Accessibility Policy

Accessibility Policy

Review GEM Health Care Service’s 2026 Accessibility Compliance Report here.

Purpose

GEM Health Care Services (GEM) always strives to provide goods, services, facilities, and employment in a way that respects the dignity and independence of persons with disabilities and is committed to removing any barriers that may prevent people with disabilities from accessing the organization and/or its services. GEM is committed to the principles of dignity, independence, integration, and equal opportunity for all persons. This policy and its procedures address GEM’s commitments to accessibility and the requirements of the Accessibility for Ontarians with Disabilities Act (“AODA”) and the applicable Accessibility Standards.

Scope

This policy applies to all persons accessing GEM services and facilities, including employees, applicants, contractors, agents, volunteers, vendors, visitors, and any third-party individuals or organizations interacting with GEM staff or the public on behalf of GEM. It also applies to all GEM office premises.

Definitions

Accessible Formats may include, but are not limited to, large print, recorded audio and electronic formats, braille, and other formats usable by persons with disabilities.

Accommodation means the special arrangement made or assistance provided so that persons with disabilities can participate in experiences available to persons without disabilities. Accommodation will vary depending on the individual’s unique needs.

Assistive Devices are supporting aids such as communication aids, cognition aids, personal mobility aids and medical aids (e.g., canes, crutches, wheelchairs or hearing aids).

Communication Supports are devices or tools to aid communication between two or more individuals and may include, but are not limited to, captioning, alternative and additional communication, plain language, sign language and other supports that help with effective communication.

Disability means:
(a) any degree of physical disability, ailment, malformation or disfigurement caused by bodily injury, birth defect or illness and includes, but is not limited to, diabetes mellitus, epilepsy, a brain injury, paralysis, amputation, lack of physical co-ordination, blindness or visual impairment, deafness or hearing impairment, muteness or speech impairment, or physical reliance on a guide dog or other animal, wheelchair, or remedial appliance or device;
(b) a condition of mental impairment or developmental disability;
(c) a learning disability or dysfunction in one or more processes involved in understanding or using symbols or spoken language;
(d) a mental disorder; or
(e) an injury or disability for which benefits were claimed or received under the Workplace Safety and Insurance Act.

The definition includes disabilities of varying severity, visible and non-visible disabilities, and disabilities whose effects may be intermittent.

IASR means Integrated Accessibility Standards Regulation.

Support Persons are individuals, whether paid professionals, volunteers, family members, or friends, who accompany a person with a disability to assist with communication, personal care, medical needs, or access to goods, services, or facilities.

Service Animals are animals individually trained to do work or perform tasks for the benefit of a person with a disability.

Unconvertible means it is not technically feasible to convert the information or communication, or the technology required to convert it is not readily available.

Web Content Accessibility Guidelines (WCAG) means the World Wide Web Consortium recommendation dated December 2008 entitled “Web Content Accessibility Guidelines.”

Procedures

1. General Requirements

GEM shall use every reasonable effort to ensure that it and all its representatives meet the needs of persons with disabilities in a respectful and timely manner. To do so, GEM shall:

• ensure equal access and participation for people with disabilities
  
• ensure that information is communicated in an accessible manner
  
• ensure that GEM and its representatives follow the Customer Service Standard
  
• ensure that GEM and its representatives follow the Integrated Accessibility Standards
  
• ensure that office premises are barrier-free where reasonably practicable
  
• ensure employees and prospective employees are aware that accommodations can be made upon request
  
• provide training and education regarding accessibility and the Ontario Human Rights Code as it relates to persons with disabilities
  
• remain committed to identifying, removing, and preventing barriers to accessibility by establishing and maintaining a multi-year accessibility plan
  
• establish and maintain processes for receiving and responding to feedback and ensure that those processes are provided in accessible formats, upon request

2. Customer Service Standard

GEM is committed to excellence in serving all persons, including people with disabilities, and will carry out its functions and responsibilities as follows:

(a) Communication

GEM will communicate with persons with disabilities in ways that take into account their disability and will work with the individual to determine appropriate communication methods.

Employees and representatives who communicate with the public will be trained on how to interact and communicate with people with various types of disabilities.

(b) Telephone Services

GEM is committed to providing accessible telephone services. Employees who communicate by telephone will be trained to speak clearly, slowly, and in plain language. Alternative communication methods, such as e-mail or TTY relay services, will be offered where telephone communication is not suitable or available.

(c) Assistive Devices

GEM is committed to serving persons who use assistive devices to obtain, use, or benefit from GEM’s goods, services, or facilities. Staff will be trained and familiar with various assistive devices that may be used.

(d) Billing

GEM is committed to providing accessible invoices and related documents upon request. Alternative formats will be provided where appropriate, and staff will answer questions regarding invoices by telephone, e-mail, or other accessible communication methods.

