swan's comments in Rc
St. .lean De Brehe~f Hospital and C. U.P.E., Loc. 1101, (1977) 16 L.A.C. (2d) 199 at pp. 204-206).
As a general matter, the least intrusive non-punitive interpretive approach that balances the
legitimate business interests of the employer and tbe privacy interests of the employee is
appropriate. But what the employer is entitled to, and concomitantly what the employee is
required to provide, will first and foremost depend on what the collective agreement or legislation
provide in that respect.
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26. J note that the privacy legislation provision is written to require that (subject to exceptions
stipulated) the person concerned is the one who must provide an. appropriate consent to the
disclosure of her confidential medical information. This does not necessarily mean that the person
concerned is the only one who can consent to the release of confidential personal medical
information for the purpose of establishing the bon.a fides of an absence fOnD work or an
entitlement to paid benefits in that respect. In this jurisdiction a union which holds bargaining
rights for a bargaining unit of employees has tbe exclusive right to represent those employees in all
employment related matters. An employee cannot bargain directly with her employer in that
respect. Indeed. it is an unfair labour practice for an employer and an employee to bargain directly
with respect to any term, condition or other matter related to the employee's employment in the
bargaining unit (sections 70 and 73 of the Labour Relations Act, 1995). Accordingly, the Union is
entitled to negotiate both collective agreement benefits entitlements and the preconditions to such
entitlements, including the infonnation that must be provided in order to obtain a particular
benefit. That is, as the exclusive bargaining agent the Union can effectively consent to th.e .relea.se
of the confidential personal medical information that is required in order to establish entitlement to
an srn benefit payment on behalf of bargaining unit employees (subject of course to a bargaining
unit employee declining available sm benefits).
27. The several layers oflegitimate employer interests suggest that there is more than one stage
to the process that is engaged when an employee seeks the benefit of the sick leave provisions in a
collective agreement. It also suggests that the employer will generally be entitled to less
information at the initial stage than at a subsequent stage. The employer's desire for more
information, or its genuine concern for an employee's welI-being or desire to assist the employee~
operate to trump the employee's privacy rights. Nor do questions of expediency or efficiency. In
the absence of a collective agreement provision or legislation that provides otherwise the employer
is entitled to know only that the employee is unable to work because sbe j s ill or injured, the
expected return to work date, and what work the employee can or cannot do. A document in
which a qualified medical doctor certifies that an employee is away from and unable to work for a
specified period due to illness or injury is prima facie proof sufficient to justify the absence.
Unless the collective agreement (or less likely, legislation) stipulates otherwise~ it will also be
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sufficient to qualify the employee for any applicable sick benefits for that period. To require more
invites an unnecessary invasion of the employee's privacy. In order to obtain additional
confidential medical information, the employer must demonstrate a lcgitimate need for specific
information on an individual case-by-case basis. That is, for sick bencfits purposes an employer
has no primafade right to an employee's general medical history, a diagnosis, a treatment plan, or
a prognosis other than the expected date that the employee will be able to retum to work with or
without restrictions.
28. As a general matter there is nothing to prevent an employer from contracting out the
information gathering or assessment of medical information function, as the Hospital has done in
this case. But the party to whom the employer has contracted out this function stands in the shoes
of the employer and has no greater right to or need for infonnation than the employer has .if It
performs the function. itself. And the employer is responsible for the conduct of any third party
that performs such a function for it. However, the insertion. of such a third party; which is a
stranger to the workplace and beyond the direct reach of the collective agreement, may raise
suspicions and increase an employee's reluctance to provide confidential personal medical
information.
29. A diagnosis or statement of the nature of an illness is undoubtedly confidential medical
information. There is a broad and consistent arbitral and judicial consensus that in the absence of
contractual provision binding on the employee an employer has no right to a diagnosis. I agree.
The British Columbia jurisprudence draws a distinction between a "diagnosis" and a statement of
the "nature of the ilIn.ess". Is there a meaningful distinction between "diagnosis" and "nature of
the illness" such that an employer is entitled to the latter in the first instance?
30. Santerre testified that the "primary diagnosis and symptoms" requirement reveals the
nature of the illness. That is undoubtedly so, but is the reverse is not necessarily the case. Taber's
Cyclopedic Medical Dictionary defines "diagnosis" as "the term denoting the name of the disease
or syndromc a person has or is believed to have" based on medical tests or an examination of
symptoms. That is~ a diagnosis is a formal statement that specifically identifies a disease or injury
based upon an application ofmedicaJ scientific methods. It is a medical conclusion that is the
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product of a process of identifying or detennining the nature and cause of an illness or injury from
an. examination and evaluation of the patient. There are many kinds of "sy:mptoms" (e.g. objective~
subJective, cardinal and constitutional), but the term generally refers to any perceptible change in
the body or its functions which indicates disease or injury. "Nature ofiJIness" is not a medical
term. Having an "illness" or "injury" is the state of being sick or injured, as the case may be. In
this context "nature" refe.rs to the kind, class or essential qualities of a disease or injury.
Accordingly, "nature of the illness" (or injury) suggests a general statement ofa person's illness or
injury in plain language without any technical medical details, including diagnosis or symptoms.
Although revealing the nature of an illness may suggest the diagnosis, it will not necessarily do so.
"Nature of illness" and "diagnosis" are not congruent terms. For example, a statement that a
person has a cardiac or abdominal condition or that she has undergone surgery in that respect
reveals the essence of the situation without revealing a diagnosis. On.ce again, what information
the employer (or its agent) is entitled to in that respect beyond that described in paragraphs 24 and
27, above, is a matter of contract and legislation.
31. The 1980 HOOD IP refers to a proof of disability "such as a doctor's certificate" (see
paragraph 52, below). A "certifi.cate~' is a document that testifies to the truth of something. For
example, a birth certificate testifi.es to a person's birth name; sex, and the date and location of
birth; a marriage certificate testifies to the fact and prima facie legality of a marriage; and so on. A
certifi.cate from a qualified medical health professional testifies that s/he has assessed a person as
being incapable of working at her occupation due to illness or injury for a specified period and
constitutes prima facie proof of those facts. I agree with the thrust of the British Columbia
jurisprudence that it is not inordinately invasive for an employer to ask that a medical certificate
include the reason for incapacity, which would appropriately consist of a general statement of the
nature of the disabling iIJn.ess or injury, without diagnosis or symptoms. It is not unreasonable for
an employer to require an employee to prOvide tbe reason for ber absence or claim tor sm
benefits, and the mere fact that providing that reason (i.e. the nature of her illness or i~jury) may
suggest a diagnosis does not excuse the employee from providing the reason in order to satisfy the
onus on her to justify her absence and claim for benefits even in the first instance.
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32. But in the absence of a statutory or collective agreement requirement, a diagnosis or
description of symptoms or treatment goes beyond the certification of illness or incapacity that is
legitimately required in the first instance. It is only where the employer has a statutory or
collective agreement right to more infonnation, or where the employer has reasonable cause to
suspect the genuineness, accuracy or quality of the information provided to substantiate an absence
that it is entitled to additional information. For example, if the employer has au objective reason to
doubt that the doctor who signed a medical certificate actually saw or made any professional
evaluation of the employee or that the doctor was qualified to provide the assessm.ent in the
certificate, or suspects that the employee had gone "doctor shopping", or has infonnation that casts
doubt on the bona fides of the alleged illness or injury that the employer is entitled to seek
additional infonnation that is specific to and reasonably necessary to address its concerns (see, for
example, Re York County Hospital and S.E.L 0., Lot.'. 204, (1992) 25 L.A.C. (4th) 189 (Fisher,
Chair) at page 193). But these are issues that can arise in individual cases, and is not th.e more
general first instance issue before Ole in these policy grievances.
