Physiotherapy FAQ Answered by the Patient and Caregiver Help Team

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FAQs: Public Asking About the Complaints Process

How can I contact someone to make a complaint or inquire about the complaints process?
Staff from the Professional Conduct team can help you with any questions that you may have about the complaints process. Call 416-591-3828 ext. 227 or 1-800-583-5885 ext. 227 or email investigations@collegept.org.
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Can the College accept anonymous complaints?
No. A formal complaint must include the name and contact information of the person filing the complaint, the patient’s name when relevant, as well as the name of the physiotherapist involved (College staff can help you to determine the physiotherapist’s name).
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Who can file a complaint with the College?
Anyone can file a complaint with the College. This includes a patient, family member or friend of a patient, colleague, employer, insurer, or anyone else.
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Can I file my complaint online?
Yes. An online complaints form is available on the College’s website at www.collegept.org under Public and File a Complaint. File a complaint (LINK)
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Can the College accept complaints about a clinic or employer?
The College only regulates the practice of individual physiotherapists and not the place where physiotherapists practice. In some cases, if the employer or owner of the clinic or business is a physiotherapist it might be appropriate to file a complaint naming that person. Staff in the Professional Conduct team can help you with this situation.
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Should I contact the physiotherapist directly to discuss the issue before making my complaint to the College?
A person who is considering filing a complaint with the College may find it helpful to discuss his or her concerns with the physiotherapist before contacting the College. In many cases, the concerns might be resolved by the person and the physiotherapist without going through a formal complaints process.
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What information should I include in my letter of complaint?
To process your complaint, the College must receive the following information from you:

- the name of the physiotherapist
- your name and contact information (daytime phone number and mailing address) and
- as much detail as possible about your concerns or the incident in question.
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Can the College staff provide me with advice related to my complaint?
College staff can only provide information about the complaints process. Their role is to impartially gather information from both parties on behalf of the Inquiries, Complaints and Reports Committee.

The College has a person on staff called the Practice Advisor whose job it is to answer questions and direct people to helpful resources. She provides this free, anonymous service to the public, physiotherapists, insurers and others. The Practice Advisor can be reached at practiceadvice@collegept.org or 416-591-3828 ext. 241 or 1-800-583-5885 ext. 241.
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Is the complaints process confidential?
All information related to the complaints process is held in confidence by the College and by people who work at or on behalf of the College. The College does not disclose information about specific complaint matters unless we are required to do so by law or as required by the College by-laws. Additional information about our confidentiality obligations is available in Section 36 of the Regulated Health Professions Act. Where information is made available to the public on our website or on the Public Register, the names of complainants and/or witnesses will not be included.
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Will the College access my health information/patient records related to the complaint?
If the person is filing a complaint about their own treatment, the College will ask the physiotherapist for a copy of that person’s patient record to be reviewed by the Inquiries, Complaints and Reports Committee (ICRC). If however a complaint is submitted by a third party, a family member of the patient for example, the patient’s consent to get information may be requested if the patient record is required.
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Can the ICRC require the physiotherapist to apologize or provide me with a refund?
No. The Regulated Health Professions Act (RHPA) defines the ways in which the Inquiries, Complaints and Reports Committee (ICRC) can resolve a complaint. The Committee cannot require a physiotherapist to apologize and cannot require financial compensation in any form.
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How long does an individual have to file the complaint after the incident has occurred?
There is no time limit for filing a complaint. It is important to consider that the ability to recall events may fade with time. A physiotherapist is only required by law to keep patient records for 10 years after the date of a patient’s last treatment. If the patient was a minor at the time of treatment, the retention period is 10 years after the patient turns 18.
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What happens after a complaint is filed with the College?
College staff will contact the person who made the complaint to acknowledge that they received the complaint. If necessary, they will also ask for any necessary clarification about the concerns identified.

