Ensuring access to euthanasia by encouraging physician
participation: it's complicated
14 October, 2017
In July, 2017, Canadian euthanasia/assisted suicide (EAS)
practitioners and advocates alleged that patient access to
euthanasia and assisted suicide was in danger because of
"barriers" and "disincentives" to physician participation.
Dr. Stefanie Green, president of their professional
association, described the situation as "a crisis."1 There
was, in fact, no crisis — only a false perception of crisis
fuelled by unrealistic expectations about levels of
physician participation in euthanasia and assisted suicide.2
Nonetheless, it is reasonable for policy makers to
respond to their concerns that physicians are discouraged
from participating in euthanasia and assisted suicide. Indeed, objecting
physicians are less likely to experience disadvantage and
coercion if policy-makers seriously
consider suggestions by EAS practitioners and advocates about how to
encourage physician participation in euthanasia.
Removing barriers and disincentives to physician
Minimizing procedural and administrative requirements
Returning to the complaints and concerns of Canadian
euthanasia practitioners (see Canada's
Summer of Discontent2),
reducing or streamlining procedural requirements and
minimizing burdensome paperwork might encourage more
physicians to participate. However, this raises a question
that may prove difficult to answer. Is a procedural
requirement a "barrier" — or a necessary safeguard? A
"disincentive" — or an essential ethical prerequisite? The
difficulty is illustrated by developments in Belgium.
In 2001, when Belgium was considering the legalization of
euthanasia, the Flemish Palliative Care Federation urged
that euthanasia requests should pass through a "palliative
filter," an "indispensable precautionary requirement."3
Among other things, the Federation argued that "an informed
and therefore free and real choice for euthanasia is simply
impossible" without full information about alternatives.
It insisted that it was important to avoid "pseudo-choices" for
euthanasia by patients who had inadequate knowledge and
access to palliative care.4 This position was reiterated in
20035 and again in 2013, in relation to
the extension of euthanasia to minors, those with dementia,
those "tired of living," etc.:
Given the radical nature of euthanasia
– where suffering is 'solved' by terminating the life of the
sufferer – it can never be a first resort. To avoid the risk
of euthanasia being administered for improper reasons,
extending it to further populations groups should only be
considered if basic palliative care is fully provided to
Making adequate palliative care available to patients as
a precondition for euthanasia was understood by the
Federation to be both an ethical prerequisite for genuine
consent and an important safeguard, not a barrier to access.
Dr. Wim Distelmans has a different perspective. Dr.
Distelmans is, perhaps, Belgium's best-known euthanasia
practitioner and advocate.7 He was the president of the
Flemish Palliative Care Federation from 1996 to 2002,8
when he became chairman of Belgium's federal commission
responsible for overseeing euthanasia.7 He recently complained about delays even in
Belgian facilities "that officially claim to allow
All the delaying manoeuvres, such as
waiting for the approval of the ethics committee of the
hospital or the obligatory review of all palliative care
options - the so-called 'palliative filter' - make it
impossible to provide euthanasia in practice, or result in
the patient dying 'spontaneously' or by suicide.9
Dr. Distelmans' sneering characterization of prioritizing
palliative care as a delaying manoeuvre is at some distance
from the position of the Federation. His views do not seem
to reflect current attitudes in Canada, where exploring all
palliative treatment options is considered preferred and
even legally obligatory practice, not a delaying tactic.10
A similar conflict of perspectives arises with respect to
the concerns of Canadian EAS practitioners and advocates.
They identify a number of "barriers" or "disincentives"—
that patients be near the end of life, that practitioners
review medical histories, meet patients, refer them to
specialists, ensure informed consent and voluntariness by
means of witnesses, safeguard lethal medications, and report
to the coroner or other authorities. However, some of these
requirements reflect the norms of ethical medical practice.
