The College of Midwives of Ontario is consulting the public and midwives on a proposed change to the Designated Drugs and Substances Regulation under the Midwifery Act, 1991, to add the Respiratory Syncytial Virus (RSV) monoclonal antibody to the list of drugs and substances that midwives can prescribe and administer. RSV is a serious, potentially life-threatening illness which leads to the hospitalization of newborns in Ontario every year, and monoclonal antibody immunization is currently recommended by NACI to prevent this disease.
Background
The College’s Designated Drugs and Substances Regulation O. Reg. 188/24 came into effect on May 3, 2024. This regulation included an expansion to the list of drugs and substances that midwives may prescribe and administer on their own authority, including the RSV vaccine, enabling clients in midwifery care to directly access this immunization.
Immunization is a broad term referring to the process of making someone resistant to disease. Immunizations (also called immunizing agents) include a wide range of substances that help the body fight disease. The terms vaccination and immunization are often used interchangeably, but technically, vaccination is a type of immunization that uses a vaccine to trigger the body’s immune response.
On May 17, 2024, two weeks after the revised regulation came into effect, the National Advisory Committee on Immunization (NACI) released a statement recommending the RSV monoclonal antibody as the immunizing agent for the 2024-25 RSV season to protect newborns from serious illness. Monoclonal antibodies are safe and commonly used immunizing agents, however, they are not technically considered vaccines. The Designated Drugs and Substances Regulation specifically lists the RSV vaccine, and therefore newborn midwifery clients were not able to directly access the RSV immunization from their chosen primary care providers in the 2024-25 RSV season.
Proposal
The College is proposing to add the RSV monoclonal antibody to the Designated Drugs and Substances Regulation, to allow midwives to prescribe and administer the immunization to protect newborns from RSV and provide the immunization by injection.
Review the College’s proposed changes to the regulation. (Proposed additions in red)
Consultation
The College has a duty to consult on changes to regulations. The College’s Board has directed the College to write to the Minister of Health to seek an exemption or abridgement from the requirement to hold a public consultation on this proposal. The Board understands the addition of this one immunization to the Regulation to be a minor change that is in keeping with the spirit of the existing Regulation.
The consultation will be up to 60 days but may change pending the response from the Minister of Health. The consultation will close no later than Tuesday, August 26, 2025. If you have comments you would like to share, you are encouraged to submit them. Any collected feedback will be reviewed by the College and shared with the Ministry.
We welcome all feedback from members of the public, clients, midwives, and system partners. Please share your comments on our website below.
FAQs
RSV is a serious, potentially life-threatening illness which leads to the hospitalization of newborns in Ontario every year. Midwives are primary health care providers who have the knowledge, skills, and judgement to provide immunizations to newborns, and are already providing vaccinations to help prevent the spread of RSV. Ontarians must have access to immunizations that protect against serious illness, and midwives are ideally positioned to provide this service to their clients.
RSV (respiratory syncytial virus) is a serious respiratory illness that can be particularly severe for newborns and persons with pre-existing conditions. Following seasonal spikes in transmission rates and hospitalizations due to RSV in Ontario, immunization is considered the most effective method to protect Ontarians from viral infection.
Providing immunizations for newborns is in the scope of midwifery practice, and midwives are trained to prescribe and administer immunizations.
To prescribe and administer the RSV monoclonal antibody, as with all vaccines and immunizations, midwives will have to ensure they have sufficient knowledge, skill, and judgment to use the drug or substance safely and effectively.
The College maintains the evidence-informed position that midwives prescribing and administering drugs and substances to a list is not in the interest of clients. The College recognizes that specified lists of drugs and substances are at risk of becoming outdated as new drugs and substances become available and practice standards change. We will continue to work with the Ministry to find a sustainable solution for clients to continue to receive optimal care by midwives as medication treatment evolves.
In October 2024, the College worked with the Standing Drug Regulation Committee (a consortium of Ontario health profession regulators and associations of which the College is a member) to submit a proposal to the Minister of Health to consider a prescribing framework within scopes of practice. The College will continue to work towards regulatory changes which support midwives to prescribe and administer to their full legislative scope.