The physiotherapist will then be sent a copy of the letter of complaint and he or she will be asked to provide a response, the patient record, and if necessary, any additional information that would be helpful to the Inquiries, Complaints and Reports Committee (ICRC). This initial documentation is forwarded to a panel of the ICRC. In some cases, additional information may be needed to help the panel considering the complaint.
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How long does the process take?
The Regulated Health Professions Act (RHPA) requires that a complaint be closed within 150 calendar days. While the College does its best to meet this requirement, it is not always possible. Where delays occur after 150 days, the parties will be notified of the status of their file on a regular basis. They can also contact the College at any time to ask about the status of the complaint.
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When timelines are set, are they referring to business days or calendar days?
The timelines refer to calendar days.
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What happens if during the process someone is unable to meet a timeline?
College staff will review all requests for an extension and if appropriate will agree to a short extension. In the event of a delay, both parties will be notified.
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During the complaints process, can a complainant contact the College?
Yes. College staff are always available to answer questions about the process.
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What information will the person who made the complaint receive from the College during the process?
The person who made the complaint will receive regular updates about the status of the complaint. At the conclusion of the investigation both parties will receive a copy of the panel’s decision.
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Who are the members of the Inquiries, Complaints and Reports Committee (ICRC)?
The panel of the ICRC which reviews complaints is made up of six people: four physiotherapists and two members of the public who have been appointed by the government.
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How often does the panel reviewing complaints meet?
Generally, the panel meets every 4 to 6 weeks.
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What are the different decisions that can be made?
The panel may:
- close a case taking no further action
- make recommendations and/or issue advice
- issue a caution to the physiotherapist
- require that the physiotherapist participate in initiatives to improve their practice (SCERPS or Undertaking).
- refer the matter to a Health Inquiry Panel if it is apparent that the physiotherapist may be suffering from a health condition or disorder which is affecting his or her ability to practice safely
- refer the case to the Discipline Committee of the College if serious issues of incompetence or professional misconduct are identified and a public hearing is warranted
- refer the case to the Fitness to Practise Committee if the member is unable to practice safely due to a medical condition and is unable to comply with a treatment/monitoring program
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What kinds of cases are referred to the Discipline Committee?
A referral to the Discipline Committee for a hearing is reserved for the most serious cases of professional misconduct or incompetence. Summaries of previous cases that have gone to the Discipline Committee are available on the College’s website at www.collegept.org. (Public>Discipline and Fitness to Practice Hearings).

View a Summary of all Hearings
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What can the parties do if they are not happy with the decision?
Both parties involved have the right to request a review of the panel’s decision by the Health Professions Appeal and Review Board (HPARB) if they believe that the Committee’s investigation was inadequate or that its decision was unreasonable. HPARB is an external review board. Learn more about HPARB at www.hparb.on.ca. The review process takes about 6 to12 months to complete.
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Is any part of the complaints process, including the decision, made public?
The information that you share with the College is kept confidential. Some of the decisions made by the Committee are made available in the Public Register (referrals to the Discipline and Fitness to Practice committees). As of July 1, 2015, additional information can be released in specific circumstances as identified in Section 36 of the Regulated Health Professions Act (RHPA).
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Should a person continue to be treated by or contacted by the physiotherapist after he or she files the complaint?
The College does not have the authority to direct you one way or another about whether you continue your contact with the physiotherapist.
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When participating in the complaints process, can the person who made the complaint get advice from a lawyer or other legal representative?
Yes. People who make complaints can choose to hire a lawyer or other legal representative to help them with the process, although most do not. If a representative is hired, please provide the contact information of that person to College staff.
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What happens if I change my mind after I file a complaint?
All requests to withdraw from the complaints process are carefully considered by a panel of the Inquiries, Complaints and Reports Committee (ICRC).
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Can I use the Inquiries, Complaints and Reports Committee decision in other proceedings?
The Regulated Health Professions Act (RHPA) prevents the use of a College decision in civil proceedings.
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FAQs: Virtual Practice in Physiotherapy

What is virtual practice (also known as virtual care or tele-rehabilitation)?
Virtual practice is the provision of physiotherapy services at a distance, by an information or communication technology such as video conferencing, when an in-person visit is not possible.

