Progress on the report of the Advisory Panel on Healthcare Innovation (2015) for Canada is limited. While Manns et al. (2025) advocate for a national innovation agency and fund, their analysis underemphasizes the catalytic role of health data infrastructure as the foundation of an innovation engine. Consequently, Canada has not cultivated the strategic infrastructure necessary to enable spread and scale. This commentary argues that pan-Canadian health data ecosystems are foundational to scaling innovation. By prioritizing data liquidity, real-world evidence generation and data stewardship, Canada can transform its “perpetual pilot projects” into a learning health system that accelerates the scale and spread of value-based innovations.

Introduction

Ten years ago, the Advisory Panel on Healthcare Innovation (2015) diagnosed Canada's healthcare malaise: fragmentation, risk aversion and a “country of perpetual pilot projects.” A decade later, Manns et al.'s (2025) assessment surfaces a sobering reality of having achieved minimal progress on core recommendations, evidenced by worsening wait times and a persistent inability to scale innovative solutions. Their call for a National Healthcare Innovation Agency and Fund is well thought out, but unfortunately, will not achieve its intended aim because it does not address the fundamental barrier behind Canada's innovation deficit. The reason, I contend, is that Canada's innovation deficit stems from a deeper, unaddressed root cause: treating health data as a byproduct of care rather than a significant sovereign natural resource to be cultivated to not only transform the lives of patients and families, but also to be an economic driver for the broader benefit to Canadians. As a result, Canada did not build the strategic infrastructure across the country, which would enable the scale of adoption necessary to positively disrupt a Canadian health system that is $399 billion (Canadian Institute for Health Information 2025) in size and growing. Without data liquidity and pan-Canadian data stewardship and governance to build the pan-Canadian foundation for a sovereign health data infrastructure, even a well-funded agency risks replicating past stagnation.

The Innovation Chasm

Manns et al. (2025) document Canada's innovation paralysis: disjointed electronic health records, lost referrals and provinces operating as isolated self-contained domains. Central intake/triage – a proven model – fails nationally due to incompatible systems and fee-for-service disincentives. However, these symptoms share a common root, lack of integrated, interoperable and standardized health data:

• Fragmentation: Inefficient referrals, redundant tests and delayed diagnoses cost billions annually. The panel's cited 30% inappropriate care rate is exacerbated by data opacity – clinicians lack access to prior records, while patients cannot track referrals.
• Accountability void: Without integrated, interoperable standardized data, provinces cannot benchmark performance or enforce value-based procurement. Through the Canadian Institute for Health Information (CIHI), Canada already has a pan-Canadian health data content framework that includes data standards, common data architecture and core data for interoperability. While CIHI partners with jurisdictions and vendors, adoption remains voluntary. (Note that former Bill C-72 is Federal legislation that aimed to facilitate interoperability but was not passed.)
• Missed economic opportunities: Canada's medical device and pharmaceutical sectors, as a share of the global market, stagnate at less than 1% partly because Canadian innovators cannot access real-world data to validate products. Contrast Israel's national health database, which is a magnet for AI because it contains a comprehensive, digitized record of its citizens' medical data, with de-identified data used by researchers, companies, and start-ups to develop and advance AI-driven applications for medical research, diagnosis, and treatment. Market opportunities are significant, with global health spending on clinical trials exceeding USD $150 billion (Razak and Verma 2025). Yet Canada's share of clinical trials has dropped by 50% since 2010 (Razak and Verma 2025). What is critical to understand is that missed economic opportunities end up harming patients, as Canadians do not therefore have first access to effective therapies and interventions, while patients in those other countries do.

Data are not merely “technology” but the connective tissue enabling patient empowerment, improved clinical care and coordination, workforce modernization and economic resiliency.

The Case for Strategic Data Infrastructure: From Cost Centre to Growth Engine

In addition to the fact that a strategic data infrastructure would serve to remedy the issues outlined by Manns et al. (2025), there is also the argument for how it can enable health system sustainability. Hence, there is an economic imperative as well. Healthcare innovation is often framed as a cost challenge. Manns et al. (2025) note that health spending rose to 12.4% of gross domestic product (GDP) since 2015. However, the aim should be both to decrease the percentage share of GDP while improving the quality of care (i.e., improve technical efficiency) and to contribute to improve GDP itself (i.e., a stronger economy). Both are made feasible through a pan-Canadian health data infrastructure. Healthier patients equate to a healthier population that serves to decrease the burden on health services, resulting in the easing of expenditure growth (via improved technical efficiency). But innovation can contribute to improving the economy, which can support, through reinvestment, sustaining health systems as well.

