As a proud Albertan seeing so many concerns within my province speaknowalberta.ca has now been added.

On November 14, 2022, the Premier of Alberta issued a mandate requesting the establishment of a Task Force under the Health Quality Council of Alberta to conduct a data review of the last several years of health information with a view to offering recommendations on how to better manage a future pandemic. 

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Here is a summary and the recommendations as written in

Alberta's COVID-19 Pandemic Response Final Report

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The 269-page document begins with the names and biographies of the members of the Task Force, led by Dr. Gary Davidson - former head of Emergency Medicine for the central zone and Chief of the Emergency Department at Red Deer Regional Hospital.​

 

The Introduction (pages 1-3) lays out the study's scope guided by the following questions:

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• Data supply: was the right data being collected?

• Data quality: was it accurate and consistent (i.e., was the data collection standardized using consistent data definitions and processes for collection across the province)?

• Data resources: was there sufficient and integrated infrastructure (databases, equipment, people, etc.) to support efficient and effective data collection, collation, analytics, interpretation, and reporting?  

• Data analytics: were the appropriate analytic methods and tools utilized to create reliable and valid information to inform decision-making?

• Data interpretation: were the data and evidence interpreted correctly from a clinical and non-clinical perspective, e.g., were the limitations of the data (importance, validity, reliability) clearly identified, articulated, and applied to how the data was assessed?

• Data triangulation: was the data validated or corroborated against other evidence, experiences, and sources? Introduction

• Data flow: was it effective in how it was shared with and interpreted by the end users to support timely and appropriate decision-making (i.e., were the end users skilled, sufficiently knowledgeable, and/or supported to use the information appropriately)? 

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The objective of this report and the information that was used during the COVID-19 response are also outlined in the Introduction:

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'The objective of this report is to analyze publicly available data to unravel the intricacies of Alberta’s decision-making framework during the pandemic. By examining who made key decisions, what information those decisions were based upon, and how information was disseminated and utilized, the Task Force aims to provide a clearer understanding of Alberta’s response strategies. This analysis is critical not only for evaluating past actions but also for enhancing future preparedness for public health emergencies. '

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'This report also delves into the types of information that influenced COVID-19 response decisions. This information encompasses epidemiological data, scientific research, health system capacity metrics, and socio-economic considerations. By scrutinizing the sources and reliability of the data used, we can assess the extent to which evidence-based decisionmaking was employed and identify gaps or limitations in the information landscape.' 

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The Methodology  (pages 4-5)  outlines the systematic approach that was used to gather, analyze and interpret data. There is also a description of the data used and the report development stages.

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This report separates the findings from the research conducted into 9 chapters, each containing an executive summary, details of Alberta pandemic response including all government and nongovernmental members involved in decision making, choices made, data received, charts and findings and ends with a conclusion and recommendations.

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Chapter 1: Governance and Flow of Information (pages 6 -32)

Chapter 2: Regulatory Bodies (pages 33-97) 

Chapter 3: Modelling (pages 98-116)

Chapter 4: Non-Pharmaceutical Interventions: Closures & Restrictions (pages117-138)

Chapter 5: Masking (pages139-149)

Chapter 6: Testing (pages 150-163) 

Chapter 7: Infection Acquired Immunity (pages164-174)

Chapter 8: Vaccines (pages 175-209)

Chapter 9: Therapeutics (pages 210-234)

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I encourage everyone to read this report, as it is well-written and provides insightful information and education. I believe that the next step in ensuring Alberta can operate effectively if another health emergency arises is for the Government of Alberta to review this report, study the findings and recommendations, and implement updated or new legislation and regulations.

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​Here are the recommendations made within the report:

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Chapter 1: Governance and Flow of Information Recommendations:

1. To prepare for future public health emergencies, ensure: (a) a central command center such as the AEMA is mobilized to direct the appropriate response; (b) the Alberta Pandemic Influenza Response Plan is reviewed, maintained and utilized; and (c) all data and research are collected, gathered and reviewed at a provincial level to ensure the most effective and appropriate response for Alberta.

