55 University Avenue, 15th Floor
Toronto, Ontario  M5J 2H7 
www.archdisabilitylaw.ca 
(416) 482-8255 (Main) 1 (866) 482-ARCH (2724) (Toll Free)
(416) 482-1254 (TTY)  1 (866) 482-ARCT (2728) (Toll Free)
(416) 482-2981 (FAX)  1 (866) 881-ARCF (2723) (Toll Free)

Sent via email at Christine.elliott@ontario.ca, Ross.Romano@ontario.ca, minister.mto@ontario.ca 

January 26, 2022

Hon. Christine Elliott, Deputy Premier and Minister of Health of Ontario
College Park 5th Floor,
777 Bay Street, Toronto, ON M7A 2J3

Hon. Ross Romano, Minister of Government and Consumer Services
College Park 5th Floor,
777 Bay Street, Toronto, ON M7A 2J3

Hon. Caroline Mulroney, Minister of Transportation
College Park 5th Floor,
777 Bay Street, Toronto, ON M7A 2J3

Dear Ministers:

Re: Expanding Health Card Renewal Services to Persons with Disabilities

We are writing with great urgency to underscore the serious impact that the upcoming renewal deadline for expired Ontario Health Cards of February 28, 2022 will have on many persons with disabilities in Ontario. 

Many Ontarians with disabilities will not be able to renew their expired Ontario Health Card prior to the deadline safely and in a manner that would avoid having to attend in person at a ServiceOntario location. The medical exemption form does not alleviate barriers which the pandemic has only exacerbated. As the deadline approaches, we are increasingly being contacted by our communities regarding their concerns of this deadline and how it impacts their safety and critical access to healthcare.

For persons with disabilities, this deadline exacerbates multiple barriers and creates disproportionate risks in having to attend Service Ontario during this fifth wave of the pandemic.

Many Ontarians, on the other hand, are able to renew their health card prior to the deadline by using the online renewal system which requires, as a condition of eligibility, a valid driver’s license. Many persons with disabilities, however, are unable to get a driver’s license and must rely upon the Ontario Photo Card as an alternative means for identification. We join others in calling on Government to accept the Ontario Photo Card to allow persons with disabilities equal access to renew their health card safely online. 

This is an important remedy to address the disability-based discrimination, however it does not resolve all of the barriers at issue.  

We are especially concerned about the exclusion of persons with disabilities who do not have an Ontario Photo Card and/or face barriers in accessing the internet. We ask for flexibility in the renewal process to allow persons with disabilities to submit other forms of proof of identity in ways that accommodate for their disability-related needs and circumstances. We remind the government that additional steps are needed to ensure all persons with disabilities who are eligible to receive OHIP are able to renew safely. We ask the government to acknowledge and take into account systemic barriers to renewing the health card for those who are at risk of being forgotten, on this path toward “modernization,” unless specific steps are undertaken to safeguard their needs.

Persons with disabilities who do not have a driver’s license and Ontario Photo Card are especially vulnerable and marginalized. There are barriers associated in obtaining an Ontario Photo Card, including the ability to provide a signature and/or access to a guarantor. Applying for an Ontario Photo Card is equally problematic for persons with disabilities who cannot, for medical reasons, attend ServiceOntario to have their picture taken. 

As it stands, persons with disabilities are in a position of having to safeguard continued access to healthcare by putting their own health and safety at risk. Our communities have expressed serious concern regarding access to healthcare that include fears of discriminatory triaging of critical care and denial of vital accommodations and supports. These and other ongoing concerns are compounded now by this impending deadline. The danger is that those who need medical attention but cannot renew their Ontario Health Card will delay seeking care and put themselves at greater risk for complications to their health, out of fear that they will incur medical debt.

We call on the Ontario government to extend the deadline for all persons with expired Ontario Health Cards to allow for a flexible approach to determining continued eligibility through a number of ways and by a variety of different means in a manner that accommodates for the needs of persons with disabilities and actively removes these barriers to accessing service.

Sincerely yours,
ARCH Disability Law Centre 

Original letter has digital signature 			Original letter has digital signature 

Robert Lattanzio						Hannah Lee
Executive Director 					Staff Lawyer