In the meantime, we see the addition of the monoclonal antibody to the Designated Drugs and Substances Regulation as a positive step as the College recognizes that it is in the interests of newborns under midwifery care, and their families, to propose a minor change to the current regulation that would easily address the issue in time for the upcoming RSV season.
Ontario Medical Association on August 26, 2025
The Ontario Medical Association (OMA) appreciates the opportunity to participate in the College of Midwives of Ontario’s (the College) consultation regarding the proposed scope of practice change to the Designated Drugs and Substances Regulation under the Midwifery Act, 1991. The proposed amendment is to update the existing drug list to allow midwives to prescribe and administer RSV monoclonal antibodies (Beyfortus).
The OMA is supportive of a collaborative, team-based health care delivery model where every professional can work to their full scope of practice and be appreciated for their unique skills and experience and that supports an efficient and effective system. Team-based care models have demonstrated success in improving patient access to allied health professionals and quality of care.
While not technically classified as vaccines, monoclonal antibodies are safe, effective, and widely recognized immunizing agents. Including them in the regulation would allow midwives to prescribe and administer the RSV monoclonal antibody directly to newborns in their care, improving timely access and enhancing continuity of care within the midwifery model.
Physicians have reported that the current limitation of midwives not being able to prescribe and administer RSV monoclonal antibodies has placed an added burden on hospital teams, who are required to create individualized medical directives to maintain equitable access for infants under midwifery care. Amending the regulation would help address this gap, streamline delivery of care, reduce administrative workload, and promote a more integrated, collaborative healthcare system that centers newborn safety and family choice.
For this change to be successfully implemented, the OMA would like to highlight the importance of midwives having the necessary knowledge, skills, and training to safely prescribe, administer, and counsel patients about the RSV monoclonal antibody. The OMA would also like to take this opportunity to emphasize the importance of appropriate education, clinical standards, and accountability mechanisms to support the safe integration of this immunization into midwifery practice.
Further, physicians have highlighted the need for digital infrastructure to support effective interprofessional communication and ensure continuity of care across providers. The OMA would encourage the College to echo the OMA’s calls to the province to develop an electronic immunization record that is integrated into the EMRs of all healthcare professionals who immunize. Without such systems, the risk of fragmented care or missed information increases and could result in an incomplete patient history.
Finally, the OMA would like to confirm if there will be any restrictions on which settings midwives would be able to administer RSV monoclonal antibodies. It will be important to ensure that midwives have the training and expertise needed should there be any adverse reactions in a non-clinical setting, for example in the home.
Once again, we appreciate the opportunity to comment on this proposal and recognize its potential to improve access and reduce burden on the system. Successful implementation will depend on appropriate training, clinical standards, and infrastructure to support interprofessional communication and continuity of care. We will continue to monitor the progress of this proposal. We welcome further discussion on team-based care and system opportunities.
Midwife on August 9, 2025
I am in support
Anonymous on August 7, 2025
Please allow midwives to prescribe the RSV vaccine. It increases accessibility, removes barriers of going to the GP which is not an option for a lot of people in Ontario. It also allows continuity of care. I am currently pregnant and due next month. I had to book with my GP to access the vaccine with long wait times and would have preferred to receive it from my midwife who provided more evidence based research than my GP did.
Anonymous on July 25, 2025
As a neonatal nurse practitioner, I fully support midwifes having authority to protect vulnerable infants by prescribing and administering RSV monoclonal antibodies. Please make it happen by RSV season so no babies are left behind!
Anonymous on July 25, 2025
As a Pediatric nurse and parent, I support this initiative to increase access to this essential treatment
Association of Ontario Midwives on July 24, 2025
Thank you for the opportunity to respond to the public consultation on a proposed change to the Designated Drugs and Substances Regulation under the Midwifery Act, 1991, to add the Respiratory Syncytial Virus (RSV) monoclonal antibody to the list of drugs and substances that midwives can prescribe and administer.
