OPEN LETTER: Supervised Consumption Services site closures due to lack of funding from Ministry of Health 

March 4 2024 

The Honourable Sylvia Jones 
Ministry of Health 
[email protected] | [email protected] 
777 Bay Street, 5th Floor 
Toronto, ON M7A 2J3 

The Honourable Michael Tibollo 
Ministry of Health 
[email protected] | [email protected] 
7 Queen’s Park Crescent 
Toronto, ON M7A 1Y7 

Dear Minister Jones and Associate Minister Tibollo, 
 
RE: Supervised Consumption Services site closures due to lack of funding from Ministry of Health 

We write to you with grave concern regarding the Ontario government’s inaction in ensuring the provision of urgently needed supervised consumption services (SCS) amidst a worsening public health emergency caused by the toxic unregulated drug supply. We are calling on you to immediately provide direct emergency funding on or before March 29 to SCS sites that have submitted their applications to the province and are under imminent threat of closure or have closed due to lack of funding, eliminate the Consumption and Treatment Services (CTS) approach to funding SCS and urgently provide, improve, and sustain uninterrupted provincial funding for SCS that includes inhalation services. 

Unregulated drugs of unknown contents and potency are driving increased deaths, hospitalizations, injuries and trauma across Ontario, with an estimated 3,644 drug-related deaths in 2023. Several communities in Ontario have declared a state of emergency due to drug toxicity deaths. SCS, and particularly low-barrier overdose prevention sites, are a necessary emergency response to this crisis and must be immediately scaled up. In 2018, the Ontario government arbitrarily capped funding to only 21 CTS. Six years later, the government has still not delivered on funding 21 sites. Despite overwhelming need and local support, the Ontario government has approved and funded only 17 CTS locations across the entire province. Only one of these is located in northern Ontario (NorWest Community Health Centre in Thunder Bay). Meanwhile, the toxic unregulated drug crisis has taken far too many lives since 2018 – nearly 20,000 and rising, with many more family and friends left grieving. 

In the context of this preventable public health emergency, urgent action is required. There are at least five submitted applications for CTS sites that have been inordinately delayed by the Ontario government in Sudbury (30 months since application was submitted), Barrie (28 months), Windsor (19 months), Timmins (13 months), and Hamilton, where the application was withdrawn in October 2023 after two years, in part due to the Ontario government’s delays and lack of transparency in providing the necessary approvals and funding to sustain the site. These delays are unacceptable and deadly.  

The tragedy of an isolated instance of gun violence in Toronto must not prevent people in diverse locations across the province from accessing vital health services any longer. The Ontario government’s decision to stop processing applications altogether for more than seven months is punitive and irresponsible. After the significant years of work and investment in each community to prepare the onerous applications under the provincial CTS model, to secure a suitable location and community support, and – in the case of Sudbury, Windsor and Timmins where the sites have been established with municipal stopgap funding – to hire and train staff and build trust and service uptake amongst people who use drugs, these sites are at imminent risk of closure or have been forced to close due to a lack of provincial funding. It should not fall to municipalities to fund healthcare services, which are a provincial responsibility. Moreover, management of these sites is extremely challenged by the Ontario government’s lack of transparency and accountability regarding site funding and approval timelines. In the case of Windsor, lacking the much-needed provincial support, the site has been forced to close.  

Of the regions with submitted, pending CTS applications, data released in 2024 from the Office of the Chief Coroner indicates that three of these regions have amongst the ten highest mortality rates in the province: Timmins, Windsor and Sudbury each have an opioid toxicity mortality rate that is nearly three times the provincial average. Further, inhalation now accounts for significantly more overdose deaths than injection in Ontario, according to data from the Office of the Chief Coroner, yet the current CTS model continues to prohibit inhalation services. Services must be designed and supported to reflect the magnitude of the crisis and the data regarding regional need and modalities of drug use. 

Failure to equitably provide for lifesaving health services like SCS is discriminatory and violates the right to life and security of the person for people who use drugs. The inordinate delays in processing applications, onerous requirements and lack of inhalation services under the provincial CTS model are also fiscally irresponsible, unsustainable and ineffective for the provision of a service that is fundamentally necessary amidst the worsening public health emergency that is the toxic unregulated drug crisis.  

