The government expanded who can provide primary care, but must now define which services Canadians are entitled to
A year ago, then-Health Minister Mark Holland issued a landmark interpretation of the Canada Health Act (CHA). His "CHA Services Policy" will finally take effect this April and declares that nurse practitioners, pharmacists and midwives providing "physician-equivalent services" must be covered by public insurance. No patient charges allowed.
It’s a bold move. But it has left a fundamental question unanswered: equivalent to what physician services, exactly?
The CHA promises Canadians access to "medically necessary" services. Yet for over 40 years, we have never defined what "medically necessary" means for primary care. The Act covers "physician services" – but the scope of these “comprehensive” services has never been specified. In practice, "medically necessary" has become whatever a physician chose to bill for – an honour system with no accountability to a defined standard.
This matters because 5.9 million Canadians lack access to a primary care provider, according to Dr. Tara Kiran's 2025 OurCare survey. But even those who have a provider have no guarantee of comprehensive services.
Access to what? We have never answered the question. It’s time the federal government waded into these waters.
Minister Holland's interpretation expanded coverage to team members – a necessary step as primary care evolves beyond what any single practitioner can provide. But we cannot fund teams for an undefined scope any more than we could hold individual physicians accountable for it.
If we want team-based care to deliver on the promise of comprehensive primary care, we need to define what comprehensive means.
The good news: we do not need to start from scratch.
We already have rigorous standards for certifying and training family physicians that describe the scope of comprehensive care they are prepared to provide – from chronic disease management to mental health, from health promotion and palliative care to women's health, from delivering babies to emergency medicine.
If the CHA uses "medically necessary physician services" as its anchor, could we start here? Could these training and certification standards serve as a foundation for defining what comprehensive primary care should include?
Given the broad scope of what family physicians are able to do, this is not about limiting scope.
Many health care professionals have overlapping scopes of practice with physicians, but what varies is the depth of expertise. We have an opportunity to use an existing family physician competency framework developed through a rigorous consensus as a starting point – one that can be used across all health professionals defining what breadth of comprehensive primary care they have been trained to provide and the depth of their expertise.
Imagine a national consensus process that brings together provinces, medical associations, health professional organizations, regulators, accreditors and patient advocates to validate a "basket" of essential primary care services. A framework that guides provincial decision-making while respecting their jurisdiction. One that links defined services to population health outcomes – the ultimate measure of whether primary care is working.
The policy window is open.
Ontario's Primary Care Act requires the Ontario Health Minister to annually report on access; the federal government has invested billions in team-based care through bilateral agreements; and now the Health Standards Organization (HSO) has just launched its revised primary healthcare standard for public review which offers another opportunity to define what the public can expect and what the system should be accountable for in delivering primary care regardless of funding model. The HSO primary healthcare standard, like hospital standards, is optional for use and is voluntary but not tied to any accountability process.
So, we have principles and frameworks. We even have education and practice standards – and a huge investment of money. Now we need alignment towards a common purpose.
Some will argue health is a provincial responsibility. But the federal government sets national standards and conditions for health transfers.
A consensus process convened at the FPT Primary Care Table with the Canadian Medical Association, its provincial medical organizations and other health professional associations could produce a pan-Canadian framework that would guide provincial/territorial decision-making while respecting local adaptation – just as has been done with other national standards.
Others will worry about scope-of-practice battles among professions. But defining what services Canadians are entitled to receive is different from prescribing who must deliver them and how. A defined scope actually enables team-based care by clarifying what the team must collectively provide within a practice context.
For decades we have promised Canadians access to medically necessary services without defining what that means in primary care. It is time to set this idea in motion: a framework that guides provinces and territories, enables accountability and ultimately improves the health of Canadians.
The question is will governments have the courage to convene and lead the way.
Dr. Ivy Oandasan is a family physician, Full Professor in the Department of Family and Community Medicine at the University of Toronto. She co-led the $45.3 million Team Primary Care: Training for Transformation initiative.
