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Member Feedback Requested: Restricted Activities Standard

In accordance with Section 133(2) of the Health Professions Act, the College of Physiotherapists of Alberta is seeking registrant feedback on the 2022 draft Performance of Restricted Activities Standard of Practice.

Background

Physiotherapists will recall that the College implemented a revised Performance of Restricted Activities Standard of Practice in October 2021. That revision occurred to address expectations for the performance of pelvic health internal examinations. In contrast, the proposed 2022 revisions to the Performance of Restricted Activities Standard of Practice are being made to address significant changes to the legislative framework that governs the performance of restricted activities by regulated health professionals in Alberta.

Restricted activities are currently established in Schedule 7.1 of the Government Organization Act. A restricted activity is a regulated health service that by law can only be performed by an individual authorized to perform the activity. While the Government Organization Act establishes those activities that may only be performed by authorized individuals, it is the Physical Therapists Profession Regulation that:

  • Stipulates the restricted activities physiotherapists are authorized to perform
  • Which restricted activities require additional authorization from the Registrar
  • The other requirements, expectations and restrictions related to the performance of restricted activities by physiotherapists

Bill 46, the Health Statutes Amendment Act encompasses several changes to the Health Professions Act and is being implemented in phases. One change includes transferring Schedule 7.1 of the Government Organization Act (GOA) to the Health Professions Act (HPA) and moving the restricted activities that physiotherapists are authorized to perform from the Physical Therapists Profession Regulation to a restricted activity regulation enacted by a Lieutenant Governor of Alberta Order in Council. The restricted activity regulation will apply to all regulated health professionals subject to the Health Professions Act but will not include all the details that are currently located in the Physical Therapists Profession Regulation.

Importantly, the Government of Alberta has specified that despite these legislative changes, there will be no change to the activities authorized to regulated health professionals at this time nor the requirements for the performance of these activities by regulated health professionals.

Due to these changes, health regulatory colleges are required to develop standards of practice pertaining to the performance of restricted activities that specifically address:

  • How a regulated member performs the restricted activity
  • Who may be permitted to perform the restricted activity under the supervision of a regulated member
  • How a regulated member must supervise persons who provide restricted activities under the regulated member’s supervision

This information was previously captured in Sections 13 through 16 of the Physical Therapists Profession Regulation.

What has changed?

The College has amended and reorganized the current Performance of Restricted Activities Standard of Practice to meet these requirements. The 2022 Standard of Practice has been organized into sections. The first 3 sections are largely unchanged from the current Standard of Practice, and address expectations for the performance of restricted activities in general, including education and authorization requirements for those activities that require additional authorization from the Registrar.

Two sections have been added to the Standard. These address when supervision is required by registrants, and outline supervision requirements. Expectations regarding supervision of restricted activities were included in the 2021 Standard of Practice. However, the 2022 draft Standard has been expanded to include provisions that are currently captured in the Physical Therapists Profession Regulation and which the Government of Alberta has advised will not be contained in the restricted activity regulation. With content being removed from the Physical Therapists Profession Regulation, the College was required to include this content in a Standard of Practice.

What hasn’t changed?

Although the format of the draft 2022 Standard differs from the previous Standard, with the addition of details as already discussed, the expectations related to the performance of restricted activities, the supervision of restricted activities, and the restricted activities authorized to physiotherapists are unchanged.

Next steps

The Government of Alberta has advised that the necessary work to implement the majority of phase two of the Health Statutes Amendment Act, which includes the restricted activity regulation, will completed by late 2022/early 2023. The College of Physiotherapists of Alberta is required to have the revised 2022 Performance of Restricted Activities Standard of Practice in effect by the date that the restricted activity regulation is proclaimed, to enable ongoing provision of these activities by physiotherapists.

What does this have to do with me?

All regulated members of the College of Physiotherapists of Alberta are subject to the legislation and, to varying degrees, this Standard of Practice. Section 133(2) of the Health Professions Act stipulates that the College must provide a copy of proposed Standards of Practice to its regulated members for review and comment. The consultation period for review of the 2022 Performance of Restricted Activities Standard of Practice will end on October 23, 2022.

The College encourages all regulated physiotherapists to review the draft Standard and frequently asked questions (below), providing their comments during the consultation period. Your comments are important to us, but please note the College has limited ability to incorporate additional changes on the restricted activities Standard as this revision is driven by legislation.

Regulated physiotherapists who have questions regarding the draft Standard that are not addressed through the frequently asked questions document are encouraged to contact the College Practice Advisor at professionalpractice@cpta.ab.ca.

