The Case

The College received a report from an insurer about the practice of a physiotherapist. The PT is also registered to practice as a massage therapist. The insurer flagged the claims as it appeared that the PT would provide a single treatment and then bill it using both their physiotherapy and massage therapy number.

The College appointed an investigator to examine the PT’s conduct and practice. The investigator obtained 10 patient charts from the clinic, including some charts that were flagged by the insurer.

A review of the charts indicated that a number of patients received physiotherapy and massage treatments on the same day.

Additionally, the investigation identified concerns with the following areas of the PT’s practice:

• Excessive or unnecessary treatment
• Assessment, diagnosis and treatment
• Informed consent
• Patient abandonment
• Record keeping

Many of the patient charts lacked evidence of reassessment, treatment plans were not updated according to patient needs and progress, and treatment extended well past what was outlined in the treatment plan. Further, the charts often lacked objective data related to patient goals and outcomes, discharge reports or summaries, or any record of informed consent.

Patients were billed for identical physiotherapy and massage treatments frequently – up to 20 times in some cases. Often, the PT would sign the treatment notes with the wrong designation.

The PT indicated that their approach to treatment was “unique” as it involved using both physiotherapy and massage therapy to treat patients. They would assess the patient and recommend one or more modalities. The physiotherapist said this approach is no different than a patient receiving physiotherapy and massage therapy from two different practitioners.

The PT acknowledged gaps in their record keeping and indicated that many of the issues were because of inherent faults in the software they were using.

The Standards

As per the College’s Record Keeping Standard, clinical records must contain information to support the physiotherapist’s rationale for the care they provided. They must also contain objective data, evidence, and outcome measures whenever possible and appropriate. Informed consent to treatment should also be documented in the patient chart.

The Fees, Billing and Accounts Standard states that PTs must ensure that any fee, billing or account that uses their name and registration number is an accurate reflection of the services and/or products provided. Physiotherapists must never charge fees or create billings or accounts that are inaccurate, false or misleading.

Lastly, physiotherapists must employ a patient-centred approach that respects the uniqueness, diversity and autonomy of each patient. In this case, the PT’s more generic approach to assessment and numerous similarities in the clinical notes raised questions about the individualization of assessments and treatment plans.

The Outcome

The College was very concerned with the lack of detailed, patient-specific physiotherapy treatment plans, the insufficiency of the PT’s record keeping, and the errors and inaccuracies in the clinical and financial records.

The physiotherapist noted that many of the errors were because of limitations with the software they were using, however it is the responsibility of the PT to ensure that any clinic management tools do not hinder their practice. Further, the physiotherapist should have routinely been auditing their fees, billing and accounts to identify and correct any inaccuracies.

The PT was required to participate in a Specified Continuing Education and Remediation Program and will receive a caution that will appear on the Public Register. All costs associated with the SCERP will be paid by the physiotherapist.

Fees, Billing and Accounts Standard

Record Keeping Standard

Consent Resource