FAQ: Dietitians Regulation

The following FAQ provides interpretation to the newly proposed amendments to the Dietitians Regulation.

Q1: What is different about the definition of “design”?

The definition was broadened to support a variety of therapeutic diets within dietetic scope of practice, including oral, enteral, and parenteral nutrition and to recognize that “design” means more than simply selecting ingredients. It formalizes dietitians’ authority to determine appropriate oral, enteral and parenteral nutrients, including vitamins and minerals for supplementation, and other nutritional substances such as the ones listed in Q3. “Design” is different in meaning than “prescribe” as defined in the Pharmacists Regulation.

Q2: The definition for “order” is new. How should dietitians interpret it?

“Order” is defined specifically for section 6, Restricted activities for certified practice registrants. This definition sets the context within which dietitians receive authorization for feeding tube insertions from health professionals who are authorized to order this within their scope. It should be interpreted with the definition for “health professional”. Health professional was added to include all regulated health professionals authorized and qualified to order tube feeding insertions.

The second part of the definition provides flexibility for a variety of “orders” for a certified dietitian to receive for tube feeding insertions (for example, the need to administer a motility drug to facilitate insertion).

The definition of “order” in regulation is different from the definition of “client-specific order” in the Position Statement on Dietitians’ Authority to Order Nutritional Substances for Therapeutic Diets.

Q3: How should I interpret the definition for “substance”?

This definition is used to align with the HPA model. It is broad enough to include nutritional substances dietitians work with as defined in the CDBC Position Statement on Dietitians’ Authority to Order Nutritional Substances for Therapeutic Diets: “water and ingredients such as food, food texture substances, thickening agents, formulas and other nutritional supplements, macro-nutrients (polymers and monomers), and micronutrients (vitamins and minerals) that are considered Unscheduled drugs or Natural Health Products. Nutritional substances for the purpose of parenteral (intravenous) nutrition are considered Schedule I drugs and require a prescription from an authorized prescriber. Nutritional substances are ingredients for the design of a nutrition care plan and therapeutic diet. Nutrition care plans and therapeutic diets involve feeding through oral, enteral, and parenteral means.”

Q4: Why does the definition for “therapeutic diet” include drugs?

A therapeutic diet may include “substances” and “drugs”. Therapeutic diets may include scheduled drugs that require a prescription from an authorized prescriber. For example, a therapeutic diet for parenteral nutrition. This definition is meant to clarify dietetic scope of practice and align with other existing definitions in different profession-specific regulations. Diets that include prescribed drugs will require a prescription from an authorized prescriber.

Q5: Do the changes to section 5, Restricted activities, remove restricted activities for dietitians?

The intent is not to remove existing restricted activities; rather, it removes the need for CDBC to specify “additional qualifications” for restricted activities in bylaws. Restricted activities are supported within education programs in the national Integrated Competencies for Education and Practice by PDEP, by the CDBC Standards of Practice, and competencies found in the CDBC Restricted Activities Interpretive Guide.

The fact that restricted activities are considered “entry-to-practice” for a majority of dietitians, (meaning that the Integrated Competencies for Dietetic Education and Practice (ICDEP) are met upon graduation) does not diminish the level of risk of harm, responsibility, and requirement for clear and accurate clinical judgement involved in their practice. For example, risks associated with poor enteral and parenteral nutrition design and administration may involve fluid overload which can lead to edema and respiratory difficulty, or refeeding syndrome, which can result in multi-organ failure and death. Conversely, underfeeding may negatively influence a client’s ability to recover from disease, injury, or surgery.

Dietitians will still need to:

  • register with restricted activities,
  • legally declare upon registration and annual renewal, that they meet the competencies specific to each restricted activity and that they are ready to practice each one safely, and
  • report annually within their continuing competence program on each type of restricted activity they are registered to practice.
Q6: Do the changes to section 5, Restricted activities, mean that dietitians can now independently order parenteral nutrition?

No, because dietitians cannot write prescriptions, an authorized prescriber needs to sign off on a dietitian’s design for parenteral nutrition.

Q7: In section 5, Restricted activities, I also read that a new proposed restricted activity might relate to the use of sensors for blood glucose monitoring and insulin pumps. Is this accurate?

Yes, this is an accurate interpretation and was added to support the ongoing role of dietitians who provide clients with diabetes care. Dietitians can only discuss with and show their clients how to change insulin units within a prescribed amount.

Q8: Is the amendment in section 6 regarding placement of enteral tubes? Specifically regarding "artificial hole," is this regarding replacing balloon gastrostomies?

The amendments to section 6 would enable dietitians who are certified to do insertion of feeding tubes to change the volume of a balloon retention device. If the proposed changes are adopted, the new proposed College of Health and Care Professionals of BC would communicate practice standards and an updated program a study for certification under this subsection of the regulation.

Currently, registrants who are registered to do insertions of feeding tubes (scroll to the bottom of the page) can only do so under medical delegation and must, on an annual basis:

  • Register with restricted activities A and C,
  • Report on continuing education for restricted activities A and C,
  • Fulfill the Standards for Insertion of Nasal/oral Feeding Tubes, and
  • Submit a form signed by the delegating physician and the registrant’s employer on the type of insertions they are qualified to perform (gastric or post-pyloric).

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