33. The issue in tbis case concerns the extent of the confidential medical. infonnation that the
employer can reguire an employee to provide in the first instance. This subsumes the consent issue
because the employer cannot require the employee to consent to a release of more confidential
personal medical information than it is entitled to for sick leave justification or benefits purposes.
The employer can always ask an employee if she is willing to volunteer more information than the
employer is actually entitled to, but an employer cannot coerce an employee into '.consenting" to
provide broader disclosure, and is not entitled to take disciplinary or other steps againstt or deny
sick benefits to, an employee who declines to provide more medical intonnation than the employer
is entitled to. An employer cannot require an employee to consent to a release of more
confidential medical information than is permitted or required by statute or the collective
agreement, and that is demonstrably necessary for the particular purpose.
34. Further, the intensely personal nature of confidential medical infonnation, the individual,
societal and institutional interests in preserving the confidentiality of such information, and the
protections that have been legislated to protect its privacy and use, suggest a conservative
approach. Accordingly, collective agreement provisions that speak to the information that an
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employee must provide to the employer in order to satisfy the employee's obligation to justify an
absence or to obtain SID benefits in that respect should be strictly construed.
35. In the first instance for SID benefits purposes, therefore, in the absence of statutory or
collective agreement authorization an employer cann.ot .require an employee to consent to the
release of more than certification that she is absent and unable to work because she is ill or injured,
the general nature oftbe Ulness or injury, that the employee has and is following a treatment plan
(but not the plan itself), the expected return to work date, and what work the employee can or
cannot do. Th.e consent must be both focused on the particular purpose and limited to the
particular medical professional. A consent that must be provided for the purpose of STD benefits
sbould not include return to work accommodation considerations other than whether there are
likely to be any restrictions on tbe anticipated return to work date. A "basket" consent that
purports to authorize anyone who the employer may ask to release confidential medical
infonnation is not appropriate. Nor is it appropriate to require an employee to sign a forward-
looking consent that may exclude her from the confidential medical information loop. The
overwhelming weight of the arbitral jurisprudence takes a dim view of consents that purport to
give an employer prospective permission. particularly where the consent purports to permit the
employer to unilaterally (with or without notice to the employee) initiate direct contact with a
doctor or other custodian of confidential medical information. Every contact should be through or
at the very least with the knowledge and consent of the employee. a separate consent should be
required for every contact, and every consent should be limited to the completion of the
appropriate form or tbe specific infonnation required, as appropriate.
36. In the absence of collective agreement authorization a "one size fits all" medical certificate
of disability fonn for sm benefits purposes will necessarily be limited in scope in the first
instance. Such a consent should identify the medical professional or custodian of medical
information~ specify the period it relates to, and although it can ask, the employer cannot require an
employee to consent to a release of the employee's general medical history, a primary or
secondary diagnosis, a treatment plan (as distinct from the fact that there is one and that it is being
followed), or any medical prognosis other than an expected return to work date.
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37. What an employer can require of an employee should not be mixed into the same form or
same section of the form as what it can ask an employee to volunteer. If a single form is used, it
must clearly distinguish between what information is required (i.e. what the employer or its agent
is entitled to) and what the employee is being asked to volunteer (i.e. what information the
employer or its agent would like to have if the employee is willing to allow the employer to
access).
38. An assertion or undertaking to treat all medical information received in a bighly
confidential manner. and disseminating it solely on a "'need to know" basis, alters none of this. It
does not expand an employer's entitlement to information, and really adds nothing to the equation
since the employer is under such an obligation in any event. Nor does the fact that an employee
has a continuing obligation to account for her absence and the employer has a concomitant right of
continuing inquiry in that respect alter the analysis. Th.e nature, extent and frequency of an
employer's requests for continuing information, from either the employee or medical professionals
must be reasonable in the circumstances (and is an issue addressed in Phase 3 of this proceeding).
The fact that a new focused consent is required every time an employer seeks to acquire
confidential medical information from someone other than the employee may appear to be
inconvenient or inefficient, but convenience or efficacy do not modify an employee's privacy
rights. This approach will also both encourage the employer to act reasonably and wl.th due
consideration of what it really requires for the particular purpose, and offer some comfort to an
employee who may already be feeling vulnerable and exposed.
The CUPE Case
39. The text of the Knopf Award in the CUPE case is two single-spaced pages long. It reveals
that a mediation/arbitration process was en.gaged to address "numerous" group and policy
grievances challenging the Hospital's use of Cowan to adjudicate benefits claims under the CUPE
collective agreement, and the Cowan fonn and conduct in that respect. The evidence before
Arbitrator Knopf was that Cowan ~ s employees are governed by their professional obligations
under the Regulated Health Prqfessionals Act. That is not the case for the all of the Cowan
. employees who deal with DNA bargaining unit nurses. The evidence before me is that at least two
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of these Cowan employees are not medical health professionals (see paragraph 12, abovc). The
Knopf A ward indicates that CUPE raised concerns about the text and content of the Cowan.
"Medical Certificate of Disabiliti' (i.e. the Cowan Form). Except for the treatment of the doctor's
fee for completing the fonn, these concerns are not specified, and the extent to which the arbitrator
considered the concerns to be valid must be gleaned form the amended form that is Appendix "B';
to the Knopf Award. A "Required Accommodation Form" was also in issue in the CUPE case.
There is an identical such fotm in evidence before me (Exhibit #24) but the parties paid scant
attention to it in the hearing. Their focus was on the Cowan form and the Hospital's own FAF. In
any case, it appears that the arbitrator's statement that she was satisfied that the conte.nt and
treatment of "this form." comply with all statutory requirements and do not violate the CUPE
collective agreement refers to this Required Accommodation Form and not to Cowan form that is
the focus of this proceeding. Because she does not provide any basis for her conclusion; I cannot
tell from her award whether the arbitrator was "satisfied" on the basis of her independent
assessment or because the parties came to an agreement in that respect through the mediation part
of the process. Since it is unlikely that a one-day mediation/arbitration process presented a full
adjudication opportunity in that respect I think that the latter is more likely the case. For policy
and practical reasons labour arbitrators are generally willing accept whatever agreements the
parties can come to, and unless there is an obvious legal problem are generally "satisfied" that the
parties' agreement is statutory and collective agreement compliant. Further; the excerpts from the
CUPE collective agreement that are appended to the Knopf Award reveal that only the 1992
HOODIP applies to the CUPE bargaining unit. There are significant differences between the 1980
and 1992 HOODIPs which are important in the case before me. For aU of these reasons the Knopf
Award is of limited assistance.
A Reality Check
40. I recognize that the real world is not an ideal one. In the ideal world doctors would have
perfect knowledge ofthe relevant m.edical matters, their patients and their patients' workplaces,
and would be completely objective. If that were so, a doctor's s.imple statement certifying that an
employee was ill and unable to work for some specified period of time; and specifying restrictions
for return to work and accommodation purposes when and as appropriate, would be good enough
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for all purposes and nothing further, including any diagnoses or even a statement of the nature of
the illness or injury would be required. But that is not the real world, or at J.east not the one I am
famiUar with. Medical health professionals are also human beings. The fact is that they are n.ot
always entirely o~jective. It is quite appropriate f.or medical health professionals to act as
advocates for their patients in medical matters within their competence, but n.ot when tbe advocacy
extends bey.ond their medical expertise or matters .of which they have direct knowledge, such as
when they bave little or no kn.owledge .of tbe workplace .or th.ei.r patient's j.ob or empl.oyment
situation other than what their patient decides to tell them.
41. Having said that, this case concerns nurses employed in a hospital setting. As a group,
physicians are uniquely situated t.o assess a nurse's ability t.o work in a hospital. A physician is
likely to know m.ore about the w.ork that a nurse patient typically performs than he does about the
work that other patients are engaged in. A physician is likely t.o know what s.ort .of nurse his
patient is and the nature of the w.ork in the department she works in, and is therefore likely t.o be in
g.ood position to assess her ability to perf.orm the w.ork of her occupation.
