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OHRC letter to Ontario government ministers on the online health card renewal service

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December 20, 2021

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Hon. Christine Elliott, Minister of Health
Hon. Ross Romano, Minister of Government and Consumer Services
Hon. Caroline Mulroney, Minister of Transportation

Dear Ministers:

Re: Online Health Card Renewal Service

I am writing about concerns over the new online government service for obtaining health card renewals that have been brought to my attention.

The Human Rights Code requires proactive planning to prevent or remove barriers to people with disabilities and older adults in services. I am writing to encourage you to make sure people with disabilities and older adults will have the same opportunity as others to obtain the health card renewal online.

This online service allows citizens to renew their health card online if they have a current driver’s license and meet other criteria such as not needing a new photo (which is required every 10 years). However, many citizens with disabilities do not have a driver’s license. As many people with disabilities also face barriers in travel and may be more vulnerable in any exposure to COVID-19, it is especially important that they be able to access, use and benefit from the convenience of any online services available to avoid travel and in person services. 

Several years ago the Ministry of Transportation introduced the Ontario Photo Card at the request of the disability community. This was an excellent initiative to offer people with disabilities and others who do not have a driver’s license an equal opportunity to obtain an official government identification card with a photo. Unfortunately, the Ontario Photo Card is not accepted as identification in the new online health card renewal system, so many people with disabilities are unable to use this option.

I recognize that health card renewals have not been required during COVID-19, but understand that this requirement will be reinstated in February 2022. People with disabilities may need to plan significantly ahead to ensure their health card is renewed. I would welcome hearing of your plan to address this barrier for people with disabilities and older adults, so they may equally benefit from the new online service.

It may also be helpful to consider whether a policy or procedure may be needed to ensure the needs of people with disabilities and older adults are considered and addressed in future service offerings.


Patricia DeGuire
Chief Commissioner

cc:      Hon. Raymond Cho, Minister for Seniors and Accessibility
          OHRC Commissioners