(e) Use of Support Persons and Service Animals

GEM is committed to welcoming people with disabilities who are accompanied by a support person or service animal into GEM office buildings and facilities. At no time will a person with a disability who is accompanied by a support person or service animal be prevented from accessing their support person or service animal while on GEM premises.

If a person with a service animal seeks access to an area where the service animal cannot enter due to legal, safety, or health restrictions, GEM will discuss the reasons for the restriction with the individual and determine alternative ways to ensure equitable access to goods, services, or facilities.

(f) Notice of Temporary Disruption

GEM Health Care Services (GEM) recognizes that temporary disruptions to accessible services, supports, or communication methods may occur from time to time due to planned maintenance, technology interruptions, staffing limitations, emergencies, or circumstances beyond the organization’s control.

In the event of a planned or unexpected disruption that may impact access to GEM’s goods, services, communication supports, or accessibility accommodations, GEM will provide notice as soon as reasonably possible.

Notices of disruption may include:

• the reason for the disruption
  
• the anticipated duration of the disruption
  
• information regarding alternative service methods or accommodations, where available
  
• contact information for questions or assistance

Notices may be communicated through methods such as:

• postings at reception or service areas
  
• telephone messaging
  
• e-mail communication
  
• GEM’s website or electronic communication platforms
  
• direct communication with affected individuals where appropriate

GEM will make every reasonable effort to minimize service disruptions and to provide alternative methods of access whenever possible.

Notices will be posted at entrances, reception areas, and/or on GEM’s website, as appropriate.

(g) Training for Staff

GEM will ensure accessibility training is provided to employees, contractors, vendors, policy developers, and any other individuals providing goods, services, or facilities on behalf of GEM.

Training will be provided within three (3) months of assuming applicable responsibilities and whenever significant changes are made to this policy. GEM and/or its vendors will maintain records of training provided.

Training will include:

• an overview of the AODA and applicable accessibility standards
  
• GEM’s Accessibility Policy and Multi-Year Accessibility Plan
  
• how to interact and communicate with people with various disabilities
  
• how to interact with persons using assistive devices, service animals, or support persons
  
• accessible features available at GEM facilities
  
• procedures for assisting persons experiencing accessibility barriers

(h) Feedback Process

GEM welcomes feedback regarding the accessibility of its goods, services, facilities, and employment practices. Feedback may be provided in a variety of ways, including:

• by e-mail: services@gemhealthcare.com
• by phone: 1-613-761-7474
• in person at 383 Parkdale Ave Suite 304 Parkdale Ave, Ottawa On, K1Y 4R4

 

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Multi Year Accessibility plan for GEM HCS

1. Statement of Commitment

GEM Health Care Services (“GEM HCS”) is committed to providing a barrier-free environment that respects the dignity, independence, integration, and equal opportunity of persons with disabilities.

GEM HCS is committed to meeting the accessibility needs of persons with disabilities in a timely manner and will do so by preventing and removing barriers to accessibility and by meeting the requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (“AODA”) and the Integrated Accessibility Standards Regulation (“IASR”). 

This multi-year accessibility plan outlines GEM HCS’s strategy to identify, prevent, and remove barriers for employees, residents, patients, families, volunteers, contractors, visitors, and members of the public.

The organization will:

• Maintain accessibility policies and procedures; 
• Review this plan at least once every five years; 
• Report annually on progress; 
• Provide accessible formats and communication supports upon request; 
• Promote a culture of inclusion and accessibility throughout all operations. 

2. Purpose

The purpose of this policy and plan is to:

• Achieve compliance with Ontario accessibility legislation; 
• Improve accessibility across all GEM HCS facilities and services; 
• Ensure equitable access to employment, communication, care services, and public spaces; 
• Establish accountability for accessibility initiatives; 
• Foster an inclusive environment for individuals of all abilities. 

3. Scope

This policy applies to:

• All employees; 
• Medical and clinical staff; 
• Contractors and consultants; 
• Volunteers and students; 
• Visitors and family members; 
• Third-party service providers acting on behalf of GEM HCS. 

4. Legislative Framework

This policy is developed under:

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA); 
• Ontario Regulation 191/11 – Integrated Accessibility Standards (IASR); 
• Ontario Human Rights Code; 
• Accessibility Standards for Customer Service; 
• Employment Standards under the IASR; 
• Information and Communications Standards; 
• Design of Public Spaces Standards where applicable. 

5. Definitions

Disability

“Disability” has the same meaning as defined under the Ontario Human Rights Code and AODA.

Barrier

Anything that prevents a person with a disability from fully participating in society, including:

• Physical barriers; 
• Architectural barriers; 
• Information or communication barriers; 
• Technological barriers; 
• Attitudinal barriers; 
• Policy or practice barriers. 

Accessible Formats

Formats that enable persons with disabilities to access information, including:

• Large print; 
• Braille; 
• Audio formats; 
• Electronic accessible documents; 
• Plain language materials. 

