NP Medical Directors and the March 2027 changes

From March 1, 2027, the Nurse Practitioner behind an Ontario injectables practice assesses each client and writes client-specific orders, instead of authorizing treatments through a directive. That is genuine medical direction, and every practice that relies on a directive today needs a prescriber who works this way by the same date.

What changes for an NP who directs injectors

CNO's updated standards expect the authorized provider to complete an initial client assessment, in person or virtual, and establish a plan of care with follow-up before issuing a client-specific order. For aesthetic services involving prescription drugs or controlled acts, nurses use those client-specific orders instead of directives. If you delegate a procedure to someone without the authority to perform it, you must be onsite for the whole procedure.

What genuine oversight looks like

CNO's Aesthetic Services guideline already lists what an NP is accountable for when nurses carry out their orders. Among them:

• deciding when your direct involvement or supervision is needed, based on the risk of the procedure;
• assessing whether remote or virtual prescribing suits the treatment and the client;
• a treatment and management plan with follow-ups, made with the client and the team;
• orders that are clear, complete and appropriate;
• making sure the nurses carrying them out have the competence and resources to do it safely;
• being competent to manage adverse outcomes, and acting promptly when one happens.

The rest of the role is in what a Medical Director does.

Why this is an opportunity

A directive let one signature cover a whole practice. A client-specific order needs a prescriber who assesses each client. Practices that relied on a directive will be looking for NPs and physicians willing to do that work properly, and an NP who sets up a sound assessment process early, including virtual assessments where appropriate, is the kind of director they will want.

What to set up before March 1, 2027

• How clients are booked for your initial assessment, and how long it takes.
• The length of your orders, and how reassessment is triggered when they end.
• How nurses reach you when something changes between visits.
• Your documentation of each assessment and plan of care.
• Whether any practice you direct delegates to aestheticians, and how the onsite rule will be met.

Before you agree to a practice, read the questions to ask first.

Questions NPs ask about March 2027

Can an NP still use a directive for injectors after March 1, 2027?

Not for aesthetic services involving prescription drugs or controlled acts. CNO's summary says nurses providing those services will use client-specific orders instead of directives.

Does an NP have to assess every client in person?

No. CNO says the assessment may be in person or virtual, as appropriate, and the NP is accountable for deciding whether virtual assessment and remote prescribing suit the procedure and the client.

Does the NP have to be onsite when nurses inject?

Not when an RN or RPN is performing a controlled act they are authorized to perform under a client-specific order, unless the NP or nurse considers it necessary. An NP who delegates a procedure to someone without authority must be onsite for it.

Is this a good time to become a Medical Director?

Practices that relied on directives need prescribers who assess each client by March 1, 2027. If aesthetics is within your competence, it is a good time to set up the process and start.

General information about the College of Nurses of Ontario changes to the Scope of Practice and Medication standards that take effect on March 1, 2027, based on CNO's published summary and FAQs as read in October 2026. The updated standards had not been published when this was written. Not legal, regulatory or compliance advice. Plus One MD is not affiliated with or endorsed by CNO. Confirm your own obligations with CNO and your liability protection provider.