The College of Midwives of Ontario recently had the opportunity to express our support for several proposed expansions to professional scope: for chiropractors, chiropodists, dental hygienists, denturists, optometrists, pharmacists, physiotherapists, psychologists, and speech-language pathologists. These expansions were largely to medications these professionals can prescribe and administer, and access to diagnostic imaging.
We shared the following points with the Ministry of Health through their public consultation in November, 2025.
As the regulator for the midwifery profession, our legislated mandate requires us to put the public’s health needs and safety first. We share the government’s goal as stated in the Ontario’s Primary Care Action Plan: a commitment to ensuring all of Ontario’s highly qualified health care professionals can work to their full scope of practice. We also are deeply supportive of initiatives to connect Ontarians to relevant health care while maximizing the expertise of health care workers.
As such, we support expanding health care scopes of practice in the public interest, provided the practitioners have or acquire the knowledge, skills, and judgement to perform the acts in the proposed expansion safely and ethically.
Our experience of regulating midwives with list-based regulations for medications and laboratory tests leads us to caution the Ministry on applying this approach for other health care professionals. While the decision on how to regulate each profession should be informed by their regulator, we understand there are significant challenges of regulating to a list, or even to a category, as it may not allow for health care providers to evolve with best practice.
The College of Midwives of Ontario supports regulated health care practitioners under the Regulated Health Professions Act, 1991 (RHPA), being permitted to prescribe and administer drugs and substances to their full scope, and being permitted to order laboratory tests to their full scope.
Public safety is maintained when regulated health professionals are permitted to work to their full scope. All RHPA professionals with prescribing privileges are well educated in their respective fields with foundational education, knowledge, and demonstrated competency in proper prescribing. The Colleges that regulate health professions in Ontario have the tools necessary to ensure that practitioners are only prescribing medications and ordering tests that they have the knowledge, skill, and judgement to use. We have effective regulatory tools, including standards, policies, quality assurance, and the ability to investigate and address professional misconduct when necessary.
However, list-based approaches to regulation can unnecessarily limit access to care. We can share a cautionary example from midwifery that we recently worked with the Ministry of Health to resolve. The College’s Designated Drugs and Substances Regulation O. Reg. 188/24 came into effect on May 3, 2024, after many years of work between the College and the Ministry. This regulation included an expansion to the list of drugs and substances that midwives may prescribe and administer on their own authority, including the Respiratory Syncytial Virus (RSV) vaccine, enabling clients in midwifery care to directly access this immunization. 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 listed 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.
We worked closely with the Ministry to add the RSV monoclonal antibody to the list of drugs and substances that midwives can prescribe and administer, and the regulation has now been amended; but the process to add an individual medication is lengthy and time intensive. Both the College and the Ministry held public consultations to garner feedback that was overwhelmingly positive – it is so clearly in the public interest for newborns’ primary care providers to be able to access this immunization. The Ministry worked hard and quickly with us on this addition to the list, but the process itself is rigid, which creates a barrier to clients receiving timely, safe, and effective care. The College is grateful for the opportunity to share our support for expanding scope of practice, and to provide the Ministry with our feedback on the challenges of using list-based regulation. For the benefit of Ontarians, we encourage the Ministry to choose a more flexible and sustainable approach to regulation. We are available