Practice Advisory – FAQ

A: Refer to “Where’s the Line?” Professional Boundaries in a Therapeutic Relationship included in the CDBC Patient Relations Program.

You may not use the term “specialist”. According to section 74(7) of the CDBC bylaws: “Unless otherwise authorized by the Act, the regulations, these bylaws, or the board, a registrant (a) must not use the title “specialist” or any similar designation suggesting a recognized special status or accreditation on any letterhead or business card or in any other marketing.” As the CDBC Board has not recognized any specialty designation, an RD may not use the term “specialist”. However, you may add diploma (e.g., BSc, MSc, PhD) or certification titles (e.g., CDE, Certified Nutrition Support Dietitian (CNSD), Sports Dietitian, etc.) to your signature.

A: Refer to “Where’s the Line?” Professional Boundaries in a Therapeutic Relationship, the College’s Patient Relations Program. Page 6 reviews important steps to setting the stage for a therapeutic relationship, including consent to care guidelines.

Consent should be obtained from the minor, given that you are providing a service to him/her, regardless of whether her mother is present or not. Consent should be obtained in accordance with CDBC Standards for Record Keeping, which includes the requirement to comply with part 2 of the Infants’ Act.

The BC Branch of the Canadian Bar Association has published The CBA Child Rights Toolkit regarding competency, capacity, and consent, which is relevant to physicians and other health care providers. Within this document, children (anyone under 19) can consent to their own medical care if they are “capable” (i.e. if he/she understands the medical care requested, the treatment process, and the risks and benefits of care). Children who are capable can normally obtain medical treatment without their parents’ or guardian’s knowledge or consent. In addition, you are unable to discuss a capable child’s medical care with the parents or guardian unless the child agrees.

It is recommended that you review the Interpretive Guidelines—Privacy Legislation for Private Practitioners along with the Standards for Record Keeping, particularly with respect to Standard 3: “Dietitians ensure a comprehensive client health record is maintained when individual nutrition assessments and interventions are provided.” There is no requirement to have a separate chart for the client’s care and one for the client’s mother. The child (and not her mother) is your client, all documentation related to the care of your client, should be included within one chart.

Yes. Additional professional liability insurance must be purchased if dietetic services are delivered independent of the employer providing liability insurance. Insurance provided by an employer only covers the dietetic services delivered in that workplace. As per CDBC bylaws, section 55 – Professional Liability Insurance. “All full, temporary and emergency registrants must obtain and at all times maintain professional liability insurance coverage in an amount of at least two million dollars ($2,000,000) per occurrence in a form that is satisfactory to the College.”

A: Yes. If the current CDBC registrant is using the protected title “dietitian”, he/she must have professional liability insurance regardless of whether or not his or her current job is in dietetics. Professional liability insurance is a requirement for registration with the CDBC. As per the CDBC bylaws, section 55, “All full, temporary and emergency registrants must obtain and at all times maintain professional liability insurance coverage in an amount of at least two million dollars ($2,000,000) per occurrence in a form that is satisfactory to the college.” Registrants may obtain liability insurance from: Employers/Health Authorities. Please verify this coverage meets the minimum requirement set in the CDBC bylaws. Remember this coverage may not include dietetic practice performed outside the employer/Health Authority’s jurisdiction. Membership with Dietitians of Canada through LMS Prolink Ltd. Sheppard Insurance Service Inc. or Other private insurance providers. Applicants and registrants legally declare that they carry professional liability insurance when they apply/renew their registrations. The legal declaration is part of the Statutory Declaration section of applications for registration and reinstatement. Registrants are encouraged to save proof of insurance in their personal records.

A: The answers depend on your practice setting. The following information can be found in CDBC Standards for Record Keeping (standard 5h(a,b,c)).

In a hospital, according to the Limitation Act, hospital medical records must be retained for a minimum period of sixteen years from either the date of the last entry or from the age of majority, whichever is later, except as otherwise required by law.

In community care and assisted living, according to section 92 of the Residential Care Regulation, resident health records must be kept a minimum of 2 years after discharge.

In private practice, according to section 35 of the Personal Information Protection Act, information used to make a decision that directly affects the individual must be kept at least one year after using the information (gives the individual an opportunity to access the information).

Health care facilities/Health Authorities may have policies that have longer timelines than the minimum duration stated in legislation. There are no prescribed methods for record destruction. Commonly accepted destruction methods include: cross-shredding of paper records, incineration of non-paper records and erasure of data, including any backup copies, for electronic records. Whatever method used, client privacy must be ensured.