SCS are evidence-based, highly effective, and must be recognized as an integral part of Ontario’s publicly funded healthcare system. As such, these services must be universally available wherever there is need. These sites relieve the burden from overtaxed emergency first responders and are not complex to implement; they require an accessible location, oxygen, naloxone, sterile medical and first aid supplies, and supervising staff. It is indefensible as a matter of public health and fiscal policy that we currently have a two-tiered healthcare system where SCS are available in some southern Ontario communities and not in northern Ontario. It is a violation of the fundamental rights to equality and security of the person. 

We call for urgent action from the province, commensurate with the magnitude of the crisis our communities are facing. It is vital that the Ontario government embrace a harm reduction approach to substance use, which centres the dignity, health and safety of people who use drugs while providing pathways to care, services, and community. 

We are calling on the Ontario government to: 

  1. Immediately provide direct emergency funding on or before March 29 to supervised consumption services (SCS) sites that have submitted their Consumption and Treatment Services (CTS) applications to the province and are under imminent threat of closure or have closed due to lack of funding. 
  1. Urgently provide, improve, and sustain uninterrupted provincial funding for SCS, including inhalation, and ensure equity in regional service availability, particularly in northern communities. 
  1. Phase out the Consumption and Treatment Services (CTS) approach to funding SCS, which requires additional and overly stringent conditions over and above Health Canada’s requirements.  
  1. In the interim, immediately remove the cap on the number of funded SCS sites and the prohibition on inhalation services under the provincial CTS model. 
  1. In the interim, introduce transparency and an expedited 30-day timeline for responding to applications under the provincial CTS model.  
  1. Introduce a low-barrier process by which community organizations can seek provincial funding for SCS. 
  1. Integrate SCS into Ontario’s core funded healthcare system with ongoing, integrated funding and resources. 
  1. Meet with us by March 13. 

We look forward to hearing from you as soon as possible on this urgent matter. 

Signed by, 
 
DJ Larkin, Executive Director, Canadian Drug Policy Coalition 

Heidi Eisenhauer, Executive Director, Réseau ACCESS Network 

Janet Butler-McPhee & Sandra Ka Hon Chu, Co-Executive Directors, HIV Legal Network 

Dr. Julie Samson, Co-lead of the addiction medicine consult service, Timmins and District Hospital 

Michael Brennan, Executive Director, Pozitive Pathways Community Service 

Michael Parkinson, Coordinator, Drug Strategy Network of Ontario 

Endorsed by, 

Adrian R. Betts, Executive Director, AIDS Committee of Durham Region (ACDR) 

Alison Stagg, Director of Programs, Four Counties Addiction Services Team

Alyssa Wright, Co-Lead, Supervised Consumption Saves Lives – Barrie 

Andrea Sereda, Dr., London Intercommunity Health Centre 

Ashley Schuitema, Lawyer, Waterloo Region Community Legal Services

Ashley Smoke and Missy McLean, Co-founders, TweakEasyCBG 

Avery Ng, PFAC Member, WEOHT 

Brooke Rorseth, Crisis Worker (MSW, RSW), Hotel Dieu Grace Healthcare 

Cameron Dearlove, Chair, Waterloo Region Integrated Drug Strategy

Chandra Ewing, Chair, Board of Directors, Maggie’s Toronto Sex Workers Action Project

Dane Record, Executive Director, PARN 

Denise Baldwin, Administrator, Indigenous Harm Reduction Network 

Dr. Dan Werb, Executive Director, Centre on Drug Policy Evaluation 

Dr. Doris Grinspun, RN, BScN, MSN, PhD, LLD(hon), Dr(hc), DHC, DHC, FAAN, FCAN, O.ONT., Chief Executive Officer, Registered Nurses Association of Ontario (RNAO) 

Elizabeth Dulmage, Executive Director, Brentwood Recovery Home 

Eric Cashmore, Executive Director, The Seeking Help Project 

Farihah Ali, Manager and Scientific Lead, Ontario CRISM Node 

Heather Johnson-Dobransky, Director of Operations, Hiatus House 

Holly Gauvin, Executive Director, Elevate NWO 

Jackie Barrett-Greene, Director, Positive Living Niagara 

Jason Sereda, President, Board of Directors, DIY Community Health Timmins 

Jason White, Chairperson, The Human Factor Community Organization

Jean Hopkins, Manager, Wellington Guelph Drug Strategy

Jody Jollimore, Executive Director, CATIE

John Maxwell, Executive Director, ACT 

Julie Nobert-DeMarchi, Executive Director, Timmins & Area Women in Crisis 

Karen Henze, Manager, Community Development and Housing, Canadian Mental Health Association – Sudbury/Manitoulin Branch

