The following submission was made to the Ministry of Education by BPS negotiators Jeffrey Weston and Nick Mustari on February 11, 2022, on behalf of Sector 3 (Boards of Education) and Sector 15 (Child Treatment):
Ministry of Education
Mowat Block, 900 Bay Street
Toronto, ON M7A 1L2RE: Review of Policy/Program Memorandum 81: Provision of health support services in school settings (PPM 81)
Thank you for the opportunity to hear from OPSEU/SEFPO members across our education and children’s treatment sectors on updates to PPM 81. We have shared the consultation slide deck and questions with leadership in these sectors and have included their initial responses below. As the process of updating PPM 81 continues and more specific proposed changes shared, we expect to have further conversations with the Ministry on this topic to ensure that the views and needs of our members providing these services are incorporated.
While a review and update of PPM 81 may address some issues the sector faces, many problems would be solved with greater monetary investment to increase wages and benefits for Education Support staff, especially considering the significant changes to these roles and the increasingly complex needs of the students they help. Staff shortages have meant that schools boards have a harder time providing support to students, as fewer people are applying to work for school boards as support staff due to low wages.
Below are the initial answers from OPSEU/SEFPO members to the questions posed in the consultation slide deck.
General Questions:
- Are there best practices in place locally that are not currently reflected in the PPM?
Each Children’s Treatment Centre has its own methods of service delivery, which our members feel are not entirely captured in the current PPM. Recognizing that best practices will look different across each region and location, a revised PPM 81 should attempt to establish a minimum standard of best practice, while the Ministry ensures that required funding to achieve and exceed those practices is provided.
- Once the revised PPM is released, how long do you anticipate will be required for full implementation? What issues and opportunities need to be considered to support effective implementation?
In the children’s treatment sector, increased staffing and front-line training for therapists would be needed depending on how significantly the model of service shifts. For school boards to roll out required changes it would also likely take months to a year to properly roll out changes, depending on how significant they are. Our members in the education support sector emphasized training developed and delivered in a timely manner, and increased hiring for job requirements, specifically nurses. Our members also indicate that effective training related to the specific student needs must be provided.
Health Supports and Interventions Questions:
- What medical interventions are provided day-to-day to students?
Support Staff in the education sector administer some oral medications. However, more training and instruction need to be provided for PRNs, as this is new for Support Staff. Many do not come with medication training and courses from acceptable diploma or degree courses. These members also support students with prevalent medical conditions (anaphylaxis, asthma, diabetes, and/or epilepsy), feeding tubes, suctioning for physically disabled students, lifting, transferring, positioning, assistance with mobility, feeding, toileting, prescribed exercises (physio), daily hygiene (showering), speech and language, interpreting/communication for hearing impaired and blind students. Many of the complex needs of our students, are not met with necessary training and instructions from school boards or medical practitioners.
- What are the core roles and responsibilities in the delivery of health supports and interventions for students? How can these services be provided most efficiently and in a way that meets students’ needs?
Educational Assistants and Speech and Language Assistants are spread very thin across all school boards, and with increasing unfilled assignments this is becoming very problematic. It is causing challenges for staff to ensure all sure all required needs of the students are met.
- How are emergency medical supports provided (e.g., emergency seizure medications)? Are there barriers to providing these services and how can they be addressed?
It’s a requirement that medical documentation be submitted by a physician and paperwork must be in place for medication to be administered, however this requirement is not always followed by Administrators and parents. A medical plan should be in place for students with needs. Another critical issue is not having specific training by medical professionals to assist with Support Staff in schools being directed to follow some medical plans.
- Are there concerns related to PPM 81 for those providing dietetics services that should be taken into consideration?
There are concerns that some of the requirements fall under the job description for Educational Assistants/Support staff, but many do not come from nursing backgrounds or training. Education-related programs typically do not include training on dietetics services such as catheterization, manual expression of the bladder, stoma care, postural drainage, suctioning and tube feeding.
- What opportunities exist within the context of a revised PPM 81 to help address health human resources challenges, particularly with nurses?
Assessing students needs, and providing such services as injection of medication, catheterization, manual expression of the bladder, stoma care, postural drainage, suctioning and tube feeding are specific duties that are in the scope of nurses versus an Education Support Staff. School boards should be hiring nurses, as they had in the past to support in training and delivering services and supports.
School-Based Rehabilitation and Community-based Clinical Services Questions:
- Are there revisions that could be included in a revised PPM that would better support students to receive rehabilitation and/or community-based clinical services in the school setting that are coordinated, child-centred, and based on their strengths and needs?
Speech and Language services would be ideal, as currently boards only can provide a certain number of assessments across the school boards, otherwise responsibility falls under parents’ responsibility for psychoeducational assessments, speech and language, which many can’t afford therefore students stay undiagnosed and not support appropriately to their needs.
- What effective practices for supporting local collaboration between school boards and community service providers have you implemented in your region? What has enabled effective collaboration? What barriers have been experienced and how can they be addressed?
School boards work with various community services, depending on the area/region. However, staffing shortages amongst agencies and providers are becoming increasingly concerning.
- Is there additional content that should be included in a revised PPM to support the development of protocols and processes between school boards and community service providers to best meet students’ needs?
There needs to be some considerations to where the responsibilities fall for the services required for student needs. There needs to be considerations for the downgrade of duties on specific classifications like an Educational Assistants. School boards seem to be going down a route to add additional duties and responsibilities for Educational Assistants, which concerns our members in these roles and without additional training and support could undermine the level care they provide to students.
In conclusion, OPSEU/SEFPO would like to reaffirm its commitment and interest in continuing conversations on the development of a revised PPM 81. We request that we be notified as the proposed changes are written, and reserve the right to provide further submissions as the Ministry moves forward with this process.
Thank you,
Jeffrey Weston and Nick Mustari
Negotiators – BPS Negotiations Unit
Ontario Public Service Employees Union
100 Lesmill Rd.
North York, ON M3B 3P8