Canadian AIDS Society’s response to Government of Canada’s STBBI Action Plan

On July 17, 2019, the Government of Canada published an action plan entitled, “Accelerating our response: Government of Canada five-year action plan on sexually transmitted and blood-borne infections”. While this Action Plan is a much needed step in the right direction toward addressing the drastically increasing rates of sexually transmitted and blood-borne infections (STBBI) in Canada, there are some significant gaps of concern.

Firstly, the Canadian AIDS Society (CAS) would like to express support for the priorities and over-arching themes of the Action Plan. The seven broad Action Plan priorities are:

1. Moving towards truth and reconciliation with First Nations, Inuit and Métis People
2. Stigma and discrimination
3. Community innovation – Putting a priority on prevention
4. Reaching the undiagnosed – Increasing access to STBBI testing
5. Providing prevention, treatment and care to populations that receive health services or coverage of health care benefits from the federal government
6. Leveraging existing knowledge and targeting future research
7. Measuring impact – Monitoring and reporting on trends and results

CAS recognises that these priority areas will be crucially important to reducing rates of HIV in Canada, and is committed to working toward these priorities, though we would like to highlight the lack of priorities in the Action Plan that are specific to the care and support of people living with HIV.

CAS was disappointed to see that the Action Plan does not contain specific action items or any specific domestic objectives. Outside of the 2030 global targets, it is unclear what Canada will be trying to achieve under the Action Plan. Equally concerning is that how Canada will create positive change remains unidentified. CAS fails to understand how an action plan without clear action items will be effective and believes that the Action Plan must be more specific in both its objectives and measurable steps towards addressing HIV in Canada.

We are concerned by the timelines discussed in the Action Plan and interpret them as a lack of urgency towards addressing HIV in Canada. Despite previously endorsing global targets for HIV (90-90-90) aimed at 2020, this Canadian Action Plan focuses on 2030, stating that the objective of the plan is to “[a]ccelerate prevention, diagnosis and treatment to reduce the health impacts of sexually transmitted-and blood-borne infections (STBBI) in Canada by 2030”. Not only is the plan ignoring Canada’s limited success in meeting the 2020 goals, but this “five-year action plan” also fails to present any objectives that are less than ten years away.

The Action Plan states, “The Government of Canada is committed to playing its role in the development, regulatory approval and deployment of POCT and additional novel technologies(3).” CAS finds that this statement is inaccurate given the federal government’s lack of support for national community-based initiatives such as national HIV Testing Day, which brought POCT to Atlantic Canada where it had not been previously available. There is also a lack of emphasis on tried and true prevention strategies such as condoms.

In terms of populations to be prioritized, the Action Plan states, “Reaching the undiagnosed is key to improving the health of people living with STBBI and reducing transmission. The Government of Canada will continue to support programs and initiatives that promote access to and uptake of STBBI testing.” As of the time of writing this position statement, preliminary data from the 2019 national HIV Testing Day demonstrates that 35% of the people who were tested as part of Testing Day had never been tested before, and 67% had not been tested within the past year. This initiative has clearly been successful in reaching populations who had not previously been tested, yet the federal government has declined to support it financially since the first national HIV Testing Day in 2018, stating that testing is under the jurisdiction of provinces and territories. All provinces and territories have endorsed the Action Plan. Over and beyond the role of the province and territories, PHAC has a responsibility to increase access to testing across Canada recognizing the diversity of populations and the importance of adapting strategies. Providing funding support, recognition, human resource support, and engagement is one step towards this responsibility that cannot be assigned.

While CAS appreciates the Government of Canada’s recognition that there are current gaps in STBBI surveillance data, all that is mentioned in the Action Plan is that “federal, provincial and territorial governments have made a commitment to work together to strengthen STBBI surveillance as a priority.” The integrity of accurate surveillance data is an immediate and important need, and concrete steps must be developed and detailed to the public beyond a vague commitment to prioritize filling in these gaps.

Finally, we are concerned that inadequate funding will continue to affect the work of HIV organizations over the next ten years and challenge Canada’s ability to reach international targets, just as it has over the past ten years. The Action Plan identifies that “federal STBBI investments of $81.5 million annually remain foundational to our work”. This Action Plan fails to recognise Recommendation 20 from the most recent report from the Standing Committee on Health:

Recommendation 20: That the Government of Canada increase total funding for the Federal Initiative to Address HIV/AIDS in Canada to $100 million annually, as recommended in the 2003 report of the Standing Committee on Health entitled Strengthening the Canadian Strategy on HIV/AIDS.

CAS supports the recommended funding increase to $100 million annually, specifically allocated to HIV, rather than $81.5 million for all STBBI (which is not a guaranteed sum yearly). Without funding, organizations that build capacity for care, treatment, support, testing, research and capacity building will be restricted in the delivery of their services.

In summary, while it is a good sign that the Government of Canada recognizes the importance of a plan to address the rising rates of HIV and other STBBI in Canada, the steps in their Action Plan are vague and do not provide any details about how these steps will be implemented. We recommend that the Government of Canada take the following steps in order to address the gaps in the Action Plan:

1. Follow the Standing Committee on Health’s recommendation to increase HIV funding to $100 million annually (separately from funding for other STBBI)
2. Identify clear national goals that provide accountability at the end of the five-year plan
3. Explicitly describe the measurable steps needed to achieve these national goals
4. Financially support the national HIV Testing Day (as part of a Sexual Health Awareness Week) moving forward, as well as to financially support bringing POCT and other testing technologies to communities that do not have access to them
5. Identify specific steps to improve surveillance data for HIV and other STBBI
6. Restore funding to the 40 organizations who lost funding from the redesign of PHAC’s HIV and Hepatitis C Community Action Fund in 2016 (which directly led to a historic increase in HIV cases in Canada).
7. Ensuring a harmonization of harm reduction practices within the STBBI scope