DocTalk 2022 - Volume 9 Issue 4
Changes to Regulatory Bylaws
December 2022

The College’s Regulatory Bylaws establish expectations for physicians and for the College.  They establish practice standards, establish a Code of Ethics  and Code of Conduct, define certain forms of conduct as unprofessional and establish requirements for licensure.

There were
 no changes to College regulatory bylaws since the last edition of the Newsletter.


* Bylaw changes come into effect once they are approved by the Government of Saskatchewan and published in the Saskatchewan Gazette.

 Policy, Standard and Guideline Updates
December 2022

Council regularly reviews the policies, guidelines and standards which are then made available on the College’s website

Since the last edition of DocTalk, Council has updated 
7 policies/guidelines/standards and rescinded one guideline. 

*Click on each title below to view the complete version of the policy, standard or guideline.

UPDATED POLICY – Completion of Third Party Forms and Certification of Work Absence/Accommodation due to Illness or Injury

At its November meeting after considering all feedback provided by stakeholders and the committee’s recommended amendments, the Council approved an amended policy.  The amended policy is more concise than the previous version, as there is an intention to create a ‘Guidance’ document to supplement the policy.  The Guidance document will include some of the information that has been removed from the previous policy. 

In addition to a modified title and reformatting, other amendments to this policy include a specific focus on the following issues:

  1. a) The requirement for consent specific to the request;
  2. b) Timing of a response (within 30 days of receiving the request or in compliance with legislated expectations, such as in relation to WCB or SGI requests);
  3. c) Fees should be communicated in advance, and must be fair and reasonable reflecting the work required;
  4. d) The expectation that forms/reports should be based on an objective exam and should be formulated within the physician’s current skill and knowledge; and
  5. e) The distinction between discretionary or non-discretionary forms/reports and how this distinction impacts physicians’ obligation to provide the report.

The amended policy was assigned a three-year sunset review date.

NEW POLICY (formerly a guideline) – Medical Examinations by Non-Treating Physicians

At its November meeting, Council considered all feedback provided by stakeholders as well as the committee’s recommendations.  It then approved an amended policy with a sunset review date of three years.  This document was previously a guideline, but Council accepted the committee’s recommendation that a pared-down version of the document should become a policy (with the consequent expectations of compliance).  The policy was reformatted to be more consistent with recent CPSS policy drafting principles.  Similar to the ‘Completing Medical Forms’ policy, the intention is to create a ‘Guidance’ document to contain additional information that may be of assistance to those physicians providing non-treating medical examinations (“NTME”). 

The policy focuses on specific issues including:

  1. a) Expectations of physicians prior to accepting a request to conduct an NTME, including addressing any real, perceived or potential conflict of interest;
  2. b) Expectation that physicians must only accept a request to conduct an NTME if they have an active licence, the matter falls within their scope of practice and area of competency, and they have the requisite knowledge, skill and judgment to perform the NTME;
  3. c) Expectations prior to the physician performing the NTME, including ensuring the claimant has provided consent, conveying certain information to the claimant, agreeing on the fee structure and payment terms, and notifying the requesting third party if any of the questions posed fall outside of the physician’s scope of practice or area of competency;
  4. d) Expectations of physicians completing NTMEs, including the obligation to comply with any legal requirements regarding the presence of observers and recordings;
  5. e) Expectations of physicians in the event of a clinically significant finding during the NTME.

Opioid Agonist Therapy Standards and Guidelines for the Treatment of Opioid Use Disorder
UPDATED POLICY – Opioid Agonist Therapy Prescribing (3. Buprenorphine/naloxone Prescribing for MAINTAINING (Non-Initiating) Physicians for OPIOID USE DISORDER)

Both the ‘standards and guidelines’ and the above-noted policy were amended to address an urgent request of Council from initiating OAT prescribers.  The amendment, which applies only to Buprenorphine/naloxone maintaining (non-initiating) prescribers for opioid use disorder in patients who are stable, removes the mandatory requirement for physicians to complete an OAT workshop/course recognized by the CPSS prior to being authorized by the Registrar to prescribe; instead, the workshop/course is now strongly recommended.  For further details of the amendments and the impetus for this change, please see the article Amendments to OAT Standards and Guidelines/Policy re Buprenorphine/naloxone prescribing for MAINTAINING (Non-Initiating) Physicians for Opioid Use Disorder in this issue.

UPDATED POLICY – Performing Office-based Non-Insured Procedures

At its November meeting after considering feedback from stakeholders, Council approved an updated policy “Performing Office-based Non-Insured Procedures.”  A few of the more substantive amendments are listed below:   

  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. 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 bylaw 23.5[1].
  3. 3) Paragraph 4.3 was amended to include the possibility that ‘available to attend’ may include virtual or in-person care depending on the circumstances.
  4. 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. This is a more general obligation of physicians who are affiliated with cosmetic clinics to be physically present in the clinic as required to fulfil their obligations pursuant to this policy and the relevant bylaws.
  5. 5) Paragraph 5.2 was also amended to tie in bylaws 23.3, 23.4, 23.5[2] and 23.6[3] 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.

The amended policy was assigned a three-year sunset review date.

[1] Approved by Council but not yet in force.

[2] Approved by Council but not yet in force.

[3] Approved by Council but not yet in force.

POLICY – Performing Office-based Insured Procedures

At its November meeting Council considered all feedback provided by stakeholders and then approved an updated policy “Performing Office-based Insured Procedures.”  There was minimal substantive change to this policy, including:   

  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. 2) Section 4 was amended and renamed to limit it to supervision of other providers, as opposed to authorization of other providers (as included in the previous version).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 amended policy was assigned a three-year sunset review date.

UPDATED POLICY – Website Terms of Use and Privacy Policy

The policy was approved with no changes and assigned a sunset review date of three years.