Swiftly making this change is necessary to ensure safe and convenient care for newborns during the 2025-26 RSV season. The change will improve access for more than 13,000 newborns (20% of the provincial total) who will be born in the care of midwives this fall and winter.
The AOM supports the CMO’s position that public safety is best served by allowing midwives to prescribe and administer drugs and substances necessary for client care within the midwifery scope of practice. Regulation through lists of drugs and substances must end, but the proposed regulation change in the current consultation will address the many challenges our members have faced concerning access to RSV protection for newborns in their care. Midwives are outraged by the unacceptable impact on their clients, the cost to the health care system and the strain on the midwifery workforce created by the regulatory barrier which will be removed by the proposed change.
Impact on Clients
Because midwives cannot provide the RSV monoclonal antibody on their own authority, midwifery clients have experienced:
o delays in being discharged from hospital because they were waiting for physician consultations for their newborn to receive the immunization.
o unnecessary trips to a hospital or clinic in winter weather with their newborn babies who were born at home or in birth centres.
o a disproportionate burden of care delays and extra visits on families who already have access barriers created by geographic location and/or social determinants of health.
o increased risk of exposure to contagions. The regulation forces clients to take their newborns to hospitals or clinics when, for some clients, an important reason to choose an out of hospital birth is to protect themselves, their families and their newborns by avoiding places where sick people are gathered.
Health Care System Costs
The omission of the RSV monoclonal antibody from the regulation creates costs beyond the negative experiences of midwifery clients, including:
o unnecessary physician visits and OHIP billings as, prior to the Public Health recommendation for newborns to receive this immunization as soon as possible after birth, most newborns in midwifery care could receive all the care they needed in the first two months of life from their midwives, who do not bill fee for service.
o added workload for hospital staff and community clinics to care for newborns in midwifery care.
Impact on the midwifery workforce:
Like many health professions in Ontario, midwifery is experiencing provider shortages and burnout. Not allowing midwives to provide the RSV monoclonal antibody on their own authority has not relieved them of the responsibility of ensuring the best standard of care for 20% of the province’s newborns. It has only made it more difficult because:
o the burden of finding solutions to the access problem has fallen on individual midwives.
o creating piece-meal approaches and work arounds, different in each of the 250 communities they serve, to get access to the RSV monoclonal antibody for every newborn in their care, has been exhausting and frustrating for midwives.
o midwifery clients deserve and expect to receive the right care, in the right place, from the right provider, and they are unhappy that regulation prevents them from accessing critical RSV protection for their newborns from their midwives.
o in requiring list-based regulations, and a poorly planned roll-out of a public health program, the needs of newborns in midwifery care have been disregarded. Midwives want the problem fixed by those who caused it.
BORN data on midwives’ perceptions of the 2024-25 RSV season
Midwife responses to a survey conducted by BORN on experiences with the 2024-2025 Ontario Infant RSV Prevention Program confirm the feedback that the AOM received from members:
o A majority of respondents reported challenges with nirsevimab (RSV monoclonal antibody), with 1 in 3 reporting significant challenges, including difficulties actioning medical directives, exclusion of out-of-hospital births and delays in protection.
o Only 50 percent responded that midwifery clients had equitable access to RSV protection.
o Respondents commented that not having the RSV monoclonal antibody included in the regulation:
“has a significant impact on midwifery families”
(led to) “some clients electing to forego it altogether”
“was a big oversight that led to much work”
“impacted the trust and professional respect towards midwives”
Can midwives safely prescribe and administer RSV Monoclonal Antibody?
Prescribing, administering, and maintaining the cold chain during storage and transportation for the RSV monoclonal antibody is very similar to care midwives have safely provided for decades.
Midwives have training and experience prescribing and administering Hepatitis B vaccines and Hepatitis B immune globulins to newborns and RhD immune globulins to clients in all settings where they work, including clients’ homes, because these immunizing agents have been authorized to midwives in regulation since 1994.
In 2024, many other immunizing agents were added to the Designated Drugs and Substances Regulation, including the RSV vaccine. Because they can prescribe and administer the RSV vaccine under their own authority and must provide informed choice discussions about both the vaccine and the monoclonal antibody, midwives have a firm foundation of knowledge about RSV prevention. Most midwives have already administered the RSV monoclonal antibody to newborns during the 2024-25 RSV season.
