Bill 15 overhauls how Québec’s professional system is regulated and expands several health and social‑services scopes of practice. It transfers many regulation‑making and approval powers from the Government to the Office des professions du Québec (the Office), lets professional orders adopt certain regulations without prior government approval (subject to Office guidelines), and gives the Office direct rule‑making power that can bind one or more orders and repeal order rules.
On health practice, the bill enables nurses to initiate certain examinations and to prescribe medications, tests, products and dressings in cases and conditions set by regulation; broadens midwives’ authority to prescribe contraceptives, screen for and treat sexually transmitted and blood‑borne infections in asymptomatic screened positives; loosens prescribing and care limits for optometrists; recognizes marriage and family therapists as able to practise psychotherapy; and updates dietitian‑nutritionist practice. The package also amends pharmacy and pharma‑supply regulations to permit limited pharmacist substitution and intermediary payments under defined conditions.
These changes are implemented largely by new and amended regulations and include transitional measures and training requirements for some professions.
At a Glance
What It Does
The bill shifts core regulatory powers from the Government to the Office des professions, authorizing the Office to adopt regulations that determine diplomas for permits, adopt an accounts conciliation and arbitration regime, and issue binding regulations applicable to one or more orders after consultation. Separately, it amends multiple professional Acts to expand scopes of practice for nurses, midwives, optometrists, dietitian‑nutritionists and marriage and family therapists, with the detailed boundaries left to implementing regulations.
Who It Affects
The Office des professions and Québec’s professional orders (nursing, midwifery, optometry, pharmacy, psychology, social work, agrology, etc.), regulated health professionals (nurses, midwives, optometrists, dietitian‑nutritionists, marriage and family therapists), educational institutions that grant qualifying diplomas, pharmacists and pharmaceutical manufacturers/wholesalers/intermediaries, and patients who receive primary and specialized care.
Why It Matters
The bill centralizes regulatory authority and accelerates order‑level rulemaking; that changes the balance between self‑regulation and centralized oversight and will affect how quickly new practices or training standards are introduced. For health systems, the scope expansions are significant: they enable task‑shifting and new autonomous roles for several professions but hinge on forthcoming regulations, training programs and governance adjustments that will shape access, liability and commercial interactions.
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What This Bill Actually Does
Bill 15 reorganizes who makes and approves the detailed rules that govern Québec’s professions. Rather than the Government approving many order regulations, the Office des professions gains the lead role: it can write regulations setting which diplomas give access to permits, adopt rules that bind multiple orders, and create a single accounts conciliation and arbitration procedure for fee disputes.
Professional orders still adopt many regulations, but those regulations must take Office guidelines into account and be transmitted to the Office; some order rules may be replaced or repealed by Office regulation after consultation.
On practice scopes, the Act pushes substantive decisions into regulation. For nurses, the statutory list of permitted activities now includes initiating examinations and tests in situations defined by regulation and, separately, prescribing medications, other substances, products, dressings and diagnostic tests where regulations permit.
Midwives gain explicit powers to prescribe and administer contraceptives for any person (not only in pregnancy), to initiate STI/BBI screening under public‑health operations, and to treat asymptomatic people who test positive on screening. Optometrists may prescribe and administer medications and provide certain care in primary‑care contexts or under ophthalmologist treatment plans, but optometrists who lack both earlier permits must complete an approved program (at least 145 hours) before engaging in the newly listed activities.The bill also modernizes recordkeeping and governance: it expands the information that must appear on professional rolls (membership numbers, main sector of practice, special permits and past revocations), changes quorum and signature thresholds for special meetings, and removes several legacy restrictions (for example, voting rules in nurses’ general meetings and the requirement that agrology acts be remunerated).
For pharmacies and drug supply chains, the legislature enacts two specific regulations: one narrowly permitting pharmacists to prescribe or substitute manufacturer‑affiliated products when strict conditions are met (e.g., the product is a generic or biosimilar and the pharmacist lacks a significant interest), and another authorizing certain benefits (declared dividends) to intermediaries and wholesalers. Finally, the Act contains many transitional provisions that convert former government regulations into Office regulations and set deadlines and bridging rules for professionals and orders while new regulations are developed.
