Restricted Activities

Note: a glossary of terms can be found at the end of this document. Glossary terms are indicated in teal with a ^“G” throughout this document.

PREAMBLE

This standard applies to both the performance and supervision of restricted activities^G as defined in the Health Professions Restricted Activity Regulation. It does not imply any expectation or requirement for a regulated member of CPSA to supervise other regulated healthcare professionals performing restricted activities within their scope of practice, training and authorization by their regulatory college.

Supervision occurs in different formats (e.g., in person, on site, remotely, etc.) based on the person being supervised, the restricted activity being performed and the supervising regulated member’s confidence in the person’s skills and abilities. The level of supervision may vary as the person’s skills and abilities improve. It is important for the supervising regulated member to be aware that they are responsible and liable for the actions of the person they are supervising.

STANDARD

Self-restriction

1. Despite any authorization to perform restricted activities:
   1. a physician, surgeon or osteopath must only perform a restricted activity that the physician, surgeon or osteopath is competent^G to perform and that is appropriate to the clinical circumstance and the regulated member’s scope of practice; and
   2. a physician assistant must only perform a restricted activity that the physician assistant is competent to perform and that is appropriate to the clinical circumstance and scope of practice of the supervising physician, surgeon or osteopath.
2. A regulated member who performs a restricted activity must do so in accordance with the Standards of Practice.

Restricted Activities

3. A regulated member on the physicians, surgeons and osteopaths register may, in the practice of medicine or osteopathy and in accordance with the Standards of Practice, perform the following restricted activities:
   1. to cut a body tissue, to administer anything by an invasive procedure on body tissue or to perform surgical or other invasive procedures on body tissue below the dermis or the mucous membrane or in or below the surface of the cornea;
   2. to insert or remove instruments, devices, fingers or hands:
      1. beyond the cartilaginous portion of the ear canal;
      2. beyond the point in the nasal passages where they normally narrow;
      3. beyond the pharynx;
      4. beyond the opening of the urethra;
      5. beyond the labia majora;
      6. beyond the anal verge; or
      7. into an artificial opening of the body;
   3. to insert into the ear canal, under pressure, liquid, air or gas;
   4. to set or reset a fracture of a bone;
   5. to reduce a dislocation of any joint;
   6. to use a deliberate, brief, fast thrust to move the joints of the spine beyond the normal range but within the anatomical range of motion, which generally results in an audible click or pop;
   7. to prescribe a Schedule 1 drug within the meaning of the Pharmacy and Drug Act;
   8. to dispense, compound, provide for selling or sell a Schedule 1 drug or Schedule 2 drug within the meaning of the Pharmacy and Drug Act;
   9. to administer a vaccine or parenteral nutrition;
   10. to prescribe, compound or administer blood or blood products;
   11. to prescribe or administer diagnostic imaging contrast agents;
   12. to prescribe or administer anaesthetic gases, including nitrous oxide, for the purposes of anaesthesia or sedation;
   13. to prescribe or administer radiopharmaceuticals, radiolabelled substances, radioactive gases or radio aerosols;
   14. to order or apply any form of ionizing radiation in medical radiography, nuclear medicine or radiation therapy;
   15. to order or apply non-ionizing radiation in lithotripsy, magnetic resonance imaging or ultrasound imaging, including any application of ultrasound to a foetus;
   16. to prescribe or fit an implant-supported prosthesis;
   17. to perform a psychosocial intervention with an expectation of treating a substantial disorder of thought, mood, perception, orientation or memory that grossly impairs judgment, behaviour, capacity to recognize reality or ability to meet the ordinary demands of life;
   18. to manage labour or deliver a baby; or
   19. to prescribe or dispense corrective lenses.

