I am advocating this proposed act:

Pan-Canadian Legislative Framework for the Accelerated Integration of Internationally Trained Health Professionals

Prepared by: Amir Noferesti, Magedicus Solutions
Date: 2025
Primary Audience: Federal Cabinet Ministers, Parliamentary Committees (Health, Immigration), Provincial Health Authorities, and Public Advocacy Groups
 

Background & Context

Canada faces a critical health human resource crisis: a nationwide doctor shortage coinciding with a vast underutilization of skilled immigrant health professionals. Projections indicate Canada will be short over 44,000 physicians by 2028, including 30,000 family doctors. At the same time, more than 13,000 internationally trained physicians are in Canada but not practicing due to licensing barriers. This mismatch has concrete impacts on Canadians – over 6 million people have no access to a regular primary care provider, and patients languish on waitlists that cost the economy an estimated $3.5 billion in lost productivity in 2023 alone. Immigrant doctors often end up in survival jobs (e.g. driving taxis) despite desperately needed credentials – immigrants with medical degrees are six times more likely to be working in unrelated jobs if they trained outside Canada. This represents a moral and economic failing in our current system.

The following proposal outlines a comprehensive Pan-Canadian policy framework to rapidly integrate internationally trained health professionals into the workforce. It is grounded in Canada’s constitutional values, federal and provincial statutes, and international commitments, and it provides an actionable roadmap (over an ideal 3-year timeline) with clear responsibilities, budget considerations, and evaluation metrics. The urgency is undeniable: Canada’s laws and policies must evolve to remove systemic barriers and unlock the potential of qualified professionals ready to serve in high-need areas such as family medicine, rural health, and critical specialties like oncology.

Figure: An internationally trained doctor faced with a maze of licensing hurdles en route to practice. This illustration depicts the systemic complexity and frustration foreign-trained physicians encounter under the current fragmented provincial licensing regime. Simplifying this pathway is a core goal of the proposed framework.
 

I. Constitutional Foundations – A Legal and Moral Duty to Integrate

Section 15 (Charter – Equality Rights): Substantive Equality and Professional Dignity. Canada, as a constitutional democracy and multicultural society, has a legal obligation to ensure fair access to essential professions. Excluding foreign-trained health professionals based on national origin or non-Canadian credentials constitutes systemic, adverse-effect discrimination. The Charter’s equality guarantee (Section 15) promises not just formal equality but equal benefit of the law. The Supreme Court’s ruling in Eldridge v. British Columbia (1997) affirmed that even facially neutral policies can violate Section 15 if they fail to accommodate distinct needs, thereby denying benefits to disadvantaged groups. In Eldridge, the Court held that the failure to provide sign language interpreters for deaf patients – effectively barring equal access to healthcare – infringed equality rights, and it ordered the government to rectify this despite minimal cost. By analogy, denying qualified immigrant doctors the opportunity to practice is an adverse systemic barrier that mirrors this harm. It deprives a class of people (internationally trained professionals, many of whom are racialized immigrants) of equal opportunity to contribute their skills, and it deprives the public of their services. Under Section 15, governments and regulators have a positive obligation to dismantle such barriers to achieve substantive equality.

Section 7 (Charter – Life and Security of the Person): Patient Rights to Timely Care. Excessive wait times and doctor shortages are not merely policy problems – they engage fundamental rights to life and personal security. In Chaoulli v. Quebec (2005), a majority of the Supreme Court found that unduly long wait times for essential medical care infringed patients’ rights to life and security of the person, and that “the government cannot choose to do nothing in the face of the violation of Quebecers’ right to security”. In other words, state inaction that leads to denied or delayed care can violate Section 7. By maintaining artificial workforce shortages through restrictive licensing, governments and colleges are effectively complicit in prolonging wait times and denying Canadians timely access to life-saving services. There is a positive duty on the state to take reasonable measures to alleviate critical healthcare delays. Fast-tracking the integration of available qualified health professionals is a clear and necessary measure to uphold the Section 7 rights of patients.

Section 6 (Charter – Mobility Rights): Freedom to Pursue Work Across Provinces. Canadian citizens and permanent residents have the right to move and pursue a livelihood in any province. Yet the patchwork of provincial licensing regimes – each with its own exams and requirements – severely limits mobility for healthcare professionals. An immigrant doctor licensed in one province often cannot practice in another without restarting onerous processes. For newcomers, provincial inconsistencies can altogether bar entry into practice. This impedes the mobility rights in Section 6. All Canadians (including immigrants granted permanent residence) should be free to use their qualifications wherever opportunities exist. A national approach that standardizes recognition of credentials would support mobility rights and the efficient allocation of skills across the country.

In sum, the Charter establishes a duty to integrate: Canada must not erect or tolerate systemic barriers that exclude capable individuals from essential sectors. Ensuring internationally trained health professionals can fully contribute is not only a policy choice but a constitutional imperative grounded in equality, the right to life and security, and mobility rights.
 

