What is the standard of proof required to establish a future care item?

The standard of proof required to establish a claim for the cost of the future care item is the same as any other future pecuniary loss. The plaintiff must establish the real and substantial risk of a pecuniary loss. Such items do not need to be proved on the basis of medical necessity. The proper approach to this head of damages was set out by Madam Justice Garson in Gregory v. Insurance Corporation of British Columbia, 2011 BCCA 144 at para. 39: 39 I do not consider it necessary, in order for a plaintiff to successfully advance a future cost of care claim, that a physician testify to the medical necessity of each and every item of care that is claimed. But there must be some evidentiary link drawn between the physician’s assessment of pain, disability, and recommended treatment and the care recommended by a qualified health care professional… [Citation omitted]