Regulation Matters 2021 - Issue 2, September

Vaccination Status Disclosure Guidance for CDO Members

Registered Dietitians across Ontario have continued to deliver safe, ethical and competent dietetic services throughout the COVID-19 pandemic. Recently, questions have been raised regarding the disclosure of vaccination status by both clients and health professionals, and under what circumstances health professionals may restrict in-person care.

These are complicated questions for which there are no simple answers. Public policy continues to develop as circumstances related to the pandemic continue to change. Generally, the vaccination status of any individual is considered personal health information, although some employers may require such disclosure from employees under certain circumstances. While the College of Dietitians of Ontario does not require members to be vaccinated against COVID-19, nor does the College require members to disclose their vaccination status, we encourage dietitians to use evidence-informed decision making when it comes to COVID-19 vaccinations.

The College is guided by its duty to serve and protect the public interest under the Regulated Health Professions Act, 1991. Our Professional Practice Program provides guidance to Registered Dietitians as well as the public, other health professionals, employers and students. We address inquiries about the standards, laws and ethics that impact dietetic practice to ensure the delivery of safe, client-centred nutrition care.

If your question is not addressed here, or if you need further support beyond the information provided below, please do not hesitate to contact the College’s Practice Advisory Service.


Can a Registered Dietitian ask a client about their vaccination status?
A client should only be asked questions about their health status if it is relevant to their care. Vaccination information is often irrelevant to dietetic assessment and treatment. Dietitians have a fundamental responsibility to act in a client-centred, ethical manner and use professional judgment to make decisions in the best interests of their clients.

Can a Registered Dietitian restrict in-person care to only those clients who have been vaccinated or have a recent negative COVID-19 test result?
Many health professionals, including dietitians, have provided in-person care throughout the pandemic by taking appropriate precautions, including the use of personal protective equipment. The College has encouraged members to provide care virtually where possible and otherwise comply with the guidance provided by the Ontario Ministry of Health. For guidance on providing virtual and in-person care during COVID-19, please see resources here.

Before making decisions about in-person care, dietitians should consult with their employer (or, if in private practice, seek legal advice as applicable) before making decisions about in-person care. A dietitian should not discontinue dietetic care that is needed unless alternate services are arranged, or clients are given reasonable notice to arrange alternative services. For further information, please read "Can I refuse to provide dietetic services with an infected client?" on the Pandemic FAQs webpage.

Can a client ask a Registered Dietitian about their vaccination status?
The public has a right to ask questions of their health providers regarding issues, including vaccination status, that may affect their care or treatment. It is not unusual for a dietitian to provide limited self-disclosure of personal information in certain circumstances to develop rapport and trust.

While an individual's vaccination status is considered personal health information, dietitians who are employees (or employers) may be bound by employment obligations to disclose their vaccination status. Dietitians in private practice are encouraged to use professional judgment and evidence-informed decisions.

Registered Dietitians are accountable to all the standards of practice. Key resources provided by the College are the Code of Ethics and the Collaborative Care Guidelines. Dietitians must use professional judgment to make decisions in the best interests of their clients. For more information, please read Pandemic FAQs.