September 12, 2016
The Honourable Jane Philpott
Minister of Health
House of Commons
Ottawa, ON, K1A 0A2
Dear Honourable Minister,
On behalf of Action Canada for Sexual Health and Rights, I want to indicate how pleased we have been to see a number of tangible indications that the Government of Canada takes seriously the importance of sexual and reproductive health. Action Canada for Sexual Health and Rights is a national sexual and reproductive health and rights charitable organization engaged in domestic and global policy work, as well as in domestic health promotion, including through a network of 23 frontline service-providing associate organizations located across the country offering a wide range of sexual and reproductive health services as well as community education on these issues. Your statements on abortion access and recognition of the need to improve the accessibility and availability of this essential service within Canada have certainly been welcome by our community who see directly the impact of these substantial accessibility barriers. We also recognize commitments made towards a revised, integrated approach to Sexually Transmitted and Blood-Borne Infections (STBBIs) through stakeholder engagement as an important development.
While these initial steps are welcome, they do not rise to the level of leadership needed on sexual and reproductive health and rights in Canada after consistent neglect of – and even hostility towards – these issues by federal, provincial and territorial governments. In fact, UN bodies have begun showing strong concerns with the lack of action to improve Canada’s domestic record on these issues. During this year’s review of Canada’s compliance with the International Covenant on Economic, Social and Cultural Rights, the Committee that monitors Canada’s compliance with the Covenant questioned the government on severe discrepancies in the quality and delivery of comprehensive sexuality education in Canada as well as in access to services, particularly abortion. The Committee on the Elimination of Discrimination against Women has followed suit and has indicated that it will be questioning Canada at its upcoming review in the Fall on these exact issues as they relate to Canada’s international human rights obligations towards women and girls. Federal leadership is urgently needed on these issues in order to address domestic shortcomings that are being recognized on an international level and tarnishing Canada’s former reputation as a leader on sexual health and gender equality.
A serious commitment to an integrated sexual and reproductive health and rights agenda certainly requires significant changes in federal leadership, funding and infrastructure, and Action Canada for Sexual Health and Rights and its network of Associate Organizations would be pleased to support the government in actualizing these significant and urgently necessary reforms. Leadership of this type would require, first and foremost, a plan of action for sexual and reproductive health that will both review access barriers with a view to their removal, as well as facilitate sound, multi-tiered, integrated and informed responses to sexual and reproductive health and rights in Canada. These are urgent priorities and it is our belief that an integrated approach to sexual and reproductive health and rights would not only result in a more effective approach to health care and significantly reduce burden on the health care system but would also be imperative in meeting your mandated aims while ensuring that the government actualize its existing goals of upstream prevention along with its larger goals of embodying a feminist government.
We are requesting a meeting with you to further discuss how a comprehensive and integrated approach to sexual and reproductive health, embodied through a plan of action articulated below, would help you meet your mandated aims.
We look forward to working with you to implement these and other reforms in Canada and welcome the opportunity to meet with you to discuss in greater detail.
Action Canada for Sexual Health and Rights
Also on behalf of the following Associate Organizations of Action Canada for Sexual Heath and Rights:
CC: The Right Honourable Justin Trudeau, P.C., M.P., Prime Minister of Canada
The Honourable Marie-Claude Bibeau, Minister of International Development and la Francophonie
The Honourable Patty Hajdu, Minister of Status of Women
Within the Minister of Health’s mandate letter, and echoed in the Speech to the Throne, are explicit commitments relating to improving partnerships with provincial, territorial and municipal governments, indicating a desire to move towards a more comprehensive and integrated approach to health. Similarly, Minister Philpott has been mandated to work with and support provincial and territorial governments to support them in making prescription drugs more affordable, including through bulk purchasing agreements for prescription medications. Listed among the Minister’s top mandated priorities is the development of a new, multi-year Health Accord, which would necessarily require a much more collaborative approach to federal leadership than we have seen in previous years. To us, these steps indicate a move towards a more comprehensive and integrated approach to health care and this approach must be extended to sexual and reproductive health and rights in order to fully meet these mandated priorities and create “real, positive change.” This comprehensive and integrated approach to health, which requires that multiple levels and parts of governments work more collaboratively, is crucial to fully realizing sexual and reproductive health in Canada in a meaningful way and addressing serious disparities that are now being noticed at an international level.
While current efforts towards a revised, integrated approach to STBBIs are an important first step, these efforts will ultimately prove inadequate if they do not form part of a larger, more comprehensive and integrated approach to sexual and reproductive health. In the context of federal leadership in sexual and reproductive health, the following actions are critical in actualizing an approach that fits within the federal role for health and is comprehensive, integrated and ultimately effective in meeting mandated priorities and securing better health outcomes for Canadians. Federal leadership of this type would require, first and foremost, a plan of action for sexual and reproductive health that will review access barriers with a view to their removal, as well as facilitate sound, multi-tiered, integrated and informed responses to sexual and reproductive health and rights in Canada.
