March 4 2024
The Honourable Sylvia Jones
Ministry of Health
[email protected] | [email protected]
777 Bay Street, 5th Floor
Toronto, ON M7A 2J3
The Honourable Michael Tibollo
Ministry of Health
[email protected] | [email protected]
7 Queen’s Park Crescent
Toronto, ON M7A 1Y7
Dear Minister Jones and Associate Minister Tibollo,
RE: Supervised Consumption Services site closures due to lack of funding from Ministry of Health
We write to you with grave concern regarding the Ontario government’s inaction in ensuring the provision of urgently needed supervised consumption services (SCS) amidst a worsening public health emergency caused by the toxic unregulated drug supply. We are calling on you to immediately provide direct emergency funding on or before March 29 to SCS sites that have submitted their applications to the province and are under imminent threat of closure or have closed due to lack of funding, eliminate the Consumption and Treatment Services (CTS) approach to funding SCS and urgently provide, improve, and sustain uninterrupted provincial funding for SCS that includes inhalation services.
Unregulated drugs of unknown contents and potency are driving increased deaths, hospitalizations, injuries and trauma across Ontario, with an estimated 3,644 drug-related deaths in 2023. Several communities in Ontario have declared a state of emergency due to drug toxicity deaths. SCS, and particularly low-barrier overdose prevention sites, are a necessary emergency response to this crisis and must be immediately scaled up. In 2018, the Ontario government arbitrarily capped funding to only 21 CTS. Six years later, the government has still not delivered on funding 21 sites. Despite overwhelming need and local support, the Ontario government has approved and funded only 17 CTS locations across the entire province. Only one of these is located in northern Ontario (NorWest Community Health Centre in Thunder Bay). Meanwhile, the toxic unregulated drug crisis has taken far too many lives since 2018 – nearly 20,000 and rising, with many more family and friends left grieving.
In the context of this preventable public health emergency, urgent action is required. There are at least five submitted applications for CTS sites that have been inordinately delayed by the Ontario government in Sudbury (30 months since application was submitted), Barrie (28 months), Windsor (19 months), Timmins (13 months), and Hamilton, where the application was withdrawn in October 2023 after two years, in part due to the Ontario government’s delays and lack of transparency in providing the necessary approvals and funding to sustain the site. These delays are unacceptable and deadly.
The tragedy of an isolated instance of gun violence in Toronto must not prevent people in diverse locations across the province from accessing vital health services any longer. The Ontario government’s decision to stop processing applications altogether for more than seven months is punitive and irresponsible. After the significant years of work and investment in each community to prepare the onerous applications under the provincial CTS model, to secure a suitable location and community support, and – in the case of Sudbury, Windsor and Timmins where the sites have been established with municipal stopgap funding – to hire and train staff and build trust and service uptake amongst people who use drugs, these sites are at imminent risk of closure or have been forced to close due to a lack of provincial funding. It should not fall to municipalities to fund healthcare services, which are a provincial responsibility. Moreover, management of these sites is extremely challenged by the Ontario government’s lack of transparency and accountability regarding site funding and approval timelines. In the case of Windsor, lacking the much-needed provincial support, the site has been forced to close.
Of the regions with submitted, pending CTS applications, data released in 2024 from the Office of the Chief Coroner indicates that three of these regions have amongst the ten highest mortality rates in the province: Timmins, Windsor and Sudbury each have an opioid toxicity mortality rate that is nearly three times the provincial average. Further, inhalation now accounts for significantly more overdose deaths than injection in Ontario, according to data from the Office of the Chief Coroner, yet the current CTS model continues to prohibit inhalation services. Services must be designed and supported to reflect the magnitude of the crisis and the data regarding regional need and modalities of drug use.
Failure to equitably provide for lifesaving health services like SCS is discriminatory and violates the right to life and security of the person for people who use drugs. The inordinate delays in processing applications, onerous requirements and lack of inhalation services under the provincial CTS model are also fiscally irresponsible, unsustainable and ineffective for the provision of a service that is fundamentally necessary amidst the worsening public health emergency that is the toxic unregulated drug crisis.