A patient can expect the same safe, effective, and ethical care as an in-person visit and the physiotherapist must comply with all regulatory requirements.

Virtual practice may be appropriate if the patient cannot easily access an in-person visit due to a shortage of physiotherapy services available in the region where the patient lives or because of transportation or mobility concerns. Physiotherapists should use their professional judgment to determine if this model of care is the most appropriate available method to deliver physiotherapy care and that the patient is not exposed to any increased risk. Patients and physiotherapists alike need to recognize any limitations that virtual practice services present including privacy of personal health information, safety of the patient within the context of their home or work environment and the inability to perform a hands-on assessment and subsequent treatment.
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When is virtual practice appropriate?
Virtual practice may be appropriate if a patient cannot easily attend in-person sessions because of things like a shortage of physiotherapists in their region, transportation or mobility issues, or a health pandemic that discourages physical contact. As regulated health professionals, physiotherapists must use their judgement to decide if virtual practice is an appropriate way to deliver safe and effective care to their patient.

Also check out the Canadian Alliance of Physiotherapy Regulators Guidelines for Telerehabilitation.
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How does a physiotherapist know if virtual care is the right option?
PTs should ask themselves the following questions before making the decision to use virtual care with their patients:

• Do you have the skills and training to provide remote physiotherapy?

• Have you chosen a virtual platform that meets your legal, regulatory and privacy requirements?

• Do you have access to a space that is safe and will work well to deliver virtual care? Is it private and will you be able to safeguard your patient’s health care information during the session?

• If the patient is located in another province, are you registered to practice in that jurisdiction?

• Do you understand the how the College’s Standards apply in this setting?

• Can you confirm the patient’s identity?

• Are you prepared to manage an adverse event (a fall or medical emergency for example) should it occur while you are running a virtual session? PTs should have emergency contact information easily accessible and be prepared to call 911 and provide an address.
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Which types of treatment or modalities are acceptable to deliver virtually?
This list includes but is not limited to a range of different kinds of physiotherapy that can be provided remotely using technology:
1. Triaging or initial assessment (subjective and some objective components including outcome measures), ongoing assessments to monitor progress including use of objective assessment tools that are available in many software programs and apps.
2. Exercise prescription, supervised therapeutic exercise and appropriate progressions, gait assessment and re-education
3. Home-based modalities, including electrical stimulation and heat and cold applications, if the patient has the equipment at their home.
4. Self-administered techniques such as soft tissue massage or frictions under the direction of the physiotherapist, including patient education on how to do and at what intensity.
5. Support for self-management, education, coaching and reassurance for patients and for caregivers. This includes teaching patient’s families how to assist in performing stretches or guide home exercises.
6. Assessment of how patients are functioning and adapting in their home environments, including assessment of fall risks and other functional activities of daily living assessments.
7. Bracing, donning, removal and check in on fit and outcomes for bracing.
Physiotherapists and patients partner in the care plan and collaboratively set goals. Progress during virtual visits should be tracked based on the patient-centred goals, using patient report outcome measures. This includes functional outcome measures and other measurements under the direction of the physiotherapist. Each measure should be assessed, including a predicted timeline and milestones to achieve these goals based on the identified prognosis for each unique patient.
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What are some of the risks of virtual practice?
Patients must always be able to rely on receiving safe and effective care from a physiotherapist, regardless of how the service is delivered.

Tele-practice (also known as virtual care) has some challenges you need to plan for and in some cases attempt to mitigate.