We are pleased to hear Prime Minister Justin Trudeau speak of the importance of adopting feminist policies throughout the federal government. This and other explicit commitments made by Ministers Bibeau and Hajdu indicate that the federal government is increasingly moving towards a feminist approach to governance. In the context of health, a feminist approach to governance means taking seriously the role of sexual and reproductive health as a crucial component to overall health and ensuring that individuals have the education, resources and conditions necessary to practice positive approaches to sexuality and sexual relationships, free of discrimination, coercion and violence. A comprehensive and integrated approach to sexual and reproductive health is absolutely essential if Health Canada wishes to embody a feminist government. Tangibly, this would entail positioning issues of bodily autonomy, agency, empowerment, human rights and gender equality at the centre of all health related decision making, including expanding choices for women and marginalized groups and promoting and safeguarding their right to health.
A truly integrated approach to sexual and reproductive health would directly meet these mandated priorities and simultaneously contribute to the upstream prevention of STBBIs, including HIV and hepatitis C. Similarly, a comprehensive approach to sexual and reproductive health would take seriously social determinants of health and the way that these social determinants simultaneously influence access to health care and are shaped by identity characteristics and systemic factors. Adopting such an approach to sexual and reproductive health would also help realize human rights obligations, including the right to health, which requires that services and information be accessible, acceptable, available and of quality. This approach would undoubtedly have positive social and economic benefits, both in terms of positively influencing individual and family well-being and in reducing long-term burdens on the health care system through informed and effective responses to ever-growing health concerns.
Federal leadership relating to sexual and reproductive health and rights would require a concerted response to identifying and alleviating legislative, regulatory and policy barriers that hinder access to integral medications, services and procedures. Such a regular review is integral to a human rights-based approach to these issues. While many such laws, regulations and policies forming barriers to access exist at provincial and territorial levels, a number do lie within federal jurisdiction.
For example, we know that access barriers with respect to abortion do not only relate to provincial and territorial restrictions, but that revisiting the Health Canada-imposed restrictions relating to Mifegymiso – the gold standard for medical abortion – needs to be an essential action taken in light of the growing number of stakeholders concerned that such restrictions will result in low uptake of this essential medicine and thereby further hinder access to abortion. Federal leadership towards alleviating barriers to this essential medicine would include removing the regulatory requirements for physician-only dispensing and extending the gestational limit of the medication to up to 70 days as is supported by evidence. Similarly, removing access barriers for Mifegymiso would require making a registry of prescribers publically accessible and removing the requirement for extensive training in order to prescribe this medication – a requirement that is currently in place only for controlled substances such as methadone.
As noted in the Minister’s statements regarding the decision to provide abortion services on-island in Prince Edward Island, the federal government is committed to examining ways to equalize access to abortion for Canadian women. Taking seriously the barriers to access to services that exist in Canada is an integral step to achieving this and it would require taking stock of legislative, regulatory and service barriers, and taking corrective action to remedy them. For those barriers that are within federal jurisdiction, reviewing and removing them would be a necessary component of a sexual and reproductive health plan of action. For those within provincial and territorial jurisdiction, necessary components of a sexual and reproductive health plan of action at the federal level would include surveillance of the impact of these barriers on health outcomes in Canada and regular dialogue with provincial and territorial ministries on these issues. Effectively responding to access barriers would also require actively seeking out important commodities relating to sexual health – for example, contraceptive implants and new HIV prevention technologies – and bringing them to Canadian markets and proactively approving their use, in addition to regularly reviewing processes by which products and medications are approved for use and brought to the Canadian market, with a view to streamlining these processes. Such regular law and policy reviews are necessary in the interest of greater access to sexual and reproductive health services, products and medicines.
While the Government of Canada cannot dictate the agendas or funding of provincial health ministries, it has significant power in promoting best practices and working constructively with provinces and territories to meet such standards. Federal leadership of this type would entail significant and improved dialogue between federal and provincial and territorial bodies of government to articulate and enforce minimum best standards. Improved dialogue between federal and provincial governments is also imperative to effectively alleviate access barriers, particularly as various restrictions that impact access to services and health outcomes can fall under federal and provincial and territorial governments, not simply the latter.
A key area where leadership is needed is in standardizing and monitoring sexuality education. The federal government has already shown its commitment towards the language of comprehensive sexuality education, including voicing its support at both the High Level Meeting on HIV and AIDS and in introducing and advancing the first ever United Nations Human Rights Council resolution articulating the importance of comprehensive sexuality education, without caveat or qualifier. Despite these steps forward taken internationally, comprehensive sexuality education at home remains marked by vast discrepancies and a lack of national guidelines outlining best practices and standards. To fully actualize these commitments to comprehensive sexuality education, Health Canada and the Public Health Agency of Canada must demonstrate leadership by revising the Canadian Guidelines for Sexual Health Education through a consultative and participatory approach that involves young people. The current approach to sexual health education is inadequate in meeting the needs and realities of young people and nationally, there must be a shift towards a model of comprehensive sexuality education in line with international best practices and human rights standards. Comprehensive sexuality education, coupled with public education campaigns, is central to ensuring that individuals have the knowledge needed to make informed decisions and behavioural choices that work for them in their sexual and reproductive lives, and has been linked to better sexual health outcomes including lowered pregnancy and STBBI rates and increased contraceptive use and sexual health testing. Done properly, it is also a key intervention in creating environments of gender equality and healthy and consensual approaches to sexual relationships and therefore reduces rates of sexual and intimate partner violence.