II. Federal Statutes: Bridging the Disconnect Between Immigration and Healthcare Systems

Immigration and Refugee Protection Act (IRPA): There is a stark policy contradiction between Canada’s immigration objectives and its professional licensing reality. IRPA’s purpose is to welcome skilled workers to Canada to bolster our social and economic fabric. In fact, IRPA explicitly calls on the government to “secure better recognition of the foreign credentials of permanent residents and their more rapid integration into society”. Each year, thousands of doctors, nurses, and other health professionals are selected as economic immigrants under federal and provincial programs. They arrive as highly skilled newcomers – only to face systemic exclusion from their professions upon arrival. This undermines IRPA’s core intent of benefiting from newcomers’ skills. It is a fundamental inconsistency (and inefficiency) to recruit physicians and other health workers through programs like Express Entry or the Provincial Nominee Program, yet have no effective mechanism to integrate them into the health workforce. The federal government has a duty, under IRPA’s mandate, to work with provinces on removing credential barriers – a duty which this framework seeks to fulfill.

Canada Health Act (1984): Accessibility is one of the five pillars of the Canada Health Act’s guaranteed principles (along with Public Administration, Comprehensiveness, Universality, and Portability). Accessibility means all insured persons must have reasonable access to medically necessary services without barriers. While the Act is typically enforced to prevent user fees or extra-billing, the spirit of the accessibility principle is clearly violated when Canadians cannot find a family doctor or wait months for care because qualified practitioners are kept out of service. Arguably, the regulatory bottlenecks that prevent capable internationally trained professionals from serving patients undermine the Act’s promise of reasonable access. The federal government possesses spending power leverage through the Canada Health Transfer – if provincial policies result in egregious lack of access, Ottawa could invoke compliance measures. While this is a blunt instrument, the mere prospect underscores how serious the issue is: failing to integrate available doctors and nurses could be seen as non-compliance with the accessibility criterion, justifying federal action. (Notably, when the Canada Health Act was introduced, the federal Health Minister assured it wouldn’t intrude on provincial control of health human resources. However, the current crisis blurs that line – systemic inaccessibility caused by labour market rigidities was never the intent of the Act.) In short, federal and provincial authorities share responsibility to ensure the health system’s accessibility isn’t compromised by avoidable workforce shortages.

Provincial Professional Licensing Statutes: Provinces delegate self-regulatory powers to professional colleges (medical, nursing, pharmacy, etc.) through laws that establish those bodies (e.g. provincial Medical Professions Acts). While provinces have autonomy in regulating professions, this autonomy does not equate to immunity from broader law and policy. All provincial actions are subject to the Charter and must serve the public interest. If a college’s practices are exclusionary beyond what is necessary for competence and public safety, they can be challenged as unreasonable or discriminatory. Provincial governments, which empower these regulators, must ensure they operate in alignment with Canada’s constitutional commitments and values. Trinity Western University v. Law Society of Upper Canada (2018) is instructive. In that case, the Supreme Court upheld that a professional regulator (the Law Society) could deny accreditation to a proposed law school that contravened equality values, noting the regulator’s mandate to act in the public interest included upholding principles of diversity and equal access to the profession. By parallel, medical and nursing colleges must interpret their mandate not as gatekeepers of exclusion, but as guarantors of public well-being – which in 2025 decidedly includes addressing health human resource needs in an inclusive manner. Provincial governments can and should set expectations (through legislation or policy direction) for their colleges to adopt fair, expedited pathways for qualified internationally educated professionals. Self-regulation is a privilege, not a right – and with that privilege comes a responsibility to respond to public needs in a Charter-consistent way.
 

III. International Law and Ethical Imperatives

Canada’s commitment to integrating skilled immigrants is not only a domestic concern but also a matter of international obligation and moral leadership:

• International Human Rights Instruments: Canada is party to the International Covenant on Economic, Social and Cultural Rights (ICESCR), which affirms the right to work and the right to the highest attainable standard of health. Article 6 of ICESCR recognizes the right to gain a living by work freely chosen, and Article 12 recognizes everyone’s right to timely healthcare. Systematically denying internationally trained health workers the opportunity to practice – and thus denying communities the healthcare they could provide – runs counter to the spirit of these commitments. The Universal Declaration of Human Rights (UDHR) likewise upholds the right to work (Article 23) and to participate fully in society. Ensuring skilled immigrants can work in their profession is part of guaranteeing those basic rights.

• UN Global Compact for Safe, Orderly and Regular Migration (2018): In this non-binding yet globally endorsed pact (which Canada signed), Objective 18 calls on states to “invest in skills development and facilitate mutual recognition of skills, qualifications and competences” of migrants. The proposed framework directly advances this objective by creating a national mechanism for credential recognition and bridging into practice. By acting on this, Canada would not only alleviate its doctor shortage but also stand as an international example of how to effectively leverage migrants’ skills – a key aspect of safe and orderly migration.

