1. Background and Purpose
On November 13, 2019, the Minister of Health issued transfer orders under Section 40(1) of the Connecting Care Act, 2019 transferring the following agencies into Ontario Health on December 2, 2019: Cancer Care Ontario, eHealth Ontario, HealthForceOntario Marketing and Recruitment Agency, Health Shared Services Ontario, and Ontario Health Quality Council (each a “Legacy Agency” and together, the “Legacy Agencies”).
This Policy sets out how Ontario Health will achieve accessibility, including through meeting the requirements of the Accessibility for Ontarians with Disabilities Act, 2005 and the Integrated Accessibility Standards Regulation. This Policy should be read in conjunction with Ontario Health’s Accessibility Plan.
Ontario Health acknowledges and recognizes the accessibility training provided by each Legacy Agency to its respective employees prior to its transfer into Ontario Health.
For clarity, the Accessibility Policy of each Legacy Agency will continue to apply to such agency in its capacity as an operating division of Ontario Health. In the event of any conflict between this Policy and the Accessibility Policy of a Legacy Agency, this Policy will prevail.
2. Statement of Commitment
At Ontario Health, we are committed to doing all we can to respect the core principles of accessibility legislation: dignity, independence, integration and equal opportunity. We will incorporate these principles into our policies, procedures, training and best practices. Our aim is that all Ontarians can access our services and information when and how they need them, regardless of their abilities or disabilities.
Ensuring our operations are accessible and barrier-free is a shared effort. As an organization, we are dedicated to working with the people of Ontario to make accessibility for everyone a reality.
This Policy applies to:
· all Ontario Health employees, whether full or part-time, temporary or permanent,
· all individuals paid by, or under contract with Ontario Health, including but not limited to consultants, service providers and independent contractors, and
· all researchers, clinical advisors and leads, and any individual working for or on behalf of Ontario Health on a volunteer basis or for nominal consideration, including, but not limited to, secondees, students, and Regulated Health Professionals (as such term is defined in the Regulated Health Professions Act, 1991).
In the event of any inconsistency between this Policy and the requirements of applicable law, the requirements of applicable law will prevail.
Accessibility Plan – means Ontario Health’s multi-year accessibility plan which outlines the specific measures taken by Ontario Health to achieve compliance with the requirements of AODA.
Accessible Formats - means formats that are an alternative to standard formats and are accessible to persons with disabilities, including, without limitation, braille, accessible audio formats, large print, text transcripts of visual and audio information, and other formats usable by persons with disabilities.
AODA – means the Accessibility for Ontarians with Disabilities Act, 2005, including the IASR.
Assistive Device - means a device that assists users in accomplishing day-to-day functions. These include, but are not limited to, wheelchairs, hearing aids, adaptive computer technologies, ventilators, walkers, crutches and personal sound amplification devices.
Career Development and Advancement – means providing additional responsibilities within an employee’s current position and the movement of an employee from one job to another that may be higher in pay, provide greater responsibility or be at a higher level or any combination of them and, for both additional responsibilities and employee movement, is usually based on merit or seniority, or a combination of them.
Communication Supports - means supports that individuals with disabilities may need to access information. These include, but are not limited to, captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.
Communications - means the interaction between two or more persons or entities, or any combination of them, where information is provided, sent or received.
Disability - means:
- any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness,
- a condition of mental impairment or a developmental disability,
- a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language,
- a mental disorder, or
- an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
IAP – means an individual accommodation plan, as described in Section 7.5 below.
IASR – means the Integrated Accessibility Standards Regulations under AODA, which establish various accessibility standards, including standards related to information and communications, employment, transportation, design of public spaces and customer service.
Internet Website – means a collection of related web pages, images, videos or other digital assets that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to the public.
Mobility Aid – means a device used to facilitate the transport, in a seated posture, of a person with a disability.
Mobility Assistive Device – means a cane, walker or similar aid.
Ontario Health Communications - means Ontario Health’s Communications Department.
Ontario Health Customer Service Documents - means all documents, policies, procedures and guidelines related to Ontario Health’s compliance with the Customer Services Standards under AODA.
Ontario Health Premises - means all locations open to the public in which Ontario Health Services are provided.
Ontario Health Services - means all services Ontario Health provides to members of the public.
Ontario Health Procurement - means Ontario Health’s Strategic Sourcing Department.
Ontario Health Staff - means all the persons identified in Section 2.1 above.
Performance Management – means activities related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.
Service Animal - means any animal used by a person with a disability:
- if it is readily apparent that the animal is used by the person for reasons relating to his or her disability, or
- if the person provides a letter from a regulated health professional confirming that the person requires the animal for reasons relating to his or her disability.
