It’s Just Cosmetic

The Case

The College received a report from a member of the public detailing concerns about a physiotherapist. In particular, the report noted that the PT was performing cosmetic acupuncture, which is a controlled act outside the scope of practice of physiotherapy. The physiotherapist referred to themselves as a “facial acupuncture specialist” even though they did not complete a recognized speciality designation certification program and did not have proper authorization from a regulatory college to use a speciality title.

The reporter brought the information forward to the College because she was concerned about the safety of the public as facial acupuncture carries a lot of risk and practitioners generally obtain post-graduate education to perform it safely.

The physiotherapist advertised the services under a natural skin health clinic operating in a fitness facility that is not owned by a regulated health professional. Both the PT and the clinic advertised cosmetic acupuncture services on social media. The fitness facility did not employ a registered acupuncturist.

The physiotherapist confirmed that they offered cosmetic acupuncture to patients and noted that they began doing so after completing training in Traditional Acupuncture Facial Rejuvenation. They acknowledged that cosmetic acupuncture is not within the scope of practice of physiotherapy, but said they were unaware that they were not authorized to perform acupuncture beyond the scope of practice of physiotherapy. Additionally, when they signed their acupuncture records, they did not use their PT designation.

The PT was rostered to perform acupuncture with the College, however their cosmetic acupuncture practice treated conditions including wrinkles and acne, which fall outside the scope of practice of physiotherapy.

The Standards

The Controlled Acts and Restricted Activities Standard stipulates that every controlled act performed by a physiotherapist, including acupuncture, must be within the scope of practice of physiotherapy. The standard also states that physiotherapists must have the authority to perform a controlled act. While physiotherapists can roster to perform acupuncture, they can only provide acupuncture in accordance with the standards of practice and within the scope of practice for physiotherapy.

It was concerning that the physiotherapist didn’t know that they were unable to perform acupuncture outside the scope of practice for physiotherapy, as every PT who rosters to perform a controlled act must complete a declaration stating that they have reviewed, and understand, the College’s Controlled Acts and Restricted Activities Standard.

If the PT intended to provide acupuncture services outside the scope of practice of physiotherapy, they should have registered with an appropriate regulatory college where cosmetic acupuncture is an acceptable service and within the scope of practice.

The College’s Restricted Titles, Credentials and Specialty Designations Standard states, “Registrants must not use the ‘physiotherapist’ title when they are practicing outside of the scope of practice of physiotherapy.” Although the PT indicated that their cosmetic acupuncture practice was separate from their physiotherapy practice, it is still possible that members of the public could be misled by the physiotherapy designation.

The Outcome

Given the above information, which of the following outcomes do you think is most appropriate? Use the comment section below to share your thoughts.

a. The PT should receive advice/recommendations and participate in a practice enhancement program to ensure that they understand the standards of practice

b. The physiotherapist knew that they were operating outside the scope of practice and putting patients at risk – they should be suspended

c. The PT should receive a caution, which appears on the Public Register, and participate in a practice enhancement program

d. It appears that the physiotherapist genuinely didn’t realize they were doing anything wrong and they seem remorseful – the College should take no action

Controlled Acts and Restricted Activities Standard

Restricted Titles, Credentials and Specialty Designations Standard