A: The CDBC’s mandate includes enforcement of BC’s health legislation. Therefore, the CDBC is required under the Health Professions Act to register qualified dietitians wishing to practice dietetics in BC. If a CDBC RD informs us that he/she wishes to practice in another province while living in BC, the registrant is advised refer to QA-10 Virtual Dietetic Practice and Virtual Dietetic Practice Guidelines.

A: Things to consider when starting a private practice in dietetics:

• As per CDBC policy, Qac-03: Privacy Legislation for Private Practitioners, RDs working in private practice must meet privacy requirements outlined in Personal Information Protection and Electronic Documents Act (PIPEDA). For more information, review the CDBC’s Interpretive Guideline: Privacy Legislation for Private Practitioners.
• Storage of client records. According to section 35 of the Personal Information Protection Act, information used to make decisions that directly affect individuals must be kept for at least one year after using the information. This gives individuals the opportunity to access their information.
• Virtual Practice. Many private practice RDs provide nutrition services on-line, by phone, or by using social media. It is important to note that the use of technology does not alter the ethical, professional and legal requirements around the provision of appropriate nutrition care. RDs who chose to make their services available in this manner should also acquaint themselves with the CDBC’s policy on Virtual Dietetic Practice. For more information, review the CDBC’s Virtual Dietetic Practice Guidelines.
• CDBC strongly recommends getting in contact with an insurance provider and seek legal advice to determine liability coverage for clients who do not reside in BC or Canada.

Yes, it is within dietitians’ scope of practice to provide and/or teach insulin dose adjustment (IDA). Dietitians must practice IDA within limits of their knowledge, skills, abilities and judgment, in compliance with CDBC Standards of Practice and Code of Ethics, and current evidence-informed clinical practice guidelines as well as any policies and guidelines that may be required by their employer. A Health Authority, hospital or health care facility may restrict the scope of practice for health care professionals. Dietitians must comply with employer policies related to IDA.

The first step to take is to consider whether the client’s request falls within a BC dietitian’s scope of practice. It is within the scope of dietitians in BC to discuss nutritional aspects of cannabis edibles, given that the definition of dietetics in the Dietitians Regulation is:

“the assessment of nutritional needs, design, implementation and evaluation of nutritional care plans and therapeutic diets, the science of food and human nutrition, and dissemination of information about food and human nutrition to attain, maintain and promote the health of individuals, groups and the community.”

Once you have determined that the question from the client is within the dietetic scope of practice, the CDBC encourages you to reflect on your own personal limitations on scope of practice. Do you have the knowledge, skills and judgement to take on a new aspect of practice safely, ethically and competently? Included in the Standards of Practice , “a Dietitian uses critical thinking to obtain assessment date, determine practice problems, plan, implement and evaluate professional services.” You may consult the CDBC Decision Tool for New Aspects of Dietetic Practice  to help you determine whether counselling on cannabis is right for you. If you determine that you are outside of your personal scope, you may choose to refer to another health professional for independent or collaborative practice, as appropriate.

A:  Dietitians’ Authority to Recommend Vitamins and Minerals for Therapeutic Diets

JOINT STATEMENT (BCCNP, College of Pharmacists, CDBC)

When recommended by a dietitian as part of a therapeutic diet, pharmacists may release Schedule III and unscheduled drugs¹ and nurses² may administer them.

BACKGROUND

The Dietitians Regulation under the Health Professions Act authorizes dietitians to assess nutritional needs, and design, implement and evaluate nutritional care plans and therapeutic diets.

Dietitians recommend Schedule III and unscheduled vitamins and minerals as part of a nutritional care plan or therapeutic diet. These products do not require an order (or prescription). Similarly, other unscheduled products such as protein powder, pectin and medium chain triglycerides (MCT) may also be recommended for inclusion in oral or enteral diets.

Dietitians have clinical expertise in the design of nutritional care plans and therapeutic diets. Nurses seek advice and receive direction from dietitians in these clinical areas to provide safe and effective care to clients.

 ¹Schedule III drugs may be sold by a pharmacist to any person from the self-selection Professional Products Area of a licensed pharmacy. Unscheduled drugs may be sold by a non pharmacist to any person.

²In this document, “nurses” refers to registered nurses, nurse practitioners, licensed practical nurses, registered psychiatric nurses and licensed graduate nurses. 

Even through the Joint Statement allows you to order oral and enteral vitamins and minerals, you may find that your health authority or workplace has restricted dietitians’ scope in this regard. Further, all IV preparations are Schedule 1 of the BC Drug Schedules, which require a physician/NP order.