Others are intended to function as part of what the Supreme
Court of Canada called "a carefully designed and monitored
system of safeguards" designed to limit risks associated
with allowing physicians to kill patients or help them
It would seem that minimizing or eliminating some of
these requirements would be inconsistent with ethical
medical practice, while dispensing with others would
eliminate or compromise the "system of safeguards" the
Supreme Court believed necessary. This presents something of
a conundrum for Canadian authorities, so a quick fix seems
Granted that the Supreme Court of Canada expected careful
monitoring of euthanasia/assisted suicide practice, one can
appreciate Dr. James Downar's concern that EAS practitioners may
resent and fear having their professional judgement
second-guessed by oversight committees, especially
committees consisting of people with no experience in the
field.12 Some modification of oversight arrangements might
be possible, but a significant change would have to take
into account entrenched practices and attitudes.
Prior to June, 2016, when someone was killed by a person
claiming legal justification — by the police, for example —
exceptional care was taken to investigate thoroughly in
order to ensure that the killing could be justified by law.
It was generally understood that killing people is an
exceptionally serious business, that it must be avoided if
at all possible, and that those authorized to kill must be
held to an exceptionally high standard of accountability.
Moreover, it was thought imprudent to allow those authorized
to kill to act as judges of their own conduct. On the
contrary: ultimate judgement was frequently left to a jury
composed of independent but professionally inexperienced
This is still the case when the police kill someone. Like
Dr. Downar, police representatives have sometimes expressed
concern that a jury verdict against one of their number is
demoralizing and will discourage them from doing their
job.13 Nonetheless, there is substantial support for
existing mechanisms that hold police accountable when they
kill someone.14 The ex post facto review of EAS
practitioners is not nearly as strict, so reducing it
further may be difficult and controversial, at least for the
On the other hand, EAS practitioners and other physicians
are obviously anxious that they might be charged for murder
if they make a mistake in assessing patient eligibility. Dr.
Tanja Daws expressed this concern:
She said there are serious
consequences if doctors are forced to rush through
assessments or medically assisted deaths because of poor
"The consequences of us doing shoddy work is we
can go to jail," she said.15
This kind of anxiety is unnecessary and can be
It is true that EAS practitioners who do "shoddy work"
could face discipline by professional regulatory
authorities, since it is the responsibility of medical
regulators to ensure that physicians do not do "shoddy
work," even if they are "forced" to do so by "poor pay."
That expectation reflects the most basic principles of
medical ethics and the ideal of patient-centred practice for
all physicians. Exempting EAS practitioners from this
kind of oversight would be difficult to justify.
However, regulators called upon to deal with good faith
mistakes by physicians typically do not respond by imposing
discipline, but by providing remedial advice, requiring
further training or taking other steps to prevent
mistakes from happening again.16
More important, physicians cannot go to jail for acting
on "a reasonable but mistaken belief" when providing
euthanasia or assisted suicide.17 Assuming a bona fide
intention to comply with legal requirements (as opposed
to deliberate non-compliance), and assuming that "shoddy
work" does not amount to criminal negligence (non-compliance
showing "wanton and reckless disregard for the lives or
safety of other persons"18), it is highly unlikely that EAS
practitioners would be charged for murder or criminal
negligence causing death merely for making a mistake or
"doing shoddy work."
Providing incentives for physician participation
Increasing compensation: fair pay or more pay?
It is obvious from the complaints of EAS practitioners
that increasing compensation would motivate some physicians
to participate in euthanasia and assisted suicide (see
Canada's Summer of Discontent2). Here one can distinguish
two issues, identified by Dr. Stefanie Green as "fair pay"
and 'more pay.'19
Paying fully for all time actually spent doing what is necessary to provide the
procedures and reimbursing their travel and
out-of-pocket expenses are "fair pay" issues. Other things
being equal, it would be unfair to compensate physicians
generally for actual time and travel costs, but deny the
same compensation to EAS practitioners.
