Hamilton Health Sciences
Quality and Performance

Broader Public Sector Accountability

About Broader Public Sector Accountability Act, 2010

The Broader Public Sector Accountability Act, 2010 (BPSAA) was introduced on October 20, 2010 and received Royal Assent on December 8, 2010. The BPSAA establishes new rules and higher accountability standards for hospitals, Local Health Integration Networks (LHINs) and broader public sector organizations.


  • Bans the practice of hiring lobbyists using public funds
  • Increseas accountability for hospitals and LHINs
  • Establishes new procurement and expense rules for certain large BPS organizations
  • Adds accountability measures related to compliance and expense rules
  • Brings hospitals under the Freedom of Information and Protection of Privacy Act (FIPPA)

BPSAA Legislation and Reporting Directives

On April 1, 2011, all hospitals were subject the following components of the BPSAA:

  • BPS Expense Directive
  • BPS Procurement Directive
  • Annual Reporting on consultant use
  • Posting expenses
  • Attestation related to compliance with reporting on use of consultants, lobbyist rules, expense claims and procurement directive


BPSAA Expense Directive

The BPSAA Expenses Directive improves accountability and transparency in the Broader Public Sector by:

  • Requiring designated BPS organizations to establish expense rules
  • Setting out requirements for what needs to be included in each organizations' expense rules

The requirements in the directive contribute to greater alignments with the high standards expected in ministries and agencies of the Government of Ontario.

BPSAA Expense Directive  


BPSAA Procurement Directive

The purpose of the Directive is:

  • To ensure that publicly funded goods and services, including construction, consulting services and information technology are acquired by BPS organizations through a process that is open, fair, and transparent;
  • To outline responsibilities of BPS organizations througout each stage of the procurment process; and
  • To ensure that procurement processes are managed consistently throughout the BPS

BPS Procurement Directive  


Annual Reporting On Consultant Use

The Government of Ontario through the Ministry of Finance and the Ministry of Health & Long Term Care have placed considerable emphasis on the manner in which BPS organizations engage consultants. Recently passed legislation in the form of Bill 122 and new BPS Procurement Directives require all hospitals to follow specific rules. In response, HHS has developed a new policy entitled; "Use of Consultants". Key elements of the Use of Consultants policy include:

  • Formal approval by a Vice-President must be given before consulting services procurement process begins using the prescribed "Consultant Authorization Form" contained in the policy
  • All consulting services must
  •  All consulting services must be competitively procured by obtaining a minimum of 3 quotations or proposals regardless of the anticipated value of  the engagement
  • Consulting Services are assigned to new financial EOC; "65091".
  • The HHS Board of Directors must provide an "Annual Declaration" to the HNHB LHIN that all engagements of consultants at HHS have been performed in accordance with requirements of Bill 122 and BPS Procurement Directives.
  • Online annual compliance tracking and traceability to Board of Directors (in support of annual Declaration)
  • HHS Internal Audit department will conduct internal review of Use of Consultants on a scheduled and recurring basis
  • Use of Standardized Consultant Agreement(Contract)

Please take a few moments to familiarize yourself with the details of the policy found in the attachments listed at the end of this page.

Posting of Expenses

Hospitals will be required to post the expenses of board members, the CEO/President and members of senior management that report directly to the CEO/President.

The posting cycle will be semi-annually with expenses posted on the hospital's public website 60  days after the end of each reporting period.

To view the Executive and Board Expense Disclosure, please
click here.

Attestation related to compliance with reporting on use of consultants, lobbyist rules, expense claim and procurement directive 

Hospitals will be required to submit attestations indicating compliance with the following requirements of BPSAA: 

  • Completion and accuracy of reports required on the use of consultants;
  • Compliance with the prohibition on engaging lobbyist services using public funds
  • Compliance with expense claims directives
  • Compliance with procurement directives.

The reporting period the hospital is attesting to is April 1 to the following March 31.  Attestations will be submitted on an annual basis and be due to the LHIN's by June 30th each year.  Every hospital is required to post its board approved attestations on its public website by August 31st of each year for one year and archived after that time.

HHS Attestations:

HHS Attestations 2018

HHS Attestations 2017

HHS Attestations 2016


The following are HHS policies that are in compliance with various requirements set out in the expense rules for an organization:

HHS Use of Consultant Policy

Hamilton Health Sciences Procurement Card Policy

Hamilton Health Sciences Travel & Expense Reimbursement Policy

Hamilton Health Sciences • Hamilton, Ontario • 905.521.2100

Disclaimer: Hamilton Health Sciences (HHS) offers Google Translate to better facilitate access for our community. However, HHS makes no claims regarding the accuracy of translations. Any and all health information should be verified by a health care professional.