Questions and answers about the Health Professions and Occupations Act
Have questions about the Health Professions and Occupations Act (HPOA)? We’re here to help!
Browse this page for answers to the most frequently asked questions about the HPOA.
When will the HPOA come into force?
The BC government announced that the HPOA will come into force on April 1, 2026.
What is the HPOA expected to accomplish?
The HPOA will:
- commit to anti-discrimination, cultural safety and humility
- improve governance by moving to competency-based appointment process for board members
- strengthen oversight by creating the Health Professions and Occupations Regulatory Oversight Office
- create a safer complaints process with a new independent disciplinary hearing process
- improve information sharing
Will any terms change under the HPOA?
“Registrant” to “licensee”
The HPOA will create a change in regulatory language; for example, upon the in-force date all regulated health professionals will be referred to as “licensees” rather than “registrants.” Changing the term from “registrant” to “licensee” is intended to make it clearer to the public that health professionals regulated under the HPOA must have a license to practise their profession.
Use of “doctor” title
Under the HPOA, health professions that are authorized to use the title “doctor” must now make it clear that they are not a medical doctor by using it with a qualifier so that it is clear to the public. If any of the following circumstances apply, a registrant (licensee) who is authorized to use the title “doctor” must, in using the title, indicate clearly that the licensee is not authorized to practice medicine as a licensee of the College of Physicians and Surgeons when:
- the licensee is engaged in the practice of the designated health profession;
- the licensee is interacting with a person in carrying out business, professional, or other activities related to the practice of a designated health profession;
- the licensee is providing information to the public with respect to the practice of a designated health profession, or a matter in relation to health.
In circumstances outside the list above, health professions that are authorized to use the title “doctor” may still use the title as a prefix to identify themselves.
Change to reserved title: Massage Therapy
The regulation under the HPOA authorizes registrants in this profession to use the titles “massage therapist” and “massage practitioner.”
A (registrant) licensee may still choose to refer to themself as “registered massage therapist” or another title that includes “massage therapist/practitioner.”
If you prefer to use the title “registered massage therapist/practitioner” in marketing your practice (website, social media, business cards, signage, and any and all marketing collateral), or in other areas of business, you may continue to do so. There is no need to adjust your marketing if it uses the title “registered massage therapist,” or otherwise includes “massage therapist” or “massage practitioner.”
What will the HPOA change?
Changes made by the Ministry of Health under the HPOA that are specific to regulated health professionals include:
New terms:
All regulated health professionals will be referred to as “licensees” rather than “registrants.” Changing the term from “registrant” to “licensee” is intended to make it clearer to the public that health professionals regulated under the HPOA must have a license to practise their profession.
Expanded licensees duties:
The HPOA sets out clear and comprehensive duties for licensees. Many of these are duties that health professionals are already expected to comply with, but which were previously articulated only in bylaws, or in practice and ethical standards, or which existed simply as general legal principles. Under the HPOA, these duties are clearly articulated and codified for all licensees, and include duties regarding:
- compliance,
- fitness to practise,
- ethical practice,
- misconduct,
- delegation,
- cooperation,
- giving notice, and
- providing information to their regulatory college.
The HPOA also gives regulatory colleges additional tools to address issues such as compliance and misconduct when licensees are not practising consistently with these duties.
What is the role of the Health Professions and Occupations Regulatory Oversight Office?
The role of the Health Professions and Occupations Regulatory Oversight Office is to oversee all health colleges in B.C., ensuring they continue to be transparent, accountable, and operate in the public interest. Its role is to make merit-based recommendations to the Minister of Health for board appointments, conduct oversight activities (e.g. audits, investigations, general reviews), and make recommendations on which health professions should be regulated. The Office will also house the Discipline Tribunal, an independent adjudicative body that will make disciplinary decisions for licensees.
Read the province’s announcement appointing Sherri Young as the new superintendent on June 7, 2024.
Will the HPOA bring changes to scopes of practice?
Overall, the updated professional regulations under the HPOA will not change the day-to-day practice for health professionals once the Act is in force.
The scopes of practice outlined in the health profession regulations may look and read differently for many regulated health professionals as they were written to align with the HPOA. However, registrants’ scopes of practice are not changing, and regulated health professionals will still be permitted to perform the same activities they were permitted to perform under the Health Professions Act.
Following the release of the updated professional regulations that align with the HPOA, CCHPBC has summarized a list of notable updates that may impact registrants (licensees) regulated by the college. However, it’s important to note that these changes will not be in effect until the in-force date of the HPOA on April 1, 2026.
Leading up to the in-force date, CCHPBC will provide licensees with the opportunity to participate in webinars and educational sessions related to the HPOA.
What committees are required under the HPOA?
There will be three legally mandated decision-making committees under the HPOA:
- investigation committee
- licence committee
- permit committee
Other committees may be formed at the discretion of the board. Under the HPOA, CCHPBC will have two board support committees:
- finance and audit committee
- governance and human resources committee
A board member cannot be a member of the investigation or licence/permit committee
What will the governance structure of CCHPBC look like under the HPOA?
