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


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. 1. Rescinding bylaw 23.3(a)(vi) permitting delegation of the injection of bioactive agents to RNs (with incidental amended paragraph numbering);
  3. 2. Adding bylaw 23.5 establishing expectations of physicians when providing a directive to RNs authorizing the injection of bioactive agents; and
  5. 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


MEDICAL ASSISTANCE IN DYING – Draft Policy for Saskatchewan



The Canadian Government has adopted legislation to regulate medical assistance in dying (MAID). That legislation authorized Canadian physicians, and nurse practitioners in some provinces, to assess whether patients meet the requirements for medical assistance in dying and, if they do, to either administer the pharmaceutical agents that will cause the patient’s death, or prescribe pharmaceutical agents that will cause the patient’s death.

While the legislation established a number of requirements for medical assistance in dying to occur, some details are not addressed in the legislation. That is left for the provinces or regulatory bodies to address.

The Government of Saskatchewan established a provincial working group with broad representation from a number of groups to assist in developing appropriate standards for physicians and nurse practitioners who deal with medical assistance in dying.

At its September, 2016 meeting, the Council of the College of Physicians and Surgeons of Saskatchewan adopted a policy that addressed medical assistance in dying which was provided in hospitals or similar settings. That policy described the requirements that physicians must meet to comply with Canadian legislation and established standards for the administration of pharmaceutical agents that are intended to cause the patient’s death.

The provincial working group subsequently provided recommendations related to patient self-administration. The Council of the College met on January 20, 2017 and approved those recommendations in principle for the purpose of consulting physicians and the public. The Council will consider responses to this consultation request at its meeting on March 25 and expects to adopt a final policy on that date.


Subject of Consultation

The Council of the College seeks your input specifically on the recommendations related to patient self-administration as outlined below.


Summary of the recommendations from the provincial working group

The working group addressed two primary issues:

1. Should a physician who prescribes the pharmaceutical agents that are intended to cause the patient’s death be required to be immediately available to complete administration by intravenous agents if something goes wrong with the patient’s self-administration?

2. Should there be a process which approves physicians who wish to participate in medical assistance in dying? If so, who should do that and what should be the process?

The Council agreed with the working committee’s recommendations when it approved in principle the redraft of the College policy. The draft of the College’s Medical Assistance in Dying Policy states that:

1. A physician who prescribes pharmaceutical agents for self-administration should receive those pharmaceutical agents from a pharmacy and personally deliver the pharmaceutical agents to the patient at a time that the patient and the physician agree the patient will self-administer. The physician should be required to be immediately available, with the pharmaceutical agents and equipment necessary to administer medical assistance in dying by intravenous means if patient self-administration fails.

2. A physician who will assess a patient to determine whether the patient meets the criteria to receive medical assistance in dying or who prescribes or administers the pharmaceutical agents to cause the patient’s death must be approved by the College to do so if the medical assistance in dying will occur in a place that is not a Regional Health Authority Facility.

The Council was aware that both issues are controversial and that individuals have expressed inconsistent positions on these two issues. The Council’s perspective in approving in principle the policy is that:

1. We currently do not have sufficient information to know what risks exist that a patient may not be able to complete self-administration of pharmaceutical agents to cause death. There are reports of patients who have been unable to complete swallowing pharmaceutical agents or who have vomited after partially consuming the pharmaceutical agents. If no physician is present to complete medical assistance in dying in such circumstances, the consequences may be catastrophic for the patient and the patient’s family.

2. This is an issue to be revisited when better information is available, which should be not more than one year after a policy is adopted, to determine if there should be changes to the policy. Such a review should be based upon the best available evidence of the experience with patient self-administration. That review should also consider whether the requirement that a physician be available is a barrier to patient access to medical assistance in dying.

3. The College currently has a requirement that physicians cannot change their scope of practice without approval from the College. Assessing patients for eligibility for medical assistance in dying is a change of a physician’s scope of practice. The College expects that in situations where Regional Health Authorities have approved physicians to assess patients for eligibility for medical assistance in dying, or have approved physicians to administer medical assistance in dying, that approval will be sufficient for the College to approve the change in scope of practice.


Related Documents

Provincial Committee Report
Redrafted Policy - Medical Assistance in Dying  (complete version)

How to Respond 

You may provide your response by following the link below, or send an e-mail to  

Council will review and consider all responses at its regular meeting on March 24-25, 2017.

Deadline for responses: March 8, 201