Policy Framework: Vaccine Impact Assistance Program

Last updated: April 1, 2026

This document is subject to periodic updates. Please consult this page to ensure you're referencing the most current version.

1. Overview

The Vaccine Impact Assistance Program (the "Program") provides access to Financial Support for individuals in Canada who have experienced a Serious and Permanent injury as a result of receiving a Health Canada-authorized vaccine Administered in Canada on or after December 8, 2020.

The Program is based on the principle of reciprocity, people who suffer a Serious and Permanent Vaccine Injury as a result of being immunized should be supported in a fair and timely manner, without having to incur the additional burden of pursuing litigation.

The Program is established by the Government of Canada and administered by the Public Health Agency of Canada. The Government of Quebec independently administers its Vaccine Injury Compensation Program, and individuals who receive a vaccine in Quebec must apply to Quebec's program. This Policy Framework does not apply to Quebec's program.

The purpose of this Policy Framework is to establish the rules, principles, and requirements governing the Program, including eligibility, Medical Assessment, decision-making, Financial Support, and appeals.

Guidance documents in support of this Policy Framework are available and provide plain-language explanations and operational direction to support consistent application of the Policy Framework. The Guidance documents do not modify this Policy Framework. In the event of any inconsistency, this Policy Framework prevails.

2. Guiding Principles

The Program is administered in accordance with the following principles:

Fairness and Transparency: Decisions are made impartially and communicated clearly, with reasons that explain how evidence and criteria were applied.
Evidence-Informed Decision-Making: Eligibility and Financial Support Decisions are based on medical evidence and consistent application of Program criteria.
Integrity of Information: Claimants, Authorized Representatives, and Beneficiaries are responsible for providing information that is accurate, complete, and verifiable.
Consistency and Predictability: Policies and procedures are applied consistently to ensure equitable treatment and predictable outcomes for all Claimants and Beneficiaries.
Accessibility: The Program strives to process claims, collect records, and communicate decisions in a manner that is accessible and easy to understand.

3. Eligibility Requirements

3.1 The Program's eligibility requirements are designed to ensure fair and equitable access to support for anyone who experiences a Serious and Permanent injury as a result of receiving a Health Canada-authorized vaccine.

3.2 Requirements

To be eligible for the Program, a Vaccine Recipient must have experienced a Serious and Permanent injury as a result of receiving a Health Canada-authorized vaccine, Administered in Canada, on or after December 8, 2020. A Vaccine Recipient, or their Authorized Representative, may submit a claim and is referred to as a "Claimant" in this Policy Framework. Claimants must provide documentation demonstrating that the injury meets the Program's eligibility requirements.

3.2.1 Health Canada-authorized vaccines administered to members of the Canadian Armed Forces, Government of Canada officials, and their dependents who are deployed or posted outside of Canada are considered to have been Administered in Canada for the purposes of the Program.
3.2.2 All current and future Health Canada-authorized vaccines or immunoglobulin administered for prophylactic purposes that provides protection from preventable infectious disease, and are authorized for sale by Health Canada at the time of administration, are covered under the Program. This does not include a vaccine only authorized for clinical trials. A full list of Health Canada-authorized vaccines can be found in the National Vaccine Catalogue.

3.3 Three-year time limit

Claimants will have up to three years after the date of vaccination to submit a claim. In the event of a death, an Authorized Representative will have up to three years after the date of death of the Claimant to submit a claim for a death benefit.

3.3.1 When an injury becomes apparent gradually, the time limit will be counted from:
1. 3.3.1.1 the day the injury first becomes apparent; or,
2. 3.3.1.2 the day when a link with the vaccine is established by credible sources.
3.3.2 Exceptions to the three-year time limit may be granted in rare and exceptional circumstances. Exceptional circumstances must be supported by documentation.

Exceptions may be granted in cases where: (a) credible evidence explains the delay; (b) the delay arose from circumstances beyond the Claimant's control; and (c) it is reasonable, in the circumstances, to extend the time limit, with the onus on a Claimant to demonstrate that an exception is warranted.

3.4 Reconsideration

Claimants may submit a reconsideration request if their claim was ineligible under section 3.3 for not being submitted within the time limit.

3.4.1 Reconsideration requests must be submitted within 90 days of the date on which the Notice of Decision with respect to ineligibility is dated and must include a clear rationale explaining the basis for reconsideration with supporting documentation.

4. Claims Assessment

4.1 Integrity of Information

Claimants must provide complete and accurate information, including personal identification details, vaccination records, medical documentation supporting a Serious and Permanent injury, and any additional materials requested by the Program to assess eligibility for the Program.