42. Arbitrators who have concluded that particular collective agreements do not require
medical diagnoses to be disclosed to the employer have observed that the employer can often guess
the diagnosis from the restrictions.or other accomm.odations that are suggested by a doct.or. That
is, a diagn.osis can often be discerned even when it is not specifically stated. If S.o, one might well
ask: s.o why not provide the diagnosis? And how can one reas.onably object to providing
inf.ormati.on which will probably also discl.ose the diagn.osis when that inf.ormation is reasonably
required for return to work or accommodation purposes? Is the situation different when an.
employee is seeking SID benefits? And if it is, and strict limits are imposed.on the use of the
information that must be discl.osed in the first instance for th.ose purposes, what is the likely result?
Could limiting an employer's access to confidential medical inf.ormation result in applications f.or
sick leave benefits being rejected more .often, perhaps requiring more frequent resort to the
expensive and time-c.onsuming grievance arbitration process? If so, b.oW does it serve the
employee seeking benefits, the privacy interests of that empl.oyee, the interests .of the parties, or the
health system?
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43. First of all~ the issue before me concerns the Hospital's entitlement (through its agent
Cowan) to confidential medial infonnation in the first instance. The fact that additional
infonnation may subsequently be required does not mean that the employer is entitled to it in the
first instance.
44. Secon~ it is true that if the matter goes to arbitration, the employee will have to establish
that she is (or was) entitled to the benefits. To establish this, it will generally not be good enough
to present a doctor's certificate stating only that the employee was disabled and unable to work for
a specific or indefinite period. The employer will be entitled to test the claim and the doctor's
assertion by questioning the empl.oyee and requiring that the doctor to attend the hearing and give
evidence, something that even the most cooperative doctors do not like to do. The employer will
be entitled to examine the basis for the simple certificate, which will inevitably include what the
doctor did or did to do, hislher knowledge of the patient and the workplace, and what conclusions,
including the diaJmosis, and the basis for the conclusions slhe atrived a.t. The employee's personal
and medical history will be subject to much more detailed and intense scrotiny at such a hearing,
and in a much more public forum, than. is the case in the normal benefits application process. At
the end of a lengthy, and for the employee an arduous and often nerve-wracking legal proceeding~
the employee may well be awarded the benefits sought, which benefits may well have been
approved many months before in the frrst instance if more information had been provided in the
first place. That is, there is a danger that an employee will not receive benefits that she is entitled
to in a timely way, when they are most needed.
45. But the real world also includes a society mandated legislated right to privacy, and the fact
that narrow disclosure of medical information may have unfortunate or unintended consequences
in an individual case, or tbat broad disclosure of medical information may be appropriate or
required in preparation for or during a grievance arbitration (or other legal) proceeding does not
alter the analysis. Either an employee has privacy rights or she does not. A right that cannot be
exercised is no right at all. Although early broad disclosure might prove to have been useful in a
particular case, this does not mean that such broad disclosure is necessary or appropriate in the first
instance in every case as a matter of general poHcy. There are many business or other matters on
both sides of the labour reJati.ons divide that are "confidenti.al" outside of the grievance litigation
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process which are no longer confidential for litigation purposes once tbe grievance arbitration
process is invoked. That docs not suggest that they should not remain confidential outside of the
litigation process. Indeed, the legislative scheme treats litigation disclosure requirements or
obligations as an exception to the general mle of voluntary consent restricted to the purpose
disclosure of personal health infonnation.
46. The appropriate requirements and concomitant limitations on the disclosure of confidential
medical information is also something that the parties to a collective agreement can address
themselves to in bargaining. . In a particular case, the possible consequences of refusing to provide
broader disclosure than is technically required in. the first instance is something for the individual
employee to weigh, hopefully in consultation with the Union, when she is considering her response
to a request for confidential medical infonnation. It is also one of the things that the parties and
the employee(s) must consider when they contemplate engaging the grievance litigation process.
But the real significance of the real world analysis is that it focuses on individual circumstances
and further demonstrates that less disclosure of confidential infonnation is required in the more
general first instance inquiry than in an individual case in which questions arise.
IV. DECISION
47. Turning to the case at hand, I begin by looking at the legislation and collective agreement.
Le~islation
48. The PHWA is a comprehensive piece of health care privacy legislation. It recognizes the
confidentiality of personal medical infonnation and, among other things, establishes rules for the
collection, use and disclosure of personal health infonnation to protect the confidentiality and
privacy of that information. Relevant excerpts from the PHIP A are set out in Appendix '~D".
Section 63(6) of the OHSA contains a medical infonnation privacy provision which prevails over
the PHIP A (see Appendix ~'E"). I bave already noted that the parties to a collective agreement are
bound by and cannot contract out of this legislation.
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49. The legislation reflects the modem approach to the issue and emphasizes the individual
employee right to keep confidential medical information private except where it is absolutely
necessary to disclose it. The PHIP A makes it clear that the individual's freely given (i.e.
uncoerced) express or implied informed consent regarding specific personal health information
must be obtained before any such jnformation can be colJected used or disclosed (section 18) and
that personal health information shall only be collected, used or disclosed to the extent reasonably
necessary to serve the particular purpose (sections 30 and 37). The OHSA, which prevails over the
PHIPA, specifies that no employer (or its agents) shall even seek access to a worker's health
records except under authority of a court or tribunal of competent jurisdiction or as required by law
without the worker's consent (section 63).
The Collective AlU'eement
5Q. The collective agreement between the parties in evidence is in two parts: the "Central
Agreement", which as its label suggests is negotiated (or arbitrated) centrally between the
"Participating Hospitals" as a group and the Union, and the "Local Agreem.ent" negotiated directly
between the Hospital and the Unlon. The Central portion of the collective agreement between the
parties includes the following sick leave provisions:
ARTICLE 12 - SICK LEAVE AND .LONG... TERM DISABILITY
(Articles 12.01 to 12.1 I apply to full-time nurses only)
] 2.01 The Hospital will assume total responsibility for providing and funding a short-term
sick leave plan at least equivalent to that described in the 1980 Hospitals of Ontario
Disability Income .J:>lan brochure.
The Hospital wiJI pay 75% ofthe billed premium towards coverage of eligible employees under
the long-term disability portion ofthe Plan (HOOOlP or an equivalent plan). The employee will
pay the balance of the billed premium through payroll deduction. For the purpose of transfer to
the short-term portion of the disability program, employees on the payroll as of the effective
date of the transfer with three (3) months or more of service shall be deemed to have three (3)
months of service. For the purpose of transfer to the long-term portion of the disability program,
employees on the active payroll as ofthe effective date of the transfer with one (I) year or more
of service shall be deemed to have one (I) year of service.
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12.05 Any dispute which may arise conceming a nurse's entitlement to short-term or long-term
benefits under HOODJP or an equivalent plan may be subject to grievance and arbitration under
the provisions of this Agreement. The Union agrees that it will encourage a nurse to utilize the
carrier's medical appeals process, if any, to resolve disputes.
12.11 A nurse who is absent from work as a result of an j Ilness or inj ury sustained at work and
who has been awaiting approval of a claim for Workers' Compensation for a period longer than
one complete pay period may apply to the Hospital for payment equivalent to the Jesser of the
benefit the nurse would receive from Workers' Compensation if the nurse's claim was approved
or the benefit to which the nurse would be entitled under the short-term sick portion of the
disability income plan (HOODIP or equivalent plan). Payment will be provided only if the
nurse provides evidence of disability satisfactory to the Hospital and a written undertaking sat-
isfactory to the Hospital that any payments will be refunded to the Hospital following final
determination of the claim by The Workplace Safety and lnsurance Board. If the claim for
Workers' Compensation is not approved; the monies paid as an advance will be applied towards
the benefits to which the nurse would be entitled under the shorHerm portion of the disability
income plan. Any payment under this provision will continue for a max.imum of fifteen (15)
weeks.
