PandemicFAQs

1. Where can I get more information about the coronavirus pandemic?

Employers
Dietitians can consult their employer’s organizational protocol for operating during a pandemic. Dietitians, including those who are employers, can also keep informed with daily updates from the Ministry of Health and Ministry of Long-Term Care and Public Health Ontario.

Dietitians should work with their manager and organization if they are redeployed to ensure the following:

• they have the necessary knowledge and skill required (or receive necessary training) to work in any new capacity
• infection prevention and control measures are taken for patient safety and dietitian safety as per the Ministry of Health’s guidelines/organization guidelines  
• when completing tasks beyond scope of practice under another health care professional’s supervision, consider the Role & Task Framework and the Delegation Standard and document in the health records, as required
• when completing other tasks, e.g., tasks related to COVID-19 screening, document as per the employer’s directions
• appropriate liability insurance is in place in the expanded role and responsibilities performed  
• Dietitians only perform controlled acts if delegated by a health professional who has the authority to delegate the specific controlled act(s).  See Delegation Standard.

In these extraordinary times, thank you for providing these vital services to Ontarians. You and your colleagues are valued and appreciated in stepping up and filling the need for additional support.

2. Can my employer direct me to do other tasks (e.g. outside of dietetic scope) during a pandemic?

There are no simple answers to this question. During an infectious disease outbreak, demands for care may result in health care providers being asked to perform other tasks in their organization. In some cases, dietitians may be asked to provide care in an area of dietetic practice they do not commonly work in, or to assist in area that is outside of the dietetic scope of practice. 

Individual circumstances will vary depending on the practice setting, legislation and nature of professional practice. Consider your personal competence (knowledge and skill). The College’s Role and Task Framework may be helpful when considering opportunities for assuming new tasks, roles and responsibilities during a pandemic. 

Example: How to Use the Role and Task Framework to Perform a Temperature Screen

A. Is the new task or role within the dietetic scope of practice?
Temperature checks can be within dietetic scope of practice when it is being measured as part of a nutrition assessment (i.e. the assessment of fluid status, consideration of energy requirements/stress factor assessment). However, if the RD is taking temperature checks for circumstances that do not relate to their nutrition care plan, e.g. for purposes of routine screening, an organization would need to determine if this is considered a diagnostic procedure/treatment. Depending on how the temperature check is being used and the practice setting, different circumstances may apply.

B. Are there any legal barriers restricting an RD from performing the task (e.g., performing a Controlled Act)? For example, would an authority mechanism be needed for an RD to perform the task?
Temperature checks are not a controlled act. If an organization determines that temperature checks are screening and not diagnostic procedures/treatment, authority mechanisms would not be required to permit dietitians to perform temperature checks. If deemed a diagnostic procedure/treatment, dietitians may be delegated to perform the task as necessary per the applicable legislation (i.e. in a public hospital).

C. Do I have the required skills and competence to perform the new task? If not, how can I obtain what is necessary to become competent?
Dietitians would need to have the appropriate skills and competence to perform temperature checks. Dietitians could be easily trained by a colleague on how to use the thermometer and how to perform a reading. 

It would also be important for dietitians to be trained on the steps involved in the screening and to know the protocol to follow depending on the temperature reading result.

Dietitians will also need to be careful to avoid violating the controlled act of communicating a diagnosis. Dietitians may indicate that the temperature is elevated, but they are not permitted to label it as a clear medical diagnosis.
 
D. What are the interprofessional care team possibilities? Given all of the local circumstances, who is the most appropriate person(s) to perform the task (e.g., an RD, or another health care provider/team member, or both)?
Dietitians performing temperature checks may be helpful in some circumstances. This may reduce the pressure and demand on the health care system as the pandemic evolves. Dietitians are asked to use their professional judgement and continue to seek direction from their employer.

3. Will my obligations and accountabilities change if caring for clients diagnosed with (or suspected of having) COVID-19?

Dietitians’ obligations and accountabilities do not change and they have a fundamental responsibility to act in an ethical manner. Dietitians are accountable to all the standards of practice. Key resources to keep in mind 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.

4. How can dietitians remain aware of infection risks?

Dietitians must be risk-aware and to identify any potential type of harm when practising dietetics, including infection risks, as applicable. Dietitians can keep up to date on Infection Prevention and Control (IPAC) through Public Health Ontario’s website and mitigate infection risks by:

• Applying proper hand hygiene principles;
• Wearing personal protective equipment (PPE) as appropriate to prevent and control the transmission or spread of infection;
• Developing and ensuring appropriate protocols are in place and, where applicable, collaborating within teams and working with your employer to review organizational policies;
• Using evidence-based decision making to inform practice;
• Understanding and following workplace organizational policies about infection prevention and control; and
• Being aware of  precautionary measures to minimize the risk of infecting themselves, colleagues, clients and others as described on the Public Health Ontario’s Coronavirus information page.

