Accessibility Policy

1.1.1 Ontario Health policies are an important part of developing an organizational culture that connects and inspires all team members across the province. The foundation of that culture is our shared Vision, Mission, and Values. These help define our unified purpose, set the direction for where we are going as an organization and describe how we will work together to get there.

1.1.2 Our mandate is to connect, coordinate and modernize our province’s health care system to ensure that the people of Ontario receive the best possible patient-centered care, when and where they need it. We oversee health care planning and delivery across the province, which includes ensuring frontline providers and other health professionals have the tools and information they need to deliver quality care in their communities.

1.1.3 This Policy sets out our commitment to accessibility in accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and the Integrated Accessibility Standards Regulation (“IASR”). This Policy should be read in conjunction with Ontario Health’s AODA Multi-Year Accessibility Plan (“MYAP”).

1.2.1 The Accessibility Policy (the “Policy”) is developed to ensure that Ontario Health meets its obligations for accessibility set out in the AODA and IASR (collectively, “AODA”) and the AODA requirements as it pertains to people with disabilities in the Ontario Human Rights Code. (The Code protects people from discrimination and harassment due to disability in employment, services, goods, facilities, housing, contracts and membership in trade and vocational associations.)

1.3.1 Ontario Health is committed to respecting the core principles of accessibility legislation: dignity, independence, integration and equal opportunity. We incorporate these principles into its policies, procedures, training and best practices. We strive to ensure that all Ontarians have access to its services and information when and how they need them.

1.3.2 Ontario Health is dedicated to working with Ontarians to make accessibility for everyone a reality.

1.4.1 This policy applies to:

1.4.2 For unionized employees, where accessibility provisions are stipulated in their collective agreement, those collective agreement terms will take precedence over this Policy. Where the collective agreement is silent on the terms related to this Policy, this Policy will apply.

1.5.1 Compliance with this Policy is mandatory. Failure to comply with the requirements of this Policy may result in disciplinary action up to and including revocation of appointment, termination of employment with cause or termination of contract without notice or compensation.

1.5.2 In the event of any inconsistency between this Policy and the requirements of applicable law, the requirements of applicable law prevail.

This Policy follows certain wording conventions. There are precise requirements and obligations associated with the following terms:

• Must: This requirement is mandatory
• Should: This requirement ought to be adhered to, unless pressing or urgent business needs dictate otherwise and the full implication of non-compliance are understood. Exceptions must be approved by management as modifications to this Policy.

1.6.1 The words “include” and “including” when used are not intended to be exclusive and mean, respectively, “include, without limitation,” and “including, but not limited to”.

1.6.2 Words and terms in this Policy that have meanings differing from the commonly accepted definitions are capitalized and their meanings are set out in Section 4, Definition and Acronyms.

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. Our Accessibility Plan is available on our website and is available in an Accessible Format upon request. We prepare annual status reports on the measures taken to implement the Accessibility Plan. These status reports are posted on our website. The Accessibility Plan is reviewed and updated at least every five (5) years and in consultation with persons with disabilities.

Ontario Health provides training to our Staff members as it relates to their specific roles. This training includes information 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. Ontario Health Staff will also receive updates when changes are made to this Policy. Our Staff training records (including (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) and individual certificates of completion are located in Ontario Health’s Learning Management System (LMS).

Ontario Health incorporates accessibility design, criteria and features, when procuring or acquiring goods, services or facilities. Where it is impracticable to do so, Ontario Health Procurement will provide an explanation upon request. Our 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.

2.4.1 Accessible Formats and Communication Supports

Ontario Health notifies the public about the availability of Accessible Formats and Communication Supports. Upon request, we will, in a timely manner and at no additional cost, provide or arrange for the provision of Accessible Formats and Communication Supports unless it is not practical or possible to do so.

Ontario Health consults with requestors to determine the most appropriate Accessible Format or Communication Support. If we determine that the requested information or communications cannot be made accessible, the requester will receive (a) an explanation as to why, and (b) a summary of the unconvertible information or communications in an accessible format.

2.4.2 Feedback

Ontario Health is committed to creating a process for receiving and responding to feedback about services provided to persons with disabilities. Accessible Formats and Communication Supports are available upon request. Any individual can submit feedback to us by phone (accessible via TTY), email, in person or by mail at the details provided here: www.ontariohealth.ca/accessibility.

2.4.3 Website

In order to be accessible, information added to the Ontario Health Internet Website, including web-based applications and web content, whether controlled directly or indirectly, is to conform to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level AA.

2.4.4 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.

2.5.1 Recruitment

Accommodations are available for applicants with disabilities in the Ontario Health recruitment process. Information regarding accommodations are available to applicants as part of the recruitment process.

2.5.2 Informing Employees of Supports

Ontario Health informs 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 is provided to new Ontario Health employees as soon as practicable after they begin employment.

2.5.3 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, we will consult with the employee making the request.

