Accepting Delegation of Controlled Acts authorized to Naturopaths

We’ve received several questions about whether Registrants can accept a delegation of prescribing and administering intravenous infusion therapy. These questions offer a great opportunity for us to provide some clarity around these controlled acts.

Delegation of a controlled act, by definition, means that a regulated health professional who is authorized by law to perform the controlled act is passing that authorization on to another person who is not authorized by law to perform that controlled act.

By extension, accepting a delegation of a controlled act can only occur when the person accepting the delegation is not authorized by law to perform that controlled act. A regulated health professional who is asking another regulated health professional to perform a controlled act that both are authorized by law to perform is referring a patient from one to the other.

Any time a person wishes to perform a controlled act under delegation, one of the basic questions is whether they have the knowledge, skill and judgement to perform it. Knowledge, skill and judgement is determined by the profession’s and/or the individual’s education and training.

The General Regulation made under the Naturopathy Act, 2007 sets out the education and training required to prescribe, dispense, compound or sell a drug and to administer a substance by injection or inhalation. That education and training is the successful completion of a course and examination set or approved by the Council of the College. The Council has established that the Ontario Therapeutic Prescribing Course and Examination are the required education and training.

When it comes to compounding for or the administration of a substance by IVIT, the General Regulation also sets out the education and training necessary to perform this procedure, which is an extension of the controlled act of injecting a substance. That education and training is the successful completion of a course and examination set or approved by the Council. There are presently two courses approved by the Council, one from the OAND and the other from CCNM. The examination required is one that has been set by the Council and is delivered by the College twice a year.

Here’s the crux of the matter: the Regulation tells us what is needed to perform these controlled acts. The Naturopathy Act, 2007 and the General Regulation also say that if you meet these requirements, you are authorized to perform these controlled acts. In essence, you cannot accept a delegation of these controlled acts unless you meet these educational and training requirements and, if you do meet them, you do not need a delegation to perform them on patients.

It is for this reason that an ND cannot accept a delegation for prescribing, dispensing, compounding or selling a drug and for administering a substance by inhalation or injection, including IVIT. To accept the delegation, you need the approved education and training and once you have that education and training, you no longer need a delegation to do it.

With that said, there are other requirements surrounding both performing a controlled act and delegation of controlled acts.

Do you find the requirements about delegating and accepting a delegation confusing? Watch for the upcoming Regulatory Education Program session on delegation!