The AOM supports midwives whenever their pharmacopeia is expanded, including RSV prevention measures, with website resources, webinars, a mobile app and weekly updates on programs and best practices. There should be no doubt that midwives will be ready to safely provide this care.
Thank you for considering the AOM’s input in the consultation and for the actions that the CMO is taking to allow midwives to provide care to their full and appropriate scope of practice. Midwives across the province are hoping that the regulation change can be made in time to make the upcoming RSV season easier and safer for their clients and newborns.
Anonymous on July 17, 2025
Excellent! Thanks for doing this work.
Anonymous on July 15, 2025
Would midwives also be able to administer the maternal RSV vaccine during pregnancy for clients?
Stakeholder on July 14, 2025
As a paediatrician, I am in agreement with this proposal.
Stakeholder on July 9, 2025
As a paediatrician, I wholeheartedly support the administration of RSV monoclonal antibody by midwives.
Stakeholder on July 9, 2025
As a community Pediatrician, I believe it is imperative that midwives be able to prescribe this important immunization. The goal is to have as many babies as possible receive this important treatment to prevent RSV infection. Not allowing midwives to prescribe it is a barrier to care, and further burdens other community providers, such as Pediatricians and family physicians.
Stakeholder on July 8, 2025
I agree to MW to prescribe RSV Antibodies
I m a Neonatologist
Anonymous on July 8, 2025
I fully support the addition of the RSV prophylaxis (long action immune globulin) to the midwives list of drugs that they can administer. Midwives are uniquely positioned and have fantastic relationships with their clients to provide the needed education on what RSV is and the benefits for RSV prophylaxis in infants, especially during the first year of life. It is important that we capture families at the time of birth in providing this prophylaxis so that babies are covered immediately against severe RSV infection which ultimately helps to minimize strain on our healthcare system at all levels (community, ED’s and inpatient units).
Stakeholder on July 7, 2025
I am a neonatologist at the Kingston Health Sciences Centre in Kingston , ON. I fully support the expansion of the midwifery scope of practice to include prescribing RSV mononclonal antibodies to the infant’s under their care. This scope-of-practice change would streamline program delivery, reduce institutional administrative burden, and close a care gap for a large number of infants. This is particularly true for our organization, where we have midwifery providing well newborn care for newly born infants, as well as followup care for a brief time following discharge. They already operate under a medical directive to do this but makes much more sense that this be added to their scope.
Midwife on July 7, 2025
This past cold & flu season (2024-2025), we saw a significant decrease in the number of babies requiring readmission to hospital as a result of the Nirsevimab RSV antibodies offered at 24 hours of age. The uptake was better than anticipated in our community, which was a significant relief for our already over-extended pediatricians and nursing staff. Unfortunately, because midwives were not awarded prescribing capabilities for Nirsevimab, the babies discharged home before 24 hours under the care of a midwife, or those born at home, had impediments to accessing this protective intervention and were unfairly and unjustly disadvantaged. The midwives who served their communities by decreasing the lengths of stay in hospital, or caring for families at home, were then penalized for the benefits they provided the health care system. Midwives should be able to offer the same routine care to any childbearing family in Ontario. We are able to offer Tdap, RSV PreF, Rotarix, Vaxneuvance, Pentacel, MMR, varicella, Hepatitis B, Covid & Influenza vaccines without hindrance. It would be logical and beneficial to include RSV antibodies as part of the care midwives can provide.
Stakeholder on July 7, 2025
No problem with them administering Byfortus
Member of the public on July 6, 2025
I’m definitely in support!
Anonymous on July 6, 2025
Adding RSV monoclonal antibody to the Designated Drugs and Substances Regulation would streamline access to this crucial medication for newborns. By allowing RMs to prescribe and administer this treatment under their own directive, we will reduce barriers to care and confusion about processes, ultimately improving care for clients. This change would leverage the skills and knowledge of RMs, enhancing the efficiency and effectiveness of RSV prevention PH programs. It’s a practical step towards better healthcare delivery and aligns with the goal of optimizing patient care.