The monitoring and accumulation of statistics and indicators relating to sexual and reproductive health is absolutely vital in informing sound policy and programming decisions and expenditures. This surveillance requires the creation and monitoring of new sexual health indicators that reflect an integrated and comprehensive approach to sexual and reproductive health and rights. A key component of this data accumulation includes periodically reviewing statistics and indicators to ensure adaptability to the ever-changing environment and that strategies are created to respond to issues revealed by such data. For instance, data indicating major access issues to abortion must be met with federal leadership in working with provinces and territories to take corrective action.
Existing data collection for sexual and reproductive health is currently limited to compiling data such as STBBI and pregnancy rates but data of this type rarely provides an accurate picture of sexual and reproductive health and how it is influenced by social determinants of health. Previous work done by the Public Health Agency of Canada that saw the creation and pilot-testing of new Canadian sexual health indicators http://your-pharmacies.com was not federally supported in a significant way by previous governments. As such, the current federal government must revisit this project and support its continued progress. These indicators would similarly need to be responsive to the ever-changing environment of sexual and reproductive health, and therefore be evaluated and updated on a continual basis.
The government would need to reflect this integrated approach to sexual and reproductive health through changes in infrastructure that permit a more integrated and collaborative approach to sexual and reproductive health. Meeting existing best practices requires that the federal government move away from single-issue health programming towards a structure that more comprehensively acknowledges the complexity and integrated nature of health issues and by necessity, the responses to these health issues. These infrastructural changes would require the creation of avenues to allow different areas of government to work collaboratively, such as, for example, realigning the mandate of the Infectious Disease Prevention and Control Branch within the Public Health Agency of Canada to enable collaboration with other sections of the Public Health Agency of Canada and Health Canada as well as other federal departments and PT governments. It would be crucial to ensure appropriate integration of the new branch in the work of other units and branches to avoid the silo-ing of these issues. This infrastructural realignment would ensure that proactive and effective approaches to sexual and reproductive health can be pursued, and is necessary in order to implement a comprehensive plan of action relating to sexual and reproductive health and rights.
An integrated approach to sexual and reproductive health would also require – and conversely, enable – the full realization of the Canada Health Act and its principles of universality, comprehensiveness and accessibility. In order to meet the Minister’s mandated priority of a new, multi-year Health Accord, this includes ensuring that provinces and territories guarantee access to all medically necessary services, including abortion and other sexual and reproductive health services, and meet the principle of universality including barrier-free access to health care across the country. As noted most recently in Minister Philpott’s discussion of abortion services, vast discrepancies still exist in access to comprehensive sexual and reproductive health care services and the Minister has expressed commitment to equalizing this unequal terrain of access.
A truly integrated approach to sexual and reproductive health would therefore require that services, including abortion, be comprehensive, accessible and free of barriers. Barrier-free, comprehensive and accessible care would ultimately require federal leadership in holding provinces accountable for meeting the Canada Health Act’s accessibility and universality criteria through the provision of accessible services in a sufficient number of locations to ensure individuals do not have to accumulate extensive travel and accommodation fees to access care. Federal leadership may include withholding cash contributions when provincial and territorial governments fail to ensure the availability and accessibility of these key services, as well as ensuring cost coverage of sexual and reproductive health medicines and commodities to ensure the elimination of cost barriers. Similarly, the federal government must ensure that Mifegymiso is widely accessible and rolled-out with the appropriate regulations to ensure that it is able to alleviate the existing lack of availability of services in many rural and remote areas.
Key to actualizing all of these components of federal leadership is sound funding for multi-tiered initiatives, which will be informed by the revised indicators and data accumulated through updated surveillance methods. Multi-tiered initiatives could include establishing a national protocol for those individuals who must travel to the United States for later-term abortion services and the negotiation and implementation of appropriate monitoring and evidence and rights-based education and campaigns that comprehensively address sexual and reproductive health and rights in school and among key individuals within the public. Sound investments are required to create more equitable access to reproductive health care and complex funding solutions must therefore be negotiated as part of the new Health Accord. This would permit the most efficient use of existing resources, including sound provincial transfers for provinces and territories to ensure the availability of medically necessary medications and procedures relating to sexual and reproductive health, thereby meeting commitments under the Accord and the Canada Health Act.