(Articles 12.12; 12.13 and 12.14 apply to both full-time and part-time nurses)
12.12 Nurses returning to work from an illness or injury compensable under Workers'
Compensation will be alisigned light work 8.5 necessary, if available.
12.14 lfthe Employer requires the employee to obtain a medical certificate, the ~'p-loyer shall
pay the full cost of obtainin.R: the certificate.
NOTE: This clause shall be interpreted in a manner consistent with the Ontario Human
Rights Code,
(Emphasis added.)
The Local portion of the collective agreement contains tbe foHowing management rights provision:
ARTICLE C - MANAGEMENT RIGHTS
C- t Except as specifically abridged, delegated, granted or modified by this Agreement, all the
rights, powers, and authority of management are retained by the management and remain
exclusively and without limitation witbin the rights of management
C-2 Without limiting the generality ofthe foregoing, management's rights in.cludc:
a) The light to maintain order, discipline and efficiency, and in connection therewith to make,
alter and enforce from time to time, reasonable rules and regulations, policies and practices,
to be observed by its' employees, and the right to discipline or dismiss employees for just
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cause.
b) The direction of the working forces; the right to plan, direct and control the operation of
the Hospital, the right to introduce new and improved methods~ facilities and equipment,
the right to determine: the amount of supervision necessary, combining or splitting up
departments, work schedules, establishment of standards and quality of care, the
determination ofthe extent to which the Hospital will be operated and the increase or
decrease in employment.
c) The right to select, hire, discipline, dismiss, transfer, assign to shift, promote, demote,
classify, lay--off, recall, suspend employees and select employees for positions not covered
by this Agreement.
d) The sole and exclusive jurisdiction over all operationst buildings, machinery and
equipment vested in the Hospital. .
C-3 The exercise of any of these right.. will not be inconsistent with the provision of this
Agreement.
51. Notwithstanding Article 12.01, it is common ground that the 1980 Hospitals of Ontario
Disability Income Plan ("HOODIP") applies to bargaining unit nurses hired before January 1,
2006 and that under the current coUective agreement the 1992 HOODIP applies to bargaining unit
nurses hired on or after January 1,2006. There is no suggestion that the HOODIPs do not form
part of the coUective agreement between tbe parties. This being a forward-looking policy
grievance, it is appropriate to consider the implications of both, notwithstanding that the
grievances predate the actual introduction of the 1992 HOODIP.
52. Th.e 1980 HOODIP provides (with emphasis added) that it:
... consists of two periods of benefits, the Sick Pay Bene.fit and the Lo.ng Term Disability
Benefit. These cover the periods before and after the payment of disability benefits by the
Unemployment Insurance Commission.
For the purposes of the Sick Pay Benefit and the Long Tenn Disability Benefit, "total
disability" and "totally disabled" 1l1ean, during the first 104 weeks you are absent from
work, that you are unable to perfonn the regular duties ~itljn~ to your occupation due to
injury or illness and that you are not engaged in any gainful occupation. After 104 weeks,
you must be prevented, by injury or illness, from engaging in any gainful occupation for
which you are or may become fitted by training; education or experience.
REINSTATEMENT OF BENEFIT
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When you return from an absence and work fuJI-time continuously for three weeks, your benefit
period of 15 weeks is reinstated in full. If you are absent from work again due to total disability for
the same or a related cause or before you have completed three weeks of full-time employmen4 the
balance of your original sick pay benefit will apply. However, if your subsequent absence is due to
a different illness unrelated to the initial one, the full IS-week benefit period wilt apply evon if the
absence due to the second .illness occurs within three weeks following your return to work
PROOF OF DISABlLITY
Proof of your total disability ID!tisfactory to your employer such as a doctor's cerl;i.fiC4!t~ is required
for absences of three days' duration or over, and is subject to a periodic review thereafter. However,
such proof may be required at any time in order for you to qualitY for benefits.
(Emphasis added.)
The 1992 HOODIP contains relevant provisions as follows:
Introdudion
The Hospitals of Ontario Disability Income Plan ("HOODIP") is comprised of two parts: the short
term disability plan (Part A) and the long term disability plan (Part B) ... the Sick Pay benefit (part
A), covering the first 15 weeks of Total Disability. The Sick Pay benefit is administered and paid
by the Participating Employer. ..
Definitions
Actively working and Actively at Work mean the perfonnance for a Participating Employer of
the regular duties ofilie person's own, occupation for one full working day or shift. This includes
vaclrtion days, personal days andlor holidays 88 well as occasional days used for educational
purposes or union business, as granted by the Participating Employer. An Employee on extended
leave, such as an approved leave of absence, is not considered to be Actively at Work.
Total Disability and Totally Disabled means the Member has a medically determinable ph)!sical
or mental imp-ainn~t due to injury or illness which prevents her from perfonning the regJ!lar duties
of tile occupation in which she participated imm~!iJ!teJy preceding the start Qfthc disability.
Entitlement to Benefit
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A Member is not considered Totally Disabled unless she is under the active. continuq,us and
medically appropriate care of a Phvsioian and is followinlLthe treatment pr~sc:ribed by the
,~hYsician for that di.sabHity.
A Member is not considered Totally Disabled due to a psychological disorder unless she is under
the !!ptive an~lJtinu~us pare of a Physician or other professional ~tisfactory to the ParticiRatinR;
Employer and is fQ)lowin,R; the tr:e.atment nrescribed by the Physician or other professional for that
disability.
Recurrence ofDisabiJity
Recurrence
If a member returns to work after receiving Sick Pay benefits under this Plan any subsequent period
of Total Disability for the same or related cause will be considered as a continuation ohhe previous
benefit period, unless the successive periods of Total Disability are separated by a period where the
Member;s Actively at Work for:
I. three regular work weeks for full-time employee; or
2. aU of the scheduled working days within 21 calendar dsys for a part time employee,
in which case her benefit period of 15 regular work weeks will be reinstated in full.
(Emphasis added.)
53. The Union acknowledges that in the past individual employees have given the Hospital a
broad consent and access to their confidential medical information, and that such broad access may
be appropriate in a particular case. Indeed a review of the Attending Physician's Statements that
were used by the Hospital's EHS Department pre~Cowan (see Appendix "AA") reveals that they
too asked for a primary diagnosis, whether the employee had previously suffered fomt the same or
a similar condition, any conditions or secondary diagnosis underlying the current illness, whether
the employee bad been hospitalized and when, whether the employee had undergone surgery as
welt as the date of the surgery and the name of the surgeon, whether a specialist was involved or
had been consulted, and the treatment and dates that it had been provided. That is, the.re are many
similarities between the intrusive questions in the EHS form, to which it appears the Union did not
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object; and those that the Unlon complains about in the Cowan form. However, the consent that
was required by EHS Attending Physician's Statements was much narrower than the disputed
consent in the Cowan fO.nll.. The consent in the Attending Physician's Statements wa~ .limited to
the treating physician (as opposed to '<any party involved in my treatmenf" in the Cowan fonn),
and it restricted the information that could be passed through the "Chinese wall" between the
Hospital and its EHS Department to a statement indicating whether the employee was unfit for
work, fit to work with restrictions or fit for regular work, and the return to work date if known (as
opposed to the far broader disclosure and use of information contemplated by the Cowan consent).
55. But none of that is really significant. The fact that the Union did not complain about an
EHS form that required similar disclosure or that individual employees bave given broad consent
and acoess to their confidential medical records in thc past, with or without the knowledge or
participation of the Union is neither here nor there. The personal nature of confidential medical
information is such that permission to access it may be revoked at any time, subject to the
consequences of doing so. Except where the issue .ls one of interpretation of collective agreement
provisions in that respect, the concepts of past practice or estoppel do not apply. That is, the fact
that an individual employee or bargaining unit employees as a group have voluntarily permitted an
employer broad access to confidential information in the past, or that their union has acquiesced to
this, does not mean that either tbe employees or the Union must continue to do so.