Karla Ghartey, Member; Assistant Professor, Sudbury Temporary Overdose Prevention Society; Nipissing University 

Kate Fairbairn, Patient, Family & Caregiver- Partnership Council, Windsor Essex Ontario Health Care team 

Khaled Salam, Executive Director, AIDS Committee of Ottawa 

Lady Laforet, Executive Director, Welcome Centre Shelter for Women and Families

Lindsay Jennings, Reintegration Specialist, Incarcerated Voters of Ontario 

Lisa Toner, Team Lead, Ontario Aboriginal HIV/AIDS Strategy 

Liv Delair, Co-Chair, Canadian Students for Sensible Drug Policy

Dr. Louisa Marion-Bellemare, Physician, Timmins and District Hospital 

Lori Vachon, Addiction and Mental Health Worker Program Coordinator, Northern College

Luciano Carlone, Interim CEO, Canadian Mental Heath Association, Windsor Essex County Branch 

Marie Morton, Executive Director, CAYR Community Connections 

Meghan Young, Executive Director, Ontario Aboriginal HIV/AIDS Strategy (OAhas) 

Mike Murphy, Addiction Medicine Physician, NOSM U 

Mika Wee, Steering Committee Member, Shelter & Housing Justice Network 

Molly Bannerman, Director, Women and HIV / AIDS Initiative

Mona Loutfy, Maple Leaf Medical Clinic 

Michelle Boileau, Mayor, City of Timmins 

Nadine Sookermany, Executive Director, Fife House 

Natasha Tousenard, Executive Director, Canadian Association of People Who Use Drugs

Neil Stephen, CD, Registered Nurse

Noulmook Sutdhibhasilp, Executive Director, Asian Community AIDS Services

Olivia Mancini, Registered Social Worker / Co-Founder, Student Overdose Prevention and Education Network 

Pamela Taplay, Supervisor, National Overdose Response Service

Patrick Kolowicz, Director, Mental Health and Addictions, Hôtel-Dieu Grace Healthcare

Patty MacDonald, Chief Executive Officer, Canadian Mental Health Association – Sudbury/Manitoulin 

Rebecca Robinson, Violence Against Women’s Services Coordinator, Sudbury and Area Victim Services 

Renee M Geniole, Executive Director, R.O.C.K. (Reach Out Chatham-Kent)

Reverend Christine Nayler, Co-founder/ Director, Ryan’s Hope 

Rita Taillefer, Executive Director, Windsor Essex Community Health Centre 

Robert Cameron, Executive Director, Downtown Windsor Community Collaborative

Rukshini Ponniah-Goulin, Executive Director, The United Church Downtown Mission of Windsor

Ruth Cameron, Executive Director, ACCKWA 

Ruth Fox, Regional Director, Ontario, Moms Stop the Harm 

Sarah Haanstra, Director of Integrated Programs, Guelph Community Health Centre

Sarah Pimperton, CEO É FOUNDER, Helping Hearts and Hands Housing Initiative Inc.

Sarah Tilley, Harm Reduction Manager, Gilbert Centre

Scott Roose, Founder, Weather the Storm Outreach and Harm Reduction Services

Seamus Murphy, Deputy Chief of Standards and Community Services, Cochrane District Paramedic Service 

Sharmin Sharif, Interim Executive Director, Moyo Health and Community Services

Shelley Muldoon, Director, Mental Health and Addictions, Woodstock Hospital 

Stacey L. Mayhall, Executive Director, AIDS Committee of North Bay & Area

Susan Stewart, Chair, KFL&A Community Drug Strategy Advisory Committee

Suzanne Paddock, Executive Director, Toronto People With AIDS Foundation 

Thierry Croussette, Board President, Seizure and Brain Injury Centre 

Thomas Hutchison, Outreach Coordinator, Living Space

Tiffany Pyoli York, Co-Chair, Greater Sudbury Anti Human Trafficking Coalition 

Toronto Overdose Prevention Society 

Victoria Scott, Director, Engage Barrie Organization 

Updated March 27, 2024

About Canadian Drug Policy Coalition

Advocating for public health- and human rights-based drug policy grounded in evidence, compassion, and social justice