• Ethical Considerations: Perhaps most fundamentally, it is a moral absurdity for a country to have trained physicians driving Uber or working in survival jobs while patients go without care. This scenario represents a profound waste of human potential and a failure of stewardship. The World Health Organization has warned of global health workforce imbalances; ethically, wealthy countries like Canada must optimize domestic talent instead of aggressively recruiting from countries with greater shortages. Embracing internationally trained professionals already in Canada is a win-win: it fulfills our ethical duty to treat newcomers justly and utilizes their talents to save lives. In short: a physician forced to drive a taxi while patients languish on waiting lists is not just inefficient – it’s immoral.

⚖️ “To deny a skilled hand its rightful scalpel is to steal healing from those in need.” This encapsulates the ethical imperative at the heart of our policy. Wasting the expertise of immigrant health professionals isn’t victimless – the victims are Canadians who suffer from inadequate care access, and the victims are the professionals themselves, stripped of their dignity and purpose.
 

IV. Legal and Strategic Risks of Maintaining the Status Quo

Continuing along the current path of minimal integration effort is not only harmful to the public interest; it also exposes governments and regulatory bodies to significant risks:

• Charter Litigation: As awareness grows, we can expect increased legal challenges by both patients and sidelined professionals. A class action by internationally trained doctors alleging Section 15 Charter violations for systemic exclusion is conceivable. Equally, patient advocacy groups may bring Charter challenges (akin to Chaoulli) arguing that provincial licensing schemes contributing to wait times violate Section 7. The costs of litigation (and potential court-ordered remedies) could far exceed the costs of proactive reform.

• Human Rights Complaints: At least at the provincial level, human rights commissions may investigate professional colleges for discrimination. For example, policies that blanketly refuse to consider qualifications from certain countries or that impose unreasonable Canadian experience requirements could be found to have a disparate impact on individuals based on national origin, race, or ethnicity – prohibited grounds under human rights codes. A recently released report by the immigrant support organization MOSAIC indeed highlighted systemic discrimination in the licensing of International Medical Graduates, with only 13.6% of surveyed immigrant doctors attaining licensure despite qualifications (a stark disparity).

• Economic and Taxpayer Losses: The Conference Board of Canada and other analysts have often pointed to the “brain waste” problem – the lost earnings and productivity from immigrants not working at their skill level. Underutilization of internationally trained health professionals means Canada is forfeiting millions in potential tax revenues and spending dollars on stopgap measures (like costly locum doctors or overseas recruitment) instead of building sustainable capacity. The Royal Bank of Canada noted that immigrant medical graduates frequently end up in low-skilled jobs; this underemployment is a loss to GDP. We are also failing to recoup the investments that many immigrants made (often encouraged by Canada’s immigration marketing) to come here. In an era of tight public finances, no government can afford to ignore such inefficiency.

• Public Trust and Political Fallout: Healthcare consistently tops the list of Canadians’ concerns. If the public perceives that protectionist or bureaucratic inertia by regulators and governments is contributing to doctor shortages, trust in institutions will erode. Already media reports and public discourse highlight the absurdity of Canadian-trained doctors vs. foreign-trained disparities. There is a reputational risk to Canada internationally as well – we risk our image as an inclusive, merit-based society if highly educated immigrants tell stories of credential roadblocks and wasted talent. Politically, a failure to act could become a liability in elections, as opponents highlight government inaction in the face of suffering patients.

In summary, the do-nothing approach is untenable. Legally, morally, and pragmatically, it invites consequences that far outweigh the challenges of reform. The safer path is to acknowledge the problem and implement a bold solution – as outlined below.
 

V. Policy Recommendations, A Comprehensive Solution

To address this multifaceted issue, we propose an integrated set of policy measures. These recommendations involve federal leadership, provincial cooperation, and new oversight mechanisms to ensure accountability. Together, they form a Pan-Canadian Legislative Framework titled “Healthcare Workforce Emergency Mobilization Act (HWEMA)” (at the federal level) coupled with coordinated provincial actions.

• A. Federal Legislation – Healthcare Workforce Emergency Mobilization Act (HWEMA): Enact a federal law that establishes a uniform framework for credential recognition and expedited licensure of internationally trained health professionals during periods of workforce “emergency” (which currently exists in healthcare). While respecting provincial jurisdiction, this Act would use federal spending powers and the national concern doctrine to incentivize compliance. Key features of HWEMA: (1) It creates national standards and exams for health professional credential assessment, developed in partnership with bodies like the Medical Council of Canada and nursing regulators. (2) It mandates transparent, efficient processes – for example, foreign-trained applicants must get an answer (license, provisional license, or specific additional requirements) within a strict timeline (e.g. 90–120 days) of submitting complete credentials. (3) It authorizes federal funding to provinces conditional on measurable progress in integrating internationally trained professionals. (4) It establishes that in federally funded health institutions (e.g. federally funded clinics, or in contexts like Indigenous health services), alternative licensing pathways (such as supervised practice licenses) must be available. In essence, HWEMA would be a signal of national coordination, ensuring that an immigrant doctor or nurse anywhere in Canada faces a similar, fair process and not a patchwork of 13 different regimes. (Notably, national licensure has been championed by physician organizations – a pan-Canadian license allowing mobility would “make the path to practice clear” and let doctors go where they are needed.)