56. There are significant relevant differences between the 1980 and 1992 HOODIPs. Under
the 1980 HOODIP "totaJ disability" for sm benefit purposes means an inability to perform "the
regular duties pertaining to your occupation" because of illness or i~jury and requires proof
"satisfactory to your employer sucb as a doctor's certificate". Under the 1992 HOODIP "total
disability" for STD benefit purposes means "a medically determinable ... impainnent" because of
illness or injury tbat prevents the employee from performing ''the regular duties of the occupation"
when the disability began. In order to be entitled to the SID benefit; the employee must be "under
the active, continuous and medically appropriate care" of an appropriate medical professional "and
is following the treatment prescribed" for the disability.
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57. For SID benefit purposes, "medically detenninable" really means no more than "which has
been determined by a medical professional" in order to eliminate any suggestion that an
employee's subjective assessment or one by someone other than a medical professional might bc
sufficient. J am satisfied that the definition of(1otal disability" (and the concomitant "totally
disa.bled") is the substantially same under both HOODIPs; name)y~ an employee's medically
confirmed inability to perform the ~ular duties of her occupation due to illness or injury.
58. Under the 1980 HOODIP, all that is required to establish "total disability" for SID benefit
purposes is proof "satisfactory to your employer such as a doctor's certificate". "Satisfactory to
your employer" does not imply either a subjective test or broad employer discretion with respect to
the proof that can be required. The test is one of objective reasonableness. Further, the phrase is
modified by "such as a doctor's certificate"; which must be interpreted in light of the significant
privacy protections legislated for confidential personal medical infonnation. Accordingly, this
provides an example of what is deemed to be objectively reasonable proof for 1980 HOODIP SID
purposes: namely, a doctor's certificate or the equivalent, which.l am satisfied means a certificate
from a medical health professional qualified to make the m.edical assessment attested to. That is,
in the fIrst instance under the 1980 HOODIP, the cmployer is not entitled to more than a certificate
from a qualified medical health professional that states that s/he bas assessed the employee as
being incapable working at her occupation due to illness or injury for a specified period, the
general nature ofthe illness or injury, that the employee is undergoing treatment (without
specifying what it is), and the anticipated return to work date. The employer can only obtain
additional confidential m.edical infonnation if it has objectively reasonable grounds to doubt the
accuracy, truth or adequacy of the certificate. There is nothing in the legislation or the collective
agreement (which includes the 1980 HOODIP) which entitles the employer to a diagnosis or
recital of symptoms, a medical history, the tests or other investigations performed, the treatment
plan, or a prognosis other than the expected return to work date and identifIcation of any
accommodation requirements at that time.
59. There are significant differences between the 1980 and 1992 HOODIPs. The 1992
HOODIP requires proof that the employee seeking SID benefits has a medically determinable
impairment (i.e. that a medical health professional bas assessed the employee and concluded that
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she is has an injury or illness which medically prevents her fro.m performing the remtlar duties of
her own occupation for a specified period) and that she is "under the active, continuous and
medically appropriate care" of an appropriate medical professional "and is following the treatment
prescribed" tor the disability. Under the 1992 HOODIP fo.r other than a psycholo.gical disorder the
employee must be under the care of a physician, not any other kind of medical professional, which
suggests that the proof of disability must come from a physician. In the case o.f a psycho.logical
disorder the employee m.ust be under the "active and continuo.us care" of a physician or other
professional satisfactorY to the employer. That means that in the case of a psychological disorder
the employer can choose the physician or other professio.nal who the emplo.yee is assessed and
cared for by for SID benefit purposes. The requirement in the 1992 HOODIP that the employee
be under "medicalIy appropriate care" and is following the treatment prescribed entitles the
employer to proof from the physician or (in the case of a psychological disorder) other professio.nal
that the employee i.s under bislher active, continuous and medically appropriate care far the
disability. This requires more than a mere attestation to. that effect. After all would any physician
or other professio.nal attest that a patient was receiving anything other than medically appropriate
care? Under the 1992 HOODIP the employer is entitled to make its own assessment of the
medical appropriateness of the care.
60. Accordingly, in the first instance under the 1992 HOODIP tbe emplo.yer is entitled to a
statement from a physician, or in the case of a psycho.logical disorder fro.m a physician or other
professional satisfactory to the emplo.yer, that states that slhe has assessed the employee as being
incapable of perfo.nnmg the regular duties of her o.ccupation due to illness or injury for a specified
period, the general nature of the illness or injury, that the employee is under his/her active and
continuou.c; care, a description o.fthe treatment plan and an attestatio.n that the employee is
follOWing the treatment prescribed, and the anticipated return to work date.
61. .In the first instance under the 1992 HOODIP, the employer is still n.ot entitled to a primary
or secondary diagnosis or symptoms, or to particulars o.fthe employee's medical histo.ry, or the
tests or other investigations performed, or to. a prognosis other than the expected return to work
date and identification of any accommodatio.n requirements at that time. The employer can o.nly
obtain confidential medical information in excess of the broader medical statement it is initially
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entitled to under the 1992 HOODJP if it has an objectively reasonable basis for doubting the
accuracy or truth of the information provided in the ftrst instance.
62. The employer is entitled to more confidential personal medical information under the 1992
HOODIP than under the 1980 HOODIP but in the first instance in both cases the employer is not
entitled to more than the medically appropriate attestation as aforesaid unless it has an objectively
reasonable basis for doubting the accuracy or truth of the information provided. In tbe first
instance an employer is not entitled to require an employee seeking STD benefits under either
HOODIP to consent to the relea..qe of more medical information than it is entitled to.
Conclusion
63. I am satisfied that the Section B - Consent Information of the Cowan form overreaches.
First, the consent should be limited to the treating physician (or other professional in the case of a
psychological disorder under the 1992 HOODIP). If there is more than one medical or other
professional involved a separate consent is required for each. Second, there is no primafacie basis
for including any reference to an automobile insurer, which is likely to provide only second hand
information if the employee's disability arose out of a motor vehicJe accident with respect to which
an insurance claim was made. There is no basis for including any reference to the WSIB which
operates under a separate statutory insurance scheme for workplace injuries; and which provides
its own disclosure (including fonns to be completed by the accident employer and the treating
medical professionals), adjudication and retum to work process. Neither an employer nor any
agent of the employer can pUlport to "adjudicate" a WSIB claim. If the WSlB process is engaged
and Cowan's assistance is required that is a separate matter and is prIma fade not part of the STn
benefits claim process. Third, neither the Hospital nor Cowan can seek access to "all information
and documents requested concerning [the employee's] medical condition relative to this claim for
the purpose offacilitating the delivery oftbe best medical care and assessment of [the employee's]
ability to work." It may not be the place of a medical health professional to assess an employee's
entitlement to SID benefits under either HOODIP (but see my observation in paragraph 41, above,
regarding the likelihood that physicians are likely to be more familiar with the duties and
responsibilities of nurses in a hospital environment and able to assess their ability to perform the
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32
same, than of other occupations); but bow can it not be the place of the treating physician or other
professional who actually examines and treats the employee/patient to assess the employee's
ability to work and to dctctmine and facilitate treatment? How can it be the place of someone who
may be less qualifi.ed (and who may not even be a medical health professional) and who bas never
met the employee or been in the workplace to assess that employee's ability to work - particularly
when they could only do so on the basis of the information provided by the very professional who
the Hospital and Cowan assert cannot do so? Fourth, an undertaking to hold all medical
information obtained confidential is appropriate, but the employee should not at the same time be
required to consent to the disclosure of more infonnation than the Hospital is entitled to.