2. Ensure transparency at all levels of decision-making. 3. All decisions regarding Alberta’s response to any public health emergency shall be made by the AEMA or appointed person

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Chapter 2: Regulatory Bodies Preliminary Recommendations:

1. Decentralize Decision-Making and Information Dissemination: Empower local committees comprising practicing physicians, ethicists, and patient representatives to review complaints and disciplinary actions. This decentralization will ensure decisions are made by those with direct understanding and experience of clinical realities. • Strengthen appeal mechanisms to allow healthcare professionals to challenge decisions made by regulatory bodies. These mechanisms should be independent and have the authority to overturn or amend decisions based on comprehensive reviews.

2. Enhance Transparency and Accountability: Codify and make publicly available the process for developing guidelines, advisories, and communications by regulatory bodies. This transparency will prevent ad-hoc directives and ensure that regulatory bodies are accountable for their actions. • Implement a system for the periodic review of standards and guidelines to incorporate the latest scientific evidence and address emerging concerns from the healthcare community.

3. Protect Professional Autonomy and Patient-Centered Care: Reinforce the protections in the Health Professions Act, allowing physicians to employ nontraditional therapies, especially when evidence suggests they are safe and potentially beneficial. • Encourage regulatory bodies to respect physicians' clinical judgment, especially in unprecedented situations like a public health emergency. Guidance should allow flexibility for individualized patient care.

4. Foster Open Scientific Debate and Whistleblower Protections: Create forums and platforms where healthcare professionals can discuss and debate emerging evidence without fear of retribution. Such dialogue is crucial for advancing medical knowledge and improving patient care. • Strengthen protections for physicians who raise legitimate concerns about public health measures or emerging therapies. These protections should ensure that whistleblowers are not subjected to retaliatory disciplinary actions.

5. Enhance Scientific Rigor and Diversity: Encourage Regulatory Bodies to consider a diverse range of scientific sources and viewpoints for communication development to avoid bias and ensure a comprehensive understanding of evolving evidence.

6. Improve Communication and Education: Develop and mandate training programs for regulatory body members on the ethical and professional standards related to disciplinary processes. This training should emphasize the importance of evidence-based practice and the need for due process. • Ensure the rationale for disciplinary decisions is transparently reported and communicated to the public and healthcare professionals. This transparency will build trust and accountability.

7. Safeguard Against Biased or Politically Motivated Disciplinary Actions: Establish clear criteria for identifying disciplinary actions that are driven by mal-incentives, vexatious intent, bias, or political motivations. Once identified, such actions should be subject to stringent review and possible annulment. • Implement accountability measures for individuals or entities that are found to misuse the complaint process. This could include sanctions, fines, or other disciplinary actions against those who initiate complaints with malicious intent. • Conduct independent reviews by panels of experts not involved in the initial complaint process. This will add an additional layer of scrutiny and fairness. 

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Chapter 2: Regulatory Bodies Call for Further Inquiry:

1. External Influences on Regulatory Bodies: Initiate an inquiry into the sources of external influence on regulatory bodies, including funding sources, partnerships, and collaborations, to assess their impact on decision-making processes and policy development. This should include the role of external stakeholders, such as pharmaceutical companies, in shaping public health policies and guidelines.

2. Regulatory Capture and Conflicts of Interest: Perform a detailed analysis of the mechanisms that can lead to regulatory capture, including the appointment processes for regulatory body members, to identify potential vulnerabilities and areas for improvement. An assessment of the current policies and procedures in place to manage conflicts of interest among regulatory body members, including their effectiveness and potential gaps is needed.  

3. Transparency and Accountability: Review the current transparency measures in place for regulatory body decision-making processes, including the disclosure of meeting minutes, agendas, and conflict of interest declarations. Conduct an examination of the effectiveness of current accountability mechanisms, including complaint procedures and appeal processes, to identify areas for improvement.

4. Professional Autonomy and Patient-Centered Care: Initiate an investigation into the impact of regulatory body actions on professional autonomy and patient-centred care, including the effects of disciplinary actions on healthcare professionals' ability to provide individualized care.

