In Alberta, the performance of restricted activities is regulated by the Government Organizations Act (GOA).1 Schedule 7.1 of the act outlines which activities are restricted under Alberta law. If an activity is not listed as restricted, it is considered to be in the public domain, meaning that anyone (regulated health provider or not) can perform the task. When an activity is restricted, the legislation states that no person may perform a restricted activity or a portion of it on or for another person unless they are a regulated member, under the Health Professions Act, and authorized to perform the activity by the regulations under the Act.1
The Physical Therapists Profession Regulation (PTPR), which all physiotherapists must follow, specifically states that only regulated members (including physiotherapist interns) may perform basic restricted activities and that only regulated members on the General Register or Courtesy Register may perform advanced restricted activities.2
Treating urological gynecological and rectal conditions
Wound debridement and care2
Although no additional authorization process is required, this does not mean that all physiotherapists are competent to perform these activities. It is up to each physiotherapist to develop their competence prior to engaging in their independent practice. When deciding if you have the competence to perform a basic activity, ask yourself this question: “If I was called before a hearing tribunal because of a complaint and asked to explain how I determined that I was able to perform the task, what would I say? Would a group of my peers agree that I had the competence to perform the task?”
If the answer to that latter question is either “maybe” or “I’m not sure,” this should cue you to do more work to develop your knowledge and skills.
Supervision required for basic activities
In the case of basic restricted activities, if the member performing the activity is on the Provisional Register (in other words a physiotherapist intern who has not yet passed the clinical component of the PCE), they must practice these activities with the patient’s consent and under the direct supervision of their supervising physiotherapist. The supervisor must be able to observe and promptly intervene if action is required.2,3 Members on the General Register, who have developed their competence to perform basic restricted activities do not require supervision to perform these activities.2
Advanced restricted activities for physiotherapists include:
Ordering diagnostic imaging
Performing spinal manipulation
Using needles in practice for the purpose of needle acupuncture, intramuscular stimulation or biofeedback2
Frequently asked questions about advanced restricted activities
What are the waiting periods before I can become authorized to perform advanced activities?
As previously mentioned, only members on the General Register may perform advanced restricted activities.2 Sections 14 and 16 of the PTPR discuss the requirement that only regulated members on the General Register may perform these activities and discuss the requirements that members who are learning to perform a restricted activity obtain patient informed consent and be supervised.2
There is no allowance in the legislation for the learning of advanced authorized activities by physiotherapist interns. There is also no distinction made in the legislation between practicing the skills in the context of a classroom and practicing the skills in the context of a patient care environment. Members wishing to learn advanced restricted activities must be admitted to the General Register before they can enroll in education programs to learn these techniques.2
In addition, to be authorized to order diagnostic imaging, physiotherapists must have five years of clinical physiotherapy experience (completed in Canada).4
What can a physiotherapist intern do if they want to take an advanced restricted activity education program?
Physiotherapy Alberta doesn’t control who can and cannot register for an education program. However, the legislation prohibits a physiotherapist intern from performing advanced restricted activities on another human being, whether in a course environment or in a clinical environment.
Although you can register for the course you cannot take part in any of the practical components of the course, limiting the value of participating in the program. We recommend waiting until you can fully participate before registering for these programs.
As a physiotherapist intern, don’t these rules make me unmarketable?
Often, newly graduated physiotherapists feel pressure to obtain special designations and authorizations. This has been true for decades and shows no sign of changing. However, the reality is that an employer hiring a new graduate knows that they are getting someone with limited clinical experience. No special designation will change this, only time and practice will. In the early phase of your career, instead of trying to complete these courses as soon as you can, focus on building your clinical experience and patient interaction skills, as these are ultimately more important and valuable in the long run.
What are the supervision requirements for advanced restricted activities?
When members on the General Register are learning advanced restricted activities they must be under supervision of another physiotherapist who is a member on the General Register. Supervision must be direct, meaning that the supervisor must be able to observe and promptly intervene if action is required.2
The supervisor must also be authorized to perform the advanced activity themselves and be knowledgeable and competent in the technique performed.3 In the case of dry needling where there are several schools or approaches that a physiotherapist may learn the supervisor must be authorized, and be competent to perform the technique or "style" that their supervisee is learning (if the supervisee is learning acupuncture the supervisor must be competent to perform acupuncture). They must be able to recognize when the supervisee is performing the technique incorrectly or unsafely and intervene to ensure patient safety and positive outcomes.