However, compensation arrangements are determined
independently by each province, so the issue is more complex
than appears at first glance. If EAS practitioners and other
physicians in British Columbia are all governed by the same
compensation rules, are EAS practitioners in B.C. unfairly
treated because a different province has more favourable
physician compensation arrangements? If so, would
that not imply that compensation should be increased for all
B.C. physicians, not just for EAS practitioners?
Justifying "more pay" for EAS practitioners is more
complicated still, since they complain mainly about
compensation for services, responsibilities and burdens that
are ordinary aspects of general medical practice.
• Especially when dealing with cancer
or other serious illnesses or disorders, physicians
routinely meet patients, review complex medical histories,
and refer patients to specialists for assessment.
• Physicians dedicate time and energy
to counselling patients and families about medical
interventions, particularly in complex cases and in
• Generations of physicians have been
called out in the evenings and on weekends to attend to
labouring mothers or patients needing urgent or specialist
medical treatment, and this continues today.
• While house calls are no longer
routine, some physicians and health care workers continue to
visit patients at home when need be, even in squalid
conditions; bed bugs and cat feces are not unfamiliar to
them, or to first responders and social workers.
• Other physicians are also burdened
by administrative paperwork, especially for injuries that
are the subject of insurance and workers' compensation
claims, and they, too, must provide documents and
information required by coroners.
This probably explains the response of Dr. Trina Larsen
Soles of Doctors of BC to complaints about inadequate
euthanasia fees. Conceding that providing
euthanasia/assisted suicide is "really stressful," she noted
that counselling suicidal patients and bedside palliative
care is also stressful. Moreover, she said,
euthanasia/assisted suicide fees in British Columbia are
determined in the same way as fees for other services, so
"[if] we're going to argue about which part of our jobs are
more stressful and whether all parts of our job are
adequately compensated, that's a big discussion."1
One could argue that EAS practitioners should be paid
more because killing patients is different from and more
stressful or demanding than other services provided by
physicians, so, in fairness, they deserve more pay for the
work. Here the difficulty is that EAS advocates seem
unwilling to make this argument. They generally refuse to
acknowledge that killing is involved,20 insist that
providing euthanasia/assisted suicide is no different from
providing other physician services,21 and, as will be seen
presently, usually assert that it is personally rewarding.
Attracting physicians to an unattractive specialty
On the other hand, a claim for additional compensation
(by special reimbursement of expenses and/or increased fees)
could be based, not on fairness or the burdens of practice,
but on a pragmatic need to attract physicians to what seems
to be an unattractive specialty.
An article in Mcleans argued that doubling physician compensation for Caesarean sections
had been shown to increase the rate of C-sections by 5.6%,
so increasing compensation could encourage more physicians
to participate in "assisted dying." The article suggested that higher fees, premiums or bursaries for
euthanasia practitioners could be funded with money saved by
providing euthanasia/assisted suicide instead of extended
care and treatment.22
This would be effective in convincing some EAS
practitioners to remain in practice and others to resume
providing the service, but what about physicians generally?
An unknown number find euthanasia/assisted suicide so
morally abhorrent or contrary to their philosophy of
medicine that they are unwilling to facilitate the practices
by consultation or even by referral. Increasing compensation
would be completely ineffective in convincing them to change
Recruits are more likely to be found among physicians who
support euthanasia/assisted suicide, especially those
already providing consultations and assessments for the
service. The number inclined to support the procedures
appears to have increased since the Carter decision in
2015.23 Nonetheless, the number of physicians willing to
personally inject patients with lethal drugs or help them
commit suicide remains much lower. Dr. Downar himself
exemplifies the phenomenon. A member of Dying With Dignity
Canada's Physicians' Advisory Council, he states, "I cannot
foresee personally providing this for my patients."24
The extent to which increased compensation might convince
more of these physicians to provide euthanasia/assisted
suicide depends primarily upon the reasons for their
reluctance. Here one cannot avoid the elephant in the
room: reluctance arising from unease at the prospect of
having to personally kill another human being.