• B. Provincial Regulatory Reform – Emergency Pathways: Provinces would complement the federal Act by amending their health profession laws and regulations to create “conditional” or “associate” licenses for internationally trained professionals. For example, a province could issue a 12–24 month conditional license to an IMG (International Medical Graduate) or IEN (Internationally Educated Nurse), allowing them to practice under supervision or in defined settings while they complete any additional assessments or training. During this period, they can gain Canadian experience and prove competence on the job. Several provinces have piloted such return-of-service or practice-ready assessment programs; this framework makes it standard. Additionally, provinces must streamline their credential evaluation: all relevant colleges should commit to processing credential and exam applications within 90 days (with fast-track options for high-need specialties). Where exams or training modules are required, these should be offered frequently and locally (ending the absurd waits of a year or more for limited exam spots). Provincial governments should also remove arbitrary restrictions – e.g., revisit quotas that limit how many foreign-trained candidates can enter residency or practice programs. Instead, capacity should be driven by public need, not protectionism. The provincial reforms ensure that being in one province vs another is not a make-or-break factor – standards remain high, but unnecessary differences are evened out.

• C. Independent Oversight – Credential Equity Ombudsperson: To inject accountability and transparency, a new federal office of the Credential Equity Ombudsperson should be created (by statute under HWEMA). This independent official would have the mandate to monitor licensing outcomes for internationally trained health professionals across all jurisdictions, investigate complaints of unfair treatment, and report publicly to Parliament on progress. The Ombudsperson could also arbitrate disputes – for instance, if a qualified applicant is repeatedly denied for unclear reasons, they could review the case. Importantly, this office would work with provincial fairness commissioners (some provinces have Fair Registration Practices Acts overseeing regulators). It would ensure no credential goes unrecognized without good reason. By publishing data – e.g., number of applications, approval rates, processing times by each college – it would shine a light on who is doing their part and who is lagging. This kind of oversight has precedent: Ontario’s Fairness Commissioner model has improved transparency in some professions. A national Ombudsperson amplifies that, backed by the moral suasion of federal oversight and funding conditions.

• D. Transparency & Tracking – National Integrated Health Workforce Registry: We recommend establishing a National Registry of Internationally Trained Health Professionals, a centralized database (managed by Health Canada in partnership with provinces) that tracks the pool of internationally educated doctors, nurses, and others in Canada and their progress towards licensure. This registry serves multiple purposes. (1) Workforce planning: It gives policymakers real-time data on how many qualified people are “stuck” and where talent could be deployed – addressing what experts call a current blind spot in health human resource planning. (2) Mobility: An individual’s verified credentials and assessment results could be ported through this system, so if they move from Ontario to Alberta, they don’t start from scratch – their profile follows them (facilitating the “Pan-Canadian” license concept). (3) Accountability metrics: The registry can track outcomes – e.g., how many internationally trained professionals become licensed each year, in what fields and provinces – which will feed into the Ombudsperson’s reports. This recommendation aligns with calls for better data to plan health systems and ensure the “right kind of care, in the right places, at the right times”. Privacy will be protected, but the aggregate data will inform policy tweaks and highlight successes or bottlenecks in the integration process.

Taken together, recommendations A through D aim to attack the problem from all angles: legislative change, regulatory practice change, oversight, and information infrastructure. The approach is holistic – no single silver bullet will suffice, but a coordinated strategy can definitively turn the tide. We deliberately include both carrots and sticks: incentives (funding, reducing bureaucracy) and enforcement (ombudsperson, potential funding penalties under Canada Health Act or HWEMA). Importantly, while physicians are a focal point (given the acute doctor shortage), these measures should extend to all health professionals facing similar barriers (nurses, medical lab technologists, pharmacists, etc.), with adaptations as needed for each profession’s context.
 

VI. Implementation Timeline, Three-Year Rollout Plan

Achieving these changes requires a phased implementation over approximately 36 months (3 years). Below is an operational rollout plan with clear phases, responsible leads, and key metrics for success:

Phase 1 – Foundation Laying (Year 1): Legislation, Agreements, and Initial Capacity Build
Timeline: 2026 (Q1 to Q4).
Responsibilities: The federal government (Departments of Health and Immigration) takes the lead in this phase. The Privy Council Office will coordinate an intergovernmental task force with provinces. Provincial health ministries and regulators begin preparatory actions.

• Legislation Enacted: Draft and pass the Healthcare Workforce Emergency Mobilization Act (HWEMA) in Parliament by the end of Year 1. In parallel, at least half of provinces (including major ones like Ontario, Quebec, B.C., Alberta) should introduce enabling amendments to their health profession laws to create conditional licensing pathways. Metric: HWEMA receives Royal Assent; provincial bills introduced in legislatures.