Support Person - means, in relation to a person with a disability, another person who accompanies such person in order to help with communication, mobility, personal care or medical needs or with access to goods, services or facilities.
Unconvertible – means:
- it is not technically feasible to convert the information or communication, or
- the technology to convert the information or communications is not readily available.
The Chief Transformation Officer is responsible for ensuring compliance with the requirements of this Policy. The Chief Transformation Officer will ensure that this Policy is reviewed on an annual basis and that this Policy, and any associated training materials, are updated as necessary, including for any changes to AODA.
6. General Requirements
6.1 Multi-Year Accessibility Plan
Ontario Health has, in consultation with persons with disabilities, developed an Accessibility Plan which outlines a strategy to prevent and remove barriers and to address the requirements of AODA and the IASR. Ontario Health will post the Accessibility Plan on its website and provide the Accessibility Plan in an Accessible Format upon request. Ontario Health will prepare an annual status report on the measures taken to implement the Accessibility Plan and post the report on its website. Ontario Health will review and update the Accessibility Plan at least every five (5) years and in consultation with persons with disabilities.
Ontario Health will ensure that training is provided to all Ontario Health Staff on the requirements of the IASR as set out in this Policy and on the Ontario Human Rights Code, as it pertains to persons with disabilities. Training will be appropriate to the duties of Ontario Health Staff members and will be provided to all Ontario Health Staff. Ontario Health Staff will also receive updates when changes are made to this Policy. Ontario Health will maintain at its head office a record of Ontario Health Staff training, which will include (i) the dates on which training is provided, (ii) a summary of the contents of the training, and (iii) the number of individuals to whom it was provided.
Ontario Health Procurement will ensure that Ontario Health’s procurement processes incorporate accessibility design, criteria and features, except where it is not practicable to do so. Where it is impracticable to incorporate accessibility into the procurement process, Ontario Health Procurement will provide an explanation upon request. Ontario Health’s Procurement Department will also ensure that all selected vendors are aware of the need to provide accessible goods and services on behalf of Ontario Health, where practicable.
7. Information and Communications
7.1 Accessible Formats and Communication Supports
Ontario Health will notify the public about the availability of Accessible Formats and Communication Supports. Upon request, Ontario Health will, in a timely manner and at no additional cost, provide or arrange for the provision of Accessible Formats and Communication Supports that takes into account the person’s accessibility needs due to a disability, unless such information is Unconvertible.
Ontario Health will consult with the requestor to determine the most appropriate Accessible Format or Communication Support. If Ontario Health determines that the requested information or communications are Unconvertible, Ontario Health will provide the requester with (a) an explanation as to why the information or communications are Unconvertible, and (b) a summary of the unconvertible information or communications in a format that is accessible to the requester.
Ontario Health will ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, Accessible Formats and Communication Supports, upon request. Any individual can submit feedback to Ontario Health either by phone (accessible via TTY) or by contacting us at the details provided here: https://www.ontariohealth.ca/accessibility
Ontario Health will ensure that its Internet Website and web content, including web-based applications, whether controlled directly or indirectly, conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level A and that by January 1, 2021 the website and web content conform to WCAG 2.0 Level AA.
7.4 Emergency Information
Upon request, Ontario Health will, as soon as practicable, provide emergency procedures, plans or safety information that is available to the public in an Accessible Format or with appropriate Communication Supports.
8. Employment Standards
Ontario Health will notify the public about the availability of accommodations for applicants with disabilities in the Ontario health recruitment process.
8.1.1 Assessment or Selection Process
Ontario Health will notify job applicants who are selected to participate in an assessment or selection process at Ontario Health, that accommodations are available upon request in relation to the materials or processes to be used in the assessment or selection process. If a selected applicant requests accommodation, Ontario Health will consult with the applicant and provide or arrange for suitable accommodation, taking into account the applicant’s accessibility needs.
8.1.2 Notice to Successful Applicants
When making offers of employment, Ontario Health will notify successful applicants about its policies for accommodating employees with disabilities.
8.2 Informing Employees of Supports
Ontario Health will inform its employees of its policies, (and any updates to policies) used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to disability. This information will be provided to new Ontario Health employees as soon as practicable after they begin employment.
8.3 Accessible Formats and Communication Supports
Upon the request of an employee with a disability, Ontario Health will consult with the employee to provide, or arrange for the provision of, Accessible Formats and Communication Supports for information that is needed to perform the employee’s job, and information that is generally available to other employees. In determining the suitability of an Accessible Format or Communication Support, Ontario Health will consult with the employee making the request.
