Release of Sunshine List regulations

September 11, 2020

Dr. Christine Molnar, AMA President

Dear Members:

On September 9, government released regulations on physician payment disclosure. The regulations are brief and lay out a 60-day disclosure date, meaning the information can be released as of Sunday, November 8, or anytime before.

The public, through their taxes, pays for our medical services. It is in society’s interest that our health care system is efficient, cost-effective and adds value. Transparency is important, as is accountability. Greater transparency for the public through the Sunshine List, in our view (August 10 President’s Letter), does not require the release of individual names. However, we understand from discussions with government that there is a decision to proceed with the release of our names with our gross billing data.

Two issues of prime importance remain: that the public is fully informed about the context of the information and that a fair and reasonable process for exemption is implemented.

For clarity, and since prior Sunshine Lists mostly reflect salaried positions, it is important that the public not confuse our billing data with our take-home pay. The AMA published a document called Context Matters: The Facts About Physician Compensation in Alberta to provide better understanding of gross billing data. Our annual billings support overhead costs in our practices, vary with hours and days worked, support disability insurance, parental and medical leave and retirement saving. They reflect the expenses from the long years of training required to achieve our degrees and certifications and the ongoing costs of required CME. In a recent September 3 letter from the Minister, he indicated, “Our intent is to provide useful information for Albertans. We are considering publishing non-payment data that will give Albertans important context for the payment information.” The AMA will work with Alberta Health to this end.

An exemption process that is fair, clearly communicated and allows time for submission and appeals is essential. The relationship of patients with their medical doctors is highly confidential and personal. The positive support patients experience in a doctor-patient relationship is important in the healing process. There are concerns that identifying physicians by name in the Sunshine List may, in some settings, negatively affect this powerful relationship. Members with family in politically unstable countries, or third-world environments have contacted me with concerns for the welfare of their loved ones for fear of kidnapping. A number of our members provide volunteer services in underprivileged countries and have expressed concern that they may become targets for ransom. The exemption process will need to be sensitive to these and other individual situations and circumstances.

On a last note, in light of the dramatic adverse changes wrought by the COVID-19 pandemic on our medical practices, the financial data to be published is historical and does not at all reflect our current reality. In this new environment of decreased revenues and increased overhead costs, the final equation is far from clear.

We met with government in August to provide feedback and explain our concerns. As noted above, the Minister’s September 3 letter stated his willingness to hear further from the AMA on issues related to the release of a physician Sunshine List. This further consultation is welcome.

I will share additional information on this issue as it becomes available.

In your service,

Christine P. Molnar, MD, FRCPC
President, Alberta Medical Association

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