by Written on behalf of Wise Health Law June 20, 2018 4 min read

The College of Physicians and Surgeons of Ontario (CPSO) has released a set of draft policies about Continuity of Care. The draft policies recognize that continuity of care is an essential component of patient-centered care. Potential breakdowns in this continuity that the policies identify include: limited physician availability, delayed or missed test results, care received in an uncoordinated manner, and transitions in care.

Some Context

The CPSO’s efforts to develop new policies relating to continuity of care began in 2016. Preliminary external consultations were held to obtain feedback from stakeholders. Based on these consultations, the CPSO developed “a suite of draft policies”, including an overarching Continuity of Care policy, and four separate companion policies on related identified issues.

Continuity of Care

The primary Continuity of Caredraft policy lays out the principles of professionalism that provide the foundation for the full suite of policies and outlines general expectations relating to the role that physicians, patient engagement, and technology use all play in facilitating continuity of care. Importantly, the draft policy recognizes that certain factors are beyond the control or influence of individual physicians and may influence whether or not continuity of care can truly be achieved but notes that the policies focus on the continuity of care issues that are within the control or influence of physicians. Policy expectations include:
  • Collaborating with other health-care providers to enable effective communication and information sharing;
  • Using expertise and influence to help advance the health and well-being of patients, communities, and the broader population served;
  • Facilitating and supporting patient engagement in a professional manner that meets the patient’s knowledge, needs, and wishes;
  • Taking advantage of advancements in technology that can facilitate continuity of care.

Availability and Coverage

The Availability and Coverage policy outlines expectations of physicians around physician availability, after-hours coverage, and coverage during temporary absences from practice. The policy recognizes that continuity of care does not require individual physicians to personally provide on-demand and continuous access to care since this would negatively impact quality of care and also compromise physician health. However, expectations do include:
  • Having an office telephone that is answered during office hours, a voicemail that allows messages to be left during office hours, and a voicemail that allows messages to be left after hours;
  • Structuring a practice in such a way that allows for the appropriate triage of patients who have urgent or time-sensitive issues;
  • Responding in a timely and professional manner when contacted by other physicians or health-care providers who wish to communicate about a patient or request information about them;
  • Having a plan in place to coordinate patient care outside of regular operating hours (for physicians providing care as part of a sustained physician-patient relationship);
  • Ensuring that critical test results can be received and responded to 24 hours a day, 7 days a week, including arranging coverage for times a physician may be unavailable.

Managing Tests

The Managing Testsdraft policy sets out expectations for physicians around the ordering and management of all types of tests. Expectations include:
  • Using clinical judgment when ordering tests, providing contextual information on requisition forms, and copying the patient’s primary care advisor;
  • Tracking test results for high-risk patients to ensure that test results are not lost or missed;
  • Using professional judgment to determine whether or not to track test results for patients who are not high-risk;
  • Reporting to the patient or those involved in their care where critical or critically significant test results are received in error;
  • Informing patients of the availability of patient portals, while maintaining the obligation to provide the appropriate follow-up;
  • Encouraging patients to discuss test results, ask questions, and discuss;
  • Informing patients of the significance of tests ordered, the importance of getting tests done, and doing so in a timely manner.

Transitions in Care

The Transitions in Care draft policy sets out expectations of physicians where patient care or an element of patient care is transferred between one or more doctors, or between doctors and other health-care providers. This includes:
  • Coordinating with others to keep patients informed about who is their most responsible provider;
  • Approaching patient handovers in a systematic manner and setting aside time to allow for a real-time and personal exchange of information between health-care providers;
  • Ensuring that a discussion is had with the patient and/or substitute decision-maker prior to discharge about relevant issues such as where to go if complications arise;
  • Taking reasonable steps to involve a patient’s family and/or caregivers in discussions about the patient;
  • Completing a discharge summary for all in-patients in a timely manner; and
  • Making referrals in writing and taking reasonable steps to confirm that the referral is within the scope of practice of the other doctor.

Walk-In Clinics

The Walk-In Clinics draft policy sets out expectations for physicians practicing in walk-in clinics and include:
  • Using professional judgment to determine whether it would be appropriate to sensitively remind patients about the nature of a walk-in clinic and that receiving care within a sustained physician-patient relationship facilitates continuity of care;
  • Meeting the standard of practice of the profession;
  • Providing or arranging for the provision of appropriate follow-up care when ordering a test or making a referral;
  • Ensuring that critical test results can be received or responded to 24/7, including establishing coverage arrangements when physicians are unavailable;
  • Providing the patient’s primary care provider with a record of the encounter;
  • Offering comprehensive primary care to patients without a primary care provider who regularly attend the same clinic (where scope of practice permits).
The CPSO is seeking feedback from physicians, the public, and relevant organizations on all of these draft policies. The deadline to provide input is December 9, 2018. At Wise Health Law, we provide exceptional guidance on health law matters to public hospitals, long-term care homes, and other health-care providers across the province. We monitor trends and developments in the health sector so that we can provide consistently forward-thinking legal advice and risk management guidance to all of our clients. We have offices in both Toronto and Oakville, Ontario, and are easily accessible. Contact us online, or at 416-915-4234 for a consultation.


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