Guidelines for Providing Virtual Care

This is an overview of the expectations when providing virtual care (also called virtual practice or tele-rehabilitation), based on existing College standards and rules. See the Standards page for a full list of standards that apply to virtual care.

In this guidance, statements that use “must” speak to the requirements of a College standard or another regulatory expectation. Statements that use “best practice” indicate that physiotherapists can use reasonable discretion when applying the expectation to their practice.

What is Virtual Care?

Virtual care means delivering physiotherapy remotely using technology. It can include any aspect of patient care such as patient interviews, assessments, diagnosis, treatment, maintenance, consultation, education, and training. Tools may include videoconferencing, telephone, email, apps, web platforms, and wearable tech. Physiotherapist assistants may or may not be involved.

Virtual care is simply a different way of providing physiotherapy and does not change the physiotherapist’s legal or professional responsibilities. Physiotherapists must follow scope of practice, the standards and Code of Ethical Conduct, and all laws when delivering virtual care.

Registration Requirements

Physiotherapists must be registered to practice in Ontario to provide virtual care to patients physically located in Ontario.

Physiotherapists who want to assess or treat patients outside of Ontario may need to be registered in the jurisdiction where the patient is located. To provide virtual care to patients in another jurisdiction, check with the local physiotherapy regulator to find out what to do.

Please see the Canadian Alliance of Physiotherapy Regulators’ list of physiotherapy regulators.

Competence

Physiotherapists who provide virtual care must ensure they have the knowledge, skills, and judgement to do so safely and effectively.

Standards and Expectations

Physiotherapists must follow all College standards when delivering virtual care. Below, are some key areas for virtual care.

The Code of Ethical Conduct and all relevant provincial and federal laws also apply.

• Physiotherapists must use their professional judgement to determine:
  • If virtual care is appropriate for the patient’s needs.
  • If an in-person physical exam is needed.
  • If they can provide care that is comparable to in-person treatment.
    • If similar care cannot be delivered virtually, physiotherapists may, as a best practice, arrange or recommend in-person services and document the reason for this decision.
  • If patient factors (like physical, sensory, or cognitive challenges) affect the safety or effectiveness of virtual care.
  • If the patient’s environment is appropriate for safe, effective virtual care.
  • If there is an appropriate plan in place to manage any emergencies or safety concerns.
• Virtual care must not place the patient at greater risk than in-person care.
  

• The patient record must clearly state that the physiotherapy session was provided virtually.
  • As a best practice, physiotherapists may also document the platform used, patient location, any third parties present in the session, and details about adverse event management.
• Physiotherapists must follow all privacy laws that apply to virtual care, including the Personal Health Information Protection Act.
  • Physiotherapists are responsible for protecting patients’ personal health information during virtual care, including when selecting and using a technology platform.
  • Communication by email before, during, and after virtual care must also comply with privacy law requirements.
  • Please see the College’s resource on Privacy for more information.
• Physiotherapists must manage technology risks, including security, data storage, and technical issues.
• Physiotherapists must get the patient’s consent for virtual care services before providing virtual care, according to the Health Care Consent Act.
  • The consent conversation must include the nature of the treatment, expected benefits, material risks and side effects, any potential alternatives, and any consequences of not doing the treatment.
  • For virtual care, the consent conversation may also include how privacy and confidentiality will be maintained, any recording policies, limitations of the assessment because of no hands‑on interaction, available alternatives such as in‑person care, and the steps that will be taken if the technology fails.
  • Record a summary of the consent discussion in the patient chart, including enough detail about risks and benefits to show the patient’s decisions were informed.
• Physiotherapists must ensure clear communication during virtual care.
• Physiotherapists must have a plan in case a patient experiences an emergency during a virtual session, and document protocols for action.
  • As a best practice, the adverse event plan may include the following elements:
    • A process for verifying the patient’s location at the start of every session, a callback number for the patient in the event of a platform disruption, and emergency contact information.
    • An emergency response protocol, including clear steps for how the physiotherapist will respond if the patient becomes unwell, injured, or unresponsive.
    • A process for ensuring the physiotherapist understands how to contact emergency services in the patient’s location.
  • The plan must be included in the patient’s record, and if an event occurs, any actions taken must be recorded.
    

Liability Insurance

Liability insurance requirements apply in virtual care. Physiotherapists must ensure their policy covers them when treating patients virtually. There may be additional requirements from other jurisdictions when treating patients outside of Ontario.

Fees and Billing

• According to the Funding, Fees and Billing Standard:
  • Invoices for virtual care must clearly state that the service was provided virtually, and who provided the service.
  • Physiotherapists must clearly explain fees and payment options before providing virtual care.
• As a best practice, physiotherapists may recommend their patients confirm their insurance covers virtual sessions before moving forward.

Learn More

Here are some additional resources that physiotherapists may find useful when considering virtual care: