Consultation Opportunity
Performing Office-based Insured Procedures / Performing Office-based Non-insured Procedures
The Council of the College has approved amendments to two policies, Performing Office-Based Insured Procedures and Performing Office-Based Non-insured Procedures in principle for the purpose of consultation.
The Council directed that the proposed amended policies be circulated to physicians and placed on the website to seek feedback. The Council will consider the feedback it receives when it considers the policies at its November meeting.
These documents are policies. The College has accepted the following statement in relation to policies:
Policies contain requirements set by the Council of the College to supplement the Act and Bylaws. Policies are formal positions of the College in relation to defined areas of practice with which members must comply. The Council also sets policies on registration, administration, and governance of the College.
Background
The Council adopted these policies in September 2018, and they reached their sunset dates in September 2021. The Council appointed a committee to consider these policies and the related issue of proposed bylaw amendments addressing bioactive agents (see Bylaw Consultation). In the course of its work, the committee also considered the Standard of Practice “Performing Office Based Procedures” recently adopted by the College of Physicians and Surgeons of Manitoba.
At the September 2022 meeting, the Council considered the committee’s report and approved in principle a number of amendments to the policies including the following:
Performing Office-Based Non-insured Procedures
- 1. Paragraph 4.1 was added, requiring that a physician be identified as most responsible for care for every non-insured procedure performed in a clinic with which the physician is affiliated.This was felt to be appropriate in the interests of patient safety as it will require oversight by physicians who choose to enter into arrangements with cosmetic clinics, particularly those operated by non-physicians.
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- 2. Paragraph 4.2 was amended to recognize that there are situations where another individual is permitted to take on the role of assessing patients, and therefore exceptions to a physician’s personal responsibility to assess each patient. These are situations where the care has been delegated pursuant to bylaw 23.3 or 23.4, or where a directive has been provided to a RN pursuant to the proposed bylaw 23.5.
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- 3. Paragraph 4.3 was amended to include the possibility that ‘available to attend’ may include virtual or in-person care.
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- 4. Paragraph 5.2 was amended to include the expectation that a physician performing, authorizing or supervising the procedures must be in the clinic for “sufficient time” to ensure their obligations are met.
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- 5. Paragraph 5.2 was also amended to tie in bylaws 23.3, 23.4, 23.5 and 23.6 to remind physicians that they cannot authorize non-physician providers or order/supply bioactive agents for others unless the requirements of the policy and the relevant bylaws are met.
Performing Office-Based Insured Procedures
- 1. Paragraph 1.5 was added to reference the expectation that physicians practise evidence-informed medicine (to mirror the expectation in the Non-insured procedures policy).
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- 2. Section 4 was amended and renamed to limit it to supervision of other providers, as opposed to authorization of other providers. There was a recognition that there would be very limited circumstances in which a physician could authorize non-physician providers to perform insured procedures. The amendment references the Physician Payment Schedule, as it specifically identifies those circumstances and the expectations on physicians seeking to bill for supervised services.
The previous versions of the policies are accessible on the CPSS website:
Performing Office-Based Insured Procedures
Performing Office-Based Non-insured Procedures
Click below for the amended policies as approved in principle:
Performing Office-Based Insured Procedures - approved in principle for consultation
Performing Office-Based Non-insured Procedures - approved in principle for consultation
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.