Disclosure should be limited to tbat expressly authorized by the employee or as required or
permitted by law. Fifth, the employee should never be cut out of the communication loop. Direct
contact between the employer (or its third party agent) and the employee's medical caregivers
without the employee's knowledge or consent is prohibited. In order to give the employee an
opportunity to object, the employee should be advised in advance of any such communication in
any event. Sixth, the collective agreement clearly specifies (in Article 12.14 of the Central
portion) that the employer shall pay the full cost of obtaining the certificate. It is wrong to imply
that the employee may be responsible for any amount in excess of$35.00 (or any other am.ount).
There should be no reference to the medical professional's fee, either maximum or othervvise in
consent, or indeed anywhere in the Cowan form. Since it is the Hospital, either directly or through
its agent Cowan, who is responsible for payment that.matter is best dealt with. as a separate matter
directly between (in this case) Cowan and the medical health professional, perhaps in a separate or
covering letter.
64. The Union's complaint about the form ofletter (whish J observe refers to only the 1992
HOOOIP - see paragraph 10, above) that is sent to employees along with the Cowan form may be
an overreaction, but J appreciate the Union's concern. when the letter is read together, as it must be,
with what I have concluded is the overly broad consent in the Cowan fonn. J am satisfied that it is
not improper coercion to inform an employee that they may be disqualified form receiving STD
benefits if they fail to provide the anoronriate medical or other information that the Hospital and
Cowan are entitled to.
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65. As for Section C - Medical Information, I suggest that separate forms are required for
employees covered under the 1980 HOODIP and those covered under the 1992 HOODIP.
66. In the first instance under the 1980 HOODIP the Hospital and Cowan are only entitled to a
certificate from a qualified medical health professional that states that s/he has assessed the
employee (including the date(s) of the examination/assessment) a.~ being incapable working at her
occupation (which should be specified) due to illness or injury for a specified period, a statement
of the general nature of the illness or injury, a statement that the employee is undergoing treatment
(without disclosing the treatment or treatment plan), and the expected return to work date and any
accommodation requirements likely to be required at that time.
67. In the first instance under the 1992 HOODIP the Hospital and Cowan are only entitled to a
statement from a physician, or other professional in the case of a psychological disorder, that states
that slhe has assessed the employee (including the date(s) of the examination/assessment) as being
incapable of performing the regular duties of her occupation (which occupation should be
specified) due to illness or injury for a specified period, a statement of the general nature of the
illness or injury, that the employee is under his/her active, continuous and medically appropriate
care for the disability, a description of the treatm.ent supplied, the treatment plan and an attestation
that the patient is follo~ the treatment prescribed, and the expected return to work date and any
accommodati.on requirements likely to be required at that tlln.e.
68. Under both the 1980 and the 1992 HOODIP the Hospital is also entitled to know when the
illness began or the accident occurred and when the employee became unable to attend work, and
the date of the fIrst medical examination. It might also be useful for the Hospital to know whether
the illness or injury is work...related so that the wsm process can be engaged if appropriate.
However; J am not sure that is necessary because I expect that nurses know enough about the
WSIB process, with or without tbe assistance of the Union, to know when.it is appropriate to
engage it. The Hospital is not entitled to the other information sought on the Cowan Fonn "wish
list". As the Hospital's agent Cowan is not entitled to diagnoses; symptoms, medical history, the
specifics of medical investigation or current findings, treatment or prognosis other than as
indicated above. This entire section will therefore have to be significantly revised in accordance
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34
wi.th this Award. In the fIrst instance, the Hospital is not entitled to all of the information on the
Cowan form "wi.sh list",
69, The Hospital or its agent Cowan can ask an employee to volunteer additional confidential
infonnation, but in the first instance that should be done on a separate form or at least a separate
page that makes it clear that the employee is not obliged to make the disclosure and which requires
a separate consent for each parcel of confidential personal medical information. (The information
requested should not be as a single package because an employee may be willing to disclose some
but not other voluntary infonnation.) If the Hospital or Cowan has reasonable cause to doubt the
accuracy or bona fides of the information provided in the fIrst instance, or if that information is
objectively insufficient for SID benefits purposes in the circumstances of a particular case, they
can seek specific broader disclosure. Doing so will engage an individualized process.
70. In tbe result, this part of the grievances must be allowed. Accordingly,
(a) I DECLARE THAT the Cowan fonn is improper because it requires employees to consent
to a release of private personal medical information in excess of what the Hospital or its
third party agent Cowan is entitled to in the fIrst instance for either SID benefits or return
to work purposes under either the collective agreement or otherwise.
(b) I ORDER THAT use oftbe current Cowan fonn cease forthwith.
(c) I ORDER THAT a new form or forms may be constructed for STD benefits purposes,
which form ( s) must comply with this Award.
(d) I ORDER THAT the Hospital to ensure that its third party agent Cowan complies with
this Award.
(e) I WILL REMAIN SEIZED for tbe purposes of rectification, and to deal with any issues
arising out of the implementation of this A ward. In order to relieve the parties of the time
and expense of litigating the propriety of any new Cowan or other fonn that is constructed
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35
for use in administering the SID benefits under either the 1980 or the 1992 HOODIPs
anew or before another arbitrator, J will remain seized to deal with any issues in that
respect as welJ.
71. .I recognize that this Award may result in a somewhat cumbersom.e process, but rights are
rights and employees who ~eek SID benefIts are just as entitled to stand on their legislated or
collective agreement privacy rights as anyone else.
DATED AT TORONTO THIS 5TH DAY OF OCTOBER 2007.
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WhIt --1fMt.... 011 1hIt........_1
WhIt fbncldcM lImftMlou.... yow pIIiwltt. IIWIiIJ to ~ lliIIIheraorM ICltMtJa,IncIIIdlttt \WIt?
wa..t inYe:nlptions tums becm doIIe? PleMcllllt IpOCItlc ... bdcnr.
lib
of RIIUIt$
4. T......t
DateoflMtvlllt: I I Dereofnu;tvtstt: '_'_
oo.n oo*n
l~ iheClW'Nlttdledl~ 1IMl..... ~ as well. dIo NIpOIW: fD these ~:
'IbenIpy? _Yes _No JfHf'.t" mdIcate fJ1Je .. O~y <.... pbytItJCh-.py. PIJ~oIIPy)
~ _Ves_No Jf.-y."~ofMg<<y:
Date: ~ _..a-...I 1 I
............,.-........... ,.....- SWW
AJq oUter CftlIbnent or fUturo ~ Ibr ......1Clftt?
SummIlrim pMfont's ...~ to ~
.... yourplCtent been n6rred to.. oda ~I}-~I)? ~ Yea--..--No
U-VfJI" ~'. MIlO ftDCIlpfdaIC) n.o(a..~ ~
Day Month V_ .
5. ........18
PIeue ptvfldCl dat8Ib *'-tae...... to WCIIt pi-. ~ Ippf~ time ~ CM" wark OC'-.odfflod wmt; l.medulc).
= ~- -:. = ' :"' :: ;. .;...
Nodceto Ptv&lul.o: Aff1 .......... pm.tded by 1UU to the Mec1b19cnfce PM~ IDlY be ~.. ClIo.... ~ those
auIborIzed by b~ to n::odv~.... dhatoM..
~"~
n.__L_.J_
un Mh( YY
PriIIt -..ntr.
Phano G\Imbclr ( )
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PAGE 43
Please identify dates of your treatments of the patient for this condition within the past month:
To the best of your knowledge,. indicate the datestbat your patient has been totally disabled (unable
to work in any capacity):
From: _____I ~/_ (yylmmldd)
To: _'_'_ (YY/mmldd)
Can ttie patient return to usual work now? Yes
If no, can be/she return to modified work now? Yes
No .