The Five Things You Need to Know
The Office des professions can adopt regulations that bind one or more professional orders and may expressly repeal order regulations in those areas after consultation.
Under the new section 12.0.1.1 the Office will determine, by regulation, which diplomas give access to a permit or specialist’s certificate and must consult educational networks and ministers before doing so.
The Nurses Act now authorizes nurses, when specified by regulation, to initiate examinations and tests and to prescribe medications, other substances, products and dressings in cases and on conditions set by regulation.
The Midwives Act lets midwives prescribe/administer contraceptives to any person, initiate STI/BBI screening in public‑health operations and treat asymptomatic screened positives with medication at the primary‑care level.
The new pharmacy regulation allows a pharmacist to prescribe or substitute a medication manufactured by a company in which the pharmacist holds shares only if the product is a generic or biosimilar, the pharmacist does not hold a 'significant interest' as defined by the Trust Companies and Savings Companies Act, and no prohibited benefits are received or given.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Office determines qualifying diplomas and consults education bodies
This section gives the Office express authority to list, by regulation, the diplomas that permit access to a professional permit or specialist certificate and to set cooperation terms with educational institutions. Practically, that means the Office—not the Government—will set academic gateways and formalize how orders and schools collaborate on curricula and equivalence standards. The provision requires consultation with universities, cégeps, the relevant order and the education ministers, which embeds cross‑sector input but leaves technical standards to the Office’s regulatory process.
Mandatory accounts conciliation and arbitration regime
The Office must create a single conciliation/arbitration regulation that applies to fee disputes across orders. The regulation may let claimants use the procedure even after paying, establish internal arbitration councils within orders, set whether one or three arbitrators hear a dispute based on dollar thresholds, allow application fees and permit awards to include interest and indemnities under Civil Code formulas. Members generally cannot sue while conciliation time remains, but an exception allows early proceedings where recovery is at risk with authorization—an operational detail that parties and orders will need to implement in their procedures.
Office can adopt binding regulations across orders and repeal order rules
Beyond technical standards, the Office can now step into any matter that otherwise could be regulated by an order and promulgate a regulation binding one or more orders or their members, after consulting affected orders. The section explicitly allows the Office to repeal existing order regulations or provisions. That creates a legal path for harmonizing cross‑order issues but also raises procedural questions about when the Office will use that power and how it will manage conflicts with order autonomy.
Orders can adopt regulations without government approval (with Office guidelines)
The bill authorizes boards of directors to adopt certain regulations (listed by reference) that must take Office guidelines into account and be transmitted to the Office; such regulations come into force 15 days after publication and are treated as public law. The practical effect is to speed order rulemaking by removing a separate government‑approval layer, while requiring orders to align with Office guidance and post the regulation publicly—a mix of decentralization in process and centralized normative influence.
Expanded roll contents and duties to update records
Orders must keep membership rolls up to date and now must include new fields: membership number, principal sector of practice, details of special permits (activities allowed and conditions) and notes on past revocations. The roll must also include psychotherapist‑permit details (issue date, suspensions, restrictions). This change increases transparency and administrative burden on orders to collect and publish more granular professional data, and it creates searchable markers that affect mobility, public information and complaints handling.
Scope expansion deferred to regulation: initiating tests and prescribing
The Act inserts two regulatory hooks: paragraph h lets the Government/Office define situations where nurses may initiate examinations/tests; paragraph i lets regulations set cases, conditions and training for nurses to prescribe medications, tests and products. The statute therefore authorizes expanded clinical activities but defers the substantive limits—drug lists, training curricula, and oversight—to subsequent regulations, which means the timing and content of practical scope changes depend on regulatory rulemaking and related transitional measures.
Pharmacist substitution and intermediary benefit rules with strict conditions
The legislature enacts two targeted regulations: one allows pharmacists to prescribe or substitute a medication made by a company in which they hold shares only where the product is a generic or biosimilar, the pharmacist lacks a 'significant interest' (per Trust Companies Act), and no prohibited benefits occur; another permits accredited manufacturers to pay declared dividends to intermediaries (including pharmacy banners/chains) and allows corresponding payments to wholesalers. The accreditation regulation was amended to reflect those permitted payments. These are narrow, conditional commercial exceptions that require pharmacists, manufacturers and intermediaries to document ownership and benefits and to ensure compliance with prescription‑insurance rules.
