7 points of service per 300,965 women of reproductive age
*
Women, aged 15-49 (reproductive age as defined by the WHO). Based on the 2021 Canadian census. Not all people who can get pregnant are women, but the data available only includes two gender categories.
publicly listed point of service offering both medication and procedural abortion*
publicly listed points of service*
Data on the points of service are based on Action Canada’s directory. These numbers are up to date, but not always complete as they do not include all primary care providers who prescribe medication abortion and the landscape of abortion access can change quickly.
Mifegymiso is fully covered for Manitoba residents with a valid health card.
Billing code
Billing codes are used by physicians to bill provincial/territorial health insurance plans for the different services that they provide. When there isn’t a billing code for medical abortion, physicians can be de-incentivized from providing it.
Telemedicine abortion has been found to be as safe and effective as medical abortions provided at clinics. Because telemedicine abortion allows patients to access care in their homes and often requires just one trip to a pharmacy or clinic, expanding its availability is critical to improving abortion access for people who live in rural communities, who can’t take time off work to go to appointments, or who are at risk of stigma or discrimination.
The Manitoba Physician’s Manual includes a billing code that physicians can use for virtual medical abortion care. Doctors Manitoba and Manitoba Health also agreed to introduce virtual visit tariffs equivalent to in-person rates during the COVID-19 pandemic that physicians can use when providing telemedicine. Manitoba Health has also approved these tariffs to be used for patients located in Nunavut, Saskatchewan, and northwestern Ontario.1 These tariffs have since been permanently extended.
The College of Physicians and Surgeons of Manitoba has a practice standard for virtual medicine that recognizes the “importance of virtual medicine for many patients living in some distant rural and remote areas, especially those residing in First Nations.” The College of Registered Nurses of Manitoba has a telepractice resource that states employer policies set expectations for telepractice.
Legislation, policies, and regulations
Access to abortion for minors
Under the Health Care Directives Act, it is presumed that a person who is 16 years of age or older has the capacity to make health care decisions. Minors under 16 years of age may consent to treatment where there is evidence to establish capacity, meaning they are able to understand the information that is relevant to making a decision and are able to appreciate the reasonably foreseeable consequences of a decision or lack of.
However, some physicians may require a parent or guardian’s permission for someone under the age of 18 to have an abortion.2 If a minor cannot or does not want to get permission from a parent or guardian, and are able to provide informed consent for themselves, a pregnancy counselor will refer them to a physician who does not require parental consent.3
Bubble zone legislation
Bubble zone legislation aims to prevent anti-abortion protestors from harassing people within the vicinity of a facility that provides abortion care. Even though criminalizing individual people will not effectively curb the larger anti-abortion movement, these laws can be effective in deterring anti-choice protestors from harassing providers and patients entering and exiting abortion clinics.
The Manitoba Safe Access to Abortion Services Act became law in June 2024 and came into effect in February 2025, with the goal of protecting patients and providers from harassment and intimidation. The law establishes 50-metre buffer zones around abortion facilities, as well as the residences of clinic workers, within which people are prohibited from protesting, demonstrating or picketing. Other facilities that provide abortion services can also request buffer zones.
Belief-based care denial
Although abortion is an essential medical service, physicians and nurse practitioners can refuse to provide abortion care due to their personal beliefs under current legislation and policies set by regulatory bodies. This practice is often referred to as “conscientious objection,” although a more accurate term may be “belief-based care denial.”
Physicians
In 2019, the College of Physicians and Surgeons of Manitoba adopted the Canadian Medical Association’s Code of Ethics and Professionalism, which does not require physicians to provide or refer for a service they object to based on personal beliefs. This means that a physician may deny a patient abortion care, and is not obligated to provide them a referral to another provider or clinic.
Nurse practitioners
The College of Registered Nurses of Manitoba released a document in 2019 titled Duty to Provide Care that obligates nurses to provide a timely referral to another provider in cases of belief-based care denial, and to follow up on that referral. It also states that “[t]he duty to provide care for a nurse with a conscientious objection does not include withholding client health care.”
In cases of belief-based care denial, the document states that it is a nurse’s duty to provide care that includes:
Acknowledging the client’s request and assuring the client that their request will be conveyed;
Informing both their supervisor and employer about the client’s request;
Making a timely referral, in good faith, to a non-objecting provider who is able to carry out the client’s request, and following up on that referral;
Maintaining a therapeutic relationship with the client;
Continuing to provide care unrelated to specific request;
Informing the employer about their conscientious objection; and
In accordance with professional standards and organizational policy, documenting in the client health record any request for information related to the client’s request, the interaction with the client, the care provided and/or any resources given to the client.
