The More Convenient Care Act, 2025 – Refreshed Legislative Objectives for Ontario’s Health Care Sector

On May 5, 2025, the Ontario Minister of Health, the Honorable Sylvia Jones, introduced the More Convenient Care Act, 2025 (“Bill 11”) for its first reading,[1] as part of the Government of Ontario’s ongoing efforts to modernize the province’s health care system. While Bill 11 is not yet law, it is currently being debated at Second Reading, it addresses a variety of issues in the current system, and it provides insights into the current priorities of the Ontario Government for the health care sector. This blog post will discuss the following two issues, which Bill 11 aims to address: (1) health care staffing challenges; and (2) modernization of health information records systems, and patient access thereto.

Addressing Health Care Staffing Challenges

The COVID-19 pandemic highlighted (and compounded) issues in health care staffing in Ontario, including workforce shortages, high turnover rates, and a lack of transparency regarding the use of private staffing agencies. To address some of these concerns, Bill 11 introduces the Health Care Staffing Agency Reporting Act,[2] a new framework designed to increase accountability and oversight for health care staffing agencies.

Key Provisions of the Health Care Staffing Agency Reporting Act:

• Mandatory Reporting: Staffing agencies must submit detailed reports to the Minister of Health every six months. These reports will include aggregate administrative, billing, and pay rate information for health care workers assigned to posts in public health care facilities.
• Record-Keeping Requirements: Agencies are required to maintain comprehensive records in accordance with specified standards.
• Transparency Measures: The Minister has the authority to publish certain data from the submitted reports, promoting transparency in staffing practices.
• Penalties for Non-Compliance: Staffing agencies that fail to meet these requirements could face penalties, including fines of up to $25,000 for corporations.

Bill 11 also introduces amendments to the Mandatory Blood Testing Act,[3] granting nurse practitioners greater authority to  perform certain functions that are currently specified for performance by physicians. These functions include taking a blood sample from an individual when ordered by the Consent and Capacity Board. 

Modernizing Health Information Records

The need to modernize how health information is managed, shared, and protected has become paramount. Bill 11 introduces significant amendments to the Personal Health Information Protection Act (“PHIPA”)[4]  to support the integration of digital health technologies, particularly through the use of Digital Health Identifiers (“DHIs”). DHI’s are unique identifiers created by a prescribed health care organization that can be used to confirm the identity of an individual.

Key proposed changes to PHIPA include: 

• Creation and Management of DHIs: A prescribed organization will be authorized to create and manage DHIs.
• Privacy Safeguards: Within one year of the amendment taking effect, prescribed organizations must have in place privacy practices and procedures to protect the privacy of individuals whose personal health information is in the digital health identifier records. These practices are subject to approval by the Privacy Commissioner and will be reviewed every three years. The prescribed organization will be required to publish the approved practices on the organization’s website, and make publicly available a plain language description of its DHI activities or services, including a general description of the technical, administrative and physical safeguards in place. Prescribed organizations will also have the obligation to notify individuals in the event of privacy breaches.
• New Enforcement Mechanisms: A new offence has been introduced for individuals or organizations that intentionally dispose of personal health information records to evade access requests. Violations could result in substantial penalties, including fines of up to $200,000 for a natural person[5], or up to $1,000,000 if the violating party is not a natural person. Note that under PHIPA, liability can be extended to officers, members, employees or other agents of a corporation who authorized such an offence, or who had the authority to prevent the offence from being committed but knowingly refrained from doing so.
• Access to Health Records: The Lieutenant Governor in Council has also been empowered to make regulations prescribing the format or manner in which personal health information records, including electronic records, and digital health identifier records, are to be made available, and to who, and requiring prescribed organizations to provide summaries of such records, and allowing summaries to be disclosed in response to access requests instead of the complete record. Such regulations have yet to be released.

The proposed amendments could have significant implications for Ontario's health care sector and could lead to enhanced transparency, accountability, and modernization in health care delivery, making Bill 11 an important bill to follow through the legislative process. 

For any questions, we encourage you to contact members of our Health Industry Group, Technology Group, or Cyber/Data Group.

[1]See: https://www.ola.org/en/legislative-business/bills/parliament-44/session-1/bill-11

[2] Bill 11, More Convenient Care Act, 2025 Sch. 3.

[3]Bill 11, More Convenient Care Act, 2025 Sch. 5.

[4] Bill 11, More Convenient Care Act, Ontario, 2025 Sch. 6

[5] Or to a term of imprisonment of not more than 1 year, or to both.