Re: Proposed Amendment to Ontario Regulation 552 under the Health Insurance Act

Dear Ontario Ministry of Health and Long-Term Care:

On behalf of the Travel Health Insurance Association (THiA), I’m writing in response to your 24 April, 2019 Regulatory Registry posting which asks for input from affected parties with respect to the Ministry’s proposal to amend Regulation 552 under the Health Insurance Act (HIA) to end OHIP coverage for emergency services for Ontarians travelling outside of Canada; with an effective date, if approved, of October 1, 2019.

Our Association has two key points of feedback with respect to this proposal.

First, THiA requests that should this proposal be approved, the Ontario Government and the Ministry of Health and Long-Term Care allow a one year transition period from the proposed October 1, 2019 in force date of no coverage. Cessation of the coverage as of October 1, 2019 is too soon for this change to be implemented in a smooth, seamless manner; without causing hardship to the travel health insurance industry with significant increase in costs to implement work-arounds and those costs will ultimately be reflected in the premiums Ontarians will have to pay to be covered when they travel.

In order to continue to provide comprehensive protection for Ontarians travelling outside of Canada, THiA members and other travel insurance providers will undoubtedly need to increase the premiums that will be charged to Ontarians. For this reason we need to have a sufficient transition period to determine premium changes, update operating systems and make changes to our policies.

Second, is the critical need for the Ontario Government to undertake communication campaigns to educate Ontarians about this change so they understand the limits of OHIP when they travel outside of Canada, as well as, emphasize the importance of purchasing private travel insurance to protect themselves.

Thank you for the opportunity to share our views with you. Should you require further information from THiA or wish to meet with representatives from our Association at any time, please contact Brad Dance, President of THiA.

Yours truly,

Brad Dance

President

The Travel Health Insurance Association of Canada