5. Open Scientific Debate and Whistleblower Protections: Examine the current mechanisms in place to facilitate open scientific debate and discussion among healthcare professionals, including the role of regulatory bodies in promoting or hindering these discussions. Strong protections should be implemented to protect whistleblowers.

6. Scientific Rigor and Diversity: Study of the current processes in place to ensure the scientific rigour and diversity of regulatory body decision-making, including the use of independent review panels and the consideration of diverse scientific perspectives. This should include the policies surrounding novel therapies and interventions.

7. Review of the "Substantially Equivalent" Directive: A critical examination of the "substantially equivalent" directive and the potential consequences of this directive on the provision of high-quality healthcare services in Alberta. 

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Chapter 3: Modelling Recommendations:

Previous research provides evidence to suggest that even meaningless mathematics can give the illusion of high-quality analyses, generating a false sense of control over complex, dynamical phenomena. Undue acceptance of modelling results is a common consequence of an “interpretation pitfall” whereby the model’s users – the decision-makers in the PICC/EMCC – lack critical distance from its shortcomings. Minimizing the effect of this type of pitfall requires involving experts from different disciplines to provide a necessary “red team” perspective to decision-making; replacing speculative assumptions with real, empirical data as quickly as possible; and modifying – or even reversing, if necessary – decisions considering the evolving evidence in its entirety, not just a selective subset.

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Chapter 4: Non-Pharmaceutical Interventions: Closures & Restrictions 

1. Return to pre-2020 pandemic guidance where communities faced with contagion respond best when the normal social functioning of the community is minimally disrupted.158 This means safeguarding people’s autonomy to ensure that every adult Albertan has the individual right to make informed decisions about their risk behaviour — even in the face of a pandemic. 

2. Create oversight for future declared public health emergencies. NPI public health restrictions, like their pharmaceutical counterparts, require balanced scientific evidence showing they are safe and effective before being implemented. Ensure that all “countermeasures” undergo real-time evaluation, including risk-benefit analyses. Evaluation should be overseen by a panel of peers, representing different faith, societal, and socio-economic groups.

3. Use a “Red Team” approach within health emergency operations centers. For making policy decisions, red teams overcome groupthink, confirmation bias, and anchoring behaviour which impairs the critical thinking ability of individuals and organizations.

4. Alberta’s well-being before, during, and after the pandemic requires that other important metrics – besides public health indicators – need to be examined. 

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Chapter 5: Masking  Recommendations:

1. Public mask messaging to Albertans should be updated. Specifically, there is no evidence to indicate Alberta should shift away from pre-COVID-19 masking policies. The policy-grade data indicates a lack of masking effectiveness in protecting against SARS-CoV-2 infection. This includes continuous masking in the community and universal masking within the healthcare setting. The potential harms from masking need to be highlighted, especially among children.  

2. Alberta should refrain from future mask mandates for respiratory illnesses. The choice to wear a mask is a personal medical decision, guided by informed consent and patient autonomy. As such, the maxim that “Where there is risk, there must be choice” should guide any future policies.  

3. Children should not participate in continuous or universal masking. Children have very low-risk from COVID-19, and do not readily spread SARS-CoV-2.185 This dispels the myth that children pose a transmission risk to adults.  

4. There is no benefit for masking asymptomatic individuals. Asymptomatic SARSCoV-2 transmission occurs in < 5% of cases.186 Symptomatic Albertans should avoid being in public and consider isolation at home. For some symptomatic individuals, there remains a false sense of security that they cannot transmit SARS-CoV-2 if wearing a mask. Publicly acknowledging this will help to lower SARS-CoV-2 transmission.  

5. Alberta should adhere to the Canadian Biosafety Handbook which categorizes SARS-CoV-2 as a biosafety level 3 pathogen. This requires stringent engineering controls for containment, including the need to dilute, filter and destroy SARS-CoV2 with ventilation technologies. Such approaches have already been successfully implemented by the airline industry, schools, and assisted living facilities.

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Chapter 6: Testing Recommendations:

1. RT-PCR represents an excellent high-sensitivity test to aid in accurate diagnoses of symptomatic people – if they are used for the intended purpose and at optimal Ct values (vs. Ct values at “high positive” cut-offs).

2. Rapid tests with reasonable accuracy should not be used for screening the general population but could be used as an additional diagnostic tool, where clinically indicated.

3. We recommend that future pandemic responses prioritize minimizing severe disease and mortality over extensive case detection. Specifically, Alberta should focus on developing a screening tool to help estimate individual risk. This approach will optimize resource use by directing testing capacity, which can be appropriately directed by evidence-based practices, such as testing symptomatic individuals, those whose management may be influenced by test results, and for specific surveillance scenarios.  

4. We recommend that levels of immunity be gauged using a multi-antibody serological and/or mucosal assay that accounts for both pre-existing immunity as well as the presence of immune cells with the potential for cross-protection.  

5. All tests should also be professionally administered and sufficiently sensitive to detect low antibody levels while sufficiently specific to distinguish between target and non-target antibodies. This also applies to laboratory tests used to identify specific respiratory viruses. Individual risk estimates can then be used to inform individual needs for protection either through the use of personal protective measures and/or vaccination.

6. Without being linked to a set of standardized clinical criteria, we recommend against the use of PCR tests as the sole criteria for a case definition. A confirmed case should include a pre-determined profile of signs and/or symptoms AND a positive test for the infection of concern PLUS any relevant patient history and confirmed epidemiological information.

7. Ensure that local surveillance data are used and interpreted when determining strategy and policy. 

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Chapter 7: Infection Acquired Immunity  Recommendations:

1. A balanced and nuanced approach to communicating about immunity is essential – for example, vaccination is not the sole conduit to being “immunized”, and it sometimes fails to achieve this goal.   

2. Avoid coerced vaccination of any population, especially when there are high levels of infection-acquired immunity and/or low baseline susceptibility to severe disease. 

3. Public health policy that incorporates immunological concepts needs to be grounded in sound fundamental principles and to avoid ideological bias geared towards maximizing vaccine coverage. ​

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Chapter 8: Vaccines Recommendations:

1. Immediately halt the use of all COVID-19 vaccines without full disclosure to patients regarding both the safety and efficacy issues by their physician.  

2. End use of the COVID-19 vaccines for healthy children and teenagers as other jurisdictions have done. See Denmark, Sweden, Norway, Finland, and the UK.  

3. Further research to establish the safety and efficacy of COVID-19 vaccines is necessary before widespread use in adults and children. 4. Establish a website and/or call-in center for the vaccine injured in Alberta. 5. Establish a mechanism for opting out of federal health policy until provincial due process has been satisfied.  

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Chapter 9: Therapeutics Recommendations:

1. Amend the Health Professions Act (“HPA”) to prevent regulatory bodies from using “professionalism” or “codes of conduct” to obstruct the administration of approved medications for off-label uses.  

2. Instruct regulatory bodies to halt all prosecution or disciplinary actions against healthcare workers or pharmacists for using, promoting, or publicly discussing the benefits of approved medications for off-label treatment of illnesses.  

3. Amend current law or prepare new legislation that makes the public discussion of alternative medical treatments a matter protected under the Alberta Human Rights Act.

4. Amend the HPA to protect a physician’s right to prescribe and a pharmacist’s ability to dispense drugs that, in their professional judgment, are in a patient’s best interest. This includes personalizing established guidelines and prescribing off-label drugs.  

5. Amend the Alberta Human Rights Act to protect Albertans’ right to access to therapies in their best interest including off-label drugs and natural health products.    

6. Ensure rigorous standards of safety are upheld for all treatments, even during a public health emergency, and allow for greater flexibility in the use of therapies with established safety records.  

7. When reporting on health-related matters, require media to cite levels of supporting evidence and publicly disclose any political or financial competing interests that may influence their reporting, including publicly disclosing the dollar value and conditions of their public health and pharmaceutical contracts.  

8. Enact whistleblower legislation to protect a physician’s right to publicly voice concerns regarding potentially harmful or ill-conceived policies enacted by public health, regulatory bodies, or medical facility management organizations.

9. Create an avenue to expedite the creation of clinical trials of off-label or other treatments.​​​​