Midwife on July 5, 2025
I fully support this change to the Drug regulation for midwives that the CMO is proposing. When RSV monoclonal antibody was recommended for newborns this year we had to quickly pass a medical directive in our hospital to allow midwives to order and administer the RSV monoclonal antibody under the order of a paediatrician. This proposed change will eliminate the need for a medical directive and allow midwives to order and administer this recommended antibody.
Stakeholder on July 5, 2025
I am a General Pediatrician in Toronto. I support this proposal. Reducing administrative burden and burden on pediatricians and primary care provider to provide this vaccination will be a step in the right direction.
Stakeholder on July 4, 2025
I agree that midwives should be able to prescribe RSV monoclonal ab. They need to know the risks and benefits prior to doing so but this will definitely streamline work for hospital pediatricians and midwives alike. Given that midwives can already give vitamin K, it seems reasonable they should give RSV monoclonal ab.
Stakeholder on July 4, 2025
I am fully supportive of midwives ordering the RSV vaccine,, for women and babies under their care.
Member of the public on July 4, 2025
This would be a welcome scope-of-practice change for hospital midwives that will help to ensure there are no gaps in infant care and increase ability to provide protection for vulnerable newborns. This would also help prevent placing additional burden and cost to other medical teams and streamline care.
Children's Hospital at London Health Sciences Center on July 4, 2025
I approve of midwives being able to prescribe and administer Beyfortus or other RSV monoclonal antibody for the prevention of RSV.
Stakeholder on July 4, 2025
I am in support of this change
Stakeholder on July 4, 2025
I am a community Pediatrician and fully support midwives being given the designation to prescribe and administer RSV prophylaxis.
Stakeholder on July 4, 2025
I am in support of adding the RSV monoclonal antibody to the Designated Drugs and Substances Regulation, to allow midwives to prescribe and administer the immunization to protect newborns from RSV and provide the immunization by injection.
S. Waterston
Paediatrician
Quinte Health
North York General Hospital on July 4, 2025
I think midwifes should be allowed to prescribe RSV immunization.
Dr.M.Heilbut paediatric cardiologist on July 4, 2025
Another change extending scope of practice for midwives is urgently required .
This is referral for consultations
If a midwife hears a murmur she is perfectly competent to refer to a cardiologist directly just like a nurse practioner iis able to
At present the midwiife has to send the baby to the family doctor or occasionally the pediatrician, so that doctor can send a referral
This often results in an unnecessary delay in the newborn being seen by the cardiologist.
Sometimes it takes a good few days ,a week or more for an appointment to be given by the FD
This is also an unnecessary cost for the system when the midwife could just refer directly
This iis an issue Iihave tried foryears toresolve
Stakeholder on July 4, 2025
I would be very much in favour of this. I am a pediatrician and the midwife group I work with would love to be able to do this.
Stakeholder on July 4, 2025
As a respirologist, I support this initiative to improve our ability to disseminate RSV immunization to newborns.
Stakeholder on July 4, 2025
I am in favour of this change. As a community hospital department chief, initially not having the midwives be able to put in their own orders was onorous to us as an MD group. Then we had to take time to create medical directives for this purpose. It will be more streamlined moving forward if the midwives can order their own RSV immunizations.
Stakeholder on July 4, 2025
As indicated in the document this strategy is an important move to streamline program delivery, reduce both institutional and community based healthcare administrative burden, and close a care gap for infants born under midwifery care. I fully endorse this scope of practice and it should be fully implemented in a timely manner for the upcoming RSV season.
Stakeholder on July 4, 2025
I support this
Stakeholder on July 4, 2025
I am a pediatrician practicing in Toronto. I am in support of adding RSV monoclonal antibodies to the list of drugs midwives are authorized to prescribe and administer. This scope-of-practice change would streamline program delivery, reduce institutional administrative burden, and close a care gap for infants born under midwifery care.
Anonymous on July 3, 2025
Yes, please d add RSV to midwifery scope for prescribing and administering.