2.5.4 Workplace Emergency Response Information

2.5.5 Individual Accommodation Plans (“IAPs”)

A written process is available for the development of documented IAPs for employees with disabilities. IAPs contain information about the 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 developing IAPs is outlined in the Ontario Health Accommodation Policy.

The process for the development of IAPs includes 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 (ii) 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.

2.5.6 Return to Work

Ontario Health maintains 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 outlines the steps we 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.

2.5.7 Performance Management and Career Development

Ontario Health takes 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.

2.6.1 Service Counters

2.6.1.1 Ontario Health will meet the building permit process when constructing new service counters.

2.6.1.2 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.

2.7.1 Accessible Services

Upon request, Ontario Health provides or arranges for the provision of accessible formats or communication supports for persons with disabilities in accordance with the following core principles:

• Dignity and independence;
• Integrated services;
• Equal opportunity; and
• Tailored approaches to accessibility

Refer to the related Accessible Customer Services Procedure in the Ontario Health Accessibility Procedure for more details.

2.7.2 Accessible Communication

Accessible communication takes into account the ways in which individuals express, receive and process information without making any assumptions about a particular disability.

2.7.3 Service Animals

Use of a Service Animal is permitted to be accompanied by such Service Animal when on Ontario Health Premises. This requirement does 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, we will make reasonable efforts to provide Ontario Health Services to such individual via alternate means.

Refer to the related Service Animal Procedure in the Ontario Health Accessibility Procedure for more details.

2.7.4 Support Persons

Use of and access to a Support Person is permitted when on Ontario Health Premises. 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 the Ontario Health Accessibility Procedure for more details.

2.7.5 Assistive Devices

Assistive Devices can be used when on Ontario Health Premises.

2.7.6 Training

Ontario Health Staff receives training on how to provide customer service to persons with disabilities.

Refer to the related Customer Service Training Procedure in the Ontario Health Accessibility Procedure for more details.

2.7.7 Notice of Temporary Service Disruption

Ontario Health provides public notice on its 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. This notice includes the reason for the disruption, anticipated duration and a description of alternative facilities, if available.

Refer to the related Temporary Service Disruption Procedure in the Ontario Health Accessibility Procedure for more details.

2.7.8 Feedback

Ontario Health ensures that individuals are able to provide feedback concerning the accessibility of our Services.

Refer to the related Feedback Procedure in the Ontario Health Accessibility Procedure for more details.

2.7.9 Documentation

Upon request, Ontario Health Customer Service Documents are available in an Accessible Format or with a Communication Support, in a timely manner and at no additional cost. We will consult with the person making the request to determine the most appropriate Accessible Format or Communication Support.

For all related Accessibility procedures, please refer to the Ontario Health Accessibility Procedure.

3.1.1 Approve this Policy.

3.1.2 Ensure implementation of this Policy.

3.2.1 Ensure compliance with the requirements of this Policy.

3.2.2 Ensure this Policy is reviewed on a bi-annual basis and that this Policy, and any associated training materials, are updated as necessary, including for any changes to AODA.

3.3.1 Support this Policy.

3.3.2 Implement this Policy and develop or amend applicable Portfolio/Regional procedures or documents in order to adhere to this Policy.

3.3.3 Approve accessibility reports as required.

3.4.1 Review and update this Policy every two years.

3.4.2 Review and update the Multi-Year Accessibility Plan every five years.

3.5.1 Comply with rules of this Policy.

3.5.2 Raise awareness to facilitate understanding of this Policy.

3.5.3 Participate and facilitate workplace accommodation plan, including development of contingency plans.

3.5.4 Complete required training for Managers/Supervisors.

3.6.1 Ensure they understand the intent of this Policy.

3.6.2 Comply with the provisions of this Policy.

3.6.3 Complete required training.

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 Integrated Accessibility Standards Regulations (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.

A person employed and compensated by Ontario Health as an Employee, and is classified as either Permanent Full-Time, Permanent Part-Time, Temporary Full-Time, Temporary Part-Time, Paid Student or Casual, as set out in the Employee Classification Guideline. A Consultant or Contractor is not an Employee.

IAP means an individual accommodation plan, as described in Section 2.5 above.

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.

A learning management system is a software application for the administration, documentation, tracking, reporting, automation, and delivery of educational courses, training programs, materials or learning and development programs.

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 and Engagement 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 Employees means all the persons identified in Section 1.4.1 above.

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 Supply Chain Department.

The individual to whom a Worker directly reports. An Ontario Health Worker who has the delegated authority to recruit, conduct performance reviews, and discipline Workers; supervise, control, or assign the allocation and use of human, capital, and financial resources; act on behalf of and represent the interests of management in the affairs of the organization. The function of management has a corresponding meaning. A People Leader can also be referred to as a “Manager".

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 their disability, or
• if the person provides a letter from a regulated health professional confirming that the person requires the animal for reasons relating to their 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.