The ELA is proud to welcome our newest member firm: LOGOS  in Iceland!
The ELA is proud to welcome our newest member firm: LOGOS  in Iceland!


PHO Order Requires Disclosure of Vaccine Status of Health Care Providers

Submitted by Firm:
Roper Greyell LLP
Firm Contacts:
Gregory J. Heywood, James D. Kondopulos
Article Type:
Legal Update

Article by: Danny Bernstein + Pamela Costanzo

In October 2021, the Provincial Health Officer ordered health professionals to be vaccinated if they were employed, contracted, or funded to provide services by provincially funded services.  The order, effective October 26, 2021, stated that other health professionals – those working outside provincial funding systems – would be required to be vaccinated at a future date.

On February 9, 2022, Dr. Henry announced that these other health care providers would have to be vaccinated by March 24, 2022, or cease providing services.

The Health Professionals COVID-19 Vaccination Status Information and Preventive Measures Order was published on March 7, 2022 (it can be found here).  It does not require health care workers outside provincial funding systems to be vaccinated in order to work, as was announced.  Rather, it requires their professional colleges to collect their vaccine status information, and disclose it upon request.  The Order sets out the following requirements:

  • Colleges established under the Health Care Professions Act must provide the PHO with the following information for each registrant: name, gender, date of birth, registration ID, address, phone number, email, and place of work;
  • The Minister of Health must then verify the vaccination status of each registrant and disclose that information to the college;
  • On request, colleges must disclose aggregate information respecting the vaccine status of their registrants to the PHO; and
  • On request, for the purpose of preventing or responding to exposures or outbreaks of COVID-19, colleges must disclose the vaccine status and place of work of individual registrants to the PHO.

Colleges included in this Order govern the following professions:  nurses, midwives, chiropractors, dental hygienists, dental technicians, dental surgeons, denturists, dietitians, massage therapists, naturopaths, occupational therapists, opticians, optometrists, pharmacists, physical therapists, physicians, surgeons, speech and hearing health professionals, traditional Chinese medicine practitioners, and acupuncturists.

Because the Order only requires information be shared between a college, the Ministry of Health, and the PHO (upon request), no action is required by health care employers or health care workers at this time.


Danny Bernstein and Pamela Costanzo are employment and labour lawyers at Roper Greyell LLP where they practice in all areas of employment, labour and human rights law. To obtain contact information of any other lawyer at our firm, please visit

While every effort has been made to ensure accuracy in this bulletin, you are urged to seek specific advice on matters of concern and not to rely solely on what is contained herein. The document is for general information purposes only and does not constitute legal advice.