4.2 Timelines and completeness of documentation

Claims must be submitted within the prescribed timelines, and all documentation must be sufficient to allow the Program to verify the vaccine received and to evaluate the seriousness and permanence of the injury, probable causal relationship of the injury to the vaccine, and the Severity of a Vaccine Injury. Once received, the Program will acknowledge receipt of the claim, request any additional necessary information, assess eligibility requirements and, if deemed eligible, proceed to the Medical Assessment stage to determine eligibility for Financial Support.

4.3 Program process overview

An eligibility requirements assessment, Medical Assessment and Financial Support assessment are conducted through a staged assessment process. Claimants are updated at each stage.

Stage 1: Submission of claim and eligibility requirements assessment
- The Claimant submits a completed application form along with all required documentation to initiate the claim. The Program reviews the submission to determine whether the Claimant meets the eligibility criteria under sections 3.2 and 3.3. If the criteria are met, the claim is deemed eligible, and the Claimant is notified that it will proceed to the next stage.
- If the criteria are not met, the Claimant is notified that the claim is ineligible. The Claimant may request a reconsideration of this decision in accordance with section 3.4.
Stage 2: Review of documentation and Medical Assessment
- The Program reviews medical records and supporting documents submitted by the Claimant, to prepare the file for the Medical Assessment. If additional records are required, the Program requests them from the Claimant.
- Medical experts then assess the available medical information to determine whether a Serious and Permanent injury exists, and if there is a probable causal relationship between the injury and a Health Canada-authorized vaccine. Where a probable causal relationship is established, they also evaluate the Severity of the Vaccine Injury.
Stage 3: Financial Support Assessment
- Based on the results of the Medical Assessment, the Program determines the appropriate category(s) and level of Financial Support, set out in Section 6 (to come).

4.4 Notices of Decision

A Notice of Decision will be issued to Claimants to communicate, as applicable:

a determination of eligibility or ineligibility to the Program, and the outcome of any reconsideration request;
the outcomes of the Medical Assessment, which may include the Severity assessment where relevant, and resulting assessment of Financial Support;
any appeal Decision(s).

Each Notice of Decision will clearly outline the Program's Decisions and information on the Claimant's available options for reconsideration or appeal.

5. Medical Assessment

5.1 The objective of the Medical Assessment process is to determine whether a serious and permanent Medical Condition was probably caused by a Health Canada-authorized vaccine. When a probable causal relationship is established, the condition is considered a Vaccine Injury. Once a Vaccine Injury is established, a Severity assessment process will then determine the eligible level of Financial Support.

5.1.1 Serious is defined as a life-threatening or life-altering Medical Condition that may require in-person hospitalization or prolongs an existing hospitalization, and results in a persistent or significant disability or incapacity
5.1.2 Permanent is determined when examinations and accepted medical knowledge do not point to any significant foreseeable improvement in the Vaccine Recipient's condition.
5.1.3 Severity is defined as the degree to which a Medical Condition limits bodily function, daily activities, or participation in usual roles. Severity is measured using Program criteria and a standardized assessment guide to assign a Severity rating, expressed as a percentage. It is used to determine both eligibility for Financial Support and the eligible level of that support.
5.1.4 Medical Assessments of deceased Vaccine Recipients do not include an assessment for Serious and Permanent or Severity.

5.2 Process

The Medical Assessment will be conducted by medical experts using accepted medical practices, such as assessing strength of evidence, temporal relationship, exclusion of other probable causes of the medical condition. The Medical Assessment will also consider the timing of symptom onset and relevant population-based scientific evidence on vaccine-related causality.

5.3 Severity assessment

Medical experts will conduct a Severity assessment for claims that meet the criteria for Serious, Permanent, and a probable causal relationship to the vaccine. The result of this Severity assessment determines the amount of the Financial Support.

5.3.1 Severity rating
Using a standardized assessment guide, medical experts assign a Severity rating expressed as a percentage. This rating reflects the overall impact of the injury on the Claimant's functioning and daily life.

5.4 Legacy Decisions

Medical Assessment decisions for Claimants approved under the Vaccine Injury Support Program (VISP) administered by OXARO Inc. (formerly RCGT Consulting) on or before March 31, 2026 are preserved and will not be altered by changes to the Medical Assessment processes established under the Vaccine Impact Assistance Program, effective April 1, 2026. VISP Medical Assessment decisions may be altered by appeal to the Severity assessment or changes in Medical Condition.

6. Financial Support

To come

7. Appealing Decisions

7.1 The purpose of the appeals process is to provide Claimants and Beneficiaries with a fair and transparent mechanism to request a review of certain assessment Decisions made by the Program.

7.2 Appealable decisions

Appeals are limited to Decisions related to the Medical Assessment process. Decisions on eligibility are subject to the reconsideration process in section 3.4.