• Federal-Provincial Agreement: Convene a First Ministers’ meeting or Health Ministers’ conference to secure buy-in. Aim to sign a Pan-Canadian Credential Recognition Accord – a memorandum of understanding aligning provincial participation (not unlike the national accord on foreign credential recognition in other sectors). Metric: Accord signed by provinces/territories representing 90%+ of Canada’s population.

• Establish Oversight Office: Launch the Credential Equity Ombudsperson office. Hire the Ombudsperson and core staff, allocate budget (e.g. from Health Canada). Start developing regulations under HWEMA defining the office’s investigative powers and reporting framework. Metric: Ombudsperson appointed and office operational by end of Year 1.

• Expand Assessment Capacity: Provide targeted federal funding (via HWEMA appropriations) to bodies like the Medical Council of Canada, Royal College, College of Family Physicians, Nursing regulators, etc., to increase examination and assessment slots. For example, ensure that qualifying exams (NAC, MCCQE, licensing exams) are offered quarterly (rather than annually) to clear backlogs. Metric: Number of exam seats for IMGs and IENs in Year 1 is double the previous year’s baseline.

• National Registry Development: Begin development of the National Integrated Health Workforce Registry IT system. By end of Year 1, a prototype database should be online and initial data (e.g., lists of interested internationally trained professionals from existing sources like immigration landing records, provincial college databases) consolidated. Metric: Pilot registry dashboard in place and shared with stakeholders.

Phase 2 – Pilot Integration & Program Launch (Year 2):

Deploying New Tools and Getting First Results
Timeline: 2026-7.
Responsibilities: Joint leadership. Provinces and health professional colleges take center stage in executing new licensing pathways. The federal government supports through funding, coordination, and oversight. Health authorities (hospitals, clinics) also become involved to provide supervised practice opportunities.

• Conditional Licenses Issued: Provinces begin granting conditional/provisional licenses under the new rules. For example, a cohort of IMGs is placed on 1-year supervised practice in underserved communities (rural clinics, under-served urban areas, long-term care, etc.). Metric: By mid-2026, at least 1,000 internationally trained doctors and 1,500 internationally trained nurses are working with provisional licenses Canada-wide (numbers scaled to available pool). These figures should ramp up by end of Year 2.

• Bridging Programs and Mentorship: Launch or expand Practice-Ready Assessment (PRA) programs for physicians in every region (building on existing programs in e.g. Saskatchewan, BC). Similarly, accelerate nursing bridging programs (language and clinical orientation) with additional seats. The federal funding covers stipends for these trainees and incentives for mentors. Metric: Establish PRA programs in at least 8 provinces with a combined capacity of 500+ IMG participants in the year; ensure 80%+ completion rate. Track how many participants transition to full licensure.

• Data Collection & Monitoring: The Ombudsperson’s office, in concert with the new registry, closely monitors progress. By end of Year 2, publish a report card for each province and regulator: e.g., “X applications received, Y approved for provisional license, Z fully licensed; average processing time; any identified barriers.” Metric: First Annual Report on International Health Workforce Integration published, showing quantitative gains (e.g., % increase in internationally trained health professionals licensed vs previous year, reduction in average processing time).

• Public Communication and Transparency: Implement a communications plan to inform the public and stakeholders of these changes. It’s crucial to manage expectations (e.g., let Canadians know new doctors and nurses are being added in their communities) and also to prevent misinformation. Regular briefings to media and stakeholder groups (like the Canadian Medical Association, nursing associations, immigrant community organizations) are held. Metric: High public awareness – measured by surveys indicating majority of Canadians recognize the integration initiative and support it (target: >60% approval of “fast-tracking foreign-trained doctors” in public opinion polls).

Phase 3 – Full Implementation and Evaluation (Year 3):

Scaling Up and Solidifying Changes
Timeline: 2028 and into early 2029.
Responsibilities: All partners (federal, provincial, regulatory bodies, health employers) focus on institutionalizing the new processes and ensuring permanence.

• Legislative/Regulatory Completion: By Year 3, all remaining provinces and territories pass any required legislative changes so that every jurisdiction has the new pathways embedded in law. Any sunset clauses in HWEMA (if it was positioned as an emergency law) should be reviewed – likely the need will remain, so consider extending or making permanent. Metric: 13/13 provinces and territories formally on board with credential recognition standards (or at least an arrangement via mutual recognition agreements for holdouts).

• Licensure Outcomes: The backlog of unlicensed internationally trained health professionals should be markedly reduced. The goal is that by the end of 2027, at least 50% of the known pool of qualified internationally trained physicians and nurses in Canada have obtained licensure or a clear pathway towards it. Also, new incoming immigrants in these professions should experience a much quicker transition (target: within 1–2 years of arrival). Metric: For IMGs already in Canada as of 2025, over half are integrated by 2028; for those arriving in 2026 and after, average time from arrival to start of practice is reduced by (for example) 50%.

