March 17, 2022
Practice Expectation Spotlight
Practice Expectation Spotlight: Self-Disclosure of a Medical Condition or Disorder
The Role of the College of Registered Nurses of Manitoba
Under The Regulated Health Professions Act (the “RPHA”), the College of Registered Nurses of Manitoba (College) has the legislated mandate to govern its registrants in a manner that protects the public interest. Therefore, the College must ensure that all applicants and registrants have met the established requirements for registration as included in the regulations.
One of these requirements is that a registrant does not have a physical or mental condition or disorder, including an addiction, that may impair their ability to engage in the practice of registered nursing in a safe and effective manner. To this end, applicants and registrants must self-disclose to the College any physical or mental condition or disorder, including an addiction, that may impair their ability to engage in the practice of registered nursing, The College will assess the disclosure, along with the any additional information needed for a thorough review, to ensure eligibility to practice as a registered nurse.
When a Disclosure is Made
When the College becomes aware that an applicant/registrant has a physical or mental condition or disorder, including an addiction, that may affect their ability to practice in a safe and effective manner, the person will be asked to provide the following additional information in accordance with College policy AA-3: Disclosure or a Condition or Disorder in as much detail as possible:
- particulars of the matter disclosed, including duration;
- particulars of any past and current treatment plan;
- particulars of any plan which the member has for their practice which will address public safety issues arising from the addiction and/or physical or mental condition; and
Depending on the nature of the disclosure and the additional information provided by the applicant/ registrant, the individual may also be asked to arrange for the College to receive:
- report(s) from treating physician(s) or other health care providers;
- documentary evidence of rehabilitation efforts.
Following receipt of the required information, the CEO/ Registrar will assess the matter against the following criteria:
- the applicant/registrant presents a plan which adequately addresses the public safety issues related to his/her addiction or physical or mental condition; and
- satisfactory references and/or supporting documentation of rehabilitation efforts are received; and
- there are no special circumstances warranting referral of the matter to the Registration Committee in the case of an applicant or the Complaints Investigation Committee in the case of a registrant.
Following a review of all of the required information, an applicant or registrant will be advised of the need for any further next steps as well as the option to address any remaining concerns about a potential risk to the public. It is important to know that making a disclosure does not automatically mean a person is not eligible for registration; rather, we find the balance between the need to protect the public and fairness to the applicant or registrant.
Applicants and registrants who properly disclose a medical condition or disorder are in compliance with the practice expectation regarding self-disclosure. They assist in upholding the College’s mandate and the public’s trust and confidence that the College can govern its members in a manner that protects the public interest.
A Note Regarding the Importance of Prompt Disclosure by Registrants
While applicants and registrants alike are to disclose a physical or mental condition or disorder, including an addiction, that may impair the ability to engage in the practice of registered nursing, an applicant’s disclosure is typically made on their application for registration as they have not yet achieved registration. A registrant, however, is a member of the College in one of the membership classes and holds a current certificate of practice.
Since a registrant has the authority to engage in practice, they pose a potentially higher risk to the public in the presence of a condition or disorder as it could affect their current ability to practice safely. Therefore, a registrant is required to promptly notify the College of a medical disclosure. Prompt disclosure means that the matter is reported in writing to the College as soon as possible. This means that a registrant must not wait to disclose the matter on the renewal application form; disclosures are expected to be made at any time throughout the year.