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  • Home
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  • Scope of Practice
DEFINING PROFESSIONAL BOUNDARIES

What is scope of practice, and why does it matter?

The scope of practice of a regulated health care professional outlines the activities they are educated, competent, and authorized to perform. A profession’s scope is based on the required and optional education, current practices, and evidence supporting the safety of those activities, as defined in legislation and regulation.

Take Action

Get involved & sign our letter.

We know that physiotherapists working up to their full scope of practice offers numerous benefits to both patients and the healthcare system, including getting patients faster access to care. Write to Premier Doug Ford and Health Minister Jones encouraging them to implement the regulations needed so that physiotherapists can order diagnostic imaging and lab tests.
Scope of Practice Campaign
PHYSIOTHERAPY IN PRACTICE

What’s included in a physiotherapist’s scope of practice?

The Physiotherapy Act, 1991, defines the practice of physiotherapy as: The assessment of neuromuscular, musculoskeletal and cardiorespiratory systems, the diagnosis of diseases or disorders associated with physical dysfunction, injury, or pain, and the treatment, rehabilitation and prevention or relief of physical dysfunction, injury, or pain to develop, maintain, rehabilitate, or augment physical function and promote mobility.  

The College of Physiotherapists of Ontario (CPO) ensures that standards of practice are consistent with legislation and have resources to help inform decisions on what is in a physiotherapist’s scope of practice.

Visit CPO’s Resources
WHY SCOPE OF PRACTICE ADVOCACY MATTERS

What’s happening now and why it’s critical for care.

Current advocacy on PT scope of practice focuses on implementing outstanding changes for activities that still need regulation changes, including, ordering diagnostic imaging. This advocacy highlights how implementation will positively affect access to care, improve health system efficiency and reduce workloads for all providers. Implementing outstanding scope changes for PTs will lead to people in Ontario getting the right care at the right time, and better sustainability in career paths for PTs.  

The scope of practice for a health profession evolves over time, influenced by advances in knowledge and practice, as well as the changing needs of the health system. Advocacy is necessary to implement some of these changes through legislation and to build awareness among health system partners and the public. This process helps make emerging roles for physical therapists part of regular practice.

2009 saw landmark changes for the profession in terms of scope, requiring research, outreach, and explanations of the changes and why they were necessary. In collaboration with the College of Physiotherapists of Ontario, OPA successfully advocated for the ability to diagnose PT-related conditions, as well as other related activities.

SCOPE OF PRACTICE ADVOCACY IS ONGOING

What we’re working on today, and every day. 

Scope of practice changes have a number of steps and can be slow to progress. Legislation changes are needed, both for the Regulated Health Professions Act and the Physiotherapy Act, and other related Acts. Those changes require open consultation where the public and other stakeholders, such as other professions, can comment.

If legislation changes are approved, written and accepted, other changes are needed in regulations for implementation. Regulation changes are also open for consultation and potential modifications. College standards may need to be modified or created, which also go through a period of public consultation.  

Other delays may occur due to elections, changes in government, or low prioritization by the Ministry or government. A combination of these factors has affected the implementation of physiotherapists’ authority to order diagnostic imaging and laboratory tests. Both activities also require changes to regulations outside of the RHPA and the Physiotherapy Act, namely HARPA and the Lab Specimens and Collections Act, which needs broad consensus with other professions and stakeholders.

The scope changes for physiotherapists progressed well between 2008 and 2012. The remaining changes to HARPA related to ordering diagnostic imaging did not progress until 2017, when the government at that time stated that it was prioritizing those changes. The necessary changes were announced in 2018, but the wording of those changes meant that an additional regulatory change would still be required.

Following the 2018 election and change in government, the remaining regulations necessary to implement physiotherapists ordering diagnostic imaging and laboratory tests have not progressed, despite continued advocacy by OPA. We have demonstrated the value and necessity of implementing the remaining scope changes to improve patient care.  

Ongoing Scope of Practice Advocacy 

5 ways we continue to advocate year-round.

Meetings with MPs  

OPA joined CPA and physiotherapists to meet with federal MPs from Ontario ridings during NPM 2024 and the release of CPA’s position paper on optimizing scope of practice. We met with Pam Damoff, MP Oakville-North Burlington, Peter Fragiskatos, MP London North Centre, Lindsay Mathyssen, MP London-Fanshawe, Anthony Rota, MP Nipissing-Timiskaming, and Valerie Bradford, MP Kitchener South-Hespeler. 

