Virtual Care FAQs
1. Can you confirm if we need to indicate that the service was provided virtually on the receipts?
Yes, it is recommended that you include that the dietetic care was provided virtually on receipts and invoices.
2. What are the options for clients wishing to send personal health information to a dietitian such as lab reports? Is mail an option for those who are not capable of encrypting their emails?
Yes, a client may choose to send their information to a dietitian in various ways. The dietitian may also collect information from them virtually, e.g. over the phone. What is important, here, is to explain the risks to the client and the safeguards available to protect their personal health information, such as, using an encrypted email and removing identifying information prior to mailing.
3. What about recording group sessions? Would we still need written consent if group sessions are recorded with no participants identifiers? (i.e. no names, voices, etc.)
If there are no client or participant identifiers, then written consent would not be necessary for group sessions. Requiring a consent would depend on what you are doing in the session and how the attendees are involved.
Be transparent about recording a group session: ensure that participants know the session is being recorded and what you are planning to do with the recording.
When working with clients, sessions are recorded only if the client provides an explicit, written, informed consent. Otherwise, you can reassure the client that you will not be recording the session and suggest that they should not either. If you or the client want to record the session, discuss this during the informed consent process.
4. Is a diet record considered personal health information?
Yes, a diet record is considered personal health information. Personal health information is very broadly defined in the Personal Health Information Protection Act, 2004 and includes the following:
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It must relate to an identifiable individual, including information that can be combined with other data (e.g., an ID number, code or key) to then identify the individual.
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it can be in oral or recorded format (thus simply asking a question even if the answer is not recorded can constitute collecting personal health information).
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It relates to the individual’s physical or mental condition, including his or her family health history; health care (including maintenance, preventative or palliative measures); health care provider; payment for the health service including health card number; substitute decision-maker; and/or non-health care information (e.g., home contact information) mixed in with other personal health information.
5. Is it OK to email handouts to clients or do they have to be encrypted as well?
It is good practice to encrypt all information sent to clients. Client handouts could contain personal health information. A dietitian needs to consider the characteristics of the information, the volume of information and the frequency, the purpose of transmission, the client’s expectations, availability of alternative methods and their risks, emergency and other urgent circumstances.
The Information and Privacy Commissioner of Ontario expects that email communication of personal health information sent by a healthcare provider will be secured from unauthorized access by encryption. Encryption scrambles the contents of an email so that only those with access to a secret key or password can unscramble and read it. Encryption minimizes the risk of unauthorized collection, use or disclosure of information. More information can be found on this IPC fact sheet: Communicating Personal Health Information by Email.
6. Can consent for virtual care be provided verbally and documented in the client's record?
Yes, obtaining informed consent for virtual care is a process, just like for in-person care, and may be obtained from the clients through express or implied consent and, afterwards, documented in the client’s record. Dietitians need to use their professional judgment to determine when to rely on expressed or implied informed consent by the client.
Because a client has signed up for a virtual visit (implied consent), does not necessarily mean that their consent has been informed. An informed client consent for a virtual visit includes:
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The information needed to make a decision about the treatment, including the: nature of the treatment; expected benefits, material risks and side effects of the treatment; alternative options; and the likely consequences of not having the treatment (Health Care Consent Act, 1996).
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Answers to all questions or requests by the client for additional information (Health Care Consent Act, 1996)
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An explanation about the purposes of the collection, use or disclosure of their personal health information
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That the client has the right to give or withhold consent (Personal Health Information Protection Act, 2004
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An explanation of the confidentiality and privacy risks involved in communicating personal health information (orally or written) through virtual means, with a description of the measures in place to protect it.
Refer to the Consent Standards for further details on the elements of informed consent.
7. I am a dietitian in private practice, and I work out of a multidisciplinary clinic. All these professions have returned to in-person care. The clinic has very strict safeguards in place relating to infection prevention and control. The College's guidance strongly encourages virtual care and seems to be strongly discouraging in person care. Will the College's guidance be changed to allow me to return to in person nutrition counselling, with those safeguards in place?
Dietitians are urged to use professional judgement to determine which clients can be treated virtually and which should to be treated in-person, in keeping with the protocols specified by the Ministry of Health to minimize the spread of COVID-19.
Dietitians must adhere to the measures outlined in the three documents below. These documents provide guidelines for feasibility and risk assessments, infection prevention and control, hazard controls, screening, personal protective equipment, and client scheduling to ensure physical distancing and safe care.
- Directive 2 for Health Care Providers (Regulated Health Professionals or Persons who operate a Group Practice of Regulated Health Professionals).
- Ministry of Health's guidance COVID-19 Operational Requirements: Health Sector Restart.
- The College’s a supplement to the Ministry’s operational requirements: COVID-19 Guidance for the Gradual Restart of Non-Essential Virtual and In-Person Care.
Any questions about virtual care?
Contact the Practice Advisory Service
416-598-1725 ;
1-800-668-4990 , Ext. 397 practice.advisor@collegeofdietitians.org