Scope Of Practice & Controlled Acts Scenario

During this pandemic, growing demands for care in our hospital have resulted in dietitians being asked to provide care in areas of dietetic practice they do not commonly work in, or that is outside of the dietetic scope of practice. My employer has asked if I can help with team-based care, including assisting nursing with tasks such as taking vital signs and providing suctioning for patients. Am I able to help? What should I consider?

There are no simple answers to these questions. Individual circumstances will vary depending on the practice setting and nature of professional practice. We encourage dietitians to work with their employers and consider:

• client needs
• personal competence (knowledge and skill)
• interprofessional care
• professional obligations (e.g., legislation specific to your practice setting and organization specific policies)
• risk management, including confirming liability insurance coverage, if you are being asked to perform tasks outside of your scope of practice or usual role.   

1.  Role and Task Framework 

Use the College’s Role and Task Framework  when considering opportunities for assuming new tasks, roles, and responsibilities during the pandemic, or at any time when new opportunities arise.

Click here to find how to apply the Framework 

2.  Standard of Practice – Practicing Through a Delegation of a Controlled Act

When being asked to do a controlled act that is out of their scope of practice, dietitians need either a direct order or a medical directive to accept the authority to perform it. Consult the College’s new Standard of Practice – Practicing Through a Delegation of a Controlled Act to see the minimum level of performance expectations for dietitians when practising through the delegation of controlled acts.

Clck here to find how to apply the Delegation Standard

Applying the Role & Task Framework – Performing a Temperature Screen

Refer to the Role & Task Framework to determine whether a dietitian would be able to perform this task.

a. Is the new task or role within the dietetic scope of practice?

Temperature checks can be within dietetic scope of practice when it is being measured as part of a nutrition assessment (i.e. the assessment of fluid status, consideration of energy requirements/stress factor assessment). However, if the RD is taking temperature checks for circumstances that do not relate to their nutrition care plan (e.g. for purposes of routine screening), an organization would need to determine if this is considered a diagnostic procedure or treatment. Depending on how the temperature check is being used and the practice setting, different circumstances may apply.

b. Are there any legal barriers restricting an RD from performing the task (e.g., performing a Controlled Act)? For example, would an authority mechanism be needed for an RD to perform the task?

Temperature checks are not a controlled act. If an organization determines that temperature checks are screening and not diagnostic procedures or treatment, authority mechanisms would not be required to permit dietitians to perform temperature checks. In a public hospital, a dietitian would need an order (or medical directive) if the task is deemed a diagnostic procedure or treatment.

Dietitians will also need to be careful to avoid violating the controlled act of communicating a diagnosis. Dietitians may indicate that the temperature is elevated, but they are not permitted to label it as a clear medical diagnosis, unless they receive a delegation to do so. See Example 2 below: Applying the Delegation Standard.

c. Do I have the required skills and competence to perform the new task? If not, how can I obtain what is necessary to become competent?

Dietitians need to have the appropriate skills and competence to perform temperature checks. They could be trained by a colleague on how to use the thermometer and how to perform a reading.

It would also be important for dietitians to be trained on the steps involved in the screening and to know the protocol to follow depending on the temperature reading result.

d. What are the interprofessional care team possibilities? Given all the local circumstances, who is the most appropriate person(s) to perform the task (e.g., an RD, or another health care provider/team member, or both)?

With growing demands for care, dietitians performing temperature checks may be helpful as this would reduce the pressure and demand on the health care system. Dietitians are asked to use their professional judgement and continue to seek direction from their employer.

Applying the Delegation Standard to a Controlled Act

When working with your employer to determine if you can take on new tasks, make sure you have a delegation if the task you are being asked to perform is a controlled act.  A controlled act poses risk of harm if performed by unqualified persons. The Regulated Health Professions Act, 1991 permits delegations to transfer the authority (from someone who is authorized to perform the controlled act), to dietitians to perform the controlled act in some situations.

The delegation of a controlled act in appropriate circumstances can result in more timely delivery of healthcare and can promote optimal use of healthcare resources and personnel.  When considering  a delegation for any controlled act, ask yourself the questions  below and follow the  College’s Delegation Standard to apply the knowledge, skills, and judgment necessary for safe client care:

1.  Is the delegation in the client’s best interest?

2.  Do I have the knowledge, skill, and judgement to accept the delegation?

3.  Am I aware of the legislation relevant to my practice setting?

4.  Am I meeting standards for informed consent and record keeping?

5.  Am I aware of accountability, quality assurance and delegation processes in my practice setting?

6.  Before seeking authorization, have I reviewed the minimum level of performance expectations for dietitians when practising through the delegation of controlled acts? See Delegation Standard for details.