SCS are evidence-based, highly effective, and must be recognized as an integral part of Ontario’s publicly funded healthcare system. As such, these services must be universally available wherever there is need. These sites relieve the burden from overtaxed emergency first responders and are not complex to implement; they require an accessible location, oxygen, naloxone, sterile medical and first aid supplies, and supervising staff. It is indefensible as a matter of public health and fiscal policy that we currently have a two-tiered healthcare system where SCS are available in some southern Ontario communities and not in northern Ontario. It is a violation of the fundamental rights to equality and security of the person.
We call for urgent action from the province, commensurate with the magnitude of the crisis our communities are facing. It is vital that the Ontario government embrace a harm reduction approach to substance use, which centres the dignity, health and safety of people who use drugs while providing pathways to care, services, and community.
We are calling on the Ontario government to:
- Immediately provide direct emergency funding on or before March 29 to supervised consumption services (SCS) sites that have submitted their Consumption and Treatment Services (CTS) applications to the province and are under imminent threat of closure or have closed due to lack of funding.
- Urgently provide, improve, and sustain uninterrupted provincial funding for SCS, including inhalation, and ensure equity in regional service availability, particularly in northern communities.
- Phase out the Consumption and Treatment Services (CTS) approach to funding SCS, which requires additional and overly stringent conditions over and above Health Canada’s requirements.
- In the interim, immediately remove the cap on the number of funded SCS sites and the prohibition on inhalation services under the provincial CTS model.
- In the interim, introduce transparency and an expedited 30-day timeline for responding to applications under the provincial CTS model.
- Introduce a low-barrier process by which community organizations can seek provincial funding for SCS.
- Integrate SCS into Ontario’s core funded healthcare system with ongoing, integrated funding and resources.
- Meet with us by March 13.
We look forward to hearing from you as soon as possible on this urgent matter.
Signed by,
DJ Larkin, Executive Director, Canadian Drug Policy Coalition
Heidi Eisenhauer, Executive Director, Réseau ACCESS Network
Janet Butler-McPhee & Sandra Ka Hon Chu, Co-Executive Directors, HIV Legal Network
Dr. Julie Samson, Co-lead of the addiction medicine consult service, Timmins and District Hospital
Michael Brennan, Executive Director, Pozitive Pathways Community Service
Michael Parkinson, Coordinator, Drug Strategy Network of Ontario
Endorsed by,
Adrian R. Betts, Executive Director, AIDS Committee of Durham Region (ACDR)
Alison Stagg, Director of Programs, Four Counties Addiction Services Team
Alyssa Wright, Co-Lead, Supervised Consumption Saves Lives – Barrie
Andrea Sereda, Dr., London Intercommunity Health Centre
Ashley Schuitema, Lawyer, Waterloo Region Community Legal Services
Ashley Smoke and Missy McLean, Co-founders, TweakEasyCBG
Avery Ng, PFAC Member, WEOHT
Brooke Rorseth, Crisis Worker (MSW, RSW), Hotel Dieu Grace Healthcare
Cameron Dearlove, Chair, Waterloo Region Integrated Drug Strategy
Chandra Ewing, Chair, Board of Directors, Maggie’s Toronto Sex Workers Action Project
Dane Record, Executive Director, PARN
Denise Baldwin, Administrator, Indigenous Harm Reduction Network
Dr. Dan Werb, Executive Director, Centre on Drug Policy Evaluation
Dr. Doris Grinspun, RN, BScN, MSN, PhD, LLD(hon), Dr(hc), DHC, DHC, FAAN, FCAN, O.ONT., Chief Executive Officer, Registered Nurses Association of Ontario (RNAO)
Elizabeth Dulmage, Executive Director, Brentwood Recovery Home
Eric Cashmore, Executive Director, The Seeking Help Project
Farihah Ali, Manager and Scientific Lead, Ontario CRISM Node
Heather Johnson-Dobransky, Director of Operations, Hiatus House
