Submission to Shirley Pate Re: Alberta Health consultation on the Registered Nurses Profession Amendment Regulation

Date de parution : 07/10/2015
Personne(s)-ressource(s) : Joan Weir; Stephen Frank

July 10, 2015

Ms. Shirley Pate, Policy Analyst
Health Professions Policy and Partnerships Unit
Health Human Resource Planning and Strategy Branch
Professional Services and Health Benefits Division
Alberta Health
10 Floor, ATB Place North Tower
10025 Jasper Avenue
Edmonton, AB T5J 2N3

Submitted to:

Re: Alberta Health consultation on the Registered Nurses Profession Amendment Regulation

On behalf of the Canadian life and health insurance industry, we appreciate the opportunity to provide you with our comments on the proposed changes to the Registered Nurses Profession Regulation.

The CLHIA is a voluntary trade association with member companies that account for 99 percent of Canada's life and health insurance business. In Alberta, at the end of 2013, the life and health insurance industry provided some 2.8 million Alberta residents with supplementary health benefit coverage and made payments of about $2.7 billion under these plans. During 2013, the industry also reimbursed roughly $336 million for paramedical and other healthcare goods and services - which includes the reimbursement of services provided by registered nurses.

In addition, since a suggested change to the Registered Nurses Profession Regulation includes the ability to prescribe Schedule 1 drugs in certain situations, you may be interested to note that, that in Alberta during 2013, the private payer industry reimbursed roughly $972 million for prescription drugs.

The services of Registered Nurses are often included as part of an employee's overall benefits plan. The actual services that an RN may typically provide that are covered in any benefit plan will depend on the plan sponsor's (employer) choice of benefit plan for their employees. Services that may be covered range from the provision of footcare to services provided in the home. In addition, plan sponsors will normally include coverage for prescription drug payment when certain prescriber and dispenser conditions are met.

Changes to Terminology for Consistency
The CLHIA agrees and supports the adoption of terminology that is consistent for all regulated professions and, as much as possible, across provinces and territories. As an example, the change from 'temporary register' to 'provisional register' is a change towards a term that insurers are much more familiar with. This consistency will allow stakeholders in the provision and payment of healthcare services to more clearly understand the license status of a healthcare professional.

Changes to Reflect Current Practice
The proposed regulatory changes include a number of better 'fitness to practice' requirements. These include:

  • Requiring provisionally registered RNs to practice under supervision;
  • Reducing the number of registration exam attempts;
  • Revising the 'good character and reputation' requirements;
  • Adding a professional liability insurance provision;
  • The adoption of a jurisprudence requirement;
  • Expanding the continuing competency program and putting in place a new professional development requirement;
The CLHIA supports these changes that provide more rigour to the regulations and makes them more consistent with other healthcare professionals under the Alberta Health Professions Act.

Expanded Scope: Prescribing Schedule 1 Drugs
The proposed regulatory changes include the ability for RNs to perform the restricted activity of prescribing a Schedule 1 drug within the meaning of Part 4 of the Pharmacy and Drug Act, provided the RN has been authorized by the registrar. Should this particular regulation change proceed, we'd like to ensure that the Register of RNs is updated to include whether each licensed member has been given the authority by the registrar to prescribe Schedule 1 drugs so that insurers may quickly identify eligible prescribers for prescription drug claims.

The RN Register
The CLHIA welcomes and supports the re-write of Section 35 that will provide greater transparency regarding status of license and scheduled hearings, to consumers and payers.
We welcome the opportunity to work with Alberta Health on this initiative. We would be pleased to discuss this with you at your convenience or provide any other information that you would find helpful. Please contact Joan Weir, Director, Health and Dental Policy at (416)-359-2003 or


Original signed by

Stephen Frank
Vice President, Policy Development and Health