These include things like:
- Technology failures and challenges. Plan and practice. Be sure you have used the technology before and are comfortable guiding your patient through the process if they have questions.
- Communications limitations. You might encounter audio issues or language challenges. Be patient and approach this as an opportunity to solve new problems.
- Medical emergencies. If your patient is experiencing a medical issue, be prepared to act.
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Am I required to have liability insurance if I am providing virtual care?
Yes, you are required to have liability insurance when providing virtual care (also known as tele-practice). The liability insurance requirements are the same as if you were providing in-person care.

You must meet the following liability insurance requirements:
- a minimum coverage of $5 million dollars for the annual policy period
- a liability limit of at least $5 million dollars per incident
- ·no additional terms, conditions or exclusions, other than standard
- ·no deductible
- tail insurance for a minimum of 10 years
Tail insurance means that while providing coverage for incidents occurring during your physiotherapy practice, it should also provide coverage for claims made up to 10 years after you stop practising; that is, patients may claim against your practice period after it ends.

Please check with your employer to see if their clinic or hospital has insurance coverage, and whether that coverage protects you. If it does not, it’s your responsibility to arrange your own.

Remember: If you work in multiple practice environments (at many clinics and/or hospitals), do not assume your insurance at one location covers you for the others. You may have to arrange coverage for other locations, either separately or jointly.

Liability Insurance Requirements
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How does a physiotherapist choose a technology platform for virtual practice?
When choosing a technology it is important that the physiotherapist knows:
- Who can access the information.
- How to access the information.
- If the information is being recorded and saved by the technology provider and if so, how and why?
- Where the data is stored and how they manage security risks. There are legal implications if data is stored outside of Canada.
- What to do if there is a privacy breach.
- How data will be kept safe by the technology provider from loss, theft or unauthorized access.
- If the technology provider’s retention policies allow the PT to meet professional obligations.
- PTs should be aware of cyber security risks. This includes things like lost or stolen devices, insufficient protection on your devices, firewalls, virus protection, login access controls and use of unsecured Wi-Fi connections for example. PTs should take training to become competent in this area.
- How the technology works and how to troubleshoot if something goes wrong. PTs should test the equipment and practice using it before seeing patients. They should know how to use the audio and video functions and how to share their screen or files. PTs should consider creating a “how to document” outlining the steps to successfully use the technology for themselves and their patients.
The College cannot recommend a specific technology provider, but there are many available to health professionals. Be sure to look at the PHIPA and PIPEDA requirements when making your decision.

The Ontario Telemedicine Network (OTN), Doxy, Zoom Health, Jane, Phzio, Physitrack, Physiotec, Clinicmaster, Mediseen, Dialogue and Embodia are examples of technologies that are available to physiotherapists. PTs should do their research and speak with the technology providers and peers to find a technology that addresses the issues outlined above.
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What needs to be considered when it comes to wearable technology?
Wearable technology allows a person’s physical activities and behaviours to be monitored, as well as track physiological and biochemical parameters during daily life. Wearable technology can be used in many healthcare applications, including in physiotherapy. Examples include fitness trackers (a FitBit for example), smart health watches, and wearable ECG and blood pressure monitors.

PTs should consider the following if using wearable technology in their virtual practice:
- Ensure the patient consents to the use of wearable technology as part of their physiotherapy care.
- Patient confidentiality and data security are major concerns when using wearable devices as its challenging to ensure compliance with privacy legislation. Security must be evaluated against the relevant privacy requirements.
- Wearable devices may collect very large amounts of personal data due to their capacity for continuous data recording at high frequencies coupled with potential large population use. Not only can the data be used to improve personalized intervention, but it could also be used for analysis of population patterns. Be sure you know if the data collected could be used for things other than providing care to the patient, and ensure you inform the patient appropriately.
Wearable Technology Applications in Healthcare: A Literature Review
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How does a physiotherapist get a patient's consent for virtual practice?
The consent conversation should be the same regardless of if the care is being provided in-person or virtually. The consent conversation that takes place with a patient during an assessment or treatment should include the benefits, risks, alternatives and possible outcomes should the patient not receive the treatment. The PT must get the patient’s consent to involve someone else in their care, like a PTA or student. The patient must also be informed that they have the choice to refuse care at any point during the session.