• Healthcare Impact Metrics: Begin measuring the direct impact on the health system. Key indicators include: reduction in patient wait times, increase in number of residents with a family doctor, improvements in specialist wait queues in areas like oncology. For instance, if 200 new family doctors start practicing in Year 2–3, that could attach an estimated 200,000 patients to primary care (assuming ~1000 patients per doctor). Similarly, adding specialists (e.g., foreign-trained oncologists, anesthesiologists) in regions with shortages should reduce wait times for surgeries or cancer treatments. Metric: By end of Year 3, aim for a measurable decrease in wait times in pilot regions (e.g., a province that integrated 100 new doctors sees primary care waitlist drop by X%), and nationally a reduction in the number of Canadians without a GP (perhaps from 6 million to 5 million or fewer). These improvements, while not solely attributable to this policy (other efforts ongoing), will be a key part of evaluating success.

• Evaluation and Course Correction: The end of Year 3 is time for a comprehensive evaluation. The federal government (Treasury Board Secretariat in collaboration with Health Canada) should audit how funds were spent and whether targets were met. The Parliamentary Budget Officer could be engaged to report on cost-effectiveness. This evaluation will inform whether continued extraordinary measures are needed or if the process can transition to “steady state” maintenance. Metric: An Evaluation Report completed by an independent panel, confirming how many professionals were integrated, the cost per integration, and recommendations for ongoing policy (e.g., continue program, scale down, or adjust any criteria).

Throughout all phases, a guiding principle is engagement – continue consulting with key stakeholders: internationally trained professionals themselves (to gather feedback on remaining pain points), practicing healthcare professionals and their associations (to ensure workplace integration is smooth and collegial), and of course patients and the public (to maintain support). Real-time problem-solving will be needed; for example, if one specialty like pharmacy encounters different challenges than medicine, adapt accordingly. The three-year timeline is ambitious, but as the COVID-19 pandemic showed, Canada can move quickly on health workforce measures when it deems the situation an emergency, and by all indicators, our current shortage qualifies as a slow-moving emergency.
 

VII. Budget and Cost Modeling

Implementing this framework will require upfront investments, but these costs are modest relative to the enormous downstream savings and benefits for Canada’s healthcare system and economy. We outline here the anticipated budget over the 3-year implementation, as well as a high-level cost-benefit perspective:

Year 1 Estimated Budget: $50 million (federal). This covers initial setup and coordination costs, including: establishing the Ombudsperson office ($5M for staffing and operations), developing the National Registry IT system ($10M for software and data integration), and grants to assessment bodies to ramp up exam capacity (~$15M). Additionally, about $20M is allocated as incentive funds to provinces (to upgrade their licensing systems, train staff, and perhaps modernize IT for application processing). These are one-time investments to build the infrastructure for change.

Year 2–3 Estimated Budget: $200 million per year (federal, with some provincial cost-sharing or in-kind contributions). The biggest expense is scaling up training and supervised practice positions: we estimate on the order of $100,000 per physician integrated (which is substantially lower than the cost of training a new doctor from scratch). For example, funding 2,000 provisional license residency slots or practice-ready placements might cost $200M (this includes salaries or stipends for those doctors during their supervised period, funds for mentors and clinical training resources, and examination fees subsidization). Similarly for nurses and other professionals, allocate funds for bridging programs, language training, and exam prep courses. A portion of the budget ($30M/year) continues to support the exam and credentialing bodies for high volumes. Another portion (~$20M/year) supports the ongoing Ombudsperson and data collection efforts. Finally, ~$50M could be reserved as outcome-based transfer bonuses to provinces – e.g., if a province licenses X number of professionals above a target, it receives a grant to invest back into its health system (this motivates compliance with the spirit of the program).

Total 3-Year Federal Investment: ~$500 million. This figure is not trivial, but to put it in perspective, it is a tiny fraction of Canada’s annual healthcare spending (which exceeds $300 billion across governments) and even a small fraction of annual federal health transfers. The return on investment is very high. Consider: training a single physician in Canada (medical school + residency) costs taxpayers between $455,000 and $790,000 in subsidies. By contrast, enabling an already-trained physician to become licensed might cost a fraction of that – perhaps 20¢ on the dollar. If even 2,000 new doctors are added to the workforce in the next 3 years via this plan, the value of their service (in monetary terms and in health outcomes) is enormous. Each full-time doctor contributes to the care of thousands of patients and generates significant economic activity. Similarly, every nurse or allied professional integrated reduces strain on the system (and costly overtime/temp agency staffing).

Cost-Benefit Highlights: Short-term costs will be offset by several savings and benefits:

• Reduced Wait Times = Economic Gain: Shorter wait times mean patients return to work sooner and have fewer complications. The Fraser Institute estimated that long waitlists for treatment cost Canadians $3.5B in lost wages in one year. Reducing waits even modestly by easing staffing shortages can recoup hundreds of millions in productivity.