I run a newborn program for unattached infants. I struggle to find RSV antibody access for these infants. Changing midwifery scope will certainly improve access and uptake. Thank you.
Anonymous on July 3, 2025
I’m a registered midwife, during the 2024-2025 flu season I was able to offer my clients the Beyfortus Immune globulin against RSV to newborns at my privileging hospital.
Clients who opted for this method understand that it confers greater benefits and protection to their newborn, they appreciate not having to make additional visits to their FP in the first week of baby’s life to receive this immunoglobulin for their neonate. Midwifery clients should not be disadvantaged by regulation that does not allow their primary care provider (midwife) to provide this option for their neonate. Furthermore, I feel when regulation prohibits Midwives from providing options that are readily available to other pregnant people through their MRP, it subtly lessens the role of Midwives as MRP, as a second class HCP. Some clients take that as a reflection on their own status in the community , especially non OHIP clients who choose midwives for financial reasons in our healthcare system.
Anonymous on July 2, 2025
I approve of these proposed changes
Anonymous on July 2, 2025
I am fully supportive of the College’s proposal to add the RSV monoclonal antibody to the Designated Drugs and Substances Regulation. As a midwife who works with marginalized and vulnerable populations, this change will greatly improve access and therefore uptake to this protective antibody.
Stakeholder on July 1, 2025
I am in agreement thaf midwives should be able to prescribe the RSV vaccine
Stakeholder on July 1, 2025
As a pediatrician, I urge the ministry to allow midwives to prescribe the RSV immunization to newborns as this removes barriers to care.
Midwife on July 1, 2025
We should be working in our full capacity. This will ease things on health care system and allow us to work in the hospital toward more important changes and integration vs spending significant time to try and get medical directives to do things like this. This is esp straining on paeds/MW relations. They know we can do these things and get confused why we are unable to prescribe and admister.
Anonymous on July 1, 2025
As a Pediatrician doing hospital based call i wholeheartedly support adding Rsv vaccination of any type to any age to the list of prescribable medications of midwives.
Thank you!
Anonymous on June 30, 2025
Je supporte l’ajout de l’administration de l’agent monochonal RSV par les sages-femmes. Je constate que dans le contexte anti-vaccination courant, les sages-femmes ont la possibilité et le temps d’expliquer aux parents l’utilité et les disctinctions entre vaccins, agents immunitaire, donc plus enclins à l’offrir à leurs enfants. Ce qui est particulièrement importants pour les populations à risque, sans médecin de famille.
J’appuie les efforts du Collège dans ce sens.
Anonymous on June 30, 2025
Right now we are able to give the RSV antibody under a pediatric medical directive. However, to be able to order it ourselves will allow us to then give the post partum nurses a medical directive to give the antibody anytime while babe is in hospital, prior to discharge home. Some parents do not want their baby getting the antibody right away within 2 hours of delivery but are ok with babe receiving it at 12-24hours. Right now that is hard to do as we cannot direct the nurse to give it when we are already under a medical directive.
Anonymous on June 30, 2025
Yes, yes, yes!
Anonymous on June 30, 2025
I think this is an appropriate addition to the drugs and substances that midwives should be able to order. It makes the case for midwives to have classes of medications rather than just having to add one at a time. I appreciate the recent widening of our scope to prescribe in May 2025. Thank you for your work on our behalf.
Anonymous on June 30, 2025
In our community where there is a high rate of people unattached to primary care providers, having midwives able to prescribe the RSV monoclonal antibody may, depending on uptake, improve population health outcomes, reduce ED visits and hospital admissions. Other savings include reducing time/cost of additional primary care clinic appointments for infants in midwifery care. Client experiences will be improved by having a one-stop shop for infant care. Midwives have the knowledge and skill to provide this immunization. Taking a systems approach to understand where there may be unintended consequences for individual midwives (increased work load/appointment time), practice groups (time and space ordering/storing vaccine), or the profession (opening question for one item when updating approach to pharmacopeia is needed) is important.
