Consultation Opportunity
Bylaws relating to Bioactive Agents (Providing Directives to Registered Nurses, Ordering/Supplying for Administration by another Person)
The Council of the College has approved amendments to its bylaws in principle for the purpose of consultation. The amendments relate to bioactive agents (Botox® and dermal fillers) and the expectations of physicians who interact with others who administer those agents.
The Council directed that the proposed bylaws be circulated to physicians and placed on the website to seek feedback. The Council will consider the feedback it receives when it considers whether to amend the existing bylaws, and if so, what those amendments will be, at its November meeting
Background
The definition of the practice of medicine found at section 79 of The Medical Profession Act, 1981 is very broad. The Act prohibits individuals from engaging in the practice of medicine unless they are licensed physicians. There are exceptions, including the ability of the College to adopt bylaws permitting regulated health professionals to engage in activities that constitute the practice of medicine.
CPSS regulatory bylaw 23.3 permits physicians to delegate certain acts that constitute the practice of medicine to registered nurses (RNs). The current bylaw 23.3(a)(vi) permits physicians to delegate the injection of bioactive agents to a RN but only when the physician has first assessed the patient and established a treatment plan for the injection.
It is recognized that there will be overlap in some areas between the scope of practice of physicians and the scope of practice of other regulated health professionals. There is also a recognition that scopes of practice may evolve over time, depending on training and experience within a regulated health profession.
Recently, the College of Registered Nurses of Saskatchewan (CRNS) has recognized a broader scope of practice for RNs with the required training and experience, including assessing patients for eligibility to receive injections of bioactive agents and injecting bioactive agents. Because this can now be within the recognized scope of practice of RNs, provided they meet CRNS requirements, it is no longer appropriate for it to be addressed in the delegation bylaw and the CRNS requested that the CPSS Council rescind that bylaw.
One of the CRNS requirements for RNs to practice under this expanded scope of practice is that they obtain a directive from a physician or Nurse Practitioner permitting them to inject bioactive agents. The Council appointed a committee to consider the expectations on physicians when providing this directive to RNs.
At the September meeting, the Council approved in principle several bylaw amendments for the purpose of consultation:
- 1. Rescinding bylaw 23.3(a)(vi) permitting delegation of the injection of bioactive agents to RNs (with incidental amended paragraph numbering);
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- 2. Adding bylaw 23.5 establishing expectations of physicians when providing a directive to RNs authorizing the injection of bioactive agents; and
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- 3. Adding bylaw 23.6 establishing expectations of physicians when ordering/supplying bioactive agents for administration by another person.
Click here for draft version containing proposed amendments.
Consultation Request
The Council anticipates that it will consider feedback from
stakeholders, including members of the profession, at its meeting on November
25 and 26. The Council would like to hear from you! If you have concerns with the proposed policy,
it would be helpful if you explain the reasons for those concerns.
How to Respond
In order for the College to consider feedback and correlate feedback for the Council in time for the next Council meeting, all feedback should be provided to the College no later than Friday, November 4, 2022.
Please complete the survey linked below. Feedback can also be provided to communications@cps.sk.ca.