~
No
8) Iryes, what specific .-estrietions(eg. HOUfS, posttu'es,lifting)?
b) Ifno. your best estimate ofdateabletorctum?
....
When do you plan to see your patient next fur this condition?
Other comments
Yow: name; Dr.
Practice Address:
Telephone 1#;
Signature:
- -Date: _'_'
. ". ;
(yy/mmldd)
Authorization for Release of Infonnation
I hereby authorize my treating Physician to Complete this Conn nnd fot: thiS information to be
released to my confidential medical file in EmplOYe(: Health Services, Hamilton Health Sciences.
I consent for Employee Health Semoes to rel:ease only the following limited infonnation to
Hamilton Health Sciences,. based on my Doctor's report. .
, ,
-- .
a) Fitness for work. A statement indicating whether I am. unfit for wort<, fit to work with certain _
restrictions or fit for regular work. .'
b) Date of expected return to work ifit is known. Hamilf9n Hea1fh Sciences may be notified ifno
return to. work date bas been detennined.
--~-~-~~------------~-----~-
___...~................--_..--,..~~___.A.flt.....____..........---....-...-_...""'"
Date:
Patient's Signa!llre:
Affiliated with the F<ttulty of[{ealth ScleltC(s, McMasrar (/nivtrs{(y
Fpdated No" 2001-hr .1
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APPENDIX "C"
Healtb and Disability Management
Consnlting Services
Service Agreement
between
Cowan Wright Beauchamp Limited
641 Montreal Road
Ottawa, ON KlK OT4
100 Regina Street South
Suite 270, Box 96
Waterloo, ON N2.J 3Z6
and
Hamilton Health Sciences Corporation
Sanatorium Road
Hamilton, ON
L9G 3NS
Whereas Hamilton Health Sciences Corporation (HHS) administers and pays full income
protection during illness absences ("sick leave") to its eligible employees.
And whereas HHS has requested that Cowan Wright Beauchamp Limited (CWB) provide
professional sick leave assessment and other analytical services to HHS;
Effective January lOtb, 2005, CWB is appointed by HHS to act as HHS's Health and
Disability Management and third-party administrator to provide:
· Sick Leave A4i!I~cation and Medical Case Management for all sick or injured
employees ofHHS during the Sick Leave and Employment Insurance (where
applicable) period of absence. .
Sick Leave Adjudication and Medical Case Management
HHS retains CWB to adjudicate sick leave claims teiceived by them and to provide
Medical Case Management This service will include validating whether the employee's
absen.ce is due to a defined medical restriction, the review of factors relevant to the
disability and the regular issuance of Case Management Reports. It may also
include confidential and .privileged communication with bealthcare professionals involved
and assistance and orientation of the employee with required healthcare services.
CWB's health professionals will provide recommendations concerning the eligibility for
sick leave payment according to their respective code of ethics and standards of
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PAGE 46
practice (The Col1ege of Physicians and Surgeons of Ontario for CWB Medical Director,
The Ontario College of Nurses for CWB Occupational Health Nurses and/or any other
professional accreditation). The final decision regarding pavment of sick leave benefits is
ultimatelv HHS's resoonsibility.
HHS is responsible for providing the pertinent information to CWB in order to determine
participant eligibility in accordance with the employer's poUcies and practices for sick
leave benefits. CWB will rely upon the information provided by the employer
concerning participant eligibility for its a4iudication. HHS will communicate in a time] y
fashion all the necessary information related to the absence of an employee which
may result from a medical condition. CWB will nrovide standatd room to IrnS to
facilitate the collection of the necessary information from both the employee and HHS.
CWB will Drovide orofessional sick leave adiudication and medical case management
services to attend to the needs of employees who are away from work for five (5) or more
consecutive shifts as a result of a non-occupational disability.
CWB' Sick Leave Adjudication and Medical Case Management Service includes:
. Decisions regarding the eligibility to sick leave benefit payments;
. Communication to HIlS of any issues relevant to the disability that may bIDder
recovery;
. Communication with the employee as required during the Early Intervention
program;
. Communication. with healthcare professionals involved, if ~ including
payment of any related fees;
. Assistance and orientation of the employee to an.y required hea1thcare services;
. Monitoring and communication of case progress to all stakeholders;
· Early coordination of rehabilitation initiatives to facilitate a timely return to work;
· Communication of potential return to work parameters to the employer;
. Orgaoization of independent assessments that may be necessary to facIlitate
recovery;
. Issuance of Case Management reports to the employer as needed and monthly
swnmary reports;
· Upon our recommendation, it is HHS' responsibility to initIate the L TO claim
applications. C\VB will transmit, to the insurer, copies of documents relevant to the
L 1D claim, prepared by medical professionals, without prejudicial assessments.
Fees and Payment Terms
From January 10th, 2005 until February 28th, 2005 the Sick Leave Adjudication and
Medical Case Management component will be provided on a. fee-for-service basis based
on CWB's hourly rates. During this period our services will include continued case
management for the current groups and implementation assistance.
Starting March 1st, 2005, the above services will be provided on a monthly retainer of
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. Fee for services will be reconciled monthly. Fees exceeding the retainer will be
reconciled and billed the month following the reconciliation report. Where the retainer
exceeds the fees owing, such surplus will remain in the account to be ultimately reconciled
the following months. During the first 12 months of service the minimum fee paid to
CWB will not be less than _
HHS and CWB agree to a Disability Management - Quality Service Standards model tbat
will enhance the results of the program and provide a measurable benefit to HHS. The
document win provide the basis of performance management (See attached doclUncnt
and Scorecard) (not provided].
CWB hourly rates (excluding GST) are:
.
.
.
.
(Above fees apply for 24 months. CWB reserves the right, with HHS approval, to increase
fees for se:rvices beyond 24 months to a minimum ofCPI.)
On-site communication including program launch, information sessions and any additional
requests for attendan.ce during the program period, including meetings with Managers
and employees will be provjded at a fix rate of _ + GST.
HHS and eWB shall identiry funds that may be required to reimburse .referrats or
consultations obtained through the Medical Case Management preferred healthcare
provider network (fudependent Medical Examinations, Functional Capacities Evaluations
or facilitating diagnostic tests such as MRI). HHS will incur costs for these services.
Prior to incurt'ing these expenses, eWB will seek pre~authorization from HHS and any
resulting payment or reimbursement will be detennined.
Termination of Contract
Either party may terminate this agreement at any time by providing 60 days
written notice.
Confidentiality
Infonnation referred to in the Agreement, and any other confidenti.al personal or medical
information disclosed:
(i) by HHS or,
(ii) by or on behalf of employees of HHS;
to CWB for purposes of enabling CWB to provide the selVices under this Agreement, is
referred to, collectively, as the "submitted information".
The submitted information by HHS to eWB shall only be used to provide the services
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mentioned above. CWB will fully maintain, respect and protect the confidentiality of
the medical and personal information received under this agreement and will not
release it to any other party, unless such release is authorized by the employee and
Complies with all privacy law requirements. CWB may utilize such infonnation for the
preparation ofJndepcndent Medical Examinations or Functional Capacities Evaluations.
CWB's healthcare orofessionats are o~ratin9: under the confidentiality guidelines of their
resoective professional colleges. eWB will ensure safekeeping of allllllS employees'
Medical Records incurred for the purpose of the above mentioned services for a period of
10 years, after which the files will be destroyed.
General
This Agreement is a contract made under and will be governed by and construed in
accordance with the laws of the Province of Ontario and the federal laws of Can.ada
applicable in the Province of Ontario.
This Agreement may be amended upon written consent of both parties.
