Introduction

The College of Naturopaths of Ontario is considering a program to annually collect additional data from individual Registrants relating to the Standard of Practice for Therapeutic Prescribing, which includes the controlled acts of prescribing, dispensing, compounding and selling drugs, as well as administering substances by injection and inhalation.

Though this matter is actively under consideration, no decisions to proceed to collect the data have been made at this time. The College is presently seeking feedback from its Registrants, system partners, stakeholders and the public.

This discussion paper is a part of the College’s augmented Consultation Program through which the College will actively engage stakeholders, system partners, and Registrants on topics where future changes are being contemplated or presently being proposed.

Proposal

The College is proposing to collect data from each individual Registrant who has met the Standard of Practice for Therapeutic Prescribing. The purpose of collecting this data is outlined in the sections of this consultation below.

Prescribing, Dispensing, Compounding and Selling Drugs
The College is considering asking Registrants to submit the following data related to prescribing, dispensing, compounding or selling drugs in their individual practices, including all practice locations:

• Number of drugs prescribed to patients,
• Number of drugs dispensed to patients,
• Number of drugs compounded for patients,
• Number of drugs sold to patients,
• Number of Adverse Occurrences when a patient has been prescribed, dispensed, compounded or sold a drug. An adverse occurrence would be any of the following events if they are known:
  • Patient referred to emergency services within 5 days,
  • An emergency drug had to be administered to the patient,
  • Patient subsequently diagnosed with shock or convulsions within 5 days,
  • Patient’s condition did not improve or worsened,
  • An unscheduled treatment had to be provided to the patient,
  • Patient had adverse drug reaction.
• From the following list, which types of adverse occurrences have been encountered in your practice (see list in prior bullet),
• Conditions that emerged requiring an unscheduled treatment (see additional data sets below for details), and
• Types of adverse drug reactions encountered, if applicable (see additional data sets below for details).

Administering a substance by Injection
The College is considering asking Registrants to submit the following data related to administering a substance by injection (non-IVIT), from their individual practices, including all practice locations:

• Number of injections administered to patients,
• Number of patients who experience an Adverse Occurrence (see above for definition of adverse occurrences),
• Types of Adverse Occurrences encountered (see above for definition of adverse occurrences),
• Type of infection encountered, if applicable (see additional data sets below for details),
• Conditions for which an unscheduled treatment was required, if applicable (see additional data sets below for details), and
• Type of adverse substance reactions encountered (see additional data sets below for details).

Administering a substance by Inhalation|
The College is considering asking Registrants to submit the following data related to administering a substance by inhalation, from their individual practices, including all practice locations:

• Number of inhalations administered to patients,
• Number of patients who experience an Adverse Occurrences (see above for definition of adverse occurrences),
• Types of Adverse Occurrences encountered (see above for definition of adverse occurrences),
• Type of infection encountered, if applicable (see additional data sets below for details),
• Conditions for which an unscheduled treatment was required, if applicable (see additional data sets below for details), and
• Type of adverse drug reactions encountered (see additional data sets below for details).

Additional Data Sets
The College would also like to consider seeking the following additional data:

• Where an infection has occurred, the types of infections:
  • Bronchitis
  • Cystitis
  • Gastroenteritis
  • Influenza
  • Pharyngitis
  • Pneumonia
  • Sinusitis

• Where an unscheduled treatment has occurred, the types of conditions treated:
  • Anxiety
  • Dizziness
  • Headache
  • Fatigue
  • Low back strain
  • Muscular spasms
  • Phlebitis
  • Pneumonia

• Where an adverse drug/substance reaction has occurred, the types of reactions:
  • Anxiety
  • Diarrhea
  • Headache
  • Hypertension
  • Hypoglycemia
  • Injection site extravasation
  • Maculo-papular rash
  • Nausea
  • Phlebitis
  • Pre-syncope
  • Seizure
  • Shortness of breath
  • Syncope
  • Urticaria
  • Vomiting

The College is NOT considering seeking the number of each type of infection, condition treated or adverse drug/substance reactions as it is not believed that the data will provide any greater value to the purpose of the collection.

Process for Data Collection
The College is proposing to use an online form to collect the data from Registrants to ensure the process is streamlined and easy for Registrants to use.

The online form allows the College to only ask questions relevant to your practice. For example, on the question about which controlled acts the Registrant performs, if a Registrant reports that they only prescribe drugs, only questions relating to prescribing will appear on the form.

To assist Registrants and Stakeholders to visualize this process, a mock-up of the Collection Form has been created. Readers can view and test the form here. Readers are advised that this is a mock-up only and will only be used should a decision be made to proceed with this data collection process. Additionally, if the College proceeds, the final form may look different based on the feedback received. Any data submitted as part of testing will be deleted.