Appealable Decisions include:

Causality assessment: determination of whether there is a probable causal relationship between the injury and a Health Canada authorized vaccine, based on scientific, epidemiologic, and medical evidence.
Serious and Permanent assessment: determination of whether an injury or Medical Condition is Serious and Permanent.
Severity assessment: determination of the level of Financial Support based on the Severity of the Vaccine Injury.

7.2.1 Appeals process

Appeals must be submitted online or post-marked by mail within 90 days of the date of the Notice of Decision.

For appeals to be considered, they must include:
- A clear rationale explaining why the Claimant or Beneficiary disagrees with the Decision and which aspects of the Medical Assessment are being challenged; and
- New medical information not included in the original application, or identification of specific records or clinical findings within the original application that were not adequately considered.

7.2.2 The Program will not deny an appeal because medical documentation could not be obtained within 90 days, provided the appeal, including a rationale, was submitted within 90 days.

7.2.3 Appeals submitted after the appeal deadline may be submitted where new, reliable evidence from a credible source emerges supporting a probable causal relationship between the vaccine and the injury, or the progression of the injury.

7.3 Adjustment of Financial Support following appeal

If an appeal results in a revised Medical Assessment, and as a result Financial Support is assessed at a lower amount than the original assessment, any amount previously paid in excess of the revised amount will be considered an overpayment and must be repaid to the Government of Canada. Overpayments that are determined to be a debt to the Crown are subject to the application of interest in accordance with the Financial Administration Act and Interest and Administrative Charges Regulations.

Appendix A: Definitions for the Purposes of the Program

Administered in Canada: A Health Canada-authorized vaccine administered in Canada on or after December 8, 2020. For the purposes of the Program, vaccines administered to members of the Canadian Armed Forces, Government of Canada officials, and their dependents while deployed or posted outside Canada are deemed to have been Administered in Canada.
Authorized Representative: An individual who is allowed to act for the Vaccine Recipient. This could be a parent or guardian of a minor, someone authorized to act for an incapacitated or deceased person, or someone the vaccine recipient has chosen by signing an Authorized Representative Form through informed consent.
Beneficiary: A Claimant whose claim has been approved and receives Financial Support from the Program.
Claimant: An individual who submitted a claim to the Program. This may be the Vaccine Recipient, or it may be someone identified in the system by an individual acting on their behalf (the Authorized Representative). In some cases, the Vaccine Recipient could be deceased, and the Authorized Representative would interact with the Program on their behalf under the authority of the last will and testament.
Decision: A determination made by the Program based on the evidence and information available. A Decision outlines the outcome of a Claimant's claim at specific stages of the Program (eligibility, Medical Assessment, and appeal) and forms the basis for the Notice of Decision.
Financial Support: The monetary amounts provided to the Beneficiary under the Program. Financial support may include: (a) injury indemnity; (b) income support; (c) some medical and rehabilitation expenses; and (d) death benefit.
Health Canada- authorized vaccine: A vaccine or immunoglobulin administered for protection from a preventable infectious disease and authorized for sale by Health Canada at the time of administration. This does not include a product authorized solely for clinical trials.
Medical Assessment: An assessment conducted under the Program by qualified medical professionals, supported by credible scientific, medical, and epidemiological evidence, based on the Claimant's medical history, vaccination information, clinical records, and any other relevant documentation, for the purpose of determining: (a) whether a Serious and Permanent injury exists; (b) whether a probable causal relationship to the vaccine is established; and (c) the degree to which a Medical Condition limits bodily function, activities, or participation in usual roles.
Medical Condition: A broad term that includes all diseases, lesions, disorders, or non-pathologic conditions that normally receive medical treatment, or a condition where the outcome is death.
Notice of Decision: A formal written communication from the Program that outlines the outcome of a Claimant's case, the reasons for the decision, and any available options for reconsideration or appeal. It may include determinations of eligibility, results of the Medical Assessment (including Severity and Financial Support), and any appeal decisions.
Permanent: A Medical Condition is considered permanent when examinations and accepted medical knowledge do not point to any significant foreseeable improvement in the individual's condition.
Serious: A life-threatening or life-altering Medical Condition that may require in-person hospitalization or prolongs an existing hospitalization, and results in a persistent or significant disability or incapacity.
Severity: The degree to which a Medical Condition limits bodily function, daily activities, or participation in usual roles. Severity is measured using Program criteria and a standardized assessment guide to assign a Severity rating, expressed as a percentage. It is used to determine both eligibility for Financial Support and the appropriate level of that support.
Vaccine Injury: A Medical Condition that, after medical assessment, has met the criteria for a probable causal relationship to a Health Canada authorized vaccine received by the individual.
Vaccine Recipient: An individual who received the vaccine and experienced an injury.

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2026-03-31

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