8.4 Workplace Emergency Response Information
8.4.1 Individualized Information
Ontario Health will provide individualized workplace emergency response information to Ontario Health employees if Ontario Health is aware of the need for accommodation due to an employee’s disability. Ontario Health will provide this information as soon as practicable after becoming aware of the need for accommodation.
8.4.2 Employees Requiring Assistance
Where an Ontario Health employee requires assistance, Ontario Health will, with the consent of the employee, provide the workplace emergency response information to the person designated by Ontario Health to provide assistance to the employee.
8.4.3 Reviewing Individualized Information
Ontario Health will review the individualized workplace emergency response information when the employee moves to a different location, the employee’s overall accommodations needs or plans are reviewed, or Ontario Health reviews its general emergency response policies.
8.5 Individual Accommodation Plans
Ontario Health will have in place a written process for the development of documented IAPs for employees with disabilities. IAPs will include any information regarding Accessible Formats and Communications Supports provided (if requested), individualized workplace emergency response information (if required), and any other accommodation that is to be provided to the employee.
The process for the development of IAPs will include the following:
- the manner in which an employee requesting accommodation can participate in the development of the IAP,
- the means by which the employee is assessed on an individual basis,
- the manner in which Ontario Health can request an evaluation by an outside medical or other expert, at Ontario Health’s expense, to assist Ontario Health in determining if and how accommodation can be achieved,
- the manner in which the employee can request the participation of (i) a representative from their bargaining agent, if the employee is represented by a bargaining unit, or a representative from Ontario Health, if the employee is not represented by a bargaining unit, in the development of the IAP,
- the steps taken to protect the privacy of the employee’s personal information,
- the frequency with which the IAP will be reviewed and updated and the manner in which it will be done,
- if an IAP is denied, the manner in which the reasons for the denial will be provided to the employee, and,
- the means of providing the IAP in a format that takes into account the employee’s accessibility needs due to disability.
8.6 Return to Work
Ontario Health will maintain a documented return to work process for its employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work. The return to work process will outline the steps Ontario Health will take to facilitate the return to work and will include documented IAPs as part of the process. This return to work process does not replace or override any other return to work process created by or under any other statute.
8.7 Performance Management and Career Development
Ontario Health will take into account the accessibility needs of employees with disabilities, as well as IAPs, when conducting Performance Management and providing Career Development and Advancement opportunities to employees.
9. Design of Public Spaces
9.1 Service Counters
Ontario Health will meet the following requirements when constructing new service counters:
- Where there are multiple queuing lines and service counters, there must be a minimum of one service counter that accommodates a Mobility Aid for each type of service provided and the accessible counter must be clearly identified with signage.
- Where a single queuing line serves a single or multiple counters, each service counter must accommodate a mobility aid.
- The accessible service counter will meet the following criteria:
- The countertop height must be usable to a person seated in a mobility aid.
- There must be sufficient knee clearance for a person seated in a mobility aid.
- The floor space in front of the counter must be sufficiently clear to accommodate a mobility aid.
9.2 Fixed Queuing Guides
Ontario Health will meet the following requirements when constructing new fixed queuing guides:
- The fixed queuing guides must provide sufficient width to allow for the passage of Mobility Aids and Mobility Assistive Devices.
- The fixed queuing guides must have sufficiently clear floor area to permit Mobility Aids to turn where queuing lines change direction.
- The fixed queuing guides must be cane detectable.
9.3 Waiting Areas
When constructing a new, or redeveloping an existing, waiting area, where seating is fixed to the floor, a minimum of three percent of new seating must be accessible, but in no case less than one accessible seating space. Accessible seating is a seating area where an individual using a Mobility Aid can wait.
10. Customer Service Standards
10.1 Accessible Services
Ontario Health will endeavour to ensure all Ontario Health Services and Ontario Health Customer Service Documents are made accessible to persons with disabilities and are provided in accordance with the following core principles:
- Dignity and Independence: All Ontario Health Services will be provided in a manner that respects the dignity and independence of persons with disabilities. Persons with disabilities will not be forced to accept lesser service, quality or convenience as a result of their disability.
- Integrated Services: Ontario Health will ensure that persons with disabilities are able to fully benefit from the same Ontario Health Services, in the same place and in the same or similar manner, as other individuals.
- Equal Opportunity: Persons with disabilities will be given an equal opportunity to use and benefit from all Ontario Health Services. As a result, additional services may be extended to persons with disabilities in order to ensure that they can access an Ontario Health Service.
Refer to the related Accessible Customer Services Procedure in Section 11 for more details.
