Thursday, July 16, 2026 – Yesterday, the Ontario government formally launched the procurement for its provincewide Primary Care Medical Record (PCMR) system after closing out its marketing sounding exercise earlier this month. The province is moving forward with an open competitive process to establish a Vendor of Record arrangement, led by the Ministry of Health, in collaboration with Ontario Health and Supply Ontario.
The procurement is noteworthy for three reasons, all of which are expanded upon in greater detail below:
- The procurement seeks to completely reshape the Electronic Medical Record (EMR) market in Ontario. With adoption close to 100%, EMRs are the backbone of day-to-day operations in primary care, and any change will have huge impacts across the sector.
- The procurement articulates a new vision for primary care in the province, with Ontario using a new technology approach as a mechanism to re-shape how primary care works, including things like centralized quality improvement dashboards, stringently managed cybersecurity processes, and mechanisms for centralizing appointment booking with primary care providers.
- The procurement provides a window into Ontario’s current thinking on both Artificial Intelligence (AI) policy, as well as on Buy Ontario and Canadian data residency.
Grab a coffee and dive in with us as we unpack the hundreds of pages involved in the procurement process.
Key Highlights
The Scope of the PCMR Procurement
Ontario is, in parallel, procuring two things:
- A handful of provincial EMR solutions – each will be built as a single, cloud-based EMR, and clinicians can opt to leave their current EMR and adopt one of the provincial solutions.
- A single vendor to provide centralized technical support to clinicians who opt into a provincial EMR, with services including implementation assistance, cybersecurity, and day-to-day troubleshooting.
For the provincial EMR, the government will be selecting up to four (4) total vendors. If successful, this would represent a significant rationalization of Ontario’s market – the current market has 13+ vendors, with three being dominant and controlling more than 80% of the market.
The procurement is set up as a Vendor of Record arrangement. Vendors will agree to contract terms and requirements, but will not be guaranteed any users. Instead, once the VOR is established, clinicians will have the choice to opt into the provincial approach and will select their desired vendor at that stage. If they opt in, clinicians will pay licensing fees to the province instead of their current vendors and clinicians will have a new provincial Customer Care organization that will serve as their office’s new technical support team on an ongoing basis. Clinicians will agree to a range of provincially-defined terms related to the use of the technology (e.g. stringent cybersecurity requirements); and they will, in theory, gain more rapid access to provincial applications and programs.
A Future Vision for Primary Care – What It Means for Primary Care Practices
While the procurement is being framed primarily in technological terms, it actually lays out an expansive vision for the future of primary care in Ontario.
As a starting point, the procurement raises the bar on EMR functionality. In addition to long-standing, core requirements, the procurement seeks to:
- Accelerate EMR integration with current and emerging provincial assets, including provincial hospital report, drug information, lab information, eReferral, eConsult, and eForm systems;
- Require EMRs to integrate in future with to-be-developed provincial infrastructure, such as ePrescribing, a provincial Immunization Registry, and a provincial repository for primary care data; and
- Create open-ended requirements in which the vendor agrees to rapidly comply with future provincial direction related to data standards and sharing.
The idea of all of this is to give primary care providers an EMR that doesn’t just work for their practice, but also integrates with the rest of the province’s health system.
Beyond integration, the procurement also outlines an ambitious vision for future primary care functionality, requirements, and capabilities. The procurement lays out the province’s intent to work with vendors to develop and deploy the following in the coming years:
- Tools that would enable the centralized (or patient-driven) scheduling of appointments.
- A directory of provincial health services that would enable providers to search for resources for their patients.
- A provincial platform to collect and share patient experience measures.
- New, advanced AI tools for clinical decision support and for the automatic review/organization of documents.
- Mechanisms for the province to define quality improvement metrics and enable clinicians to compare their performance.
- Dashboards that would enable clinicians to assess the overall health of their patient roster and take a population health management approach.
- A provincial app store.
The procurement also envisions a future for primary care in which clinicians have a single-window service to get support from the province, including general technical support but also assistance in quality improvement efforts. This would also include a new, centralized approach to cybersecurity, in which the provincial organization would define cybersecurity requirements and would work with clinics to ensure and monitor compliance.
