Guidance for the Profession: Delegation of Controlled Acts

Last Updated: March 2026

In some circumstances physicians may not always need to be physically onsite to supervise delegates (e.g., where the risk of the delegation is low).
What constitutes appropriate supervision in these instances is case specific. For example, in outpatient clinic settings where delegates are performing routine, low-risk acts (e.g., providing wound care, following up on test results), supervising physicians may not need to be onsite at all times. In addition, in remote and isolated areas, where it may not be possible for supervising physicians to be physically onsite, virtual support may be appropriate.

Physicians delegating to Internationally Trained Physicians (ITPs) who are not licensed with CPSO cannot rely on credentials or licences obtained in other jurisdictions to ascertain whether the ITP has the requisite knowledge, skill, and judgment to safely perform a controlled act. Physicians need to apply the same level of diligence when assessing an ITP’s competence as they would with any other delegate.
ITPs who are not licensed with CPSO cannot use titles such as “physician,” “surgeon,” “doctor,” or any variation or abbreviation (e.g., “M.D.”).

If a physician is not involved in hiring the delegate (e.g., in a hospital), it is reasonable for them to assume that the hiring institution has ensured that the delegate has the requisite knowledge, skill, and judgment, unless there are reasonable grounds to believe otherwise.
If a physician becomes aware that the delegate does not have the knowledge, skill, or judgment to perform the delegated acts competently and safely, they need to take appropriate action to inform the individual or authority to whom the delegate is accountable. Additional reporting obligations may also apply if the individual is a regulated health professional.

Physicians delegating in the context of community paramedicine are reminded to comply with CPSO’s Professional Obligations: Delegation of Controlled Acts and that they are ultimately responsible for the care being provided on their behalf. The identity of the delegating physician needs to be clear in all instances, regardless of whether the delegation occurs via direct order or medical directive.
Physicians need to be satisfied that any medical directive being implemented is appropriate in the circumstances and sufficiently detailed to support the type of care being delivered.

Although CPSO enables delegation in various scenarios, the Ontario Health Insurance Plan (OHIP) has specific billing requirements for services provided through delegation. OHIP requires that physician services, such as assessments, counselling, therapy, consultations, and diagnostic service interpretations, be personally rendered by the physician to be paid by OHIP.
For questions and advice on such matters, contact the Ontario Medical Association (OMA) or the Provider Services Branch at OHIP.
For more information, see:
- Payments for Delegated Procedures (OMA)
- OHIP Schedule of Benefits (Ministry of Health)
- OHIP Payment Requirements for Services Rendered Personally and Procedures Delegated by a Physician (Ministry of Health)