Current Information

Currently, the College maintains information about which of our Registrants have met the Standard of Practice for Therapeutic Prescribing (approximately 51% of Registrants). However, we do not have any information about which of the controlled acts are being performed, at which volume and, wherever applicable, whether there have been any adverse reactions to the performance of these controlled acts.

Intent of this Change

The purposes of collecting this new data are twofold. First, the data sets that will be collected will be used, in aggregate form, to inform the College’s Risk-based Regulation program. That program is being created to identify areas of practice that may present a risk of harm to patients and where these risks might be lessoned through proactive activities, such as educational articles, training programs, regulatory guidance and regulatory education programming.

The second purpose is to have aggregate data available that relates to the performance of the profession in the areas of prescribing, dispensing, compounding and selling drugs, as well as administering substances by injection and inhalation. It is commonly known that the profession is interested in seeing its scope of practice expanded in terms of access to additional drugs and substances. One consideration surrounding expanded access will likely be the performance of the profession in these areas to-date. This data will inform the College, the Ontario Association of Naturopathic Doctors and the Ministry of Health about overall performance of the profession in these areas. While it is believed that the profession is performing well in these areas, data collected may provide evidence to this effect.

Impact on Registrants

Registrants who have met the Standard of Practice for Therapeutic Prescribing would be required to provide the College with data relating to their own individual practices on an annual basis. As noted above, this will impact 51% of Registrants. Initially, Registrants will be asked to provide estimates; however, in the longer term, Registrants will want to consider methods by which they may individually collect actual reliable data. The stronger the data sets, the better insight the data provides.

The College would mandate that every Registrant who has met the Standard of Practice for Therapeutic Prescribing provide the data. Provisions in the by-laws would be used to mandate the provision of data, meaning that individuals who fail to provide the data might be subjected to an administrative suspension for failing to provide information to the College.

It is important to note that Registrants of the College who have met the Standard of Practice for Intravenous Infusion Therapy are currently already providing similar data to the College annually.

Financial Impact on College

The financial impact on the College would be negligible. The data would be collected using online processes currently available to the College set up by existing staff of the College. Analysis of the data would be part of the responsibilities of individuals within the College responsible for the Risk-based Regulation Program. These tasks would be performed by new staff positions to be retained in the coming fiscal year of the College.

Feedback

The College is seeking feedback from all stakeholders, including Registrants, the public, naturopathic organizations and other regulatory bodies. Feedback must be provided in writing by way of written correspondence (letter or email) or through the College’s on-line submission form (see below for more details).

All feedback will be published by the College on the College’s website. Feedback from organizations will be published such that a reader can identify the individual. Feedback from individuals within the profession or members of the public will be published anonymously.

Regardless, all feedback must include the name of the individual submitting the feedback for validity purposes. Anonymous submissions will not be considered and will not be retained by the College.

Feedback can be provided to the following addresses:

Written correspondence by mail:	College of Naturopaths of Ontario 10 King Street East, Suite 1001 Toronto, ON  M5C 1C3
Written correspondence by facsimile:	(416) 583-6011
Written correspondence by e-mail:	general@collegeofnaturopaths.on.ca
On-line form:	Data Collection Feedback Form

Instructions for Using the Online Submission Form

The online submission form for the College’s proposed data collection is an interactive and intuitive form. Before using this form, it is highly recommended that you review the proposed changes and make note of the areas where you wish to provide feedback. This will make the online submission process easier for you to use. The key questions for you to respond to are as follows:

Identification	You will be required to provide your full name and email address, as well as the name of any organization you may be representing. Providing your telephone number is optional.
Sections	You will be asked to identify all the sections on which you wish to provide feedback. This will alter the online form to allow feedback on those sections. If you do not identify a specific section for feedback, the opportunity to speak to that section will not be included in the form.
Submission Copy	At the completion of the feedback form, you can ask that the online system provide you with a copy of your submission by checking a box at the end. It is recommended that you check this box so you can recall the feedback that you have provided.
Published Summary	A summary of all of your feedback will be published on the College’s website. All information provided will be published as submitted. The College does not edit submissions prior to publication. Names, emails and other identifying information will be redacted from the materials prior to publication unless you have identified that your submission is provided on behalf of an organization.

Timeframe

The College will be providing the opportunity for feedback. Consultation will begin on or before November 24, 2023, and will conclude on or about January 31, 2024. This provides for a 68-day consultation period.

Our Thanks

The College wishes to thank everyone for taking the time to review these consultation materials, and for providing any feedback.

Andrew Parr, CAE
Chief Executive Officer