5. Can I refuse to provide dietetic services to an infected client?

6. What are my accountabilities as a dietitian manager during a pandemic?

Employers are responsible for establishing a safe work environment that supports safe and effective client care. This includes appropriate staffing coverage, infection control measures and personal protective equipment, as applicable including proper training and fitting. Access and share up to date, evidence-based information with your staff. Provide staff with clear policies, as required.
 
Act when client care may be compromised. This includes identifying strategies to prepare for, reduce and resolve situations that may leave clients without the dietetic services needed.

To ensure a safe environment, consider the following questions:

• Have you employed strategies to prioritize client care needs?
• Have you explored concerns with staff and communicated your organization’s plan to address these concerns?
• Have you included front line staff in the creation and implementation of strategies?
• Is there a readily available system for replacement staff?
• Are strategies in place to facilitate the reorganization of workload, if needed?
• Are there clear policies and lines of communication for dietitians to follow when staffing is short?
• Do staff have the necessary competence (knowledge, skill and judgment) to complete the task? If not, what additional training is needed?
• Have I provided my staff with relevant training/upskilling based on best practice and evidence?

7. When working remotely, how do I obtain consent via phone/web?

A dietitian’s professional obligations are the same for services delivered in-person or via virtual practice. This includes obligations for consent and others (i.e. documentation, access to records, privacy, confidentiality, security and retention of records. Please refer to the Virtual Care, Social Media & Technology page. The Information and Privacy Commissioner of Ontario has guidelines for health sector – Privacy and Security Considerations for Virtual Health Care Visits.
 
With regards to obtaining consent for virtual practice (telephone or web), here are a few considerations:

• Obtaining consent is a process.
• Dietitians must obtain knowledgeable consent to collect and use personal health information (See Standard 2 in Consent Standards).
• Clients should be informed of the process and the security issues of transmitting personal health information over the phone and internet (including email) in order to provide knowledgeable consent to a dietitian who is collecting and using personal health information. See the Consent Standards and Ten Principles of Privacy for Personal Information  
• Dietitians must also obtain informed consent for nutrition treatment which includes nutrition assessment provided via virtual care (See the Consent Standards and Telephone/Web Counselling).
• Dietitians should document that consent has been obtained from the client as per the Consent Standards (See Standard 9 in the Consent Standards).
• Informed consent can be express (oral or written) or implied (inferred from the words or behaviour) when using telephone and/or web-based counselling. For more details, please review the Professional Practice Standards of Consent to Treatment and for the Collection, Use and Disclosure of Personal Health Information.

8. What about charting during the pandemic? What’s the expectation?

Dietitians should implement the documentation method that makes practical sense for their practice setting while also achieving the College’s Professional Practice Standards for Record Keeping  (i.e. the minimum expectations dietitians must meet in practice). In addition, the Record Keeping Guidelines provide best practice suggestions. 

During re-deployment:

• Dietitians must follow organization’s policies regarding documentation (e.g. if you are screening, tracking through check boxes may be enough)
• As a guideline, if the original health care provider (e.g. nurse, speech language therapist) was required to document the intervention, then document in the same way 
• If you are unclear – ask your organization

Good record-keeping is important to maintain, not solely for meeting the standards as records may be used later for research and debriefing about the pandemic. 

To summarize, dietitians’ obligations and accountabilities do not change, and they have a fundamental responsibility to act in an ethical manner. Dietitians are accountable to all the standards of practice. In addition, dietitians must use professional judgment to make decisions in the best interests of their clients.

9. What’s the College advice on use of Personal Protective Equipment (PPE)?

In terms of information on the types of Personal Protective Equipment (PPE) to use and when, the College does not issue this type of guidance.  Please refer to Public Health Ontario’s PPE recommendations. There is a technical brief – Interim IPAC Recommendations for Use of Personal Protective Equipment for Care of Individuals with Suspect or Confirmed COVID-19 (December 15, 2021) and applicable directives from the Chief Medical Officer of Health.  Please continue to monitor these resources regularly, as recommendations may change. 

We know the current environment is stressful for many of you, and we thank you for your efforts to support safe patient care. If you have concerns, speak to the broader health care team to discuss strategies on how to encourage the appropriate use of PPE. Work with your employers to assess the patient, situation, and the environment for the appropriate use of PPE; not every patient situation may require the same precautions.

We know that dietitians are dealing with questions that arise as the nature of this pandemic evolves. The reality is that there will be critical decisions that require good professional judgement and collaboration in the moment.

10. I’m a dietitian working in public health. I’ve been asked to assist in providing COVID-19 test results. Do I need a medical directive?

