The Funding, Fees, and Billing Standard of Practice requires that the physiotherapist:
“Maintains current knowledge of relevant funding sources for physiotherapy services and complies with funding requirements, policies, and procedures.”
If you are a physiotherapist who treats clients who have been injured in motor vehicle collisions, it is a requirement of the Standards that you familiarize yourself with the provisions of the Care First Model of Care and what they mean for your practice.
Change is hard. For physiotherapists in Alberta, the latter half of 2026 has been filled with a significant amount of change. Let’s just go ahead and admit that truth. There might be some individuals who thrive on change and the idea of change, but arguably, they are the minority.
The second truth is the Diagnostic and Treatment Protocols Regulation (DTPR) that physiotherapists have worked with for the last 20 years is not perfect. After 20 years, physiotherapists have developed ways of navigating the DTPR and have figured out the ins and outs of the system. But it is certainly not a perfect system.
Enter Care First, the new system for funding the health-care needs of those injured in a motor vehicle collision - another change for Alberta physiotherapists to navigate. As the January 1st, 2027 Care First launch date approaches, it is not surprising that the government has released a steady stream of publications and updates about the program. It’s worth reading those carefully. There has also been a steady stream of social media posts and other commentaries about the new program. That brings us to the third truth.
Don’t believe everything you read online. Ok, that may be more advice than “truth;” however, it is fair to say that there are some who aren’t happy about the pending changes to the funding system for payment of health services for people injured in motor vehicle collisions (MVCs). It is critical that physiotherapists review the Care First materials and learn the new system for themselves. Not only is that friendly advice, it is also your professional responsibility.
- Care-First for Health Care Practitioners (eLearning module)
- Care-First: Resources for Health Care Practitioners (print resource collection)
Like physiotherapists, the College has been reviewing the materials available and working to understand Care First. As a regulatory body, the CPTA’s sole question is – can a physiotherapist fulfill their professional responsibilities while still complying with the requirements established by Care First?
Getting to know Care First
The first thing to know is that Care First is divided into two components. The “Program of Care” which involves care pathways for common MVC-related collisions, and a “Customized Treatment” component which applies to care provided outside the Program of Care, due to the nature of the client’s injury. To date, the Program of Care has been the source of most of the comments the College has received.
The Program of Care is a bundle of services that physiotherapists, chiropractors, doctors, and nurse practitioners are being paid to provide. The bundle of services includes:
- An assessment.
- Treatment that includes the interventions specified in the care pathway(s) relevant to the client’s injury or injuries.
- Reporting of the assessment findings and completion of follow up reports.
- Communication with case managers.
There are care pathways for each of the following MVC-related injuries:
- Neck and associated disorders
- Shoulder pain
- Mid-back/chest wall pain
- Low back pain
- Concussion
The care pathways for each condition have inclusion and exclusion criteria (e.g., injuries that take someone out of the Program). You can find details about the program of care inclusion/exclusion criteria in the Care-First Program of Care Guideline.
The care pathways include a summary of treatment options that are based on available research evidence. There are some recurring themes, such as the requirement that treatment includes exercise, education, and self-management advice. While some physiotherapists may chafe at the idea of being “told what to do,” care pathways are not new in physiotherapy practice. Care pathways help to support consistent, evidence-based care for clients with the same or similar conditions.
CONCERN #1: “Under this program, the physiotherapist does not have professional autonomy to assess their client and identify a treatment program based on the physiotherapist’s professional judgment and the client’s preferences.”
The Care-First Program of Care Guideline (page 12) clearly states:
Health-care practitioners delivering the PoC will develop their treatment plan based on the treatment intervention options described in Appendix III. Interventions that the evidence has shown do not provide benefits, can lead to adverse symptoms, or are not cost-effective may be included within the evidence-based treatment plan based on clinical judgement and the specific needs of the patient. These interventions should only be delivered alongside the treatment intervention options.
In other words, you can add other treatments to the client’s program of care based on your clinical experience and your client’s preferences, so long as you are also providing the basic bundle of services that are set out in the relevant care pathway.
CONCERN #2: “Why are services being provided by physicians and nurse practitioners when they fall within physiotherapists’ scope and expertise?”
Alberta’s Health Professions Act does not grant sole scope for any treatment or service to any profession. Scopes of practice of regulated health professionals overlap. Physiotherapists don’t “own” exercise or education. Other services included in the care pathways are not restricted activities, meaning they are within the public domain, and anyone can provide the service provided they have the competence to do so.