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APPENDIX "D"
EXCERPTS FROM THE PERSONAL HEALTH INFORMATION PROTECTION
AC~ 2004
PART III
CONSENT CONCERNING PERSONAL REALTII INFORMATION
GENERAL
Elements of consent
18. (1) If this Act or any other Act requires the consent of an individual for the
collection, use or disclosure of personal health information by a health
information custodian, the consent,
(a) must be a consent of the individual;
(b) must be knowledgeable;
(c) m,ust relate to the infonnation; and
(d) must not be obtained through deception or coercion.
Implied consent
ill Subject to subsection (3), a consent to the collection, use or disclosure of
personal health information about an individual may be express or implied.
Exception
ill A consent to the disclosure of personal health information about an individual
must be express, and not implied, if,
(a) a health infoMnation custodian makes the disclosure to a person that Is not
a health information custodian; or
(b) a health information custodian makes the disclosure to another health
information custodian and the disclosure is not for the purposes of providing
health care or assisting in providing health care.
Same
L41 Subsection (3) does not apply to,
(a) a disclosure pursuant to an implied consent described in subsection 20 (4);
(b) a disclosure pursuant to clause 32 (1) (b); or
(c) a prescribed type of disclosure that does not include information about an
individual's state of health.
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Knowledgeable consent
ill A consent to the collection~ use or disclosure of personal health information
about an individual is knowledgeable if it is reasonable in the circumstances to
believe tbat the individual knows~
(a) the purposes of the collection, use or disclosure, as the case may be; and
(b) that the individual may give or withhold consent.
Notice of purposes
(Q) Unless it is not reasonable in the circumstances, it is reasonable to believe that
an individual ko.ows the purposes of the collection. use or disclosure of personal
health information about the individual by a health information custodian if the
custodian posts or makes readily available a notice describing the purposes where it
is likely to come to the individual's attention or provides the individual with such a
notice.
Transition
m A consent that an individual gives. before the day th.at subsection (1) comes
into force, to a collection, use or disclosure of infonnation that is personal health
information is a valid consent if it meets the requirements of thi s Act for consent
PART IV
COLLECTION, USE AND DISCWSURE OF PERSONAL HEALTH
INFORMATION
GENERAL LIMIT A nONS AND REQUIREMENTS
Requirement for consent
12:. A health information custodian shall not collect, use or disclose personal
health information about an individual unless,
(a) it has the individuaPs consent under this Act and the collection, use or
disclosure, as the case may be, to the best of the custodian' s knowledge, is
necessary for a lawful purpose; or
(b) the collection, use or disclosure, as the case may be, is permitted or
required by this Act.
Other information
30. (1) A health information custodian shall not collect, use or disclose persona.l
bealth information if other infonnation will serve the pwpose of the collection, use
or disclosure.
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Extent of information
ill A health information custodian shall not collect, use or disclose more
personal health information than is reasonably nece~ to meet the--.numose of the
collection, use or disclosure, as the case may be.
Exception
ill This section does not apply to personal health information that a health
information custodian is required by law to collect. use or disclose.
Use and disclosure of personal health information
31. (l) A health information. custodian that collects personal health information
in contravention of this Act shall not use it or disclose it unless required by law to
do so.
m REPEALED: 2004, c. 3, Schoo. A, s. 31 (4).
ill REPEAI.,ED: 2004, c. 3, Sched. A, s. 31 (4).
ill SPENT: 2004, c. 3, Schoo. A, s. 31 (4).
USE
Permitted use
37. (1) A health information custodian. may use personal health information
about an individual,
(a) for the D~ose for which the information was collected or created and for
all tbe functions ~asonablx necessary for carrving out that pmpose, but not if
the infonnation was collected with the consent of the individual or under
clause 36 (1) (b) and the individual expressly instructs otherwise;
(b) for a purpose for which this Act, another Act or ao Act of Canada permits
or requires a person to di.sclose it to the custodian;
( c) for planning or delivering programs or services that tbe custodian provides
or that the custodian funds in whole or in part, allocating resources to any of
them, evaluating or monitoring any of them or detecting, monitoring or
preventing fraud or any unauthorized receipt of services or benefits related to
any of them;
(d) for the purpose of risk management, error management or for the purpose
of activities to improve or maintain the quality of care or to improve or
maintain the quality of any related programs or services of the custodian;
(e) for educating agents to provide health care;
(0 in a manner consistent with Part TI, for the purpose of disposing of the
info.nnation or modifying the infonnation in order to conceal the identity of
the individual;
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(g) for the purpose of seeking the individuaJ' s consent, or the consent of the
individual's substitute decision-maker, when the personal health information
used by the custodian for this purpose is limited to the name and contact
inform.ation of the individual and the name and contact information of the
substitute decision.maker, where applicable;
(h) for the oumose of a proceeding or contemolated proceeding in which the
custodian or the agent or former agent of the custodian is. or is exvected to be,
R Darty or witness. if the information relates to or is a matter in issue in the
proceeding or contemnlated proceeding;
(i) for the purpose of obtaining payment or processing. monitoring, verifying'
or reimbursing claims for paym.ent for the provision of health care or related
goods and services;
G) for research conducted by the custodian, subject to subsection (3), unless
another clause oftb.is subsection applies; or
(k) subject to the requirements and restrictions, if any, that are prescribed, if
permitted or required by law or by a treaty, agreement or arrangement made
under an Act or an. Act of Canada.
Agents
ill Ifsubsection (1) authorizes a health information custodian. to use personal
health information for a purpose, tbe custodian may provide the infonnation to an
agent of the custodian who may use it for that purpose on behalf of the custodian..
DISCLOSURE
Disclosures for proceedings
41. (1) A health infonnation custodi.an. may disclose personal health information
about an individual,
(n) subject to the requirements and restrictions, if any, that are prescribed, for
the purpose of a proceeding or contemplated proceeding in which the
custodian. or the agent or former agent of the custodian is, or is expected to be,
a party or witness, if the information relates to or is a matter in issue in the
proceeding or contemplated proceeding;
(b) to a proposed litigation guardian or legal representative of the individual
for the pu.rpose of having the person appointed as such;
(c) to a litigation guardian or legal representative who is authorized under the
Rules of Civil Procedure, or by a court order, to commence. defend or
continue a proceeding on behalf of the individual or to represent the
ind.ividual in a proceeding; or
(d) for the purpose of complying with,
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(i) a summons, order or similar requirement issued in a proceeding by
a person having jurisdiction to compel the production of information, or
(ii) a procedural rule that relates to the production of information in a
proceeding.
Disclo!ilure by agent or fonner agent
Gl An agent or former agent who receives personal health information under
subsection (1) or under subsection 37 (2) for purposes of a proceeding or
contemplated proceeding may disclose the infonnation to the agent's or fonner
agent's professional advisor for the p11fJX>se of providing advice or representation
to the agent or fonner agent, if the advisor is under a professional duty of
confidentiality .
(Emphasis added.)
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APPENDIX "E"
Section 63 of the Occupational Health and Safety Act
PART VIII
ENFORCEMENT
Information confidential
63. (1) Except for the purposes of this Act and the regulations or as required by
law,
(f) no person shall disclose any information obtained in any medical examination,
test or :x:~ray of a worker made or taken under this Act except in a form
calculated to prevent the information from being identified with a particular
person or case.
Employer access to health records
(2) No employer shall seek to gain access. except by an order of the court or other
tribunal or in order to comply with another statute. to a health record concerning a
worker without the worker's written consent.
Power of Director to disclose
ii! A Director may communicate or allow to be communicated or disclosed
information, material, statements or the result of a test acquired, furnished,
obtained, made or received under this Act or the regulations.
Medical emergencies
ill Subsection (1) does not apply so as to prevent any person from providing any
infoMn.ation in the possession of the person, including confidential business
information, in a medical emergency for the purpose of diagnosis or treatment.
Conflict
fill This section prevails despite anything to the contrary in the Personal Health
Information Protection Act, 2004.
(Emphasis added.)