CLHIA comments on HPRAC Initial Consultation – Chiropody and Podiatry Review

Date de parution : 07/04/2014
Personne(s)-ressource(s) : Karen Voin

July 4, 2014

Subject: Initial Consultation – Chiropody and Podiatry Review

On behalf of the Canadian life and health insurance industry, we appreciate the opportunity to provide you with our comments on the current model of foot care in Ontario. As requested, we have also provided feedback on issues relating to the regulation of chiropody and podiatry to assist in identifying any potential changes to the existing legislation regarding these related professions.

The CLHIA is a voluntary trade association with member companies that account for 99 percent of Canada's life and health insurance business. In Ontario, at the end of 2012, the life and health insurance industry provided some 9.3 million Ontario residents with supplementary health benefit coverage and made payments of about $9.7 billion. During 2012, the industry also reimbursed roughly $350 million for paramedical and other healthcare goods and services-which includes the reimbursement of foot care products such as orthotics, as well as the services by some of the professions that provide foot care.

Chiropody/Podiatry Regulation:

  • Based on feedback we have received from plan members, we recommend HPRAC consider combining both professions under one title and regulation. We would note that their respective competencies are substantively the same and they both are members of the same College. The current use of two titles is confusing and the differences in the scope of practice are not clear. This is further complicated given that Podiatrists receive some level of funding through OHIP which requires coordination with private benefit plans, while Chiropodists do not and yet they are members of the same College. We recommend HPRAC consider the development of one restricted title, scope of practice, and funding model for Podiatrists and Chiropodists to create clarity for the public.

Current Model of foot care in Ontario:
  • We recommend that a standardized model of foot care be developed that includes accepted definitions, guidelines, and criteria on what is considered a custom orthotic and orthopaedic shoe, and clearly outlines the education and training of professionals that is required in order to prescribe and dispense them. This will assist in ensuring treatment continues to be provided with the best interests of the patient in mind.
    Coverage for custom orthotic and orthopaedic shoes is commonly included in a benefit plan, and with the prevalence of practitioners and suppliers now prescribing and dispensing these products, utilization has increased significantly over the last several years. With the increase in utilization some plan sponsors have identified a need to modify their benefit plans in order to sustain the coverage. In addition, insurers have seen an increase in misrepresentation and abuse on claims for footwear which has created a need to develop additional controls. These may at times impact the service provided to plan members as more information is required to determine eligibility of claims. This creates confusion for the public and drives up costs. In May 2012, CLHIA members created a reference document Understanding claims for footwear and orthotics to assist plan members in understanding terminology commonly used in describing footwear and orthotics. While this is helpful, the fact that it was determined to be a need points to the confusion in the marketplace and the need for more control and consistency on definitions and scope of practice to ensure protection for the public.
  • We encourage HPRAC to consider legislation that would regulate all professionals who are involved in the delivery of foot care to Ontario residents. For example, Pedorthists are an important stakeholder in the foot care model in Ontario but are currently not a regulated profession. Regulation of Pedorthists would assist in recognizing their role in the delivery of foot care and ensuring protection of the public. In addition, it will provide more protection against fraud and abuse relating to foot care.

We welcome the opportunity to work with HPRAC on this initiative. We would be pleased to discuss this with you at your convenience or provide any other information that you would find helpful. Please contact Karen Voin, Director- Health and Dental at (416)-359-2020 or


(Original signed by)

Stephen Frank
Vice President, Policy Development and Health