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Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Office des professions du Québec — Gains substantive, centralized rule‑making authority (diplomas, cross‑order regulations, arbitration rules and standards for board conduct), which lets it harmonize standards and act against board members’ ethical breaches.
- Certain regulated health professionals (nurses, midwives, optometrists, dietitian‑nutritionists, marriage and family therapists) — Receive statutory authorization for expanded clinical activities that can increase autonomy and allow task‑shifting, potentially improving access to primary care.
- Patients in primary and community care settings — Stand to benefit from faster access to testing, prescriptions and point‑of‑care treatments (e.g., STI treatment by midwives, nurse‑initiated tests) if implementing regulations and training programs are put in place.
- Professional orders that want faster rulemaking — Can adopt some regulations without Government approval and bring rules into force more quickly while still aligning with Office guidelines.
- Pharmacies and intermediaries that hold manufacturer shares — Gain a legal path (limited and regulated) to use manufacturer‑affiliated generics/biosimilars and to receive declared dividends, under specified conditions.
Who Bears the Cost
- Professional orders — Face potential loss of autonomy where Office regulations override order rules; must also expand administrative work (new roll fields, transmission duties, arbitration council set‑up) and adapt governance rules.
- Educational institutions and training providers — Must engage in Office‑led consultations and may need to modify curricula or create new training programs (e.g., optometrist 145‑hour program) to meet diploma and permit standards.
- Health institutions and employers — Will absorb training costs, liability exposure and reorganization as nurses and midwives take on new diagnostic and prescribing tasks; they must update policies and supervision arrangements.
- Pharmacists and pharmacy owners — Face tighter conflict‑of‑interest limits and compliance duties to document shareholdings and prohibited benefits if they intend to use manufacturer‑affiliated products; chains and banners must monitor dividends and declarations.
- The Office des professions — Gains responsibilities (inquiries, penalties, expanded regulation drafting) that will require staffing, expertise and budgets to implement effectively; resource gaps could slow rollouts or enforcement.
Key Issues
The Core Tension
The bill trades speed and regulatory coherence (centralizing power at the Office and reducing government approval bottlenecks) for professional autonomy and clarity: it makes it easier to standardize and expand practice across Québec, but it concentrates authority in an administrative body and pushes many critical choices into later regulations—creating a classic efficiency‑versus‑self‑regulation dilemma with downstream consequences for training, liability and conflicts of interest.
The bill delegates many substantive choices to forthcoming regulations, so the real impact will depend on regulatory design, consultation practices and timelines. Key items—drug lists for nurse prescribing, exact training curricula and approval standards for optometrists, the thresholds that trigger one‑ versus three‑arbitrator panels, and the Office’s criteria for when it will replace an order regulation—are not set in the statute.
That creates implementation risk: stakeholders must rely on the Office and orders to translate broad statutory hooks into operational rules, and disagreements over technical details may shift to regulatory consultation and potential litigation.
Centralization of rule‑making at the Office improves coherence but compresses political and accountability pathways: the Office can now adopt binding cross‑order regulations and repeal order rules, yet orders retain responsibility for on‑the‑ground professional governance. This tension creates questions about democratic oversight, transparency of the Office’s decisionmaking, and the capacity of orders (and the Office) to manage the additional administrative load.
The pharmacy‑related changes authorize certain commercial payments and limited pharmacist substitution, but the safeguards depend on definitions (e.g., 'significant interest') and enforcement by multiple regulators (Office, accreditation regime, prescription drug insurance rules), leaving room for differing interpretations and potential commercial pressures on clinical decision‑making.
Finally, transitional provisions convert many existing government regulations to Office regulations and set phased entry dates for parts of the Act, but several core sections only take effect once the Office or Government enacts implementing regulations. That sequencing means practitioners and institutions will face a period of regulatory uncertainty during which training, insurance, and operational changes must be planned before full legal authority to practise new activities arrives.
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