Virtual care does introduce some new elements to the consent conversation, such as:
- It might become too complicated or difficult to complete the assessment or treatment and either party can stop the session and discuss to how to move forward.
- The potential benefits, constraints, and risks of using technology. Things like privacy and security and ability to communicate during a virtual session.
- The patient should be reminded that they can ask the PT questions at any time.
- The PT should summarize the discussion at the end of the session and document this in the patient chart, including the patient’s consent.
More About Consent
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Can physiotherapist assistants (PTAs) be involved in virtual care?
Yes, it may be appropriate for physiotherapist assistants to be involved in delivering care virtually. The PTA may be in the same physical location as the patient or the physiotherapist, or may be in a virtual location. In either case, the requirements in the Working with Physiotherapist Assistants Standard apply.

The PT must get the patient’s consent to have the PTA involved in their care, ensure the physiotherapist assistant is competent to deliver the care assigned to them, and provide the appropriate level of supervision. PTs should never assign any activity to a PTA that requires any element of assessment. The invoice must include the name and job title of the physiotherapist assistant. There must be a written communication protocol that states how and when they will discuss patient care with the physiotherapist assistant, how to contact the physiotherapist, and how to contact the alternate supervisor if the physiotherapist cannot be reached.

Virtual Practice
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Can I use email to communicate with patients?
Physiotherapists use emails and phone calls in practice even when seeing patients in-person. However, emails and phone calls may be even more important when providing virtual care. These forms of communication help with triaging, the initial assessment components, treatment progression and compliance, patient education, coaching and to reassure patients and caregivers.

Whatever mode of communication is used with patients, the PT must make sure it's appropriate, private and the relevant information is captured in the patient record.

When providing clinical advice or treatment related information by email, the PT should consider whether it's appropriate for the patient to receive this information electronically. The patient's personal health information must be kept private and secure and should not be shared with others without patient consent or other legal authority.

Email considerations include: An email can be inadvertently sent to the wrong person, is often accessed on portable devices vulnerable to theft and loss, can be forwarded or changed without the knowledge or permission of the original sender, and be vulnerable to interception and hacking.

Physiotherapists should the Information and Privacy Commissioner of Ontario advice on this issue: Fact Sheet on Communicating by Email.
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How do I keep records when doing virtual care?
Physiotherapists are expected to keep records regardless of how physiotherapy care is delivered – virtually or in-person. All physiotherapists must meet the expectations outlined in the College’s Record Keeping Standard. If the PT records audio or video of the session, they must have the patient’s consent to do so and the recording should be included in the patient’s record.

Record Keeping Standard
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Why do physiotherapists need to include advice provided by email or phone in patient records?
Any information relevant to patient care should be included in the record, regardless of how it is communicated.

The specifics of telephone and email advice or information should be recorded when it relates to the patient’s condition or clinical care. Information relating to changes in symptoms, condition or treatment provided should be documented to understand the care that was provided and the impact.

For example, information from a patient who telephoned or emailed to report an exacerbation of symptoms when a new exercise was added to their home program and any advice given should be included in the record. PTs should maintain a communication log in the patient’s record. Information that does not relate to the patient’s condition or care, such as how to submit an insurance claim form or where to get recommended equipment, does not need to be documented.
Record Keeping Standard
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How much can a physiotherapist charge for a virtual care session?
The College does not set the fee schedule for physiotherapy care in Ontario. This includes in-person or virtual sessions. Some physiotherapists charge by blocks of time while others charge based upon the service provided. Physiotherapists are expected to be transparent when it comes to their fee schedule.
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Is it acceptable for a physiotherapist to bill for email or telephone communication?
As with other healthcare professions, and in other sectors billing for time spent, providing interventions by email or phone is reasonable.
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What information should be included on the invoice?
Invoices should be an accurate representation of the service provided to the patient. If the physiotherapy session was provided virtually it should say this on the invoice.