The elephant in the room: reluctance to kill
This point is disputed by Dr. Downar. He admits that "a
handful of physicians" might not be "comfortable" performing
euthanasia, but he insists that factors like inadequate
compensation, burdensome administrative and procedural
requirements and legal uncertainties are by far the most
common reasons for physician reluctance.12 Further, a number
of EAS practitioners have emphasized how much
personal satisfaction they get from providing the service,
describing it as "very rewarding"25 and extolling death by
lethal infusion as "dignified,"26 "peaceful"27 and "really,
really beautiful."28 Three prominent Belgian EAS
practitioners referred to lethally infusing patients as
"professional," one describing euthanasia as "deeply moving"
with a "life intensifying and sacred dimension," another
describing himself as"drained, but relieved and satisfied"
afterward.29 Finally, several Canadian physicians have
provided euthanasia or assisted suicide many times.30
This suggests that neither the prospect nor the
experience of personally killing a patient need be
distressing. However, the attitudes and inclinations of
committed euthanasia practitioners are not necessarily or
uniquely instructive with respect to those of physicians
generally. One must also consider the very different
reactions of physicians who did so, and later regretted it.
By February, 2017, eight months after legalization, 24
Ontario practitioners who had volunteered to provide
euthanasia/assisted suicide had permanently withdrawn;
30 had suspended participation. The CMA's Dr. Jeff Blackmer
acknowledged that this was occurring "at a systemic level."
He said some were firmly convinced of the value of the work,
but others "go through one experience and it's just
overwhelming, it's too difficult, and those are the ones who
say,'take my name off the list. I can't do any more.'"12
Dr. Blackmer noted that physicians who provide the
procedure for someone they know well may find the experience
"just too difficult and too traumatizing physiologically" to
do it again.31 Some believed they were prepared for the
experience, but found it "just too difficult," he said.
"They lost sleep and they didn't eat. They worried too much
Dr. Madeliene Li, an oncological psychiatrist who
developed the euthanasia/assisted suicide protocol for
Toronto's University Health Network, recognized the issue.
Assisted death, the polite euphemism
used to describe the act, is really a misnomer. Doctors
don't "assist" in a death; they are the active agents. "We
are doing euthanasia," says Li. "We are actively ending a
life. And it's very new to us."28
She reported having seen physicians accustomed to dealing
with death daily "break down after conducting a medically
In this context, it is relevant that a survey by the
Royal Dutch Medical Association (KNMG) found that 85% of
physicians who had arranged for euthanasia rated the
emotional strain associated with doing so at five out of ten
or higher, and 57% at eight out of ten or higher.33 Eric van
Wijlick, a KNMG policy advisor, said that physicians "find it very hard to carry out," he said. "On
average they do it once or twice a year and it's very
Euthanasia practitioners in the Netherlands are given a
day off with pay after each lethal infusion so that they can
"take care of themselves emotionally,"19 a practice
consistent with the findings of a 2007 study.
Researchers found that performing
euthanasia had "a major impact" on primary care physicians.
Moreover, as previously noted, it is reported that the Dutch
rule of thumb is that a physician should not perform
euthanasia more than four or five times a year.
"It's unnatural, what you're doing,"
says Ruben van Coevorden, a doctor in Amsterdam who has been
performing the procedure for 15 years. "You do it for a very
good reason, but it's an exceptional part of medicine. It
should not become routine."28
It seems, then, in some circumstances, some physicians
are willing to kill another human being and can do so
without suffering any apparent adverse effects, that a much
larger number cannot do so without experiencing considerable
stress, and that a certain number are unable to kill or
There is nothing new or remarkable about these
conclusions. They are consistent with the observations of
Belgian researchers published in 2012. They identified three
groups among Belgian physicians who did not object to
euthanasia: those "not reluctant to inject," those who dread
doing so and typically impose restrictive conditions, and
those who feel "incapable of injecting due to technical,
intuitive or moral inhibitions" and use strategies like
referral to avoid moral or emotional conflict.36
It is not unreasonable to think that most physicians —
like most people — are reluctant to personally kill other
people. Indeed, Dr. Li understates the case when she says
that "actively ending a life" — that is, killing someone —
is "very new" to physicians. It would, in fact, be a very
new experience for all but a handful of Canadians, though
physicians currently in practice might be disproportionately
inclined against it.