We are aware that dietitians may be re-deployed to assist with tasks that are not typically part of the dietetic scope in any workplace setting, for example like calling clients with COVID-19 test results and providing guidance.

Using the College’s Role and Task Framework, we can help when considering new work tasks for dietitians:

• Is the new task or role within the dietetic scope of practice and practicing dietetics? No, this would not be within dietetic scope, however, dietitians can be re-deployed to assist with tasks that are not typically part of the dietetic scope and this may be helpful in some circumstances. This may reduce the pressure and demand on the health care system. Dietitians are asked to use their professional judgement and continue to seek direction from their employer.  
• Are there any legal barriers restricting an RD from performing the task (e.g., performing a Controlled Act)? For example, would an authority mechanism be needed for an RD to perform the task? Dietitians need to consider the controlled act of communicating a diagnosis. If your organization determines that communicating test results is a controlled act of communicating a diagnosis, then authority mechanisms (direct order or medical directive) would be required to permit dietitians to perform this task. Dietitians should work with their employers and other team members to ensure that this is done safely, ethically and competently. 
• Will the dietitians be required to have additional skills and competence to perform the new task? Your organization should ensure proper training on atypical tasks for dietitians, including resources to ensure the dietitians obtain what is necessary to become competent (what is the necessary knowledge, skill and judgment). 
• What are the interprofessional care team possibilities? Given all the local circumstances, who is the most appropriate person(s) to perform the task (e.g., an RD, or another health care provider/team member, or both)? Dietitians should work with their employers and other team members to ensure that this is done safely, ethically and competently. Individual circumstances will vary depending on the practice setting and nature of professional practice. 

Employers are responsible for establishing a safe work environment that supports safe and effective client care. This includes appropriate staffing coverage, infection control measures and personal protective equipment, as applicable including proper training and fitting and providing staff with clear policies, as required. 

In addition, dietitians are required to hold professional liability insurance when practicing dietetics that aligns with the College's requirements (this can be through their employer’s coverage or through an individual policy). Please see FAQ #14 for details.

11. What about insurance when I’m re-deployed?

12. I am asked to do tasks in the ICU, and I have only ever worked in outpatient settings. What should I do?

We are aware that dietitians may be re-deployed to assist with tasks that are not typically part of the dietetic scope or other roles within the profession of practising dietetics (e.g., working in ICU when you have only worked with outpatients). Please review FAQs 2-5, 11-12, and 14 and consider the following information:

• When practising dietetics, dietitians should always practise within their personal scope of practice so they can provide safe, ethical and competent nutrition services. 
• Treating or attempting to treat a condition that was beyond a dietitian’s competence is professional misconduct (Professional Misconduct Regulation). 
• As a dietitian, you have a professional obligation to ensure that you have the appropriate knowledge, skills & judgment to perform a role or task within your dietetic practice.  

• Being transparent, open and honest
• Checking organizational policies
• Consulting with colleagues and/or interprofessional team members as appropriate
• Considering a collaborative, interprofessional approach to providing services 
• Acquiring new knowledge 

Continued learning and education are essential in order to be able to provide evidenced-based decision-making, up-to-date information and advice. Ask for the appropriate training, competencies and knowledge. 
You can also ask to be coached by another health professional on the team who has more experience. This coaching could be given by another dietitian, or any other health professional with the appropriate skills and knowledge.

The College’s Role and Task Framework and Collaborative Care Guidelines may also be helpful to assist dietitians to consider requests and opportunities for assuming new tasks and roles, including taking on new responsibilities, if needed during a pandemic.

Dietitians performing roles they may not typically provide, like ICU coverage, may be helpful in some circumstances. This may reduce the pressure and demand on the health care system as the pandemic evolves. Dietitians are asked to use their professional judgment and continue to seek direction and appropriate supports, as applicable from their employer.

13. I’m providing essential care virtually. What platforms can I use during virtual care?

We do not advise on the types of platforms; the technology is constantly evolving and there are many options — we cannot say what is considered secure and encrypted, etc. We encourage dietitians to research and review the Virtual Care, Social Media & Technology page.
 
We acknowledge the need for flexibility in a public health emergency. However, a dietitian needs to take reasonable steps to ensure that the personal health information in their custody or control is protected against theft, loss, and unauthorized use or disclosure. One way this is accomplished is using secure, encrypted technologies.  If you are employed, ask your employer first. 
 
The Information and Privacy Commissioner of Ontario has guidelines for the health sector — Privacy and Security Considerations for Virtual Health Care Visits which can be a helpful resource to assist dietitians and their organizations in providing virtual care. 

