POLICY: Performing Office-based Insured Procedures

PREAMBLE

The College of Physicians and Surgeons of Saskatchewan (CPSS) has the authority to set standards and policies that establish expectations for high quality care for patients regardless of whether the care provided is medically required or purely elective. The College is aware that many physicians perform various in-office insured procedures on their patients, including minor surgical procedures that do not require general anaesthesia. While some of this care is provided in non-hospital treatment facilities (NHTFs) and is therefore governed by Bylaw 26.1, many procedures are performed in non-institutional settings such as physician offices (a “clinic” or “clinics”). When providing this type of care, physicians are expected to comply with policies and procedures that maximize the likelihood of safe and effective patient care.

This policy is intended to apply to the office-based provision of insured procedures. Examples of such procedures include, but are not limited to:

Joint injections or aspirations;
Removal of “lumps and bumps”;
Mole removal;
Wart removal;
Vasectomy
Male infant circumcision; and
Insertion of intrauterine devices.

For the purpose of this policy, these and any other comparable insured procedures are referred to as a “procedure” or “procedures”.

POLICY

1. Knowledge, skills and performance

1.1 Physicians are responsible to recognize and work within the limits of their competence, and to refer a patient to another practitioner if they cannot safely meet the patient’s needs.

1.2 If the procedure to be performed was not part of the physician’s medical or specialty education and training, before carrying out the procedure for the first time, physicians must ensure they have sought and obtained CPSS approval for the appropriate scope of practice in accordance with CPSS policy “Scope of Practice Change”.

1.3 In addition to obtaining approval for scope of practice (if required), physicians must ensure they can safely perform the procedure, by undergoing training or seeking opportunities for supervised practice.

1.4 Physicians must take part in activities to maintain and develop their competence and performance across the full range of their practice.

1.5 Physicians are expected to practise evidence-informed medicine, and to maintain a level of understanding of the available evidence supporting the procedure as it evolves.

2. Safety and quality of care

2.1. Physicians must be satisfied that the environment for practice is safe, suitably equipped and staffed and complies with any relevant regulatory requirements, including the CPSS guideline “Infection Prevention and Control Guidelines for Clinical Office Practice” and policy “Responsibility for a Medical Practice”.

2.2. It is each physician’s responsibility to take reasonable steps to ensure that a system is in place for the proper maintenance, cleaning and calibration of equipment used in the medical care they provide.

2.3. Physicians must ensure the clinic has the capability to provide at a minimum Basic Life Support including appropriate training and certification for staff.

2.4. Physicians must be open and honest with patients in their care, or those close to them, and disclose if there is an adverse event. Physicians must be familiar and in compliance with the CPSS policy “Disclosure of Adverse Incidents”.

2.5. In the event of an adverse event, it is also the responsibility of the physician performing or authorizing the procedure to ensure a care plan is established to mitigate the effects of the adverse event in a satisfactory manner.

3. Seeking patients’ consent

3.1. Physicians must be familiar and in compliance with the CPSS policy “Informed Consent and Determining Capacity to Consent”, and the Canadian Medical Protective Association (CMPA) document “Consent: A guide for Canadian physicians” which has been accepted by the CPSS as an authoritative statement of the requirements for informed consent.

3.2. The physician who will be carrying out or supervising the procedure is responsible to discuss it with the patient and seek their consent. This responsibility must not be delegated or authorized to be performed by another medical practitioner unless the physician is confident the delegatee has the knowledge and experience to provide adequate explanations to the patient.

3.3. The physician must ensure patients have the information they want or need, including access to written information that supports continuity of care and includes relevant information about the medicines or devices used.

3.4. The physician must ensure the patient is provided sufficient time and information to permit them to make an informed decision.

3.5. The physician must consider the patient’s psychological needs and whether referral to another experienced professional colleague is appropriate.

3.6. The physician must exercise additional scrutiny and caution when considering requests for procedures on minors or those with reduced capacity.

4. Supervision of other providers

4.1. In general, physicians performing office-based insured procedures must perform those procedures themselves. There are some exceptions as set out in the Payment Schedule for Insured Services Provided by a Physician (“Payment Schedule”), in the section “Services Supervised by a Physician.”

4.2. If permitted pursuant to the Payment Schedule to supervise another provider, the physician is responsible to meet the requirements of the Payment Schedule.

4.3. Physicians must ensure that anyone they authorize to participate in the patient’s care has the appropriate knowledge, skill, and judgment to provide competent and safe care and that they are appropriately supervised.

4.4. Physicians must not authorize non-physician providers to perform any procedure that is considered the practice of medicine as defined in The Medical Profession Act, 1981 unless delegation is specifically authorized in the regulatory bylaws or the person is a regulated health professional acting within their recognized scope of practice.

5. Obligations of medical director or physician performing or supervising a procedure

5.1 If insured procedures are performed in a non-hospital treatment facility, the medical director of that facility is subject to the obligations enumerated in Bylaw 26.1.

5.2 If insured procedures are performed in a clinic that does not have a designated medical director, the physicians performing or supervising the procedures are responsible to:

provide adequate and effective direction and supervision of other providers;
ensure that:
the procedures employed in the clinic are selected and performed in accordance with current accepted medical practice;

6. Liability coverage

6.1. Any physician offering office-based insured procedures must ensure that the physician and any supervised providers have appropriate professional liability protection.

7. Communicating information about services offered

7.1. When advertising or promoting office-based insured procedures, including through the use of social media, physicians must follow the applicable provisions in the Bylaws (Part 7) and Code of Ethics.

7.2. Physicians must ensure the information being published is responsible, factual, does not exploit patients’ vulnerability or lack of medical knowledge, does not contain content that could reasonably be perceived as misleading or misinforming the public, and does not minimize or trivialize the risks of procedures or claim that procedures are risk free.

7.3. Physicians must not mislead about the likely results of a procedure. They must not falsely claim or imply that certain results are guaranteed from a procedure.