CCHPBC will continue to have a board and committees. Under the HPOA, and as it is currently structured, CCHPBC’s board will be composed of equal numbers of licensees (registrants) and representatives of the public. Supported by the registrar, CCHPBC’s knowledgeable and diverse board members will work together to fulfill the college’s public protection mandate by providing strategic leadership and organizational direction.
Under the HPOA, the Health Professions and Occupations Regulatory Oversight Office will be responsible for establishing the guidelines for appointments and completing a merit and competency-based process in recommending board members to the Ministry of Health and has committed to doing so in consultation with the colleges. The Minister of Health is responsible for appointing all board members.
How will the complaints process be different under the HPOA?
CCHPBC will continue to handle the intake of complaints and subsequent investigations; however, it will no longer determine disciplinary outcomes.
Under the HPOA, a discipline tribunal will be formed and led by an independent director of discipline. The director will be appointed by the Minister of Health and will be housed within the Health Professions and Occupations Regulatory Oversight Office. The director will create independent panels to determine disciplinary action for misconduct.
The discipline panel must consist of one licensee, a member of the public, and a specialist in the area of concern. Colleges will be responsible for enforcing the disciplinary orders decided by the discipline panel.
Will complaints against licensees (registrants) be made public?
No, only disciplinary actions and summary protection orders (limits, conditions, suspensions) will be published on a licensee’s profile in the CCHPBC directory.
Complaints that are unfounded will be dismissed. Additionally, complaints that do not result in disciplinary action, warnings, and advice will not be published or made public. Colleges will, however, be able to acknowledge that they have received a complaint or disposed of a complaint in order to respond to public sources like the media.
How will bylaws and practice standards be made for CCHPBC?
Under the HPOA, all eligibility, ethics, practice, and accreditation standards must become bylaws, which ensures that action can be taken if a contravention occurs.
The board will be required to seek the advice of professional standards advisors for bylaws about eligibility, ethics, and practice standards. The professional standards advisors must have relevant education, training, qualifications, and experience that allows them to give expert advice. Professional standards advisors who give advice on ethics, practice, and eligibility standards must also be authorized to practice the profession to which the standards relate.
Consultation will be required for any new or amended bylaws.
When will the consultation period begin for new HPOA bylaws?
The draft HPOA bylaws will be completed, published for consultation, and presented to the Board. Please note that consultation dates may be revised based on the in-force date of the HPOA when determined.
Licensees (registrants) and other health regulators will be notified by email as the draft bylaws and online feedback forms are published on our website.
Is this impacting all regulated health professionals in BC?
Yes, all regulated health professionals in BC will have new regulations that the Ministry of Health has updated to align with the HPOA.
Notable updates for health professionals regulated by CCHPBC: Questions and answers
All professions
Can I still refer to myself as a doctor, if I am a naturopathic physician, chiropractor, or doctor of traditional Chinese medicine, once the HPOA and HPOA regulations come into force?
Yes, but there are new restrictions under the regulations.
Specifically, if you use “doctor” as a title, you will have to add mention of your profession or designation. Health professionals that are authorized to use the title “doctor” must now make it clear that they are not a medical doctor by using it with a qualifier so that it is clear to the public.
If any of the following circumstances apply, a registrant (licensee) who is authorized to use the title “doctor” must, in using the title, indicate clearly that the licensee is not authorized to practice medicine as a licensee of the College of Physicians and Surgeons when:
- the licensee is engaged in the practice of the designated health profession;
- the licensee is interacting with a person in carrying out business, professional, or other activities related to the practice of a designated health profession;
- the licensee is providing information to the public with respect to the practice of a designated health profession, or a matter in relation to health.
In circumstances outside the list above, health professions that are authorized to use the title “doctor” may still use the title as a prefix to identify themselves.
Examples:
- Chiropractic doctors can refer to themselves in their practice and related marketing as a “chiropractic doctor” or “doctor of chiropractic.” They can also refer to themselves as “Dr. Smith, DC.”
- Naturopathic physicians can refer to themselves in their practice and related marketing as a “naturopathic doctor” or “naturopathic physician.” They can also refer to themselves as “Dr. Smith, ND.”
- Doctors of traditional Chinese medicine can refer to themselves in their practice and related marketing as a “doctor of traditional Chinese medicine.” They can also refer to themselves as “Dr. Smith, Dr. TCM.”
These licensees will need to make sure all of their marketing (e.g. websites, social media, business cards, signage) is compliant, as of April 1, 2026.
Administering naloxone or oxygen to someone who may be suffering an overdose will no longer be a restricted activity. Can I do this even if it’s not normally within my scope of practice?
Yes. Amendments have been made to updated professional regulations under the HPOA to authorize all health professionals to administer emergency use naloxone or oxygen (outside of a hospital setting), even if doing so is not within their scope of practice.
This means if a registrant (licensee) suspects a person is suffering from an opioid overdose, they may assess and treat the person and administer emergency use naloxone by intramuscular injection or intranasally.
Licensees are not obligated to administer naloxone to someone suffering from an overdose; however, if they choose to do so, the Good Samaritan Act will protect them from liability for damages for injury to or death of that person unless grossly negligent.