So what if I take one course and then go on to take another? Do I apply twice?
This is a question that commonly comes up when members learn one approach to dry needling and then decide to further their skills by enrolling in a second needling program. Once you are authorized to use needles in practice, you are authorized. You do not need to apply a second time. Physiotherapy Alberta provides members with authorization to use needles in practice, not to perform any specific technique.
Does that mean that if I have authorization from taking one course I can practice the other technique without supervision before I’ve completed the test for that course?
No. The PTPR, Section 15 requires that physiotherapists who are authorized to perform a restricted activity limit their practice to those activities that they are competent to perform and those that are appropriate to the member’s practice.2 Members are also required to perform restricted activities in accordance with the Standards of Practice2 which state that physiotherapists: “Only perform restricted activities that they have the competencies (knowledge, skills and abilities) to perform.”5
When members apply for authorization to use needles in practice they provide information about the education they received (theoretical, practical and safety), the method of evaluation of that knowledge, and declare that they successfully completed that evaluation.4
Physiotherapy Alberta’s expectation is that when members are furthering their skills related to an authorized activity by engaging in further education, the member will demonstrate their competence by meeting the same education and evaluation requirements before practicing their newly acquired skills independently; and that until they have done so, they will practice these skills under the supervision of an authorized member who is knowledgeable in these skills and techniques.
What’s there to stop me?
First off, the Code of Ethics requires that you uphold the Standards of Practice and respect “all laws… that are involved in and impact physiotherapy care.”6 If that isn’t enough to deter you, go back to my earlier scenario and once again, ask yourself: “If I was called before a hearing tribunal because of a complaint and asked to explain my actions, what would I say?”
In the case of advanced restricted activities there is a clear method of measuring if someone is competent to perform an activity, would a group of your peers determine that you had acted reasonably and safely if you were performing a technique without completing and passing the evaluation?
Are there specific Continuing Competence requirements for those on advanced activity rosters?
At present there is no specific requirement for ongoing course work or other Continuing Competence activity, however such a requirement is under consideration by the Continuing Competence Committee. Regardless of the outcome of that discussion, it is a good idea for those who are authorized to perform advanced activities to spend some time each year working to maintain their skills and competence in these areas.
Province of Alberta. Government Organizations Act. Edmonton: Alberta Queen’s Printer; 2014. Available at: http://www.qp.alberta.ca/documents/Acts/g10.pdf. Accessed on December 8, 2015.
Province of Alberta. Physical therapists Profession Regulation. Edmonton: Alberta Queen’s Printer; 2011. Available at: http://www.qp.alberta.ca/documents/Regs/2011_064.pdf. Accessed on December 8, 2015.
Physiotherapy Alberta – College + Association. Restricted Activities: Supervison of a restricted activity. Available at: https://www.physiotherapyalberta.ca/physiotherapists/what_you_need_to_know_to_practice_in_alberta/restricted_activities/#supervision_of_a_restricted_activity Accessed on December 8, 2015.
Physiotherapy Alberta – College + Association. Restricted Activities: Requirements for authorization. Available at: https://www.physiotherapyalberta.ca/physiotherapists/what_you_need_to_know_to_practice_in_alberta/restricted_activities/#requirements_for_authorization. Accessed on December 8, 2015.
Physiotherapy Alberta – College + Association. Standards of Practice: Performance of Restricted Activities. 2012. Available at https://www.physiotherapyalberta.ca/physiotherapists/what_you_need_to_know_to_practice_in_alberta/standards_of_practice/performance_of_restricted_activities. Accessed on December 21, 2015.
Physiotherapy Alberta – College + Association. Code of Ethics. Available at: https://www.physiotherapyalberta.ca/physiotherapists/what_you_need_to_know_to_practice_in_alberta/code_of_ethics. Accessed on December 8, 2015.