Total Comments: 5
Other health care professional (including retired)
[April 01, 2025 8:34 PM]
While patient safety and regulatory oversight are paramount, restricting the delegation of controlled acts—such as Botox injections—would be an unnecessary overreach that undermines a system that has functioned safely and effectively for decades. Highly trained and experienced nurse injectors, such as Nurse Practitioners (NPs) and Registered Nurses (RNs) (RPNs) under proper delegation, have been safely performing aesthetic procedures across Canada and worldwide for years.

Physicians play a critical role in the healthcare system, but their expertise is best utilized in high-acuity settings such as the OR, ER, and primary care clinics. The idea that a doctor must be directly involved in every aesthetic procedure is not only impractical but also detracts from their ability to provide urgent and necessary medical care. Aesthetic medicine, while important to patient well-being and confidence, is an elective service that does not require a physician’s constant presence—especially when trained nurses can perform these treatments competently under proper delegation.

The concerns raised regarding unlicensed practitioners and improper delegation should be addressed through better enforcement of existing regulations, rather than a blanket restriction on delegation itself. It is critical to distinguish between unqualified individuals performing procedures illegally and licensed healthcare professionals operating within their regulated scope of practice. The latter group has extensive education, clinical training, and ongoing certification requirements to ensure safe and effective patient care no different than the education that MD’s have. Nurses attend the same cadaver labs, the same conferences, receive the same training by pharmaceutical companies, and attend the same educational webinars, and often are the ones that are the clinical educators that represent the major Pharma companies that teach everybody how to inject neuromodulators and filler.

By preventing or restricting delegation in aesthetics, Ontario risks overburdening its already stretched physician workforce and limiting patient access to safe, medically supervised cosmetic treatments. The focus should be on improving accountability, ensuring compliance with existing regulations, and cracking down on illegal practices—not restricting a well-established, safe, and efficient system that has benefited both patients and the healthcare system for decades.
Physician (including retired)
[March 31, 2025 9:43 AM]
I agree with the comment stating the application of this policy is misused in aesthetic medicine.

Medical Directors should have the necessary qualifications and commitment to delegate these procedures to those they oversee. It is far too common to see medical directors who are completely absent or completely unaware of what they are overseeing. Combined with a complete lack of standard of care or assessment of competence for these procedures, patients are at risk of serious complications including vascular occlusions and scarring.

As physicians we must uphold a certain standard of care, safety and practice, which is not being met.

I also urge the CPSO to implement stronger safeguards to prevent the inappropriate use of delegation, particularly in non-essential and elective procedures.
Physician (including retired)
[March 28, 2025 10:44 AM]
While the intent of this policy is to improve access to care when resources are limited, its application has been increasingly misused, particularly in the aesthetic medicine sector.
 
There is a growing trend of businesses exploiting this framework for financial gain by allowing unlicensed foreign-trained healthcare professionals—who have no recognized credentials or licensure in Ontario—to perform controlled acts such as neuromodulator and filler injections, minor surgical procedures, and lesion excisions. This raises serious concerns about patient safety and the integrity of medical practice.
 
I was recently called for a patient who suffered significant bleeding following a lesion excision performed by an unlicensed individual (IMG). When I requested a formal referral, I discovered that the individual was acting under the delegation from a family physician who had no involvement in the patient’s care and was unable to issue a referral. This incident highlights the dangers of loosely regulated delegation and the potential harm to patients.
 
This issue is particularly prevalent in private-pay services such as non-OHIP-covered mole removals and medical aesthetic treatments. Stricter oversight is needed to ensure that delegation is not used as a loophole to circumvent proper licensure and regulatory standards. I urge the CPSO to implement stronger safeguards to prevent the inappropriate use of delegation, particularly in non-essential and elective procedures.
Physician (including retired)
[March 28, 2025 10:43 AM]
We need to allow for more video/virtual contact for the definition of patient relationship as this can often be the only contact for patients in the far north at nursing stations where the attending physician cannot be local and cannot know the patient Beforehand. And this can apply to other scenarios and should be equivalent over all platforms.
We are moving in a digital age and that implies that new technologies should have defined allowance. If a competent nurse is able to provide a controlled act under my guidance or order, I should be able to delegate over video/phone after speaking at least with the patient. It often happens to me when working in the far north, so should be applicable even in the south.
Physician (including retired)
[March 28, 2024 1:01 PM]
Note: Some content has been edited in accordance with our posting guidelines.
Dear CPSO,

I am a physician and researcher at [redacted].  [redacted]. My expertise is in the role of community health workers, delegation of healthcare services to improve community health, and first aid for underserved communities.

I am writing to provide feedback on the Delegation of Controlled Acts consultation.  Specifically, I would like to add comments to footnote 9, and recommend that it be edited as seen below.

I would be happy to discuss the rationale and benefit of these changes.

Thanks,
 
9. Generally, a patient’s best interests will be served by delegation that occurs in the context of an existing or anticipated physician-patient relationship. However, in some instances a patient’s best interests might be served by receiving care in the absence of a conventional physician-patient relationship. For example, in instances where access would otherwise be compromised to the point of risking patient safety, or where patient or public safety might be otherwise compromised. Examples of appropriate circumstances in which delegation may occur in the absence of a conventional physician-patient relationship include, but are not limited to:
  • the provision of care by paramedics under the direct control of base hospital physicians or within community paramedicine programs;
  • the provision of primary care addressing the needs of underserved populations such as in remote and isolated regions of the province by registered nurses acting in expanded roles;
  • the provision of public health or population-based programs, such as vaccinations, tobacco cessation, harm reduction interventions, or communicable disease screening;
  • post­exposure prophylaxis following potential exposure to a blood borne pathogen or the provision of vaccines in the context of occupational health;
  • hospital emergency departments for routine protocols;
  • lay person first responders performing controlled acts for the purposes of care within the scope of first aid;
  • administration of over-the-counter medications or products otherwise approved for use by the general public.