Click here to view the draft Standard. Provide your feedback.

What does “present in the treatment room or cubicle, able to observe and promptly intervene” mean? Isn’t this new?

This is not a new requirement.

Section 16(5) of the Physical Therapists Profession Regulation currently reads:

A regulated member who consents to supervise [another individual’s performance of a restricted activity] under subsections (1) to (4) must

(a) be authorized to perform the restricted activity that is being supervised,

(b) be present or on-site while the regulated member or the student is performing the restricted activity, and

(c) be able to observe and promptly intervene to stop or change the actions of the regulated member or the student who is under supervision.

To be able to “observe and promptly intervene to stop or change the actions” of the individual under supervision, the supervisor has always been required by legislation to be in the treatment room or cubicle.

Due to the changes to the Physical Therapists Profession Regulation expected to take effect by late 2022/early 2023 these requirements must now be articulated in the Standard of Practice.

Isn’t the requirement to directly supervise physiotherapist interns new?

This is not a new requirement.

Section 16(1) of the Physical Therapists Profession Regulation specifies that:

“A regulated member registered on the provisional register is permitted to perform those restricted activities described in section 13 only with the consent of and under the supervision of a regulated member registered on the general register or the courtesy register.”

Section 13 of the Physical Therapists Profession Regulation currently enables physiotherapists and physiotherapist interns to perform the following activities:

This Section, in combination with Section 16(5) discussed above, establishes the requirement that physiotherapist interns be directly supervised when performing these restricted activities.

Due to the changes to the Physical Therapists Profession Regulation expected to take effect by late 2022/early 2023, these requirements must now be articulated in the Standard of Practice.

But the requirement to directly supervise physiotherapists on the General Register is new?

This is not a new requirement.

Section 16(2) of the Physical Therapists Profession Regulation currently specifies that

A regulated member registered on the general register who is learning to perform a restricted activity referred to in section 14 is permitted to perform the restricted activities described in that section with the consent of and under the supervision of a regulated member registered on the general register or the courtesy register who is authorized to perform the restricted activities described in section 14 pursuant to section 14(b) and (c).

Section 14 of the Physical Therapists Profession Regulation encompasses those restricted activities that require additional authorization from the Registrar. The amendments to the Performance of Restricted Activities Standard made in 2021 established the requirements that physiotherapists on the General Register apply for individual authorization to perform pelvic health internal examinations and that they be directly supervised when learning and not yet authorized to perform the restricted activity.

The wording of the 2021 Standard retained in this draft, combined with Section 14, and Section 16(5) discussed above, establish the requirement that physiotherapists be directly supervised when learning to perform and not yet authorized to perform these restricted activities independently.

Due to the changes to the Physical Therapists Profession Regulation expected to take effect by late 2022/early 2023, these requirements must now be articulated in the Standard of Practice.

What does “be satisfied with the knowledge, skills and judgment of any individual whose performance of a restricted activity they are supervising” mean?

Any time a regulated physiotherapist agrees to supervise another individual they are required to assess the skills and competence of the supervisee, and to assign only those tasks or activities that fall within the supervisee’s competence. Restricted activities are restricted for the very reason that they pose additional risk to the public if they were to be performed by an individual who is not sufficiently skilled and competent in the performance of the activity.

The physiotherapist has a clear duty to the patient to ensure that their supervisee is competent in the performance of a restricted activity. The supervising physiotherapist is required to decline to supervise or otherwise enable a supervisee’s performance of a restricted activity if the supervisor is not confident in the competence (knowledge, skills and judgment) of the supervisee and their ability to ensure the patient receives safe, quality, effective physiotherapy services.

What does the expectation “If performing a restricted activity not authorized to physiotherapists, under the supervision of another regulated professional, clearly explains to clients that the activity is not a physiotherapy service and the supervision arrangement in place with the other health professional” refer to?

The College is aware of instances where regulated members of the College of Physiotherapists of Alberta work outside of the scope of practice of the physiotherapy profession, as a supervisee of another regulated professional.

In these instances, the services delivered by the individual in question do not constitute physiotherapy.

In some of these instances, the individual working as a supervisee may be performing restricted activities under the supervision of the other regulated professional, who must act in accordance with the supervisor’s governing legislation and Standards of Practice.

When these situations arise, the client must be advised that the services do not constitute physiotherapy and the supervision arrangement and authority that enables the delivery of the service.

Page updated: 23/09/2022