Changes to Professional Regulation (Bill 36 – Health Professions and Occupations Act)

Changes to Professional Regulation (Bill 36 – Health Professions and Occupations Act)

On November 24, 2022, the new Health Professions and Occupations Act (formerly known as Bill 36) was passed by the BC government after a legislative process that Doctors of BC and others have criticized as lacking meaningful engagement and consultation with key partners. As most of the Act is not yet in force, and many key regulations have not been released, Doctors of BC continues to advocate for changes through the development of regulation that addresses concerns expressed by members.

When fully in force, the Health Professions and Occupations Act will replace the current Health Professions Act, which has been in place for approximately 30 years. It envisions a consolidated regulatory landscape with modernized colleges to improve their capacity to regulate in the public interest. While many of the over 120,000 regulated health practitioners in BC will see their regulatory colleges amalgamated, the College of Physicians and Surgeons will remain a single college focused exclusively on the licensure of doctors.

The new Act contains important improvements to support cultural safety and humility, and it brings a heightened level of regulation to additional health practitioners. The concerns we have heard from many regulated professionals, including doctors, focus on the shift to appointed college boards and changes to investigation and discipline processes.

Advocacy and member support

  • Doctors of BC raised concerns about the proposed changes during the province’s two engagement and consultation processes that took place prior to introducing the Health Professions and Occupations Act:
  • We also shared these concerns and our position on the Act with members via a President’s Letter (login required).
  • To support members’ understanding of the changes and the impact on physicians, Doctors of BC held a Town Hall webinar in which Government staff outlined the reasons for the Health Professions and Occupations Act and explained what it means for doctors; this was followed by a discussion with Doctors of BC leaders on the next steps to effectively advocate on behalf of the profession.
  • Doctors of BC Past President Dr Ramneek Dosanjh spoke to CTV News citing “This is not the time to implement and make these kinds of sweeping changes without deep consultation that could actually impact our profession and our patients.”
  • Doctors of BC Past President Dr Joshua Greggain spoke with Vancouver Sun noting that "Doctors of BC supports efforts to hold our health-care providers, including physicians, accountable to a high standard for both public confidence and health issues.” However, he said the “process matters as much as outcome and many physicians have been blindsided by a process they weren’t fully informed about."
  • Staff in Doctors of BC’s Policy, Strategy and Legal & Affairs Department is actively engaged in discussions with other health professional associations to understand the legislation’s impact on physicians and allied health care providers, and to develop information resources to support understanding and awareness of the Act.

Legislative History

  • April 2019: The Cayton Report is publicly released. The Report was an inquiry into performance of the College of Dental Surgeons, with Part 2 being recommendations on broader health profession regulation modernization.
  • May 2019: The Province undertakes direct engagement and releases an Engagement Summary.
  • Nov 2019: The Province releases a formal Consultation Paper on modernizing health profession regulation.
  • Aug 2020: The Province releases its What We Heard consultation summary and its Steering Committee Recommendations report.
  • Oct 2022: Bill 36 is introduced for first reading in the Legislature.
  • Nov 2022: Bill 36 receives third reading and Royal Assent. The Health Professions and Occupations Act is enacted but not in force.
  • 2023: Parts of the Act necessary to stand up the Superintendents Office and amalgamate some health regulatory colleges come into force.
  • June 2024: The amalgamation of 11 health-professional colleges into two: The College of Health and Care Professionals of BC and the College of Complementary Health Professionals of BC.

Next steps

The Health Professions Act remains the primary legislation governing the practice of all health professions in all colleges, including doctors, and will remain in effect until it is repealed when the Health Professions and Occupations Act is fully in force (estimated 2025).

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