Employer Responsibilities under the RHPA

1. the person is a member authorized by a health profession Act to perform the controlled act; or
2. the performance of the controlled act has been delegated to the person by an authorized health professional.

Controlled acts are health care actions that are considered potentially harmful if performed by unqualified persons. The Regulated Health Professions Act sets out the controlled acts that should only be performed by someone with the legal authority to do so. 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 allows RDs to take blood samples by skin pricking for the purpose of monitoring capillary blood readings while practicing dietetics:

Authorized act

3.1 In the course of engaging in the practice of dietetics, a member is

authorized, subject to the terms, conditions and limitations imposed on

his or her certificate of registration, to take blood samples by skin pricking for the purpose of monitoring capillary blood readings. 2009, c. 26, s. 7. 2

The authority to perform most of the controlled acts can be delegated to another person including a regulated health professional as long as the delegation is made "in accordance with any applicable regulations under the health profession Act governing the member's profession" (RHPA S28.  (1))

Registered Dietitians can be given the authority to order diagnostic procedures and treatments. This authority is transferred through a medical directive. The College of Dietitians of Ontario supports the delegation of controlled acts to Registered Dietitians as long as the dietitian has or acquires the competencies to perform the controlled act safely.

A guide on the use of orders, directives and delegations is available online to address questions regarding the use of orders and delegation.