Anonymous on June 30, 2025
I fully support the addition the of monoclonal RSV antibody to midwives’ designated drugs and substances. It was a ridiculous oversight that we were not able to prescribe this and caused a lot of work for midwives across in the province to be able to access this for infants.
Anonymous on June 30, 2025
I fully support this change to have RSV monoclonal antibody in our designated drugs and substances. It was ridiculous to ask us to create medical directives on such short notice last fall.
Anonymous on June 30, 2025
Very strong support in favour of this move. Urge roll out of this standard of care in the absence of including midwives resulted in countless unnecessary consultations this past season
Anonymous on June 29, 2025
Yes I agree it should be added.
Anonymous on June 28, 2025
RSV monoclonal antibodies should be included in midwives prescription list.
Anonymous on June 28, 2025
I agree that yes midwives should be able to prescribe nirsevimab as per guidelines.
Dr James Mackinnon MD, FRCP-C
Anonymous on June 28, 2025
If midwives are allowed to provide newborn care for infants, the infants in their care should have equitable access to thing including RSV prophylaxis. As a paediatrician, I do not have time to be consulted on every child they manage in order to ensure babies are offered this therapy.
Anonymous on June 28, 2025
Midwives should be able to provide complete medical care for the newborns they care for including their newborn vaccinations
Anonymous on June 28, 2025
As a pediatrician in the community at Trillium Health Partners in Mississauga and as the current chair of the Pediatrics Section of the OMA, I can speak to what an immense barrier the inability for midwives to prescribe nirsevimab to their newborns was last season as we rolled out the universal RSV prophylaxis program for infants. At the hospital level, this created an huge administrative workload in creating a medical directive. A population of newborns was still left unprotected if the birth was at home and outside of hospital walls.
This change makes sense and helps protect babies from severe RSV disease.
Anonymous on June 28, 2025
I am in full support. This will remove barriers for families to get the best care for their newborns.
Anonymous on June 28, 2025
I am in complete agreement with the addition to our list. Families should not receive less care or have obstacles to receiving important medications/vaccines etc simply because they chose a midwife
Midwife on June 28, 2025
I am 100% in support of this change
Midwife on June 27, 2025
I support this change to add the RSV monoclonal antibody to the midwifery Designated Drugs and Substances Regulation. Doing so would be in keeping with midwives practicing to the full extent of their scope of practice, and would increase access to the RSV antibody for those clients who have difficulty accessing the typical treatment pathways.
Midwife on June 27, 2025
I think we should change the regulation to include prescribing and administering all vaccines. This is so that we can administer new vaccines as they are recommended or developed.
For instance: Covid vaccine, which we could not administer or prescribe which could have helped improve access at the height of the pandemic. Recommendations and scientific findings related to vaccines continues to evolve.
Also, can we include administration and dispensing of contraceptives we can prescribe? Ie. dispensing samples of OCP and inserting Nexplanon implant?
Midwife on June 27, 2025
Absolutely, midwives should be able to order and administer RSV immunization for the newborn. As a band-aid solution to the way our pharmacopeia is regulated, the RSV immunization should be added. As a longer term solution, the midwifery pharmacopeia should be regulated such that midwives can order or prescribe any appropriate treatment for any condition under their scope of practice, provided they have the knowledge, skills and judgment.
Midwife on June 27, 2025
As with all of the other updates last year, and hopefully more to come, the addition of the RSV monoclonal antibody to our list will ensure equity for our clients by having direct access to this standard of care. It will reduce barriers of additional visits for the families, unfamiliar providers, as well as inefficient and costly (mis)use of healthcare services. *the right care, in the right place at the right time* Our clinic provided the antibody under a directive but not all clinics would have had the capacity to create a directive or such good relations with other physicians willing to participate. As we are not compensated for this increase in scope or maintaining a vaccine fridge, minimizing the amount of work needed to be done to provide the service is especially important. We found a large increase in uptake once we were able to provide it without the added barriers.
Midwife on June 27, 2025
Considering the midwifery education curriculum on immunization, as well as the experience gained through practice, and given that most of these cases are commonly encountered in maternal and child health care, assigning this responsibility to midwives appears to be an appropriate and effective choice.