Holly Gauvin, Executive Director, Elevate NWO
Jackie Barrett-Greene, Director, Positive Living Niagara
Jason Sereda, President, Board of Directors, DIY Community Health Timmins
Jason White, Chairperson, The Human Factor Community Organization
Jean Hopkins, Manager, Wellington Guelph Drug Strategy
Jody Jollimore, Executive Director, CATIE
John Maxwell, Executive Director, ACT
Julie Nobert-DeMarchi, Executive Director, Timmins & Area Women in Crisis
Karen Henze, Manager, Community Development and Housing, Canadian Mental Health Association – Sudbury/Manitoulin Branch
Karla Ghartey, Member; Assistant Professor, Sudbury Temporary Overdose Prevention Society; Nipissing University
Kate Fairbairn, Patient, Family & Caregiver- Partnership Council, Windsor Essex Ontario Health Care team
Khaled Salam, Executive Director, AIDS Committee of Ottawa
Lady Laforet, Executive Director, Welcome Centre Shelter for Women and Families
Lindsay Jennings, Reintegration Specialist, Incarcerated Voters of Ontario
Lisa Toner, Team Lead, Ontario Aboriginal HIV/AIDS Strategy
Liv Delair, Co-Chair, Canadian Students for Sensible Drug Policy
Dr. Louisa Marion-Bellemare, Physician, Timmins and District Hospital
Lori Vachon, Addiction and Mental Health Worker Program Coordinator, Northern College
Luciano Carlone, Interim CEO, Canadian Mental Heath Association, Windsor Essex County Branch
Marie Morton, Executive Director, CAYR Community Connections
Matthew Shoemaker, Mayor, City of Sault Ste. Marie
Meghan Young, Executive Director, Ontario Aboriginal HIV/AIDS Strategy (OAhas)
Mike Murphy, Addiction Medicine Physician, NOSM U
Mika Wee, Steering Committee Member, Shelter & Housing Justice Network
Molly Bannerman, Director, Women and HIV / AIDS Initiative
Mona Loutfy, Maple Leaf Medical Clinic
Michelle Boileau, Mayor, City of Timmins
Nadine Sookermany, Executive Director, Fife House
Natasha Tousenard, Executive Director, Canadian Association of People Who Use Drugs
Neil Stephen, CD, Registered Nurse
Noulmook Sutdhibhasilp, Executive Director, Asian Community AIDS Services
Olivia Mancini, Registered Social Worker / Co-Founder, Student Overdose Prevention and Education Network
Pamela Taplay, Supervisor, National Overdose Response Service
Patrick Kolowicz, Director, Mental Health and Addictions, Hôtel-Dieu Grace Healthcare
Patty MacDonald, Chief Executive Officer, Canadian Mental Health Association – Sudbury/Manitoulin
Rebecca Robinson, Violence Against Women’s Services Coordinator, Sudbury and Area Victim Services
Renee M Geniole, Executive Director, R.O.C.K. (Reach Out Chatham-Kent)
Reverend Christine Nayler, Co-founder/ Director, Ryan’s Hope
Rita Taillefer, Executive Director, Windsor Essex Community Health Centre
Robert Cameron, Executive Director, Downtown Windsor Community Collaborative
Rukshini Ponniah-Goulin, Executive Director, The United Church Downtown Mission of Windsor
Ruth Cameron, Executive Director, ACCKWA
Ruth Fox, Regional Director, Ontario, Moms Stop the Harm
Sarah Haanstra, Director of Integrated Programs, Guelph Community Health Centre
Sarah Pimperton, CEO É FOUNDER, Helping Hearts and Hands Housing Initiative Inc.
Sarah Tilley, Harm Reduction Manager, Gilbert Centre
Scott Roose, Founder, Weather the Storm Outreach and Harm Reduction Services
Seamus Murphy, Deputy Chief of Standards and Community Services, Cochrane District Paramedic Service
Sharmin Sharif, Interim Executive Director, Moyo Health and Community Services
Shelley Muldoon, Director, Mental Health and Addictions, Woodstock Hospital
Stacey L. Mayhall, Executive Director, AIDS Committee of North Bay & Area
Susan Stewart, Chair, KFL&A Community Drug Strategy Advisory Committee
Suzanne Paddock, Executive Director, Toronto People With AIDS Foundation
Thierry Croussette, Board President, Seizure and Brain Injury Centre
Thomas Hutchison, Outreach Coordinator, Living Space
Tiffany Pyoli York, Co-Chair, Greater Sudbury Anti Human Trafficking Coalition
Toronto Overdose Prevention Society
Victoria Scott, Director, Engage Barrie Organization
Updated March 27, 2024