SUPERVISION OF RESTRICTED ACTIVITIES

4. A physician, surgeon or osteopath may consent to supervising a person performing a restricted activity if the person is:
   1. another regulated healthcare professional;
   2. a clinical trainee undergoing training leading to certification in a regulated health profession and the regulated member has taken reasonable steps to confirm that the supervised person is a clinical trainee; or
   3. an unregulated healthcare provider.
5. A physician, surgeon or osteopath who supervises a person performing a restricted activity must:
   1. be personally:
      1. competent to perform the restricted activity;
      2. authorized to perform the restricted activity without supervision;
      3. satisfied with the knowledge, skill and judgment of the supervised person performing the restricted activity; and
      4. responsible for the restricted activity performed by the supervised person;
   2. ensure it is safe and appropriate for the supervised person to perform the restricted activity on the particular patient;
   3. obtain the patient’s informed consent for the restricted activity to be performed under supervision, unless consent is not possible because of emergency;
   4. ensure the patient is provided with the name and role (e.g., physician assistant, student, etc.) of the person performing the restricted activity;
   5. provide a level of supervision commensurate with the skills and abilities of the person performing the restricted activity and the risk of harm to the patient;
   6. remain readily available for consultation during the performance of the restricted activity and for an appropriate follow-up period;
   7. have a quality assurance process in place to ensure the restricted activity is performed safely;
   8. ensure the person performing the restricted activity is clearly identified in the patient’s record; and
   9. ensure the equipment and resources used to perform the restricted activity are safe and appropriate.
6. A physician, surgeon or osteopath supervising a non-regulated person performing a restricted activity must ensure:
   1. the restricted activity is performed only under a direct order from a physician, surgeon or osteopath in the context of an established physician-patient relationship;
   2. there is minimal additional risk to the patient due to the non-regulated person performing the restricted activity; and
   3. the restricted activity is performed according to an established protocol and does not require medical knowledge or expertise.

7. A physician, surgeon or osteopath must not supervise a person performing a restricted activity if that person:
   1. would be in violation of section 46 of the Health Professions Act regarding Mandatory Registration; or
   2. is registered as a regulated health professional in Alberta, but is not authorized or permitted by their profession’s regulatory college to perform that restricted activity.

Supervision of Physician Assistants

8. A regulated member on the physician assistants register may, in the practice of physician assisting and in accordance with the Standards of Practice, perform the restricted activities referred to in clause (3) under the supervision of a physician, surgeon or osteopath registered to practise in Alberta.
9. A physician, surgeon or osteopath who supervises a physician assistant under this section must do so in accordance with the Standards of Practice.
10. A physician, surgeon or osteopath may only supervise a physician assistant to perform a restricted activity if:
    1. they are competent to perform the restricted activity; and
    2. it is appropriate to their scope of practice.
11. A physician assistant must not perform a restricted activity that the supervising physician, surgeon or osteopath is not competent to perform or that is not appropriate to the scope of practice of the supervising physician, surgeon or osteopath.

Supervision of Learners

12. A person who is registered on the physicians, surgeons and osteopaths student register is authorized to perform the restricted activities set out in clause (3), in the practice of medicine or osteopathy, but must be under the supervision of a physician, surgeon or osteopath registered to practise in Alberta and in accordance with the Standards of Practice.
13. A person who is registered on the physician assistants student register is authorized to perform the restricted activities set out in clause (3), in the practice of physician assisting, but must be under the supervision of a physician, surgeon, osteopath or physician assistant-instructor registered to practise in Alberta and in accordance with the Standards of Practice.
14. A physician, surgeon or osteopath who supervises students under this section must do so in accordance with the requirements for the supervision of students approved by the Council

Supervision of Non-regulated Persons

15. A person who is not prohibited under Section 1.6 of the HPA¹ is permitted to perform a restricted activity described in clause (3) only if that person:
    1.  while performing a restricted activity, has the consent of, and is being supervised (in accordance with clause (16)) by, a physician, surgeon or osteopath who is registered to practise in Alberta and is authorized to do that restricted activity independently; and
    2. is engaged in providing health services to another person.
16. When a physician, surgeon or osteopath supervises a person referred to in clause (15) performing a restricted activity, the person being supervised:
    1. must not be a regulated member registered on the physicians, surgeons and osteopaths student register; and
    2. must be authorized to perform the restricted activity being performed.
17.  If the person being supervised is a regulated member of another college, the physician, surgeon or osteopath must:
    1. be satisfied the other college is aware that the person is performing the restricted activity under supervision;
    2. supervise the person who is performing the restricted activity by being readily available for consultation by the person who is under supervision; and
    3. comply with the clauses of this standard governing the provision of supervision by regulated members of persons performing restricted activities in accordance with the Health Professions Restricted Activity Regulation.

Glossary

Competent: the regulated member is adequately qualified, suitably trained and has sufficient experience to safely perform work without supervision.¹

Restricted activities: high risk activities performed as part of providing a health service that require specific competencies and skills to be carried out safely.²

1 From the Alberta Occupational Health & Safety Code (Dec. 1, 2021).
2 From Alberta Health’s “Regulated health professions and colleges” page (“Restricted Activities” section).