The above entails a significant evolution away from the traditional model of primary care – small, independently run organizations – to a much more top-down, provincial approach in which the province would define functionality and workflows and provide clinicians with active support to adopt a provincially defined model of primary care. The province would then be able to use this as their mechanism to deploy things like provincial population health management programs, centralized scheduling tools, and quality improvement initiatives. The procurement focuses on technology, but the approach they are taking would enable far more wide-reaching reforms to primary care.
Meeting the Challenge at Scale – What It Means for Vendors
The VOR comes with significant risk for most digital health vendors.
Large, established vendors are being asked to incur substantial costs to change their systems to gain access to Ontario customers. However, they already have the majority of these customers, so they are largely not winning net new business – just exchanging current licensing fees for future licensing fees. The provincial technical support vendor is also taking a significant portion of the work that these vendors currently do, so they are likely going to be pushed to lower their licensing costs.
For smaller, upstart vendors, the costs of succeeding in this VOR are likely to be substantial. Because requirements are so extensive, most will likely not be able to absorb costs when there is no guarantee of any actual business or funding if they get on the VOR. If any small vendor succeeds, the potential gains are theoretically enormous, but this entails substantial short-term costs and very large risks in exchange for future gains that will not materialize for most.
Who stands to gain: 1) Vendors who build and sell products that integrate with EMRs, such as AI vendors, because the new model gives them a clear path to future integration and growth; and 2) vendors that are interested in building provincial infrastructure and solutions, as the procurement lays out an ambitious path for provincial work over the next several years.
Other Important Policy Signals
Beyond the scope of the PCMR itself, the procurement also includes a handful of policy signals that are of general interest to organizations interested in working with Ontario:
- AI Policy: The procurement lays out a new approach to AI requirements that is likely to serve as a template for Ontario activities moving forward. The procurement includes a general requirement that any AI functionality comply with current and future provincial requirements. The current list of requirements include disclosing all AI-enabled functionality to the province and complying with to-be-defined requirements associated with bias, accuracy, reliability, and safety. They allow the province to conduct risk assessments and require remediations as they deem appropriate, and ultimately give the province a veto over any AI functionality.
- Data Residency and Use: The procurement includes stringent requirements related to data residency, with strict prohibitions on any data leaving Canada for any purpose. The procurement also includes a blanket provision related to any sale of data, even if de-identified.
- Buy Canada/Ontario: The procurement does not include a requirement that the vendor be Canadian or Ontarian, and the procurement scoring does not advantage local organizations. However, there are provisions that require staff to be physically inside Canada (e.g. the technical support teams that will be supporting clinical practices cannot be off-shore) and that systems be physically in Canada, so vendors will be required to have a local footprint in practice.
What Comes Next – Full Speed Ahead
Now that the procurement is out, the path forward is clearer and moving much more quickly than anticipated. Given the government’s rapid pace thus far, we expect a Vendor of Record list to be completed this calendar year or, at the latest, by March.
After vendors are selected, there will likely be a period of a few months in which vendors will need to upgrade or enhance their products per the requirements and establish their provincial solution.
We expect that clinicians will begin to have the option to opt into provincial solutions some time in the 2027-28 fiscal year, and we expect the government to begin rolling out their more ambitious technology and primary care enhancements soon thereafter.
The program contains high risk on many fronts. It is entirely plausible that, after years of work and significant cost, fewer clinicians than anticipated will actually adopt the provincial solution. Physicians may not believe that migrating from their current EMR to a provincial solution is worth the time and effort of the transition, and they may balk at the various ways in which the province will gain greater control over how they work on a day-to-day basis.
However, if the initiative is successful, the results could be transformative. The technology that is used by primary care clinicians, and the way that they work in practice, could look very different in the coming years, and the creation of provincial mechanisms to deploy primary care reporting and quality improvement initiatives at scale could usher in a new era for primary care. It’s a gamble that the provincial government is willing to take.