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. 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.
  2.  
  3. 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.
  4.  
  5. 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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  7. 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.
  8.  
  9. 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. 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).
  2.  
  3. 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.

 

MEDICAL ASSISTANCE IN DYING – Draft Policy for Saskatchewan

 

Background

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 communications@cps.sk.ca.  

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

Deadline for responses: March 8, 201