June 4, 2009


Ms. Colleen Sonnenberg
Ministry of Health and Long-Term Care
LTCHA Regulation Project
9th Floor, 56 Wellesley Street West
Toronto, ON, M7A 2J9

Dear Ms. Sonnenberg:

I am pleased to send you comments from the Champlain Region Family Councils Network (CRFCN) on the Proposed Initial Draft Regulations to be made under the Long Term Care Homes Act 2007. I hope you will find them useful. Like others, we feel that the one- month time period for review was very short and as a result we had to be selective about which proposed regulations we are able to comment upon.

In our view, the most serious failing of the proposed regulations is the failure to incorporate standards. Paragraph 38 (2) (a) of the Long Term Care Homes Act 2007 allows for the making of regulations “…establishing standards or outcomes that must be met.” We strongly recommend that the MOHLTC incorporate standards of care into these and the promised second set of regulations made under the Long Term Care Homes Act. That being said, there are some positive, new requirements in the Regulations and we are especially happy to note those with respect to abuse and neglect and continence care.

Should you require any additional information on our submission, please feel free to contact me at the telephone number listed below. You may also contact Mary Frances Taylor, Chair of CRFCN’s Advocacy Committee. She can be reached at 613-730-8450.


Sincerely,


__________________________________
Eleanor Ryan, Chair

Champlain Region Family Councils Network
Tel 613-235-5741