Licensure Policies - Licensure with Supervision Condition

Introduction

One of the objectives of a supervision condition on a licence is to facilitate access to clinical practice for a veterinarian who has not met all of the entry-to-practice requirements as outlined in section 3 of Regulation 1093.  In order to mitigate risk and protect the public interest related to entry-to-practice requirements that have not been met, the supervision process includes ongoing monitoring and assessment of the supervised licensee. 

Under paragraph 14 (6) (c) of the Veterinarians Act, the Registration Committee is authorized to direct the issuance of a licence subject to conditions and limitations, including levels of supervision. The level of supervision determined appropriate is based on the information and documentation submitted by the applicant.  Usually, a Restricted Licence is the category of licence that is granted when supervision is required. 

Some examples of when the Registration Committee might impose a supervision condition include:

• applicants who have passed the North American Veterinary Licensing Examination (NAVLE) but not the Clinical Proficiency Examination (CPE);
• applicants with impairment issues;
• applicants who are the subject of current disciplinary or incapacity proceedings;
• applicants with previous discipline findings; and
• applicants who are highly experienced in a specialty or scope of practice but not board certified (or otherwise trained beyond the basic veterinary degree). In this circumstance, there is often an additional limitation placed on the licence that specifies a particular place of employment or employment environment. 

Purpose of Policy

This policy sets out the College’s general expectation and processes for any veterinarian engaged in a Registration Committee-imposed supervision arrangement.  

Definitions

Primary Supervisor: A licensed veterinarian who is approved by the Registrar to supervise another veterinarian who has a supervision condition imposed on their licence by the Registration Committee.  

Supervisor Accountability

The primary supervisor signs an undertaking which is submitted to the College and by doing so, the primary supervisor is accepting the obligations, as outlined in this document, for the oversight of the supervisee’s practise at a particular workplace. Providing supervision is a privilege and is not a right. It is a time-consuming activity that carries with it potential liability and should not be entered into lightly by any member of the profession.

Complaints regarding the conduct or actions of a supervisee could result in an investigation by the College of both the supervisee and the supervising member. Both supervisee and the supervising member will be accountable to the public and clients for their action, which may include responsibility for failing to supervise adequately.

Levels of Supervision

The level of supervision required may be specified by the Registration Committee and if applicable will appear on the undertaking that must be signed by the licensee and on the licensee’s record on the Public Register. 

Definitions of the commonly specified levels of supervision:

1. Condition of Immediate Supervision: the supervising veterinarian is on the same premises as the supervisee and can see and hear the supervisee when the supervisee is engaged in professional activities.
2. Condition of Direct Supervision: the supervising veterinarian is on the same premises as the supervisee and, although may not be present to see and hear the supervisee, is accessible to the supervisee in a timely and appropriate manner. 
3. Condition of Indirect Supervision: the supervising veterinarian is not required to be on the same premises as the supervisee at all times but is accessible to the supervisee in a timely and appropriate manner and available to attend the premises if required

Qualifications of Primary Supervisors

A veterinarian who wishes to supervise a licensee must generally meet all of the following eligibility criteria:

• Hold a General Licence with no conditions or limitations
• Has at least 3-5 consecutive years of full- or half-time practice experience
• Has been in active practice in Ontario for at least the past two years
• Has no discipline findings within the past 5 years
• Must not be the subject of any current disciplinary or incapacity proceedings
• Has no active undertakings
• Is not under an active Registrar’s or Complaints Investigations
• Has no current referrals from Executive or Complaints Committees to Discipline
• Has no conflict of interest (any real or perceived), such as personal relationships (e.g, employment, family, dating, business, friendship, etc.) that may interfere with the supervision or objective evaluation
• Has no other factors, such as but not limited to, a history with the College or reported concerns raised by past supervisees or employees, that, in the opinion of the Registrar reasonably demonstrates that the veterinarian could not provide a suitable supervision experience.

Responsibilities of the Primary Supervisor:

In addition to agreeing to provide the supervision (to the level specified in the undertaking) to the supervisee when they are engaged in any and all professional activities, the supervisor must also agree to:

1. Provide sufficient supervision and ongoing monitoring at the level appropriate to the risk associated with the activity engaged in by the supervisee, that assures both supervisor and clients of safe practise;
2. Only delegate supervision responsibilities to other General licence holding veterinarians and ensure that these other supervisors provide sufficient supervision and that they understand the current level of supervision to be provided;
3. Understand the supervisee’s learning objectives and communicate their role to other staff and to clients;
4. Orient the supervisee to the practice (including equipment, protocols and documentation requirements) and to the specific condition, needs and/or goals of individual patients/clients;
5. Ensure that duties assigned are commensurate with the supervisee’s ability, experience, comfort level and learning style, as well as the complexity of the environment/practice setting;
6. Provide an environment that will facilitate learning and clinical growth;
7. Provide feedback to the supervisee after consulting with others who have provided supervision, regarding performance on a consistent, timely basis, based on the criteria established by the College and submit those reports to the Registrar as per schedule stated in the Undertaking (see attached assessment form);
8. Ensure that that the supervisee describes themself as a “Veterinarian working under Supervision”
9. Immediately notify the Registrar in writing if the following situations occur:
   1. There are reasonable grounds for belief that the supervisee has performed any act of professional misconduct or serious neglect
   2. There are reasonable grounds for belief that the supervisee is impaired
   3. There are reasonable grounds for belief that the supervisee’s practice may expose patients or clients to risk of harm or injury
   4. There are reasonable grounds for belief that the supervisee is practising below standard
   5. When the supervisor is unable to continue in the role, or unable to fulfill obligations on a timely or temporary basis, e.g., due to illness, vacation, personal emergency, etc.

Responsibilities of the Supervisee:

In any Registration Committee-imposed supervising arrangement, the Supervisee must:

1. Accept primary responsibility for their actions. 
2. Identify themself as a Veterinarian working under Supervision.
3. Submit an undertaking to the College that is signed by themself and any/all members of the College holding a General licence who agrees to act as a primary supervisor and to supervise their practise, at any/all locations.
4. Notify the College of any supervisor changes, as these changes must first be approved by the Registrar before a new supervision undertaking may take effect.
5. Ensure that assessment reports are submitted to the College on time.
6. Adhere to any recommendations made by the supervisor.

Approval Process

Prior to beginning supervised practice:

1. each suggested supervisor is to be pre-approved by the Registrar prior to the licensee commencing work;
2. the supervisee and supervisor must sign an individualized and situation specific undertaking to formalize the agreement with the College; and
3. the Registrar must approve the agreement.

The Registrar has the authority to decline the supervisor of choice if any of the above supervisor qualification criteria have not been met, without needing to provide written reason(s) for such decision. The confidentiality rights of the proposed supervisor may in fact preclude the Registrar from advising the proposed supervisee of the reasons why a proposed supervisor has not been approved.

Termination of Agreement

The Registrar reserves the right to terminate the supervision arrangement and may disentitle someone to act as a supervisor if there are reasonable grounds for the Registrar to believe that that the supervisor is no longer an appropriate choice. 

If the supervisor or supervisee terminates the undertaking, they must do so by informing the College in writing.  The supervisee is not permitted to practise until the Registrar has approved a new undertaking signed by the supervisee and a new supervisor who is acceptable to the Registrar.

(approved by the Registration Committee ‐ September 2021)