Midwife on June 27, 2025
Fantastic! Although categories would likely make this process less cumbersome in the future.
Midwife on June 27, 2025
I am in full support of the amendment to align midwives Drug Regulations with the Ministry of Health’s implementation of a universal RSV prevention program in 2024. The implementation of a universal prevention program program for newborns in Ontario aligned with best practices and has significant benefits for our broader health system (resulting in reduced hospitalizations where uptake was higher). The inability of midwives (who are most responsible providers for 20% of all Ontario newborns) to order and administer RSV prevention to patients in their care without much additional labour with interdisciplinary partners and enabling team members was a challenge that will be addressed by this amendment. This is a change that will have a beneficial impact at a population outcome level, for providers, will result in efficiencies and ensure better patient experience and more equitable access. Kudos.
Midwife on June 27, 2025
I am in support of this change. Implementation for 2024-2025 season was difficult due to quick roll out – and needing to arrange Medical Directives and Consults for recommended care added more work (with no additional pay) and sometimes delayed care/ access.
Not to mention babies born at home had significant barriers to getting the antibody in rural Ontario. Although there will be more to figure out than just prescribing it – this is a start.
Midwife on June 27, 2025
I don’t think we should keep expanding out scope of practice without increasing our income.
Midwife on June 27, 2025
In full support
Midwife on June 27, 2025
This change is very welcome and would remove a significant barrier to equitable access to RSV prevention for babies / clients of midwives.
Midwife on June 27, 2025
This is a change that I support and that I believe would have a positive impact in my community and practice.
Midwife on June 27, 2025
I appreciate adding this to scope, serious omission last year and did impact choice of birth place for some clients who wanted timely access. Our clinic was able to eventually receive a medical directive to ensure access after enormous work from the head midwife but the season was almost done, will help this coming season until regulation sorted out. I hope midwives will have this added to scope as soon as possible to ensure equity and access to all.
Midwife on June 27, 2025
Please add mAB for RSV for infants.
Thanks you
Midwife on June 27, 2025
I fully support this change. It created many unnecessary barriers to newborns receiving rsv immunization this past year and yet as an RM i am more than competent to be ordering and prescribing this. I am already doing all the work of the counselling and administration, with a a significant burden to use a medical directive
Midwife on June 27, 2025
My practice has a large number of out of hospital deliveries, and last RSV season, accessing this treatment for our OOH delivering families was problematic. We needed support from the PH community nursing team. and they required both an PH nurse and a midwife to attend a home visit at the same time. This created delays and a lot more leg work for midwives to reach out repeatedly to coordinate appointments with the community nursing team and the on call midwife to meet at a home visit. On call midwives need some flexibility as to when to attend home visits, due to the nature of on call work demands.
We need the scope to order and administer Beyfortus to insure we are able to meet the standard of care both in and out of hospital. If the MOH plans to continue to make RSV immunoglobulin available to every new baby’s first RSV season, This new scope prior to the next RSV season would help ensure we are able to use our health care resources more effectively.
Midwife on June 27, 2025
I am in support of adding the RSV monoclonal antibody prescription and administration to the Designated Drugs and Substances Regulation.
Midwife on June 27, 2025
I would like the ability to prescribe the RSV antibody because currently we have to receive a medical directive from pediatrics. The issue is that some parents are not interested in us administering it prior to transfer to the postpartum unit, and we cannot give a medical order or directive to the nurse on postpartum to administer. Therefore, we are running into issues where to ensure that it does not get missed, it has to be given in the initial recovery period at the same time as the vitamin K, which some parents are hesitant to do and may then decline the RSV antibody entirely. This gives clients less informed decision making power.
Midwife on June 27, 2025
We need this. It’s crazy that we don’t have it already.
Midwife on June 27, 2025
Yes please!
College of Denturists of Ontario on June 27, 2025
The College of Denturists of Ontario support this proposed regulatory change due to the arguments presented and the benefits to the public interest, specifically for newborns. This proposal will increase access to care for routine vaccinations for newborns without a separate appointment required. We are in full support of this proposal.