Overcoming reluctance to kill
We need not debate to what extent the reluctance may be
innate or acquired. The point here is that aversion to
killing is likely a significant factor making EAS practice
unattractive even to the group from which future EAS
practitioners are to be drawn — physicians who don't object
to the procedures in principle. If so, merely increasing
compensation is likely to have only a marginal effect.
Persuading them to join the ranks of EAS practitioners would
have to involve education, policies and practices that are
effective in overcoming their reluctance to kill.
This is by no means impossible, but implementing a public
policy of overcoming reluctance to kill would be
controversial and would entail risks: some readily
foreseeable, others less so. The more prudent and
practicable course might be the simplest and most realistic:
learning to live with the fact that most people are
reluctant to kill other people, and may well refuse to do
Learning to live with reluctance to kill and refusal to kill
may impede efforts to increase the number of EAS
practitioners. Here it is important to recall that
euthanasia and assisted suicide are typically provided by a
minority of physicians, and that the first year of
legalization in Canada demonstrates that the demand for the
procedures can be met by a relatively small number of
Concerns about patient access to euthanasia and assisted
suicide can be addressed without suppressing fundamental
freedoms. With this understood, and avoiding unrealistic
expectations (See Canada's
Summer of Discontent2), one can consider the claim
by Canadian EAS practitioners. They assert that reducing or eliminating
disincentives and increasing compensation will increase
physician participation in euthanasia and assisted suicide.
The claim is not unreasonable, but accepting and acting upon
it would involve practical difficulties.
Some of the requirements identified as "barriers" or
"disincentives" are essential elements in ethical medical
practice, while others are intended to be safeguards deemed
essential for the protection of patients. Reducing or dispensing with
any of them would thus involve reconsideration of serious
ethical and public policy issues.
With respect to compensation, what counts as "fair" is
determined internally in each province in relation to
compensation for all physicians in each jurisdiction. Other
things being equal, it would not be fair to reimburse EAS
practitioners for costs or pay them for services for which
their provincial colleagues are not compensated. Similarly,
fees for services provided by EAS practitioners must align
with fees for the same services provided by other physicians
in the same province. Since EAS advocates do not assert that
the act of killing a patient or assisting in suicide differs
significantly from other physician services — and even
insist that there is no significant difference — working all
of this out is a complex business.
Higher compensation could be justified, not by fairness,
but by a pragmatic need to attract physicians to an
unattractive specialty. However, this would be only
marginally effective if — as seems likely — the primary
reason for avoiding EAS practice is an aversion to killing
another human being. In that case, increasing the number of
EAS practitioners would entail significant efforts to
overcome physician reluctance to killing — a contentious
Should Canada increase physician compensation
and reduce or eliminate "disincentives" and "barriers"
alleged to discourage physicians from providing
The best answer at the moment seems to be, "It's
That is not sufficient reason to suppress freedom of
conscience among health care professionals.
1. Grant K.
Canadian doctors turn away from assisted dying over fees. The Globe
and Mail. 3 July, 2017. Accessed 2017-09-12.
2. Murphy S. Canada's
Summer of Discontent: Euthanasia practitioners warn of nationwide
"crisis." Protection of Conscience Project. 13 October, 2017.
3. Broeckaert B; Federatie Palliatieve Zorg
Federatie Palliatieve Zorg Vlaanderen pleit voor een palliatieve filter
in de euthanasieprocedure [Federation of Palliative Care Flanders
pleads for a palliative filter in the euthanasia procedure]. 21
September, 2001. Ethische Perspectieven (2001)11:3 171–76. Accessed
Broeckaert B, Jansenns R.
