The Case

The College received a report from an employer that had implemented a COVID vaccine mandate for all employees. The report indicated that one of their employees had a statement of medical exemption from COVID vaccination that was signed by the employee’s physiotherapist.

The exemption form was implemented by the employer to provide medical evidence to exempt an employee from the requirement to be fully vaccinated against COVID-19. The form indicated in two separate areas that it must be signed by a physician or nurse.

Additionally, the employer also flagged that the physiotherapist completed a medical leave form for the employee due to psoriasis.

As part of the investigation, the College also reviewed the patient records, and it was noted that the physiotherapist was treating psoriasis with phototherapy (UVB light therapy). The PT indicated that while they routinely treat patients suffering from psoriasis using phototherapy, they never diagnosis psoriasis themselves and they consult with a physician or dermatologist as needed.

The physiotherapist said that the patient had a diagnosis of psoriasis from their physician and consented to receiving phototherapy from the physiotherapist. During one appointment, the patient mentioned that they were experiencing a flare up of psoriasis symptoms and that they recently received their first COVID vaccination.

The patient asked the PT to complete their medical leave form and then their vaccination exemption form. The physiotherapist noted that the medical leave form was to be completed by “a health professional” and the PT believed their title of physiotherapist was sufficient. The PT asked the patient about completing the vaccination exemption form as a physiotherapist (not a physician or nurse as stated) and the patient allegedly told the physiotherapist that the form could be completed by any health professional.

The physiotherapist signed the form but specified that they weren’t exempting the patient from receiving the COVID vaccine but recommending that their employer should allow a grace period for the patient’s symptoms of psoriasis to clear up before requiring them to receive the next dose.

The Standards

It can be within a physiotherapist’s scope of practice to treat psoriasis and associated symptoms, as psoriasis can impact mobility and overall wellbeing. However, diagnosing or making a referral for UVB light therapy/phototherapy should be performed by a medical professional competent in assessing skin conditions, like a physician or a dermatologist. There was no evidence in the records to support that the patient received a diagnosis of psoriasis or a referral for phototherapy treatment from a physician.

As noted on the vaccination exemption form, a physiotherapist was not considered to be one of the medical professionals qualified to complete the form and provide a vaccination exemption for medical purposes. In reviewing the form, the physiotherapist did not clearly state their credentials. The Committee was also concerned that the physiotherapist included a statement on the form that specified that the patient had a severe skin condition that could flare up with the vaccine. The PT went on to say that the next dose was not recommended for two weeks, until the flare up of symptoms had improved.

As specified in the Record Keeping Standard, clinical records must support physiotherapists’ rationale for the care that they provide. Clinical records must contain objective data, evidence and outcome measures whenever possible and appropriate. In this case, the patient record lacked evidence of a proper assessment, there were no reassessments over a period of multiple appointments, no patient goals were identified, there was no justification or referral for phototherapy, and the two forms signed by the PT on behalf of the patient were not included in the record.

The Outcome

The Committee determined that these concerns were significant enough to require the physiotherapist to complete a Specified Continuing Education or Remediation Program (SCERP) focused on scope of practice, unprofessional behaviour (signing forms that they shouldn’t), and record keeping. The physiotherapist also received a caution.

All costs associated with the SCERP will be paid by the physiotherapist and notice of the SCERP and caution will appear on the Public Register permanently.

Scope of Practice

Ethics

Record Keeping Standard