If you are in private practice, you may want to search Canadian service providers and check service agreements for compliance (e.g., is the application encrypted, are they compliant with legislation etc.?). In addition, the Dietitians of Canada COVID-19 Pandemic Page may be helpful. We encourage dietitians to check with their insurance providers. A lawyer can assist you in determining if a platform is compliant with the legislative requirements. 

You may also wish to contact both the Information and Privacy Commissioner of Ontario and Federal Privacy Commissioners for further information. You can conduct a privacy impact assessment (PIA) regarding the collection, use and disclosure of personal health information for the purposes of deciding to use an app/platform. A PIA is an organizational risk management tool and a process used to identify the effects of a given process or other activity on an individual’s privacy.

14. I am continuing to provide virtual care. What should I consider?

Virtual care (also called telepractice) for the purpose of this FAQ is defined as Communication of a client’s health status and/or the treatment/intervention needed to support their care needs via: 

• Phone calls
• Video conferencing
• Secure messaging
• Remote monitoring 

• Nutrition assessments and re-assessments
• Nutrition treatment interventions, including any monitoring and evaluation related to the treatment or intervention 
• Videoconferencing for assessments, as required 
• Client/Caregiver education/training to support client care and/or self-isolation efforts
• Client education/training related to nutrition care
• As a compliment to essential dietetic “hands-on” care
• Replacing in-person care when a physical visit isn’t possible, or necessary
• Any other service aligned with the goals of this guidance and approved by employer or government agency 

• Your professional obligations do not change, regardless of the way you provide care.
• Providing virtual care requires consideration of the Code of Ethics, practice standards, and legislation. 
• The use of technology may require education and training, and one needs to consider their own individual competence, as well as the comfort and competence of the client. 
• If you are employed, please follow your employer policies as well as all College Standards, Guidelines, etc.  
• Please refer to the Virtual Care, Social Media & Technology page.
• The Information and Privacy Commissioner of Ontario has guidelines for the health sector – Privacy and Security Considerations for Virtual Health Care Visits which can be a helpful resource to assist dietitians and their organizations in providing virtual care.

• Should I provide virtual care for this client or groups of clients?
• What is the right type of contact at the right time?
• Would this client benefit from a virtual session or does the visit need to be in-person? Or can dietetic service be hybrid (partially virtual/partially in-person) for any dietetic care that you determine cannot be done virtually for whatever reason using your judgment, considering the technology you have available and your practice environment, client risk etc. (e.g. physical examination).
• Is there a need for virtual care for this client right now? Is the client interested in receiving virtual care at this time? Have I obtained informed consent?
• Where is your client located? If the client is outside Ontario, have you contacted the regulatory body where the client resides? We cannot speak for other jurisdictions and advise you to seek guidance if providing care outside of Ontario. If you choose to provide virtual care in another jurisdiction, you are expected to follow the professional obligations of the regulatory body if one exists, and all relevant laws and regulations of the jurisdiction. Dietitians must be transparent with clients to identify where they are registered. 
• If you are offering virtual care, ensure that your liability insurance covers you to practise virtually. If you are providing virtual care outside of Ontario/Canada, ensure you have liability insurance coverage and have accounted for any currency exchange. 
• Ensure you provide care in private setting and the client is in a private setting to maintain confidentiality. 
• Billing should be transparent. The invoice should indicate that virtual care was provided. 

• Consider working by phone or other technologies. Consider how easy the technology is for you to use and how easy it is for the client. What is the client’s comfort, interest/desire for virtual care? What is the client’s available technology and history of use? What other client specific factors should be considered (e.g. hearing and vision abilities, comprehension, cognition, literacy etc.). In addition, how can you keep client information private and secure? What are the benefits, risks and limitations of virtual care?  You must have the technical competence to use the technology effectively to provide virtual care (e.g. knowledge and skill) and dietitians are expected to use their professional judgment to determine the appropriateness of virtual care for each client at all stages of nutrition care.
• Confirm that your professional liability insurance covers you for virtual practice.
• Ensure your billing is transparent and your invoice indicates that you provided the service remotely.
• If providing care to a client outside of Ontario, contact the regulatory body in the jurisdiction where the client is located to confirm the requirements during this time. While circumstances may change during a pandemic, we cannot speak for other jurisdictions. 
• If you proceed with in-person care, you must have in place strict protocols, as required, around risk assessments, including an organizational risk assessment and a point of care risk assessment as per the Ministry of Health’s direction COVID-19 Operational Requirements Health Sector Restart. In addition, hierarchy of hazard controls, infection prevention and control, screening, personal protective equipment, and client scheduling to ensure physical distancing and safe care.
• Decisions about client visits must be in keeping with the principles set out in Directive #2: Proportionality; Minimizing Harm to Patients; Equity; and Reciprocity. 

Please visit the Virtual Care, Social Media & Technology section of our website.