Licensees may wish to review these resources:
Administering (semi-) automatic defibrillation for resuscitation purposes will no longer be a restricted activity. Can I do this even if it’s not normally within my scope of practice?
Yes. Like the amendments which authorize the use of naloxone in the case of emergency, the use of a (semi-) automatic defibrillation for resuscitation purposes is authorized for all registrants (licensees), even if using the device is not within their scope of practice.
A defibrillator is a device that gives a jolt of energy to the heart. It helps get the heart beating again when someone is in cardiac arrest and their heart has stopped. You might also hear it being called a defib, a PAD (public access defibrillator) or an AED (automated external defibrillator).
Licensees are not obligated to administer (semi-) automatic defibrillation; however, if they choose to do so, the Good Samaritan Act will protect them from liability for damages for injury to or death of that person unless grossly negligent.
CCHPBC Bylaws require all licensees to maintain First Aid/ CPR certification. For more specific information on this requirement for each profession, visit: For Professionals – CCHPBC.
Transcutaneous Electrical Nerve Stimulation (TENS) will no longer be a restricted activity. Can I use this in my practice?
Using TENS is currently within the scope of practice for the chiropractic and naturopathic medicine professions, and for acupuncturists, traditional Chinese medicine practitioners, and doctors of traditional Chinese medicine.
The College recognizes that massage therapists may have questions regarding the use of TENS in their practice. To clarify, even though TENS is no longer a restricted activity, the use of TENS is not within the scope of practice for massage therapists.
Prescribing of herbal formulae will be removed as a restricted activity. Can I use this in my practice?
Prescribing of herbal formulae is currently in scope of practice for naturopathic physicians, traditional Chinese medicine practitioners, traditional Chinese medicine herbalists, and doctors of traditional Chinese medicine.
This is not within scope of practice for chiropractors, massage therapists, and acupuncturists. This means that even though it will no longer be a restricted activity, these licensees cannot use it in their practice.
Allergy testing (all kinds of allergy challenge testing and desensitization treatment) will become restricted activities. Is there any change to my practice?
No. Naturopathic physicians will continue to be able to conduct allergy testing. This is not within the scope of practice for any other professions regulated by CCHPBC.
Chiropractors
Is there any change to the scope of practice for chiropractors once the HPOA and HPOA regulations come into force?
No. While the regulation may use different wording in some areas, there will be no change to day-to-day clinical practice for chiropractors.
Is there any change to the use of titles for chiropractors?
See question and answer under the heading “All professions.”
Massage Therapy
Is there any change to the scope of practice for massage therapists once the HPOA and HPOA regulations come into force?
No. While the regulation may use different wording in some areas, there will be no change to day-to-day clinical practice for massage therapists.
Is there a change in the titles for massage therapy registrants?
Yes. The regulation under the HPOA authorizes registrants in this profession to use the titles “massage therapist” and “massage practitioner.”
A (registrant) licensee may still choose to refer to themself as “registered massage therapist” or another title that includes “massage therapist/practitioner.”
If you prefer to use the title “registered massage therapist/practitioner” in marketing your practice (website, social media, business cards, signage, and any and all marketing collateral), or in other areas of business, you may continue to do so. There is no need to adjust your marketing if it uses the title “registered massage therapist,” or otherwise includes “massage therapist” or “massage practitioner.”
Naturopathic Medicine
Is there any change to the scope of practice for naturopathic physicians once the HPOA and HPOA regulations come into force?
No. While the regulation may use different wording in some areas, there will be no change to day-to-day clinical practice for naturopathic physicians.
While the restricted activity of administering treatment using and within hyperbaric chambers has been removed, this is not actually a change. The college had previously restricted this activity in practice standards.
Is there any change to the use of titles for naturopathic physicians?
See question and answer under the heading “All professions.”
Traditional Chinese medicine and acupuncture
Is there any change to the scope of practice for traditional Chinese medicine and acupuncture once the HPOA and HPOA regulations come into force?
No. While the regulation may use different wording in some areas, there will be no change to day-to-day clinical practice for registrants who practice traditional Chinese medicine and acupuncture.
For those registrants (licensees) authorized to practice acupuncture, you may notice that electrical stimulation is no longer specifically named in the definition of acupuncture, but acupuncture remains the same in clinical practice. Electrical stimulation may still be used.
Is there any change to the use of titles for doctors of traditional Chinese medicine?
See question and answer under the heading “All professions.”
Is there any change to the use of titles for acupuncturists, traditional Chinese medicine practitioners, and traditional Chinese medicine herbalists?
No, there is no change to these titles under the regulations.
Prescribing herbal formulae will be removed as a restricted activity. Does this mean unregulated persons can prescribe herbal formulae?
Yes, though the regulatory regime through Health Canada would still apply.
However, only licensees of the College can use reserved titles such as “Doctor of traditional Chinese medicine practitioner” and “traditional Chinese medicine herbalist.” These “reserved titles” (titles prescribed as being for the exclusive use of licensees of regulatory colleges) are a central and critical public protection element of professional regulation in BC.