1. Quality of Care Risks
The CPSA document’s requirements for form completion and third-party responses can inadvertently increase liability by mandating medical opinions for non-clinical purposes, risking misinterpretation and punitive consequences if information is incomplete or misunderstood.
Physician independence is challenged when external parties pressure physicians to provide judgments that may exceed their direct clinical scope, risking error and undermining their impartiality.
2. Professional Stress and Burnout
Additional administrative burdens and the fear of repercussions for honest, nuanced responses (or for refusing inappropriate requests) increase stress, discourage practitioner engagement, and contribute to burnout.
3. Threats to Access
Complex and demanding third-party requirements may deter physicians from engaging with certain patient populations or occupational health cases, worsening shortage in key areas.
4. Erosion of Trust
If physicians feel compelled to comply with requests that threaten their independence or professional judgment—for instance, issuing opinions on matters outside their expertise—patients may perceive doctors as agents of insurers/employers rather than advocates, eroding trust.
5. Chilling Effect on Advocacy
The mention of legislative requirements (HIA, provincial standards) must be balanced with respect for physician autonomy; otherwise, advocacy for patient interests and ethical dissent is suppressed.
6. Financial and Systemic Burdens
Third-party forms and the liability attached can increase malpractice risks and administrative costs, crowding out resources for clinical care.
Conclusion
Policies and standards—such as those in the CPSA document—should:
Safeguard physician autonomy so that responses to third-party requests remain strictly within scope and evidence-based, not coerced.
Limit liability for honest, bounded opinions.
Promote clear boundaries: Physicians must not be pressured to act as de facto legal or insurance gatekeepers. The role of a physician is clinical advocacy, not bureaucratic risk-bearing.




















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