Lab Testing Advisory - Update

Posted On: October 6, 2021

As Registrants will recall, the College issued an Advisory on Laboratory Tests ordered by an ND on July 21, 2021.  Since that time, we have received several questions from Registrants and have continued to seek clarification from the Ministry of Health (Ministry). To that end, we have received several new pieces of information from the Ministry.

The College of Naturopaths of Ontario is responsible for regulating naturopathic doctors in the public interest. We are not responsible for regulating laboratories in Ontario or elsewhere. The clarification we have been seeking from the Ministry have been with the intent to define where an ND’s responsibilities in relation to laboratory tests ends and the laboratory’s responsibilities begin. We believe we now have a much clearer outline of these responsibilities to share with the profession.

Through the General Regulation made under the Naturopathy Act, 2007 (the Act) and the Regulations made under the Laboratory and Specimen Collection Centre Licensing Act (LSCCLA), an ND may do any of the following:

  • Collect a blood sample from a patient in office for the purposes of performing one or more of seven Point of Care (PoC) tests listed in the General Regulation under the Act and the regulations made under the LSCCLA and in accordance with the Standard of Practice on Point of Care Testing.
  • Collect non-blood specimens (i.e., urine, vaginal swab or throat swab) in office for the purposes of performing one or more of ten PoC tests listed in the Regulations under the LSCCLA in office, and in accordance with the Standard of Practice on Point of Care Testing.
  • Collect non-blood specimens (i.e., stool, urine, saliva, hair, tissue/discharge/sputum, and breath) in office for the purposes of one or more of 61 tests—provided that the specimens are sent to an Ontario licensed laboratory.
  • Requisition the collection of a non-blood specimen (i.e., stool, urine, saliva, hair, breath and tissue/discharge/sputum) for the purposes of one or more of the same 61 tests noted in the prior bullet point, provided that the specimen is collected in an Ontario licensed Specimen Collection Centre that sends those specimens to an Ontario Licensed laboratory.
  • Requisition the taking of a blood sample for the purposes of one or more of 133 tests provided that the specimen is collected in an Ontario licensed Specimen Collection Centre that sends those specimens to an Ontario Licensed laboratory.

This means that an ND may:

  • Collect in office samples for testing in office for one or more of 17 tests (7 on blood, 10 on other specimens) performed in office.
  • Collect specimens in office for one or more of 61 tests and send those specimens to an Ontario licensed laboratory.
  • Requisition one or more of 194 tests (133 on blood, 61 on other specimens) from an Ontario licensed Specimen Collection Centre who will send the specimens to an Ontario licensed laboratory.

This also means that an ND may not:

  • Collect a specimen or blood sample that they are not authorized to collect.
  • Requisition collection or taking of a specimen that they are not authorized to requisition.
  • Collect a specimen or blood sample from a patient and send that specimen directly to a laboratory that is not licensed under the LSCCLA, including laboratories outside of Ontario.
  • Requisition the collection of a specimen or testing on a specimen directly from a laboratory that is not licensed under the LSCCLA, including collection centres and laboratories outside of Ontario.

Summary

The following table summarizes the various procedures, authorizations and limitations related to collecting and requisitioning samples and tests under the Act and the LSCCLA.

Procedure/Function Authorisation Limitation
Take blood sample in office Only for 7 PoC tests. No other blood samples may be drawn by an ND in accordance with the Standard of Practice on Point of Care testing.
Requisition collection of blood sample. Only for 133 tests. Blood collected in Ontario licensed Specimen Collection Centre; specimen sent to an Ontario licensed laboratory.
Collect non-blood specimens in office. Only for 10 PoC tests. Limited to in office testing on urine, vaginal swabs or throat swabs in accordance with the Standard of Practice on Point of Care testing.
Only for 61 tests. Specimen collected in office and sent to an Ontario licensed laboratory.
Requisition collection of non-blood specimens. Only for 61 tests. Specimen collected in Ontario licensed Specimen Collection Centre; specimen sent to an Ontario licensed laboratory.

Neither an ND nor the College of Naturopaths of Ontario are responsible for what an Ontario laboratory licenced under the LSCCLA does with a specimen that they receive directly or indirectly (via a Specimen Collection Centre) from an ND.

Registrants are reminded that it is a standard of practice of the profession that the member must immediately refer the patient to a member of the College of Physicians and Surgeons of Ontario, or a member of the College of Nurses of Ontario who holds a certificate of registration as a Registered Nurse in the extended class, if the patient’s laboratory test result from a laboratory licensed under the LSCCLA is a critical value test result. This is specified in section 13(6) of the General Regulation made under the Act and in the Standard of Practice on Laboratory Testing.

Update on Specific Tests Referred to Earlier

In the College’s earlier advisory, reference was made to two specific tests that may not currently meet Ontario’s case definition for various enteric pathogens as well as Lyme disease. As NDs have a duty to report positive findings under Ontario’s Health Protection and Promotion Act, it is recommended that other tests for comprehensive stool analysis be considered and that Lyme Disease antibody tests be ordered via the Public Health Laboratory system. This recommendation remains in place as does the requirement that Public Health Units inform patients where positive results are reported to them that further alternate testing should be undertaken.

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