• Exportable solutions: Canada has the most valuable health dataset in the world, stemming from the diversity of its population and a public pay model that captures the entire population. Canadian data can therefore produce more meaningful insights while being more generalizable than any other health dataset on earth (Razak and Verma 2025). Consider the fact that AI platforms in health developed in Canada will directly benefit Canadian patients, but can also benefit patients around the globe. Hence, Canadian innovation can be commercialized globally, resulting in a stronger Canadian economy and a greater tax base that can be reinvested to sustain Canadian health systems. It is important to note that the ability to responsibly use Canadian data for economic growth will require public acceptance (i.e., social licence). Canadians must be confident their data will never be exploited but instead leveraged in ways that return value directly to them and the health system.
• Security of Canadian supply chains: The reliability of health supply chains is paramount to national security. Yet approximately 70% of Canada's medical supplies are imported from other countries, with 40% imported from the US (ISED 2025). From this perspective, Canada must view health data as a sovereign natural resource and build an infrastructure that fosters innovation, which leads to the proliferation of Canadian suppliers who, over time, make Canada less reliant on foreign actors. Simply put, under the reality that Canada must purchase supplies from somewhere, do we want to buy Canadian or rely on others? Only one answer to this question leads to improving our national security on supply chains for Canadian health systems.
• Overall value: Altogether, the value proposition resulting from what is outlined earlier will be significant. A conservative estimate of the value of achieving data interoperability, applying AI and other data technologies enabled by the availability of high-quality data that advances uses for academic and commercial research, could create benefits valued in excess of $9.4 billion per year for Canada (Mullie et al. 2025). Note that this estimate serves as a theoretical minimum (due to data limitations), and the actual value is undoubtedly greater.

Reframing the Solution as: A Need for a Pan-Canadian Health Data Infrastructure

Manns et al. (2025) provide a blueprint for resuscitating Canadian healthcare innovation through a national innovation agency and fund. However, without data liquidity and pan-Canadian data stewardship and governance to build a pan-Canadian foundation for a sovereign health data infrastructure, even a well-funded innovation agency risks replicating past stagnation.

To avoid replicating the past, Canada must build an integrated, interoperable and standardized health data infrastructure. Places to start could be:

1. National interoperability standards with teeth: Canada already has a pan-Canadian health data content framework. Its adoption, including the core data for interoperability, must not be voluntary. Furthermore, Canada should mandate fast healthcare interoperability resources-based application programming interfaces for all public systems. Note that the passing of Bill C-72 (interoperability of health information technology) would have been a significant first domino in this transformation for Canada, however it was not passed.
2. Pan-Canadian data stewardship and governance: The size of the Canadian health system is $399 billion and growing. It therefore requires a critical mass from a one Canada mindset and social licence to achieve the scale of change necessary to make a meaningful difference. It requires a one Canada mindset to compete globally in the emerging health AI industry. Again, diversity and inclusivity are what make Canada's data the most valuable in the world, but it requires all of Canada, not some of Canada; especially when you consider the scale of competitor countries such as the UK (67M) or the European Union (450M). Canada needs a mechanism to be able to formally work across provinces and territories on data infrastructure and stewardship issues such as modernizing privacy legislation, AI governance, advancing the availability/quality of data needed for clinical care/improving the health system and patient access to their data. In a positive step forward, with the support of the conference of Deputy Ministers of Health, CIHI is establishing a pan-Canadian data stewardship framework and governance model for Canada.
3. Safeguarding Canadian health data sovereignty: Having the most valuable health dataset in the world must be protected from foreign use and be leveraged for Canadian innovation to produce a health information economy through emerging industries such as Health AI. Recommendations on how to further safeguard the sovereignty of Canadian health data have been outlined by Geist et al. (2025).
4. Enabling patient data sovereignty: Patient engagement remains tokenistic without real access and control. The proliferation of health data is exponential with the advent of wearables and other technologies. More data are therefore produced in the private sector. All patient data, public and private, ought to be made available to the patient and, as its owner, can be made available for broader use and benefits to society as outlined in this commentary. Paramount will be embedding mechanisms for social licence through patient participation and visible demonstration of benefit. This is central to sustaining legitimacy and adoption at scale.

In conclusion, Canada has existing institutions and agencies that should be leveraged (Wolfson in press), and adding another (even with a mandate for innovation) will not create the transformational change necessary. By making data its engine and building the strategic infrastructure to enable change at scale, Canada can transform healthcare from a fiscal liability into a source of national pride and prosperity.

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