If the PT is unable to enter the fact that it was a virtual physiotherapy session in an electronic invoice because of the format, it should be added as a note in the patient record.
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Is virtual care covered by third party payors and insurers?
The College is aware that some third-party payors are covering virtual assessments and treatment by physiotherapists.

Some insurers will only provide coverage if the physiotherapist and the patient are in the same province. PTs should investigate this further on their own before providing care to patients. PTs should make their patients aware if they know the session will not be covered by the insurer.

Patients should also verify this information and their claim coverage with third party payors before seeing a physiotherapist virtually..

View a list of health benefit insurers that have currently indicated they cover virtual physiotherapy.

Note: It is not clear if this coverage will continue after COVID-19 is resolved.
- physiotherapy
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Can a physiotherapist continue to provide care for a patient who is temporarily out of the province using virtual care?
Yes. If the patient's permanent address is in Ontario and the care can be appropriately managed virtually, the physiotherapist can continue to provide care while the patient is out of the province.

You must consider that other provinces / countries may require registration in their jurisdiction to deliver any virtual healthcare to a patient living or visiting that jurisdiction. We know it can be challenging to find details of overseas regulatory requirements.

Still, it is your responsibility to make your enquiries in the relevant jurisdiction and register if required. If you do not comply with any legal or regulatory obligations in the jurisdictions that require it, you may be subject to a complaint.

You should also contact your liability insurer to confirm that your coverage allows for out-of-country virtual care.

You can learn more about the requirements in Canadian provinces here.

See a list of countries where physiotherapists are regulated here.
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If I am registered as a PT in another province, can I provide care to Ontario patients? If I am an Ontario PT can I practice PT in another province?
An Independent Practice Certificate of Registration - Cross Border Physiotherapy is available to physiotherapists who currently practice in another Canadian province and who wish to provide care to Ontario patients, whether virtually or in-person.

Anyone holding a Cross Border Certificate may only provide care to Ontario patients in the following circumstances:
- If they are continuing to provide care that began in another province and the patient would benefit from continued and time-limited service in Ontario or if the services are not available in Ontario but would benefit patients.
- Physiotherapists must meet the Standards of their home province, as well as the province where they are delivering care.
A similar Certificate of Registration is available in all other Canadian provinces. View a list of all provincial physiotherapy regulators.

Or contact the College’s Practice Advice service for additional guidance. advice@collegept.org or 1-800-583-5885 ext. 241
Learn more: Cross Border Physiotherapy
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Can I use virtual care to deliver group treatment to patients?
Virtual practice is permitted by the College for physiotherapy care if the care provided (like any other care) meets all the College standards, and it is in the best interest of the patient.

Some physiotherapy may be delivered virtually in a group setting, but that does not exempt a physiotherapist from meeting all the College Standards and rules. You can see a list of those rules here.

Therefore, a physiotherapist must do things like:

1. Discuss the privacy and confidentiality risks and the precautions taken with each patient.

2. Get the patient's consent in the same way they would for an in-person assessment or treatment. In the case of virtual practice, they must be sure the patient understands explicitly how the assessment or treatment will work using technology.

3. The PT must document the discussion they had with the patient in the patient's record.

4. The Record Keeping Standard applies in the same way whether the care is delivered face-to-face, in a group, or virtually. The patient assessment, diagnosis, goals of the treatment and a treatment plan must be charted. The PT should make it clear in the patient's record and invoice if treatment was delivered virtually and in a group.

5. The College cannot recommend physiotherapy fees. All costs must be transparent to the patient and have been agreed to before the service is provided. The invoice or patient record should indicate group treatment and that the treatment was delivered virtually.

6. The decision as to whether something is covered by insurance, whether virtual and/or group therapy classes, is the decision of each insurance carrier.

Patient and Caregiver Help Team

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FAQs: Virtual Practice in Physiotherapy