Letters to the Minister of Health of Ontario, the Honourable Sylvia Jones 

OPA has consistently kept the Minister of Health updated on changes in the physiotherapy profession and advocated strongly for action to implement the outstanding elements of scope of practice for physiotherapists – ordering diagnostic imaging and laboratory tests. 

Provincial Pre-Budget Submissions 

Before tabling a budget, the provincial and federal governments have open consultations to understand requests from many stakeholders on important issues that need to be addressed in their budget. At every opportunity, OPA consistently makes a submission that voices the need to finalize the implementation of scope of practice authorities for PTs, and advocates to make implementation a priority in the budget.  

Meetings with MPPs 

OPA seeks out opportunities to advocate to MPPs the benefits of implementing the outstanding scope changes. For example, on Tuesday, April 23, 2024, OPA met virtually with MPP France Gélinas, PT, to discuss a letter OPA sent a few days prior to the Minister of Health, Sylvia Jones. Ms. Gélinas delivered the letter to Minister Jones that day.  

Meetings with the Ministry of Health 

OPA has met regularly with representatives from the Ministry of Health to discuss the implementation of outstanding scope of practice authorities over many years. Recent meetings have included the College of Physiotherapists of Ontario and led to an update on the past joint submissions on scope. Read 2008 joint submission. Read 2017 submission.

Advocating for Changes in the Healing Arts Radiation Protection ACT (HARPA) 

OPA has consulted on multiple issues related to the Healing Arts Radiation Protection Act and continues to demonstrate engagement and expertise on these issues.  

In 2021, OPA participated in a consultation to enhance the Healing Arts Radiation Protection Act (HARPA) as part of the Ontario Government’s new red tape and burden reduction measure exercise. OPA pointed out that sections within the very dated legislation impedes innovation and has been a barrier to physiotherapists being able to order X-rays under their own authority.  

Read 2021 submission  

In 2017, Health Quality Ontario formed an Expert Panel to Enhance the Safety and Quality of Energy-Applying Medical Devices in Ontario (the EAMD Panel). The mandate of this group was to provide recommendations and advice to Health Quality Ontario on the modernization of the HARP Act. Changes to the HARP Act are needed to allow PTs to order X-rays. OPA was identified as a stakeholder in this process and was invited to provide feedback to the Panel. 

Read 2017 submission 

Coordinated Work with CORHPA & RCA 

OPA coordinates with other health professional associations to collaborate on messaging that highlights the importance of scope of practice optimization and how it benefits the people of Ontario, the health system, and the health workforce.  

OPA is part of the Coalition of Regulated Health Professional Associations (CORHPA), which includes the Ontario Medical Association and the Ontario Society of Occupational Therapists, among many others. Together, CORHPA meets with representatives of the Ministry of Health to engage specifically on scope of practice advancement. 

The Rehabilitative Care Alliance (RCA) works on many fronts to promote the role of rehab professionals in all areas of the health system. OPA is a frequent contributor to their initiatives, which often highlight the benefits of scope of practice optimization or advancement.  

Scope of Practice Surveys – 2011 and 2024 

OPA conducted a survey in 2011 to better understand the knowledge, experience and preferences related to implementation of the scope of practice changes that were passed in Bill 179 in 2009.  

OPA updated this survey in 2024 to reflect the changes in practice, knowledge and readiness of physiotherapists over that time. This information helps to shape advocacy strategy and messaging to the Ministry of Health. 

Submissions and Updates to the Ministry of Health 

OPA has made substantial collaborative submissions to the Ministry of Health, in 2008 and 2017, on the importance, benefits and feasibility of implementing scope of practice changes for physiotherapists. The submissions and updates are informed by survey data, key informant interviews with PTs and patients, jurisdictional scanning, stakeholder engagement, as well as document and literature reviews.

Support for Local Advocates 

OPA supports members when they connect with their local and provincial government representatives by equipping members with key information and discussion points.  

In 2024, the Northern Ontario District of the OPA attended an event and had the opportunity to speak with Ontario’s Premier, the Honourable Doug Ford. Read news story.

