Read Our Submission & Respond to Scope of Practice Consultation 

Following our September update about the Government of Ontario’s public consultation on scope of practice changes, OPA has completed our comprehensive response to the Ministry of Health.  

The consultation period closes on November 3, 2025, and we strongly encourage all physiotherapists to participate and make their voices heard. See below for how.

OPA’s Submission: Ready for Your Use 

OPA has submitted a detailed response addressing all consultation questions, backed by evidence, research, and the results of our 2024 survey of Ontario physiotherapists. Members are welcome to reference, adapt, or use content from our submission in their own responses to the government consultation. 

Our submission emphasizes how implementing the authority for physiotherapists to order diagnostic imaging (X-rays, CT scans, MRIs, and diagnostic ultrasounds) will: 

• Improve Access to Care 

• Reduce Healthcare System Burden 

• Work Within Established Quality & Safety Frameworks 

What the Evidence Shows 

Our submission includes compelling data from the 2024 OPA survey of Ontario physiotherapists who responded that: 

• 74% experience difficulties obtaining diagnostic imaging or lab results needed for patient care 

• 84% report that these challenges lead to delayed treatment for patients 

• 82% have completed tests but never received the reports 

• 62% have seen inaccurate diagnoses result from these barriers 

Research from jurisdictions where physiotherapists already have this authority demonstrates: 

• No significant increase in overall imaging utilization 

• High concordance between physiotherapist and specialist physician ordering patterns 

• 27-49% reduction in healthcare costs (systematic review) 

• Most Alberta physiotherapists order an average of only 22 imaging tests per year 

Outstanding Authority: Laboratory Tests 

This consultation focuses on diagnostic imaging. OPA will continue to advocate for the authority to order laboratory tests- the final piece of scope expansion approved under Bill 179 in 2009 that has not yet been implemented. 

Three Ways to Participate Before November 3

Your voice matters. Here’s how you can support this critical scope expansion: 

1. Use OPA’s submission: Reference or adapt content from our comprehensive response. 

2. Submit directly to the government consultation: Visit the Ontario Regulatory Registry to provide your feedback.

3. Contribute to ongoing advocacy: Participate in OPA’s letter writing campaign to decision-makers. 

Why This Matters Now 

Since 2009, physiotherapists have been waiting for the regulations needed to implement scope of practice changes that are already approved in legislation. Four other provinces- Alberta, Quebec, Nova Scotia, and PEI- have successfully implemented this authority for physiotherapists. 

With Ontario facing: 

• Challenges for patients across Ontario to access care  

• 2.5 million people without a family physician (projected to reach 4.4 million by 2026) 

• Increasing wait times for specialist consultations 

• Emergency departments overwhelmed with non-urgent visits 

• Implementation of these scope changes will allow physiotherapists to better serve patients, reduce system pressures, and deliver on the government’s commitment to provide “the right care in the right place.” 

Timeline Reminder 

• Consultation closes: November 3, 2025 

• What happens next: Following the consultation, the Minister of Health will need to make regulation amendments (subject to Cabinet approval). 

OPA remains optimistic that the government will move quickly with the needed regulation changes following this consultation period.