10.2 Accessible Communication
Ontario Health Staff will communicate with persons with disabilities in a manner that takes into account the individual’s disability. Consideration will be given to the way in which individuals express, receive and process information without making any assumptions about a particular disability.
10.3 Service Animals
Any person with a disability requiring the use of a Service Animal will be permitted to be accompanied by such Service Animal when on Ontario Health Premises. This requirement will not apply where a Service Animal is either excluded by law from being on any Ontario Health Premises. Where a person’s Service Animal is excluded by law, Ontario Health will make reasonable efforts to provide Ontario Health Services to such individual via alternate means.
Refer to the related Service Animal Procedure in Section 11 for more details.
10.4 Support Persons
Any person with a disability requiring the use of a Support Person will be permitted to be accompanied by such Support Person when on Ontario Health Premises. Ontario Health will make reasonable efforts to ensure that persons with disabilities are not prevented in any way from having access to their Support Person when on Ontario Health Premises.
Refer to the related Support Person Procedure in Section 11 for more details.
10.5 Assistive Devices
Ontario Health will make reasonable efforts to ensure that any Assistive Device required by a person with a disability can be used by such person when on Ontario Health Premises.
Ontario Health Staff will be trained on how to provide customer service to persons with disabilities.
Refer to the related Customer Service Training Procedure in Section 11 for more details.
10.7 Notice of Temporary Service Disruption
Public notice will be provided on Ontario Health’s website, or in a conspicuous place at affected Ontario Health Premises, when any Ontario Health facility or service is temporarily unavailable. Such public notice might relate to facility renovations or repairs on Ontario Health Premises, including maintenance of elevators or accessible washrooms. The notice will include the reason for the disruption, anticipated duration and a description of alternative facilities, if available.
Refer to the related Temporary Service Disruption Procedure in Section 11 for more details.
Ontario Health shall ensure that individuals are able to provide feedback concerning the accessibility of Ontario Health Services.
Refer to the related Feedback Procedure in Section 11 for more details.
Upon request, Ontario Health will make available all Ontario Health Customer Service Documents in an Accessible Format or with a Communication Support, in a timely manner and at no additional cost. Ontario Health will consult with the person making the request to determine the most appropriate Accessible Format or Communication Support.
11.1 Accessible Ontario Health Services Procedure
11.1.1 Publically Available Information
All Ontario Health publically available information and correspondence to the public shall include the following statement or a similar statement:
Ontario Health is committed to providing accessible services and communications to individuals with disabilities. To receive any part of this document in an alternate format, please contact Ontario Health’s Communications Department at: 1-877-280-8538, TTY 1-800-855-0511, or by email at email@example.com
11.1.2 Meetings and Public Events
Ontario Health shall ensure that all meetings and events open to members of the public are made accessible. All initial correspondence and meeting or event requests/invitations shall include the following statement or a similar statement:
Ontario Health is committed to providing accessible services and communications to individuals with disabilities. To receive any part of this document in an alternate format or to request accommodation at our event, please contact Ontario Health’s Communications Department at: 1-877-280-8538, TTY 1-800-855-0511, or by email at firstname.lastname@example.org
11.2 Service Animal Procedure
11.2.1 Service Animals Permitted
Ontario Health Staff will permit persons with disabilities to be accompanied by a Service Animal in all areas that are open to the public or other third parties, except where otherwise excluded by law. Generally, the only situation in which a Service Animal is excluded by law is a situation in which food is prepared, stored or sold (see the regulations under the Health Protection and Promotion Act, 1990 and the Food Safety and Quality Act, 2001) and in situations where the presence of a Service Animal may endanger the health and safety of another person.
11.2.2 Alternative Measures
In the rare situation where another person’s health and safety could seriously be impacted by the presence of a Service Animal on Ontario Health Premises, Ontario Health will assess all options and provide alternative measures to the person in need of a Service Animal in order to enable him/her to obtain, use and fully benefit from Ontario Health Services while also taking into consideration the impact the presence of a Service Animal would have on the other individual.
Alternative measures could include, but are not limited to: leaving the Service Animal in a secured area where it is permitted by law or offering to serve the person with a disability in another area where such Service Animal is permitted. In a situation where it is necessary to leave the Service Animal in a secured location where such animal is permitted by law, Ontario Health shall ensure that the person with a disability is provided with appropriate assistance, should they so require, during such time as they are separated from their Service Animal.
Ontario Health Staff have the right to make a determination as to whether an animal is a “Service Animal” based on the definition provided in this Policy. Where an animal is not a trained guide dog and it is not readily apparent to reasonable person that the animal is a Service Animal, Ontario Health Staff shall have the right to ask the person using the Service Animal for a letter from a Regulated Health Professional explaining that the animal is needed because of a disability. The letter does not need to identify the disability, why the animal is needed or how it is used.
