Clarifying Scope: Supplement Recommendations and the Role of R.Ac.s in BC

From Dr. Melissa Carr, Executive Director, ATCMA

I want to share an important clarification with our TCM community in British Columbia.

In my previous understanding, I believed that Registered Acupuncturists (R.Ac.s) were permitted to recommend certain Natural Health Products (NHPs), such as vitamins and supplements, within the context of patient care. Upon further review and confirmation from the College of Complementary Health Professionals of BC (CCHPBC), I want to correct that understanding.

Unfortunately, R.Ac.s are not authorized to recommend Natural Health Products (NHPs).

What the Regulation Says

Under the Complementary Health Professionals Regulation, the scope of practice for acupuncturists has not changed. The CCHPBC clearly outlines the following:

“Under the new Complementary Health Professionals Regulation, the scope of practice for acupuncturists has not changed.”

Within this framework:

Permitted (with limits):

• R.Ac.s may apply pre-made, Health Canada–approved topical herbal products, including TCM topical products
• These must be used as part of an acupuncture treatment
• Products cannot be compounded or prescribed

Not Permitted:
R.Ac.s are not authorized to:

• Prescribe, compound, or dispense herbal medicines
• Recommend food cures
• Recommend Natural Health Products (NHPs), including:
  • Vitamins
  • Minerals
  • Herbal supplements
  • Any product with a Natural Product Number (NPN)

This includes recommending NHPs as adjuncts to treatment.

Who Can Recommend NHPs?

It is important to distinguish that the ability to recommend herbal medicine and NHPs does exist within the TCM profession—but not at the R.Ac. level.

The following licensee categories are authorized to recommend NHPs within their scope:

• Registered Traditional Chinese Medicine Herbalists (R.TCM.H.)
• Registered Traditional Chinese Medicine Practitioners (R.TCM.P.)
• Doctors of Traditional Chinese Medicine (Dr.TCM)

Why This Clarification Matters

Patients increasingly expect guidance on supplements and natural products, and many of us are trained to think holistically about these tools. However, as regulated health professionals, we must align our clinical practices with the scope defined by our regulator.

Even well-intentioned recommendations can be considered practicing outside of scope if they fall outside of our scope of practice.

Knowledge Still Matters

While R.Ac.s cannot recommend supplements, having a solid understanding of common NHPs remains both valuable and important in clinical practice.

Patients frequently ask about supplements such as magnesium, vitamin D, omega-3s, or herbal products they are already taking. Being knowledgeable allows you to:

• Better understand your patient’s current health regimen
• Know when referrals can support safe, coordinated care to other healthcare providers

This knowledge supports patient safety and strengthens your role as a primary point of contact in their care—even when you are not the practitioner making the recommendation.

Moving Forward

I share this clarification in the spirit of transparency and professional accountability. It’s important that we are aligned in our understanding and communication of scope.

Having said this, it's helpful for R.Ac.s to have knowledge about the natural health products your patients are taking. If you understand

R.Ac.s can continue to provide excellent care through acupuncture and TCM-based assessment, while referring patients to colleagues with herbal medicine designations when supplement recommendations are appropriate.

If you are ever unsure, I encourage you to consult directly with the CCHPBC or reach out to ATCMA for guidance.