“Unlike the five health professions authorized to use the “Doctor” title, no class of audiologist certificate required an applicant to have passed a licensing examination. Furthermore, unlike the other professions, audiologists were not entitled to communicate a diagnosis as the cause of an individual’s symptoms”.This decision was largely based on provisions within the Regulated Health Professions Act (‘RHPA’), including a provision which states:
It might seem unfair, illogical even. But this can be a harsh reality and a source of confusion for some who believe they are entitled to use the abbreviation ‘Dr.’, including some holders of doctorate degrees who can find themselves prevented at law (by the RHPA and The Medicine Act, among others) from using this abbreviation or the title ‘Doctor’. The reason has less to do with verifying those using the title ‘doctor’ (or a variation, abbreviation or equivalent in another language) have appropriate qualifications and training, and everything to do with the various Colleges’ mandate of protecting the public through regulation in Ontario. First, you have to be a member of one of the groups of health professionals with prima facie entitlement to use the title (see section 33(2) of the RHPA). Second, even if you are a member of one of those professions, if you are not registered with the relevant regulatory College in Ontario, say the College of Physicians and Surgeons of Ontario, or the College of Chiropractors of Ontario, you cannot use the title ‘while providing or offering to provide healthcare in Ontario’. A primary objective for the Colleges seems to be preventing confusion among members of the public. Among others, a problem can arise for:
Restriction of title “doctor”33(1) Except as allowed in the regulations under this Act, no person shall use the title “doctor”, a variation or abbreviation or an equivalent in another language in the course of providing or offering to provide, in Ontario, health care to individuals. 1991, c. 18, s. 33 (1).
The Chief Medical Officer of Health for Ontario has issued an updated Directive #2 (dated May 26, 2020) for Regulated Health Professionals in the province.
Pursuant to the updated Directive #2, all deferred non-essential and elective services by health care providers may be gradually restarted – subject to the rest of the requirements set out in the Directive.
The updated Directive #2 does not provide particularly detailed guidance to health professionals on how to proceed, likely because it applies to such a broad spectrum of health care and health professionals. It does, however, provide some principles to assist health care providers in making decisions as we enter this transitional period.
In addition to the mask and hand sanitizer shortages, Ontario’s response to COVID-19 highlights the need for more frontline health care workers. Each regulated health profession’s college responded differently, and we have discussed some of those changes in other posts to keep you apprised.
Today, we focus on the College of Physicians and Surgeons of Ontario (CPSO), who set out to increase the number of available and licenced physicians out on the frontlines through certificates of registration that authorize supervised practice of short duration. The temporary licences authorize practice for 30 days.
Undoubtedly, COVID-19 has affected how health professionals practice. Pharmacists across the country are not only experiencing changes in how they practice (for example, accepting emailed prescriptions, where appropriate) but the scope of their practice as well. The latter change is not permanent, although the disruptions in practice may be felt long after the COVID-19 emergency subsides.
On March 19, 2020, Health Canada issued a short-term section 56(1) exemption under the Controlled Drugs and Substances Act (CDSA) that would authorize pharmacists to prescribe, sell, or provide controlled substances in limited circumstances, or transfer prescriptions for controlled substances (the CDSA Exemption).