Once the regulations were posted, there was a 45 calendar-day limit for the posting of comments. Such a limited 'consultation' period could guarantee neither dialogue nor concrete change. And, to date, no true public debate has occurred over whether or not assisted reproduction services should be publicly funded.
The Fédération du Québec pour le planning des naissances (FQPN) is - among other groups - opposed to the adoption of the proposed regulations for a number of reasons. Perhaps the most important of these are concerns about how they will divert public funding from essential medical services and further privatise our health care system.
At the same time as it was planning to allocate $80 Million per year (after the first year) of public funds to assisted reproduction - a service that relies on high-technology-based practices to benefit the few - the Charest government was suggesting the possibility of imposing retrogressive user fees for basic health services on all Québecers. The government's willingness to divert taxpayers' money into assisted reproduction services is especially baffling when scarce funding means pregnant women across Québec increasingly lack access to family practitioners, obstetricians, and midwives. Moreover, the government has not even proposed funding for less technologically-intensive ways of preventing infertility. We must ask if the government's choice to finance IVF for some is truly a priority when the health of the general population will be put at risk if the proposed user fees are enacted.
The published regulations also suggest that public funding will cover a much broader set of activities than originally announced when Bill 26 was passed. In 2009, the government said that public funds would cover up to three cycles of IVF. Yet the March 2010 regulations state that, depending on the techniques used, public funds will cover up to six cycles of IVF as well as all related services, such as freezing sperm for an indefinite period of time. They also include funding for poorly-defined research activities and experimental techniques. Worse still, the measures to be used for supervising all of these activities are fragmentary and gravely incomplete.
Secondly, as written, the proposed regulations threaten the separation of public and private health care, something fundamental to the integrity of our universal health care system. For example, the ambiguity in the regulations suggests that there could be public payment for IVF performed in a private facility by physicians who do not participate in the public regime (RAMQ). In other words, non-participating physicians could be fully insured and compensated using public funding. If so, this would seem to contravene the law on health insurance which precludes the use of RAMQ funds to pay non-participating physicians. The regulations are also unclear as to whether physicians in the public system will be able to charge individuals privately for further IVF treatments if their first three to six attempts are unsuccessful.
Regardless of one's views on assisted reproduction, the regulations published in March can only be seen as incomplete, unclear, and inadequate - and certainly fail to justify the considerable amount of public funding to be allocated to these practices. To protect our already fragile universal health care system, the FQPN encourages the public to voice its disapproval of these regulations and of the funding of assisted reproduction at this time.