Palliative Care and Euthanasia: Belgian and Dutch Perspectives.
Ethical Perspectives (2002) 9:2-3 156–75; p. 17-9. Accessed 2017-10-12.
5. Federatie Palliatieve Zorg Vlaanderen.
met euthanasie en andere vormen van medisch begeleid sterven [Dealing
with euthanasia and other forms of medically assisted death]. 6
September, 2003. Protection of Conscience Project.
6. Vanden Berghe P, Mullie A, Desmet D, Huysmans
Assisted dying – the current situation in Flanders: euthanasia embedded
in palliative care. European Journal of Palliative Care (2013) 20:6.
7. Hamilton G.
Death by doctor: Controversial physician has made his name delivering
euthanasia when no one else will. National Post. 22 November, 2013.
8. Katholiek Universiteit Leuven, Campus
Prof. Dr. Wim Distelmans, Titularis leerstoel "Waardig Levenseinde" VUB,
Beknopt curriculum vitae. Accessed 2017-10-06.
9. "Allerhande vertragingsmanoeuvres, zoals het
wachten op de toelating van de ethische commissie van het ziekenhuis of
het verplicht doorlopen van alle mogelijkheden van palliatieve zorg – de
zogenaamde 'palliatieve filter' –, maken de toepassing van euthanasie in
de praktijk vaak onmogelijk of hebben als gevolg dat de patiënt al
'spontaan' of door zelfdoding is overleden." Distelmans W.
Eindelijk erkenning van ongeneeslijke, uitbehandelde patiënten in de
psychiatrie. DeMorgan. 25 April, 2017. Accessed 2017-09-02.
10. The exemption in Canadian criminal law
that permits physicians to provide euthanasia and assisted suicide
requires that a patient give informed consent "after having been
informed of the means that are available to relieve their suffering,
including palliative care." Criminal Code (R.S.C., 1985, c. C-46),
Carter v. Canada (Attorney General) 2015 SCC 5,  1 SCR 331,
para. 117 (Accessed 2017-09-18).
12. Kirkey S.
"Take my name
off the list, I can't do any more": Some doctors backing out of assisted
death. National Post. 26 February, 2017. Accessed
13. CBC News.
Lawyer and Police union President react to verdict in Const. James
Forcillo trial. 25 January, 2016. Accessed 2017-09-29.
14. Gee M.
Forcillo trial a warning: Police can't hide behind badges. The Globe
and Mail. 25 January, 2016. Accessed 2017-09-29.
15. Derosa K.
Island MD, citing low fee, halts assisted dying. Victoria Times
6 July, 2017. Accessed 2017-08-10.
16. See, for example, College of Physicians and
Surgeons of British Columbia.
File a complaint: General process: Responding to a patient complaint.
17. Criminal Code (R.S.C., 1985, c. C-46),
Section 227(3): Reasonable but mistaken belief. Accessed 2017-10-13.
18. Criminal Code (R.S.C., 1985, c. C-46),
Section 219(1): Criminal negligence. Accessed 2017-10-13.
19. McIntyre C.
Should doctors be paid a premium for assisting deaths? Macleans. 12 July, 2017. Accessed 2017-09-12.
20. Even eschewing the terms "euthanasia" and
"suicide." Hence, "Medical Assistance in Dying" — MAID.
21. Consider this exchange between Mr. Justice
Moldaver, one of the nine Supreme Court of Canada justices who ordered
the legalization of euthanasia and assisted suicide, and Joseph Arvay,
counsel for the plaintiffs.
Moldaver J: Here we are saying that a
doctor can actually take an active part in, in, in injecting
someone, for example, and killing them. Now, I see a
difference - maybe you don't, maybe we're dancing on the
head of a pin - I see a difference between that, and saying,
"Okay, we're going to stop the life support, and let the
patient die, the, the natural death." You don't seem to see
a distinction between that, but, and based on what you're
saying, it seems to me that the whole concept of unlawful
homicide is really not at play here.