Election Messaging 2025, 2022 & 2018 

OPA has provided messaging to members that they can share with election candidates in their ridings to advocate for scope of practice implementation as a priority if they are elected. 

Scope of Practice Milestones

How physiotherapy scope of practice has evolved.

OPA has worked for nearly two decades in advancing scope of practice changes that enable PTs to deliver more comprehensive care. These milestones capture the progress, partnerships, and perseverance that have brought us here.

The Ontario Physiotherapy Association and the College of Physiotherapists of Ontario collaborated on a joint submission requested by the Health Professions Regulatory Advisory Council (HPRAC) to review the scope of practice of physiotherapists. This joint submission proposed scope of practice amendments, which were all accepted and recommended for implementation by HPRAC, except for one – the authority to refer to specialists. The changes accepted are: 

  • Communicating a diagnosis (controlled activity that is within scope at the entry to practice level)
  • Treating a wound below the dermis
  • Internal pelvic exams (including putting an instrument, hand or finger beyond the labia majora or beyond the anal verge)
  • Administering a substance by inhalation (when the substance has been ordered by an authorized person)
  • Ordering a prescribed form of energy (e.g., diagnostic ultrasound or MRI)*
  • Ordering diagnostics (e.g., X-rays or CT scans)*
  • Ordering laboratory tests*

*These three items were accepted and recommended by HPRAC but still require changes in regulations for implementation.  

Bill 179, the Regulated Health Professions Statute Law Amendment Act, was prepared based on recommendations on changes to the physiotherapy scope of practice, alongside changes for other professions. This landmark Bill included the revision of the physiotherapy scope of practice definition to its current form, as well as the additional authorized activities identified through the review in 2008. 

Bill 179 passed in 2009, which included changes to the Regulated Health Professions Act, the Healing Arts and Radiation Act, and the Physiotherapy Act. To implement some of these changes, additional regulation changes were required.   

OPA and its advocacy partners celebrated the proclamation of changes to the Physiotherapy Act on April 1, 2011, which took effect on September 1, 2011. These changes updated the definition and expanded the scope of practice of physiotherapists to enable them to deliver more authorized acts within that scope, as outlined in 2008. 

After updates and consultation on the relevant standards of practice, physiotherapists could act on scope changes in their practice: 

  • Communicating a diagnosis (controlled activity that is within scope at the entry to practice level)
  • Treating a wound below the dermis
  • Internal pelvic exams (including putting an instrument, hand or finger beyond the labia majora or beyond the anal verge)
  • Administering a substance by inhalation (when the substance has been ordered by an authorized person)

Awaiting implementation and not able to put into practice:  

  • Ordering a prescribed form of energy (e.g., diagnostic ultrasound or MRI)
  • Ordering diagnostics (e.g., X-rays or CT scans)
  • Ordering laboratory tests

On September 20, 2017, Minister Eric Hoskins, announced that the Ministry of Health and Long-Term Care would be moving forward with expanding the scope of practice for regulated health professionals, which specifically includes the remaining elements needed for physiotherapists to order diagnostic imaging.  

OPA and the College of Physiotherapists of Ontario jointly submitted a response to the Ministry’s request for information to address the completion of regulations needed for implementation of physiotherapists ordering specific X-rays, diagnostic ultrasound and lab tests within their scope of practice.  

On April 1, 2018, legislative changes to the Healing Arts Radiation Protection Act were proclaimed, pending additional regulations needed, to add physiotherapists to the list of professions that can order X-rays. This amendment created a need for additional regulation changes to move to implementation.  

In 2023 the Canadian Physiotherapy Association initiated a task force made up of experts on scope of practice from all regions in the country and all practice areas, including Dorianne Sauvé, former OPA CEO. CPA released a position paper on scope of practice on May 1, 2024, to set a reference point for advocacy goals and efforts in each jurisdiction. 

Updates to past submissions on the physiotherapist Scope of Practice sent to Ontario’s Ministry of Health. This update was jointly prepared by OPA and the CPO, at the request of the Ministry. The update describes how implementing the outstanding elements of scope of practice, specifically the authority to order diagnostic imaging and laboratory tests, promotes the government’s goals of getting Ontarians the right care in the right place, faster access to care, and hiring more health care workers. The update also includes details on the current knowledge of the profession on these topics, the practice areas where PTs are already carrying out these activities through delegation, and the readiness of PTs to engage in these authorities.