Thank you, Mr. Chair and committee members, for the invitation to present to you today.
I would like to be clear, first and foremost, that my comments and those contained in our written brief are not intended as a reflection upon any current or former employees of the Public Health Agency of Canada. We have only the greatest respect for all of them.
It is the position of the Canadian Public Health Association that the chief public health officer should continue to be the deputy head of the Public Health Agency of Canada and continue to operate at the deputy minister level. As such, we recommend to this committee that the amendments to the Public Health Agency of Canada Act proposed in Bill C-43 be withdrawn and that the consequential amendment to the Financial Administration Act also be withdrawn.
While we agree that there should be a division of roles and responsibilities between the administrative and professional sides of the agency, we feel strongly that the titular head of the agency must be a public health professional. The current structure was established based on the recommendations of the Naylor committee after the 2003 SARS outbreak. That committee was very specific in its recommendation that the agency should be headed by the CPHO and that the CPHO report directly to the federal Minister of Health. The Naylor committee reviewed the organizational structures in place for a number of different jurisdictions and felt that its recommendations represented the best option for Canada's national public health body.
In 2010 the position of executive vice-president and chief operating officer was created to provide administrative support to the CPHO. This change formally split the administrative and professional responsibilities of the CPHO while leaving the CPHO as the deputy head of the agency. Since that time that structure has served the agency and Canadians well.
Our concerns for the proposed amendments are as follows.
First, while the CPHO has the responsibility to promote and protect the health of Canadians, in the proposed structure the position would retain responsibility but have no authority to mobilize resources.
Second, the country's public health priorities must take precedence over bureaucratic priorities, but this does not preclude the executive vice-president and chief operating officer from being responsible for day-to-day operational and administrative duties.
Third, it is essential that the CPHO work closely with fellow deputy ministers at the federal and provincial/territorial levels. Under the current structure the CPHO has a seat at those tables by right of his or her position. Under the proposed amendments the CPHO could only be invited to those discussions, and only as an adviser so that he or she would not be taking part in the decision-making process.
At the end of the day, rank matters and these amendments will essentially strip the position of CPHO of its current rank.
Our final and possibly most troubling concern is that the new model would give both the CPHO and the president of the agency direct access to the minister. In the unfortunate situation where agreement cannot be reached between the CPHO and the president, the minister could be faced with contradictory policy advice and left in the role of arbiter. This model is not considered good practice in a modern bureaucracy and should be avoided.
During a public health emergency such as a pandemic of H1N1 or Ebola, the importance of evidence-based advice from the CPHO is clear. This advice, however, is important at all times as Canadians are increasingly concerned about the sustainability of their publicly funded health care system. Public health has at its foundation the protection and improvement of health and well-being of Canadians and, as such, its policies, programs, and initiatives are focused on keeping people out of hospitals and doctors' offices. If the CPHO does not have the necessary authority to direct agency staff and marshal its resources, his or her advice may not be worth the paper on which it is written.
The structure of the agency with the CPHO at its helm has been effective for the first decade of its existence, and there is no clear evidence that the proposed changes are needed.
Thank you.