Arvay: Well, I think, after Carter,
there is no distinction.
Supreme Court of Canada, Lee Carter, et al. v. Attorney
General of Canada, et al,
Webcast of Hearing on 2016-01-11, 169:09/205:01 -
169:36/205:09. Accessed 2016-08-28.
22. McIntyre, supra note 19, citing
Trachtenberg AJ, Manns B.
Cost analysis of medical
assistance in dying in Canada. CMAJ 2017;189(3):E101-E105.
doi:10.1503/cmaj.160650. Accessed 2017-10-06.
23. Picard A.
CMA poll finds rising support for medically assisted death. The
Globe and Mail. 23 August, 2017. Accessed 2017-09-30.
24. Downar J.
Dying With Dignity Canada. Accessed 2017-10-05.
25. Dr. Tim Holland of Nova Scotia. See Davie E.
Doctors raise alarm about long delays in getting paid for medically
assisted deaths. CBC News. 4 July, 2017. Accessed
26. Dr. Scott Anderson of Ontario. See Lupton A.
1 of only 2 London doctors willing to help their patients die.
CBC News. 4 July, 2017. Accessed 2017-09-14.
27. Dr. Ellen Wiebe of Vancouver. See Gulli C.
Assisted death is the new pro-choice: When does life—and a doctor's
duty—begin and end? Assisted dying is dredging up the big questions of
the abortion debate, for better or worse. Macleans. 28 May, 2016.
28. Dr. Gerald Ashe of Ontario. See Hune-Brown N.
How to End a Life. Toronto Life. 23 May, 2017. Accessed
29. Bernheim JL, Distelmans W, Mullie A, Ashby
Questions and Answers on the Belgian Model of Integral End-of-Life Care:
Experiment? Prototype?: "Eu-Euthanasia": The Close Historical, and
Evidently Synergistic, Relationship Between Palliative Care and
Euthanasia in Belgium: An Interview With a Doctor Involved in the Early
Development of Both and Two of His Successors. Journal of Bioethical
Inquiry. 2014;11:507-529. doi:10.1007/s11673-014-9554-z.
30. Dr. Ellen Wiebe of Vancouver, for
example, lethally infused 32 patients over a five month period in 2016.
The right to die on one's own terms: At 94, sick, tired and living
alone, "Dad got the death he wanted." National Post. 20 October,
2016. Accessed 2016-11-11.
Island MD, citing low fee, halts assisted dying. Victoria
Times Colonist. 6 July, 2017. Accessed 2017-08-10.
31. Tumilty R.
Doctors struggling to cope with assisted death: Ottawa has seen 28
people take their life with the help of a doctor since legislation came
into force. Vancouver Metro. 13 February, 2017. Accessed 2017-09-06.
32. Hune-Brown, supra note 28.
33. Federatie Medisch
Specialisten (FMS), Koninklijke Nederlandsche Maatschappij
tot bevordering der Geneeskunst (KNMG), Landelijke
Huisartsen Vereniging (LHV), Nederlands Huisartsen
Genootschap (NHG), Verenso.
Helder communiceren over euthanasie met de patiënt:
belevingsonderzoek arts en euthansie. Onderzoeksresultaten
[Clear communication about euthanasia with the patient:
physiotherapy and euthanasia. Research Results] 11-12-2014.
Rise in euthanasia requests sparks concern as criteria for
help widen. 3 July, 2015. Accessed 2017-10-11.
35. van Marjwik H, Haverkate I,
van Royen P.
Impact of euthanasia on primary care physicians in the
Netherlands. (2007) Palliative Medicine 21:609-614.
DOI:10.1177/0269216307082475. Accessed 2017-10-11.
36. Sercu M, Pype P, Christiaens
T, Grypdonck M, Derese A, Deveugele M.
practitioners prepared to end life on request in a country
where euthanasia is legalised? J Med Ethics. 2012;38:274–80.