Scope of Practice Update

Thank you to everyone who has been engaged with the recent announcement about pending scope of practice implementation for physiotherapists in Ontario. We are equally excited about these next steps and want to assure our community that we will share additional information as soon as it becomes available to us. 

Following the Announcement, the Government of Ontario opened a public consultation on the scope of practice for a number of regulated health professions and specifically included the authority for physiotherapists to order diagnostic imaging.  

What’s Been Completed

Scope of practice expansion began under the Physiotherapy Act, 1991 in 2009. Specifically, members will recall that the Physiotherapy Act was amended to:

• Expand the legislative description of the scope of practice of physiotherapy in section 3 of the Act; 

• Authorize physiotherapists to “communicate a diagnosis”;

• Perform several procedures relating to wound care; 

These changes have been in place for some time. Combined with the earlier extension of authority to “administer a substance by inhalation” that was extended prior, the scope changes arguably represent the most extensive granted to any profession that was regulated by the Health Professions Regulations Act when it came into force and effect in 1993. With the pending addition of diagnostic imaging, the only outstanding authority is the ability to order of lab tests.

In the fall of 2024, OPA collaborated with the College of Physiotherapists of Ontario to update past submissions to the Ontario Government on scope of practice implementation. This included the results of a 2024 updated survey of Ontario physiotherapists to understand the current landscape. A comprehensive submission has already been made to the Ministry in advance of this announcement. OPA has been committed to advocacy in this area dating back to 2009. View the timeline of OPA activities related to scope changes. 

What Needs to Happen for Scope of Practice Changes to Advance  

It is important to know that few of the health professions that are seeking scope expansion are at the same point in terms of the necessary enabling legislation. In this regard, the physiotherapy profession is among the furthest advanced. In our case, the necessary statutory amendments have already been made and have been proclaimed.  

Once this current consultation period has ended, the following amendments to regulations need to occur. The changes to regulations are under the authority of the Minister of Health, subject to approval by Cabinet. Implementation of the physiotherapy scope of practice changes require: 

• A regulation under section 6(2) of the Healing Arts Radiation Protection Act to add prescribing of X-rays by physiotherapists. 

• Amendment to the Exemptions section of O. Reg 107/96 “Controlled Acts” under the Regulated Health Professions Act, 1991 is required to give physiotherapists the authorization to order the following “ prescribed forms of energy”: 
  o MRIs, under Sections 3.1 and 7.4, 
  o Diagnostic Ultrasound, under Section 7.1(2), by including “a member of the College” as a “member with ordering authority.” 

Physiotherapists are also seeking the ability to order laboratory tests, but the announcement did not reference this request. The following regulation changes would be required:  

• Amendment to O. Regs. 45 /22 Sections 17 & 18, under the Laboratory and Specimen Collection Act to permit physiotherapists to order laboratory tests (9.1(a)) as appropriate. 

• Amendment to O. Reg. 207/94 General, Section 12 under the Medical Laboratory Technology Act, 1991 to permit taking blood samples when ordered by a physiotherapist. 

What the Government Announcement Means

This announcement is consistent with the government’s commitment to advance scope of practice expansion. The public consultation is a forum for the government to share its intent and to receive input on the benefits and risks of implementing scope of practice changes for multiple regulated health professionals including physiotherapists. We remain optimistic that following the completion of the consultation on November 3, 2025 the government will move quickly with the needed regulation changes to expand the scope of practice for physiotherapists.  

What Information We Do Not Have Yet

• Specific timelines for the drafting and approval of the necessary enabling regulation changes. We are hopeful that the regulations pertaining to physiotherapy could be in place as early as mid-year 2026.  

• Timeline from approval of regulation changes to clinical implementation including confirmation of the College of Physiotherapists processes for rostering that will be adapted to support this new authority.  We understand that the College is preparing for implementation so that once the government has made the final regulatory changes, they will be ready to move forward. We will continue to work with CPO on implementation related considerations. 

Government of Ontario Consultation 

Thanks to all who provided thoughts to inform OPA’s feedback. This feedback closed October 8, 2025.

The Government of Ontario has released a consultation on the proposed changes to scope of practice closing on November 3, 2025.

1. Continue with your letter writing advocacy in support of scope expansion for physiotherapists. 

2. Respond directly to the government’s consultation.

We are actively collecting feedback from the physiotherapy community to include in our response to this consultation, which closes on November 3, 2025.

In addition to a summary of the existing PT competencies and scope of practice already passed in legislation, OPA will ensure the following points are clearly articulated with supporting evidence. 

• Continued access to diagnostic imaging must to be publicly-funded.

Implementing the authority for physiotherapists to order diagnostic imaging will:

• Increase access to the right health care at the right time for many people in Ontario

• Improve efficiencies and reduce costs in the healthcare system by eliminating redundancies and red tape

• Require additional education and ongoing learning by PTs to ensure best practices

• Be implemented safely and effectively by the College of Physiotherapist of Ontario’s robust and proven rostering process and quality assurance

OPA will share our submission with members prior to the government’s consultation closing. 

We strongly encourage all PTs to provide their support through any of the two remaining pathways with comments directly to the Government’s consultation or continue with our letter writing campaign. Our voices are stronger together! 

Questions? Contact OPA at physiomail@opa.on.ca