Assistant Deputy Minister and Superintendent of Insurance, Erin O’Neill spoke at the recent Alberta Association of Physiotherapy conference and pointed out two important considerations related to nurse practitioners, physicians, and the program of care:
- There are parts of the province where an injured client may only have access to a physician or nurse practitioner. Enabling these providers to deliver the program of care helps to ensure client access to treatment. Is that ideal? Maybe not. Is it reality? Apparently so.
- If a physician or nurse practitioner, acting as a primary care provider, assesses a client post MVA they need to make a decision. They can act as a “Program of Care Provider” – if they plan to deliver the services specified in the care pathways. They can also decide to send the client to a different provider (e.g., a physiotherapist or chiropractor) with that other provider completing the required assessment and taking on the role of Program of Care Provider.
For a nurse practitioner or physician to collect the Program of Care fee, they need to be the professional who is providing the program of care. As is stated in the Care First Health Care Services Fee Schedule (page 7)
When a physician or nurse practitioner examines a patient in a visit billed to the AHCIP and will not deliver the Program of Care, they may refer the patient for chiropractic or physiotherapy services. The chiropractor or physiotherapist would be entitled to a Program of Care Initial Assessment fee to be paid by the insurer.
The Program of Care pays providers to deliver a bundle of services. Physiotherapists have different skills and additional treatments they can offer as compared with other providers. It’s up to the physiotherapist to use their professional judgment to add to that bundle to help the client recover. However, Program of Care Providers cannot extra bill for services they add to the program of care.
CONCERN #3: “Why are physiotherapists paid the same fees as other health professionals when we have different skills to treat this population?”
The fee provided is based on the delivery of a program of care specified in the guidance documents. Some people will seek out a physiotherapist because they like what physiotherapists can offer. Some people will seek out a chiropractor because they like what a chiropractor has to offer. Some may receive care from their family doctor because that’s their preference or the best option available to them. Each professional providing the program of care is paid the same amount of money for providing the services specified in the care pathways.
As a point of professional pride, physiotherapists may believe they are the best people to provide services to this patient population; however, they are reminded that the client has the right to choose their provider and that the Advertising Standard of Practice includes the requirement that physiotherapists not “discredit, disparage or undermine the skills of other providers.”
CONCERN #4: Under this program the client does not have their choice of provider and is prevented from changing providers.
This is a concern that the College has heard from many people.
The College’s perspective is that clients have an unalienable right to choose their health-care providers. This is fundamental to the ethical principle of autonomy. If a client wishes to change providers for any reason, the physiotherapist has a duty to facilitate transfer to the other provider.
The Care First Auto Insurance Program of Care – Frequently Asked Questions (Release 1, 08-11-2026) publication indicates that the insurer’s authorization is required before a client changes Program of Care Provider. While that could be interpreted as the insurer preventing the client from changing providers or not having choice of provider, that is an assumption, and one that will need to be monitored as Care First comes into effect. There are administrative reasons for this requirement, for example, how would an insurer know who to pay if they were not aware of the change in Program of Care Provider?
Why might we all want to avoid unnecessary provider changes?
There is research that indicates that an effective therapeutic relationship is a fundamental element to a client’s recovery. As such, if an effective therapeutic relationship can’t be established, it is in the interest of both client and physiotherapist that the client change providers.
However, it is also true that with each change of provider there’s a delay in the client’s recovery as a new therapeutic relationship is established. It’s counterproductive to change providers unless there’s an important reason to do so, such as the inability to form an effective therapeutic relationship. On the other hand, the College agrees that a client changing providers because they don’t like the treatment offered by a physiotherapist who is following the Care First care pathways is not likely to support that client’s recovery.
The College’s Perspective
The College’s perspective, and one that we have shared with those involved in the development of this program, is that when a healthy therapeutic relationship can’t be formed it’s in everybody’s interest for the patient to find a new provider. Patient autonomy to choose their health-care provider is unalienable.
CONCERN #5: The fees are not sufficient for the work.
Only physiotherapists can decide if the reimbursement under Care First is sufficient for them to take on this type of work. Like other contracts, physiotherapists are not compelled to provide services under Care First.
Physiotherapists should familiarize themselves with the Care First fee schedule. Those wishing to advocate for a change in fees or structure to payments are directed to the Alberta Association of Physiotherapists. It is the Association’s role to advocate on behalf of the profession.
Coming Up:
In the next article in this series, we will discuss concurrent care and conflict of interest considerations when treating clients under the Program of Care.
Leanne Loranger, PT, Manager Policy and Practice