Excluded Services Regulation, Man Reg 46/93
Section 2(28) of the Excluded Services Regulation, under the Health Services Insurance Act CCSM, c H35, indicates that therapeutic abortions will not be covered under provincial medical insurance unless they are performed by a medical practitioner in one of the following locations:
In a hospital in Manitoba other than a private hospital licenced under The Private Hospitals Act;
In a hospital outside Manitoba that meets criteria set out in the Hospital Services Insurance and Administration Regulation made under the Act; or
In a facility approved by the minister. (Man Reg 46/93, s 2(28))4
Out-of-country medical policy
In some instances, patients may have to travel outside of the country to receive abortion care currently not available in Canada.
Manitoba Health has an Out-of-Province Medical Referral program for patients referred for insured health services not available in Manitoba. For a patient to be eligible for coverage for abortion care in the U.S. that is not available in Canada, a Manitoba specialist must write a letter to Manitoba Health and receive prior approval. If approved, the patient will receive 100% coverage.
Travel support
A patient traveling outside of Manitoba to access abortion care may be eligible for a transportation subsidy from Manitoba Health’s Out-of-Province Transportation Subsidy Program. The program limits subsidies to the round-trip cost of travel using one mode of transportation. For example, if a patient must take a bus to the airport in order to fly to their destination, Manitoba Health will cover the cost of the economy round-trip flight, but not the bus ticket.
In order to be eligible for a transportation subsidy, the specialist referring the patient for out-of-province care must apply for a transportation subsidy on their behalf. Travel costs for a travel companion may also be reimbursed if one is required for the patient’s well-being and safety during travel. Approval must be granted for services requested outside of Canada prior to the treatment occurring. Accommodations, meals, taxis, ambulance services, and other expenses are not covered.
What the law says
Manitoba’s Medical Services Insurance Regulation, which falls under the parent statute of the Health Services Insurance Act discusses out of country medical services for residents of Manitoba. Per section 7(2) of the Medical Services Insurance Regulation, if insured medical services are provided outside of Canada, the coverage provided will be up to but not exceeding the amount outlined in the Payments for Insured Medical Services Regulation. Further, section 7(2)(a) to (e) highlight what conditions are required for the insured medical service to be covered. For instance, the insured medical service will be covered if:
Required due to an accident or sudden attack of illness;
Could not in the opinion of the minister be adequately provided in Manitoba or elsewhere in Canada and are provided following a referral outside of Canada by a medical practitioner practicing in Manitoba specializing in the field;
Provided to a person named in an out of province certificate;
Are provided to an insured person, including insured dependents, if any, temporarily employed outside Manitoba, or
Are provided to an insured person and his or her dependents, if any, temporarily absent for the purpose of furthering his or her education.
If the requirements under section 7(2) have not been met, section 7(3) notes that no payment shall be made.
Section 7(4) outlines that once an application is received, the minister may pay amounts that are greater than the amounts payable for the respective services which meet the requirements set out in clause (2)(b) above if the minister considers it “fair and reasonable” considering the insured services provided and the financial circumstances of the affected individual.
Lastly, section 7(5) outlines that instead of making payments directly to the insured person, the minister may pay the medical practitioner who provided the insured services given the insured person has not paid the fees for the services provided.
Two women who had abortions at Winnipeg’s Morgentaler Clinic initiated a class action against the provincial government. Manitoba Regulation 46/93 excluded from the Manitoba Health Services Insurance Plan therapeutic abortion that is not performed in a hospital. As a result, the women had to pay for their own abortions at the non-funded clinic after they were told they would have to wait up to two months for a hospital abortion. They challenged the constitutionality of the provincial law and regulation that prevented government funding for abortions outside of public hospitals.
In December 2004, the Court of Queen’s Bench of Manitoba found that the legislation violated section 7 of the Charter because it forced women to wait for a therapeutic abortion in an overburdened, publicly-funded health care system, which is a gross violation of the right of to both liberty and security of the person. The Court also found that the legislation violated section 2(a) (freedom of conscience) and section 15 (equality rights).
At the appellate level, the Court allowed the appeal against the summary judgement in favour of the plaintiffs.