6. Accessibility Policies

GEM HCS shall:

• Develop, implement, and maintain accessibility policies; 
• Make policies publicly available; 
• Provide policies in accessible formats upon request; 
• Integrate accessibility considerations into operational planning and procurement practices. 

7. Training

GEM HCS will provide mandatory accessibility training to:

• Employees; 
• Volunteers; 
• Individuals involved in policy development; 
• Persons providing goods, services, or facilities on behalf of GEM HCS. 

Training will include:

• AODA requirements; 
• Ontario Human Rights Code obligations; 
• Interaction and communication with persons with disabilities; 
• Use of assistive devices and accessibility supports; 
• Procedures for accommodating individuals with disabilities. 

Training records will be maintained and updated as required. 

8. Information and Communication Standards

GEM HCS will:

• Provide accessible formats and communication supports upon request; 
• Ensure feedback processes are accessible; 
• Notify the public about availability of accommodations; 
• Ensure websites and web content conform to WCAG accessibility requirements where applicable; 
• Provide emergency procedures and public safety information in accessible formats. 

Accessibility needs will be considered in all communications and patient/resident information systems. 

9. Employment Standards

GEM HCS is committed to fair and accessible employment practices throughout:

• Recruitment; 
• Hiring; 
• Retention; 
• Career development; 
• Return-to-work processes. 

GEM HCS will:

• Notify employees and applicants about accommodation availability; 
• Provide accessible recruitment processes; 
• Develop individualized workplace accommodation plans; 
• Maintain return-to-work procedures; 
• Consider accessibility needs in performance management, redeployment, and career advancement. 

10. Customer Service Accessibility

GEM HCS will ensure that services are provided in a manner that:

• Respects dignity and independence; 
• Allows use of assistive devices; 
• Permits service animals and support persons where appropriate; 
• Communicates effectively with persons with disabilities; 
• Provides notice of temporary service disruptions. 

Feedback regarding accessibility will be accepted in multiple accessible formats.

11. Procurement

Accessibility criteria and features will be incorporated when procuring or acquiring goods, services, self-service kiosks, and facilities, except where not practicable. 

12. Built Environment and Facilities

GEM HCS will continue to identify and remove physical barriers by:

• Assessing facility accessibility; 
• Maintaining accessible entrances and pathways; 
• Improving signage and wayfinding; 
• Ensuring accessible washrooms and patient/resident spaces where feasible; 
• Considering accessibility in renovations and new construction projects. 

13. Multi-Year Accessibility Initiatives (2026–2031)

2026

Governance and Compliance

• Review and update all accessibility policies. 
• Publish the multi-year accessibility plan. 
• Establish annual accessibility reporting process. 
• Conduct organization-wide accessibility assessment. 

Training

• Deliver updated AODA training to all staff. 
• Introduce accessibility orientation for new hires. 

Communications

• Review website accessibility compliance. 
• Standardize accessible document templates. 

2027

Employment Accessibility

• Enhance accommodation request processes. 
• Develop accessible interview and onboarding procedures. 
• Review emergency response plans for employees with disabilities. 

Resident and Patient Experience

• Improve accessibility signage across facilities. 
• Expand alternate communication supports for residents and families. 

2028

Facility Improvements

• Conduct accessibility audits at all GEM HCS locations. 
• Prioritize barrier removal projects. 
• Improve accessible parking and entrance access where needed. 

Technology

• Assess digital platforms for WCAG compliance. 
• Implement accessibility features in employee and resident systems. 

2029

Organizational Integration

• Integrate accessibility into procurement standards. 
• Include accessibility metrics in quality improvement initiatives. 
• Conduct employee accessibility awareness campaign. 

Feedback and Consultation

• Review accessibility feedback trends. 
• Consult persons with disabilities regarding ongoing improvements. 

2030–2031

Evaluation and Renewal

• Conduct comprehensive review of accessibility achievements. 
• Identify remaining barriers and improvement opportunities. 
• Prepare updated 2031–2036 Accessibility Plan. 
• Continue annual reporting and compliance monitoring. 

14. Monitoring and Reporting

GEM HCS will:

• Review accessibility initiatives annually; 
• Monitor compliance with legislative requirements; 
• Document progress toward accessibility objectives; 
• Provide status updates to leadership and stakeholders; 
• Update this plan at least once every five years. 

15. Accessible Formats and Communication Supports

This document and other accessibility-related information are available in accessible formats upon request.

Requests may be directed to:

Accessibility Coordinator

Melissa Cardinal
GEM Health Care Services
383 Parkdale Ave Suite 304, Parkdale Ave, Ottawa ON K1Y 4R4
melissa.cardinal@gemhealthcare.com
613-761-7474

16. Approval and Review

Version	Date	Approved By
1.0	May 2026	GEM HCS Leadership Team

Next formal review: May 2031.