• Optimizing Immigrant Skill Utilization: When immigrants work at their skill level, they earn more and pay more taxes. A physician working as a physician (rather than in a low-wage job) might contribute an additional $100k+ in income taxes annually. Multiplied by thousands of individuals, this boosts government revenues. There’s also reduced need for social assistance or retraining programs when people can work in their field.

• Health System Savings: Integrating foreign-trained professionals can reduce expensive stopgap measures. Many provinces currently rely on locum tenens physicians or international recruitment on temporary contracts, often paying premia to agencies. By building a stable domestic supply, those costs (which often don’t show up directly but bleed budgets) diminish. Moreover, preventing burnout of current staff (by alleviating workloads) can save on retention and sick leave costs.

• Avoiding Downstream Education Costs: If Canada doesn’t utilize immigrant doctors, one might argue we’d need to train that many more new doctors domestically (increasing med school seats, residency positions, etc.). That carries a high price tag (as noted, up to $0.8M per doctor trained domestically). Our plan leverages talent that other countries have already trained (often at their expense). Ethically, we must be cautious not to poach from countries in need, but in the case of immigrants already here, that training is a sunk cost we should honor by using it.

Provincial Contributions: Provinces will bear some costs, primarily in expanding their training capacity and possibly in hiring new staff to process licenses faster. We anticipate provinces reallocating some existing health human resource funds into this (and they receive new federal funds to assist). For example, provinces could use a portion of the bilateral health funding agreements (earmarked for human resources or primary care) to support bridging programs in local colleges/universities. The federal design is to minimize net new cost to provinces by covering upfront expenses – provinces mainly need the political will and administrative effort.

In summary, the budget is an investment in solving one of the most costly problems in our healthcare system. The outlay of ~$500M over 3 years should be weighed against the status quo: billions lost to inefficiency, lives lost or harmed by inadequate care, and the incalculable opportunity cost of wasted human capital. As Eldridge showed in a different context, sometimes relatively small expenditures (just $150k was needed to fix the interpreter issue) can remedy a rights violation. Here, while the scale is larger, the principle stands – the cost of inclusion is far outweighed by the cost of exclusion.
 

VIII. Provincial and Specialty Focus Areas

While this is a national framework, its implementation must account for regional differences and target critical shortage areas. Below we highlight specific provinces and health specialties that warrant special attention:

• Quebec: Quebec’s healthcare and professional system has unique features (e.g., the Collège des médecins du Québec, French-language requirements, and civil law tradition). Quebec also faces serious physician shortages – it has among the lowest family doctor-to-population ratios and has taken controversial steps like proposed fines to keep doctors from leaving. Our framework will work with Quebec’s authorities to ensure integration programs respect French language proficiency and any distinct provincial criteria. Federal funds can support French-language medical bridging programs for francophone immigrant doctors (e.g., from North Africa or Haiti) to meet Quebec’s needs. Additionally, lessons from Chaoulli originated in Quebec – there is legal impetus for Quebec to innovate in reducing wait times. We will engage Quebec as a full partner, recognizing its jurisdiction while aligning on the shared goal of more doctors for its population.

• Rural and Remote Areas: Physician maldistribution is as serious as overall shortage. Rural Canada has long relied on international medical graduates – over 25% of rural doctors were foreign-trained in some estimates. Yet retaining them is a challenge. This policy emphasizes rural placements (through return-of-service incentives under conditional licenses) to immediately plug gaps. For example, an IMG pediatrician might serve in a northern community clinic under supervision as a pathway to full licensure. We will prioritize setting up infrastructure (telehealth support, housing, spousal employment assistance) to make these placements successful. Metric: Increase the percentage of IMG doctors who choose to remain in rural practice after their return-of-service by offering a pathway to full license and permanent opportunities (target >70% retention of those placed).

• Critical Specialties (e.g., Family Medicine, Oncology, Anesthesiology, Psychiatry): Family physicians are the most glaring need (72% of the projected doctor shortfall), so expanding the primary care workforce is paramount. International family doctors often face barriers because residency slots favor domestic grads (with matching success rates <23% for IMGs vs 98% for Canadian grads). Our plan’s practice-ready assessments will primarily target family medicine so that competent GPs can start seeing patients within months, not years. Oncology: Canada is experiencing a critical shortage of oncologists and related cancer care professionals. Some provinces have even considered waiving exam requirements to bring in foreign oncologists urgently. We will coordinate with cancer agencies to fast-track recognized oncologists (and radiation therapists, oncology pharmacists, etc.), perhaps through specialist-specific bridging modules. Reducing cancer treatment wait times is literally life-saving. Other high-need specialties: Anesthesiology (to help clear surgical backlogs), Psychiatry (mental health access) and Emergency Medicine are examples where foreign-trained specialists can have immediate impact. We will work with the Royal College to identify international training that is “substantially equivalent” so that those specialists can write the Canadian exams or be granted provisional specialty licenses with targeted top-up training. Each specialty will have a tailored approach, but under the common principle of expedited integration.

