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The Ministry of Health (the Ministry) received two requests from different requesters pursuant to the Freedom of Information and Protection of Privacy Act (the Act) for access to the "version codes" associated with the health numbers of three named individuals. In each case, the requester provided the Ministry with the name of the individual, the date of birth, the address and his/her health card number. The Ministry denied access to the requested information in both cases pursuant to sections 18(1)(c) and (d) of the Act. Both requesters appealed the decisions of the Ministry.
Neither appeal could be settled by mediation. Notice that an inquiry was being conducted to review the decisions of the Ministry was sent to the Ministry and the appellants. The parties were also asked to comment on the application, if any, of section 21 of the Act to the information at issue in these appeals. Representations were received from the Ministry, and the Ontario Medical Association (the OMA), acting as agent for one of the appellants.
Prior to considering the issues raised by these appeals, I believe it is useful to set out some background information. The following is based on materials provided to me by the Ministry and the OMA in their representations.
As I have indicated, the scope of the appeals is limited to the "version code" of three named individuals. These individuals are patients who were treated by physicians who were unable, for various reasons, to ascertain the patient's version code. Accordingly, the physicians' claims for reimbursement for medical services provided to these patients were rejected by the Ministry.
The information requested is accessed through the Ministry's Registered Persons Database. The record which contains the information requested is the patient's Registrant Detail Inquiry.
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