Regulation Matters 2021 - Issue 1, May

Are You Practising Through A Delegation of a Controlled Act?

It is essential to recognize that the job responsibilities of dietitians are evolving due to changes in technology, changes in the dietetic body of knowledge and, the changes in programs and policies relating to the health care delivery system. These changes may mean that dietitians are now more commonly engaging in tasks that require a delegation than in the past. As a result, it is increasingly essential for dietitians to understand the laws and standards regarding the delegation of controlled acts.


The new Standard is about the appropriate and safe delegation of controlled acts. Controlled acts are higher-risk procedures. No one, including dietitians, is permitted to perform them without legal authority. The system of controlled acts is fundamental to the health regulatory system and the ideals of public protection in Ontario health care. The Regulated Health Professions Act, 1991, sets out 14 controlled acts that someone can only perform with the legal authority to do so.


The ability of a health care profession to legally perform a controlled act is set out in legislation, typically the “profession-specific” act, such as the Dietetics Act, 1991. Dietitians have been granted the legal authority under the Dietetics Act to perform only one controlled act, skin pricking, which falls within the controlled act of performing a procedure below the dermis. This authority permits dietitians to take blood samples by skin pricking to monitor capillary blood readings while practicing dietetics. Dietitians must have the professional obligation to ensure that they are competent to perform the procedure following the principle of client-centred care and safety, with proper infection control procedures and waste management disposal guidelines.


Dietitians can perform a controlled act if they have a delegation, which means they have obtained the authority to do so from someone who is authorized to perform the act by their profession-specific act, such as a physician, or if one of the established exceptions applies. For example, a physician may authorize a dietitian to dispense a drug such as insulin.

A delegation can be either specific or general and conferred through an order. An order can be in the form of a direct order or a medical directive. For instance, a direct order can be made specifically for a client whose treatment has been discussed with the physician. A medical directive is a form of direction that is not restricted to a specific client and usually sets criteria for when it can be used.


In addition to the controlled acts stipulated in the RHPA, there may be employer or facility-specific restrictions on the dietetic practice. For example, the Public Hospitals Act requires orders in hospitals for acts that otherwise would not require an order or delegation if performed outside of a hospital. For example, prescribing a therapeutic diet is not a controlled act. However, most public hospitals require a dietitian to obtain an order from a physician and ensure the order is recorded in the chart before issuing a therapeutic diet.


An integral part of competence is recognizing when you need more knowledge and skills to conduct the work assigned to you. Being legally authorized to perform a procedure covers the legal aspect of an activity. A dietitian must still act ethically and competently, always ensuring that professional standards are met.

If clients are better served by having a dietitian perform new tasks or roles, the dietitian must consider acquiring the new area of competence. This consideration is an essential part of the decision and planning around new tasks and roles.

Dietitians should review the performance expectations in the new Delegation Standard to identify any further learning that could be applied to professional development goals in their Self Directed Learning Tool.


We are excited about how this new Standard clarifies the roles and expectations for dietitians when asked to help during a pandemic. Following the Standard will help ensure that dietitians are practising appropriately under a delegation. We recommend that you listen to the recording of our Reg Talks webinar about the Delegation Standard posted on our website. 


We thank all dietitians and stakeholders who participated in the consultation survey about practising under a delegation of controlled acts.

Click here to take our quiz to test your knowledge about delegations.