• Nursing and Allied Health Professionals: Though our discussion often spotlighted doctors, the framework applies broadly to health professionals. Nursing shortages are as acute as physician shortages across Canada. Many internationally educated nurses (IENs) face years-long licensing delays. Provinces like Ontario have recently moved to expedite IEN licensing – for example, Ontario began offering temporary licenses to IENs during the pandemic. We will amplify and standardize these efforts nationally. Similar strategies will apply to other fields such as medical lab technologists (critical for testing capacity), pharmacists, and paramedics. Each of these professions has its own regulator and exams, so a working group for each will be formed under the HWEMA umbrella. The Credential Equity Ombudsperson will cover all regulated health professions to ensure none fall through the cracks.

In essence, the policy is flexible and adaptive: provinces can address their specific needs (be it more francophone doctors in Quebec, more rural generalists in the Prairies, or more specialists in urban centers) under the common framework. The federal role is enabling and equalizing – providing resources and setting standards so that an immigrant health worker’s chance to serve Canadians does not depend on arbitrary factors of location or specialty.

IX. Monitoring, Evaluation and Long-Term Sustainability

To ensure that this initiative not only reaches its targets but remains effective in the long run, robust monitoring and feedback mechanisms will be in place (some already touched upon in earlier sections):

• Performance Measurement Framework: A detailed logic model and metrics plan will be developed at the outset (in Phase 1) to track inputs, outputs, outcomes, and impacts. Key indicators include: number of internationally trained professionals licensed per quarter (by profession and province), processing times for credential recognition, patient health outcome improvements (such as changes in wait times, attachment rates to primary care, etc.), and stakeholder satisfaction (immigrant professionals’ sense of integration, patient satisfaction in areas gaining new providers). These will be reported up through the federal Health Minister to Cabinet and to the public via annual reports.

• Regular Reporting to Parliament: The Parliamentary Budget Officer (PBO) and Auditor General will each be invited to review aspects of the program. The PBO could report by Year 2 on whether spending is on track and achieving value for money. The Auditor General might conduct a performance audit by Year 3 to identify any implementation shortcomings (e.g., if some regulators are non-compliant or funds misallocated). These independent reports ensure transparency and non-partisan accountability.

• Adaptive Policy Adjustment: The framework is dynamic. If mid-course evaluations (say in Phase 2) show that certain approaches are not working – e.g., if take-up by IMGs is lower than expected due to remaining disincentives – the coordinating committee (federal and provincial officials) will adjust tactics. This could mean revising requirements, reallocating resources to where they’re most effective, or introducing new incentives. Because we’ll have much better data (via the National Registry and Ombudsperson’s monitoring), we can make evidence-based tweaks quickly.

• Sustainability and Legacy: After the initial 3-year push, the goal is to normalize the fast-track integration as simply “how Canada does business.” In other words, the extraordinary measures can transition into permanent features: e.g., keep a permanent national licensing exam process for IMGs, maintain pan-Canadian licensure agreements, and keep the Ombudsperson as an ongoing watchdog. By the end of Year 3, we should plan for a post-2028 strategy: perhaps a permanent federal-provincial council on health workforce, which could continue to address not just immigrant integration but broader workforce planning (e.g., aligning medical school output with needs, mitigating regional disparities, etc.). The crisis that prompted this policy can thus be leveraged to build a stronger, more resilient health workforce system for the future.

Defining and implementing a Pan-Canadian Legislative Framework for the accelerated integration of internationally trained health professionals is not just a policy exercise – it is a constitutional, ethical, and practical necessity for Canada’s future. We have the legal underpinnings (Charter rights and IRPA objectives) that compel action, we have clear evidence of the harm caused by the status quo (from court cases to economic analyses), and we have proven tools at our disposal to fix the problem (from practice-ready assessments to national coordination models). What has been lacking is the political will and unified strategy to bring these pieces together. This proposal provides that strategy.

By executing this plan over the next three years, Canada stands to gain thousands of new health workers into our system, significantly reducing wait times and improving care, all while honoring the talents of those who call Canada home. It will help reaffirm to Canadians that our healthcare system, and indeed our immigration system, truly works in the public interest. It will also broadcast to the world that Canada is a place where skills are recognized and valued, enhancing our reputation as a destination for global talent.

Let us remember the human face of this issue: the patients waiting in pain for a procedure, and the foreign-trained doctor who sits at home unable to fulfill their calling. The gap between them is entirely bridgeable through wise policy. In the words of one observer, “To deny a skilled hand its rightful scalpel is to steal healing from those in need.” We must no longer steal that healing. By restoring skilled hands to our hospitals and clinics, we uphold the rights and values we profess and deliver tangible health and economic benefits to Canadians.

With profound respect and gratitude to my beloved friend, Dr. Hidokht Farian, a Harvard graduate and eye surgeon, who was unable to continue her job here in Canada due to excessive overregulation and barriers.