Hello Again PABC Members,

As a follow-up to my last blog about the SOP Committee’s work providing feedback on the Proposed Regulation Change, I’m writing with an update for you on our learnings from our meeting with the Ministry of Health (MoH).

The Scope of Practice Committee (SOP) continues to feel that feedback is beneficial in this process of transition.

In mid March, we met with Christopher Bennett, Brian Westgate, Mark MacKinnon and Susanne Watson from the MoH. I’m pleased to share that they were quite engaged with us and we brought informed and thought provoking questions to the conversation for consideration.

We were able to share with them the challenges that have arisen with third party payers relying on legislation to determine physiotherapy scope of practice and the realization that there needs to be better communication on the purpose of legislation so policy makers and funders can look to the professional standards of practice as the most important place for how legislation should roll out in the functional application of the Act.

Below is a summary of what we learned and confirmed.

Summary from Ministry of Health Meetings:

The goal is to modernize the regulation under the existing Health Professions Act so when the replacement Health Professions and Occupations Act (HPOA) is enacted in 2025, all of the professions will enter into this transition with a similar regulation in place under a shared scope of practice and restricted activities model.

They are trying to get language to be congruent across the different professions because synonyms are confusing and may be interpreted as different from each other (eg. adjustment vs manipulation).

Trying to get all the regulations updated to use the same language when appropriate will help with interpretation and reduce confusion in practice.

The Shared Scope of Practice and Restricted Activities is an attempt at broadly defining each profession. They recognize and support the idea that all the professions can and do overlap. In this model, they will not define where we do overlap but rather will only define where we may not.

This is where the Restricted Activities Model comes into play.

The Restricted Activities Model identifies what activities represent increased risk to the public and limits who can perform those activities.

Activities that the MoH does not perceive to be risky need not be listed and are not restricted to any profession or non-profession. When there are restrictions listed, if an activity is restricted in another health professions’ regulation and it is not listed in another, they cannot perform it.

There is no ‘master list’ of restricted activities and the MoH does not currently intend to create one.

There are generally 2 categories of restricted activities. The first are activities restricted to that profession that are trained at an entry-to-practice level. The second category are skills that require some sort of post graduate training. When it comes to interpretation of what a certified professional is, it will fall on the college to determine what will be the necessary steps to certified practice.

The MoH was clear to us that each health professions’ scope of practice is not to be interpreted as restrictive.

If a word or term is not included in our definition and thereby not referenced under the scope of practice section, it does not mean this is not part of our scope of practice (eg. prevention).

Similarly, if a skill, treatment technique or other is not listed as a restricted activity, then anyone can perform or make use of it (eg. exercise). They are not listing many of our skills because they are not restricted to us alone or to anybody else. It’s also worth noting that the singular means plural in all the regulations. Just because a regulation talks about treating a person doesn’t mean it excludes the treatment of a group of people.

The Ministry’s goal in defining the health professions is to identify what each health profession is primarily known for and focuses on. They indicated that if they add too much, the definition becomes restrictive and may miss key elements of practice.

They intend for each health professions’ definition to be broad and general.

So with all of that background there were a few key areas we asked for further information on and the feedback we learned:

  1. Physiotherapy Diagnosis – they did not realize that diagnosis was a part of our current standards of practice. There was a perception that diagnosis was something by diagnostic test (eg. Bloodwork, biopsy, imaging) and had not recognized the vast number of conditions that diagnosis is based on ie. signs and symptoms and other objective tests that physiotherapists are skilled and capable of doing. We were able to share the importance of this in enabling physiotherapists to continue to be first point of contact for care for decision making and treatment planning, especially with third party payers and helping to unburden physicians and nurse practitioners when the ailment is within our scope of knowledge. They were happy to take this into consideration and we will provide this feedback to them formally in our written feedback with reference the college standards of practice.
  2. Modalities – they have received a lot of feedback about having modalities listed and itemized on the restricted acts. The MoH has some use of modalities restricted on other health professions when they are used for uses that have higher risk – for example electricity for burning tissues (Electrocautery) vs that to modify the sensory experience or enhance muscle activation (TENS, NMES) are not. So under the broad definition the term “mechanical” is meant to encompass our ability to use machines in treatment and do not need to further itemized low grade modalities.
  3. Delegation – delegation of a task does not exist in regulatory language and the HPOA requires the rules around delegation to be set out in the College bylaws.

From all of this information our final work over the past few weeks has been to comb through the other 27 health regulations (!!), itemize restricted acts and ensure that if physiotherapists are currently performing things restricted we ensure they are listed in our proposed regulation change.  As we get the BOD to approve our final recommendations, we wanted to provide you with ideas of the feedback we will be providing to the MoH:

Our feedback going forwards will continue to be:


  • Advocate for the use of physiotherapy diagnosis in alignment with our Standards of Practice
  • Advocate for the use of movement OR activities, participation and environmental factors  to be in alignment with ICF terminology that is beyond structure and function alone.
  • Advocate for the inclusion of prevention, education and optimization – while we know these are a part of shared scope, we see them in other regs and would still like them considered so the public and policy makers understand our essential role in these.

Restricted Acts:

  • Advocate for language around respiratory support that enables administering oxygen by mechanical ventilation as well as the administering of prescribed medications. (eg nebs)
  • Advocate for language that includes wound management (eg. irrigation of wounds and procedure below the dermis or mucosal membrane)
  • Advocate for language that includes TMJ (eg. fingers in ears)
  • Advocate for inclusion of imaging for the purpose of biofeedback and monitoring of rehabilitation progress.

Certified Restricted Acts:

  • Advocate that the MoH consider delaying this category at this time in order to avoid delays in service and lack of access to care for the public. We are recommend the MoH move the restricted activities listed in the Certified Practice category into the Restricted Acts category and modify the language to reflect regulation through Standards of Practice as established by the College.

Calling You to Action:

As we wrap up our collective response, we have been advised it is often best not to have a template letter as they are more likely to be disregarded due to repetitive information.

Rather, we encourage you each to use this information to reflect the components that you are value aligned in as you individualize your response.

We also encourage you to reflect anything you feel we missed in light of all of the background learning we have gained.

Please remember the invitation to respond in this period is April 23, 2024 and you can respond to: PROREGADMIN@gov.bc.ca

As always, the SOP Committee welcomes your feedback directly through the PABC portal as we are here to try to be a voice that reflects the breadth and diversity of our field through practice scope knowledge and advocacy.

Yours in health,


PABC SOP Committee Chair

P.S. Extending my own personal thank you to the incredible dedication of the SOP Committee making this work possible. Thank you Stephen, Maria, Amy, Courtney, Jennifer, Chiara and Kevin for the immeasurable hours of meetings and your work done to understand legislation, review the regulations of all the health professionals in BC and come together to create a deeply thoughtful response.