11.3 Support Person Procedure
11.3.1 Right to Support Person
A person with a disability who is accompanied by a Support Person will be allowed to enter any Ontario Health Premises with his or her Support Person. At no time will a person with a disability who is accompanied by a Support Person be prevented from having access to his or her Support Person while on Ontario Health Premises.
11.3.2 Requirement for a Support Person
Ontario Health may, in certain circumstances, require that a person with a disability be accompanied by a Support Person when on Ontario Health Premises. Ontario Health may require the above only when Ontario Health deems, in its reasonable opinion and after consultation with the person with a disability, that requiring a Support Person to accompany the person with a disability is the only means available to allow the person with a disability to be on Ontario Health Premises and, at the same time, fulfil Ontario Health’s obligations to protect the health or safety of the person with a disability or the health or safety of others.
If there is any doubt about whether a Support Person is necessary to protect the health or safety of the person with a disability or the health or safety of others, please contact Human Resources.
11.3.3 Disclosure of Confidential Information
In certain situations, personal information or confidential information related to a person with a disability may need to be disclosed while a Support Person is present. Before disclosing any personal information or confidential information concerning a person with a disability in the presence of a Support Person, Ontario Health Staff shall first seek the consent from the person with disability to such disclosure.
11.4 Customer Service Training Procedure
Ontario Health Staff shall receive training on the Customer Service Standards under the IASR. Training for new Ontario Health Staff will be provided as soon as practicable after Ontario Health Staff commence their duties. Training will be provided on an ongoing basis in connection with any changes to the Customer Service part of this Policy or any changes in the Customer Service Standards.
Ontario Health shall maintain at its head office, a record of Ontario Health Staff training, which shall include (i) the dates on which training is provided to Ontario Health Staff, (ii) a summary of the contents of the training, and (iii) the number of individuals who received the training.
Ontario Health Customer Service training shall contain the following mandatory sections:
- A review of the purpose of the AODA and the requirements of the Customer Service Standards;
- How to interact and communicate with people with various types of disabilities;
- How to interact with persons with disabilities who use an Assistive Device or who require the assistance of a Service Animal or a Support Person;
- How to use any equipment made available by Ontario Health to help persons with disabilities access Ontario Health Services;
- What to do if a person with a disability is having difficulty accessing Ontario Health Services; and
- How to ensure that all Ontario Health Services are accessible to persons with disabilities and provided in a manner that promotes dignity, independence, integration and equality of opportunity.
11.5 Temporary Service Disruption Procedure
Ontario Health will provide a public notice via its website, or post such notice in a conspicuous place at affected Ontario Health Premises, for the disruption of any system, amenity or facility that a person with a disability must use in order for them to access Ontario Health Premises. Systems, amenities or facilities that a person with a disability may rely on include, but are not limited to, escalators, elevators, ramps, or accessible washrooms.
If possible, Ontario Health will provide reasonable advance notice of any anticipated disruption. If a disruption occurs unexpectedly, Ontario Health will provide notice as soon as practicable after it becomes aware of such disruption.
11.5.2 Contents of Notice
The following information shall be included in a temporary service disruption notice:
- The reason for the disruption;
- A reasonable estimate of how long the disruption will last; and
- Any existing alternative systems, amenities or facility that would allow persons with disabilities to access Ontario Health Premises during the disruption, if applicable.
11.6 Feedback Procedure
11.6.1 How to Submit Feedback
Any individual may submit feedback about the manner in which Ontario Health provides Ontario Health Services to persons with disabilities or whether the feedback process itself is accessible to persons with disabilities. Individuals may submit feedback to Ontario Health at any of the options available on our website https://www.ontariohealth.ca/accessibility. If the methods provided are not suitable, individuals may request another method. Ontario Health will ensure that the feedback process is accessible by arranging for the provision of Accessible Formats or Communication Supports.
11.6.2 Written Response
Once a request is received, Ontario Health Communications will review the feedback, together with other Ontario Health departments, as necessary, and prepare a written reply, if requested or appropriate. Ontario Health will endeavour to provide a written reply within two (2) weeks of receipt of feedback, but in any event, a response will be provided as soon as reasonably possible.
11.6.3 Appropriate Measures
If the feedback is in the form of a complaint surrounding the provision of Ontario Health Services, Ontario Health Communications will work together with other Ontario Health departments, as necessary, to address the complaint and ensure that the provision of Ontario Health Services are accessible to persons with disabilities.
12. Policy Change History
Revision Number: [insert text here]
Date of Approval: [insert text here]
Description of Change:[insert text here]