Collecting Specimens and Ordering Laboratory Tests - Frequently Asked Questions


These questions and the answers to them are intended as general guidance to the most common questions about specimen collection and ordering laboratory tests.  The responses are not legal or practice advice and are not intended as such.  For more detailed information on the subject, readers should review the relevant statutes, regulations and standards of practice and consult with legal counsel.

Index of Questions


Can a Member take blood from a patient in their office?
Can a Member still prick a finger for an IgG test?
Can a Member milk a finger after a patient has pricked the hand?
Can a Member order a test directly from a lab without an MD signing?
Should a Member use a specific form when ordering labs?
Who is responsible for the regulation on specimens and laboratory access?
Can a Member order lab tests from out-of-province laboratories?
Where is the list of lab tests that a Member can order?
Can a Member have a patient use a testing kit and have the results sent to the Member?
Can a patient show a Member a test result obtained from other sources? If so, can the Member use it?

Answers


Can a Member take blood from a patient in their office?

Yes, but only for the purposes of performing the seven point-of-care tests authorized in the Specimen Collection Centres Regulation made under the Laboratory and Specimen Collection Centre Licensing Act, 1990.

Can a Member still prick a finger for an IgG test?

IgG testing that is done as a point-of-care test (finger pricking and in office testing) is not permitted under the Specimen Collection Centres Regulation made under the Laboratory and Specimen Collection Centre Licensing Act, 1990. However, a Member can requisition this test through a licensed specimen collection centre in Ontario.

Asking a patient to prick their hand or finger does not allow the Member a means of circumventing the regulation and its intent. 

Can a Member milk a finger after a patient has pricked the hand?

The process described is the collection of a blood specimen. A Member can only collect a blood specimen for the purpose of performing the seven point-of-care tests authorized in the Specimen Collection Centres Regulation made under the Laboratory and Specimen Collection Centre Licensing Act, 1990

Asking a patient to prick their hand or finger does not allow the Member a means of circumventing the regulation and its intent.

Can a Member order a test directly from a lab without an MD signing?

Members are authorized under the Laboratory and Specimen Collection Centre Licensing Act, 1990 (LSCCLA)to requisition:
  • the taking of a specimen by a licensed Ontario specimen collection centre; and
  • the performance of a test on that specimen in a licensed Ontario laboratory.  
With this authority, Members  do not require signatures of other regulated health care providers.

Members can only order tests that are authorized to the profession in the Specimen Collection Centres Regulation made under the LSCCLA.  If a test is not authorized, it cannot be obtained by the Member by having another health care provider co-sign the form.  

In some cases, another health care provider might requisition a test that is not authorized to a Member; however, in doing so, the test results are sent to the signing health care provider who would then, with patient consent, share the results with the Member.  This presumes that the other health care provider has a patient-practitioner relationship with the patient.

Should a Member use a specific form when ordering labs?

It is the Member's responsibility to obtain requisition forms from the laboratory they are ordering tests from. 

Who is responsible for the regulation on specimens and laboratory access?

The Ministry of Health and Long-Term Care, through the Laboratory and Specimen Collection Centre Licensing Act, 1990 is responsible for authorizing Members' access to collecting specimens, and performing and ordering laboratory tests.  While the College of Naturopaths of Ontario may be asked for recommendations or submit recommended changes, the final decision rests with the Ministry.

Can a Member order lab tests from out-of-province laboratories?

Members can only requisition tests or take and send samples only to laboratories licensed under the Laboratory and Specimen Collection Centre Licensing Act, 1990 which is Ontario-based legislation.

Where is the list of lab tests that a Member can order?

The list is contained in the Specimen Collection Centres Regulation made under the Laboratory and Specimen Collection Centre Licensing Act, 1990.  The College has also summarized the list of labs in Ordering Laboratory Tests section of the website.

Can a Member have a patient use a testing kit and have the results sent to the Member?

Such testing kits involve the patient collecting his or her own specimen, placing it in the provided carrier, and sending it to a laboratory. These kits, which must be approved by Health Canada, require a requisition form from a laboratory to perform the test. For the results to be ordered by and sent to the Member, the test must be among those that a Member has the authority to order. If the Member cannot requisition the performance of the test by an Ontario laboratory, then the kit cannot be provided to the patient.

A Member who instructs a patient to collect their own specimen and send that specimen outside of Ontario is attempting to circumvent the legislative framework around specimen collection and laboratory testing in Ontario. That could make the Member subject to a complaint or Registrar’s report.

Can a patient show a Member a test result obtained from other sources? If so, can the Member use it?

To derive and communicate a diagnosis, a Member can use any tests that are reasonably available to them, provided:
  • The test was obtained from a reliable source.
  • The results can be deemed to be valid.
  • The Member has the knowledge, skill and judgment to interpret the test results.  
This may become of considerable importance should an investigation result from a complaint or a Registrar’s report; these factors could determine whether a referral to the Discipline Committee is warranted.