The Health Care Accessibility Act of 1986, also known as Bill 94, brought Ontario’s health policy into line with that of the Canada Health Act of 1984 by banning extra-billing. Under the Canada Health Act, any province that permitted doctors to bill patients above the amount on the provincial fee schedule would lose the corresponding amount of federal funding for medicare. Section 12 of the Canada Health Act also stated that a province’s health care insurance plan must provide for “reasonable compensation for all insured health services rendered by medical practitioners or dentists.” This allowed Ontario doctors to argue that the provincial government had no right to determine what doctors could charge for their services either within or outside medicare, as long as it was reasonable, and they attempted to persuade the public and Liberal Premier David Peterson that it was also unconstitutional. According to Dr. Barry Adams, Past President of the Ontario Medical Association (OMA), in response Peterson “told the media he would concede to binding arbitration for disputes on fees, but he never told us that. In cases where no contract could be negotiated between OMA and government, then he said we could all opt out” (A. Chouinard, “Beyond Extra-Billing . . . More Disputes,” CMAJ 134 [May 15, 1986]: 1171). Peterson’s government then proceeded to pass Bill 94. Although the doctors went on strike from June 12 to July 6, 1986, Bill 94 was implemented, and extra-billing ended in Ontario.