The Ontario Physiotherapy Association submitted feedback to the Ministry of Health and the College of Physiotherapists of Ontario’s consultation to their proposed amendment of the general regulation to establish an Emergency Class of registration.
Bill 106, the Pandemic and Emergency Preparedness Act, which came into effect in April 2022, made amendments to the Regulatory Health Professions Act (RHPA) Procedural Code that, requires all Health Profession Regulatory Colleges to establish an Emergency Class of Certificate of Registration. The aim is to reinforce the province’s health workforce planning and create an alternative pathway to register individuals in an expedited manner during emergency situations, such as a pandemic.
Our key feedback focused on ensuring that the Province and regulatory College have tools in place to address health workforce issues in an effective and expedited manner during the time of emergency, while also ensuring that any proposed regulatory amendments not add complexity that negatively impacts the safety of the public, creates confusion for employers and health system managers, or has unintended negative impacts on health human resources during an emergency situation.
Submission to Standing Committee for Finance and Economic Affairs Pre-Budget Consultations – February 14, 2023
The OPA pre-Budget submission highlighted four areas that would bring substantial returns through increasing capacity in Ontario’s health care system and achieving the government’s objectives.
- Remove the barriers to physiotherapists working up to full scope;
- Facilitate successful entry to independent practice for internationally educated PTs by reinstating funding for the Ontario Internationally Educated Physical Therapy Bridging Program;
- Address program issues for community rehabilitation, including Community Physiotherapy Clinics and bundled care programs and resource appropriately to meet rehabilitation needs and help address surgical backlogs; and,
- Reduce red tape that is a barrier to care and imposes undue burden on health care businesses by removing requirement to exhaust extended health care benefits before accessing auto insurance benefits.
OPA Letter to the Minister of Health – Scope of Practice – August 8, 2022
There are many challenges facing the health system and OPA strongly believes that allowing physiotherapists to work up to their full legislated scope of practice would be one solution to improve the efficiency and effectiveness of healthcare in the province. More and more, we are hearing that same message from system leaders and decision-makers, including a recent article in the Toronto Star that cited optimizing the scope of practice of professions, such as pharmacists and physiotherapists to respond to these challenges.
OPA has written to the Minister of Health, The Honourable Sylvia Jones, M.P.P., to congratulate her on her appointment and to seek completion of the remaining regulations needed to fully implement the scope of practice of physiotherapists (i.e., ordering diagnostic imaging and laboratory tests within practice).
Submission to Consultation on Healing Arts Radiation Protection Act (HARPA)
On April 15, 2021, the Government of Ontario announced new red tape and burden reduction measures intended to minimize existing barriers on businesses and support a long-term recovery plan. This included a commitment to consult on opportunities to enhance the Healing Arts Radiation Protection Act (HARPA) to better enable innovation and the use of new and emerging technology.
OPA was invited to participate as a stakeholder and submit a written response to the consultation. OPA used this opportunity to highlight our previous engagement and feedback on consultations related to HARPA and the fact that until a regulation that will permit physiotherapist to order x-rays is finalized, our scope of practice changes from Bill 179 remain outstanding.
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Advocating for Implementation of Physiotherapy Scope Changes
The Standing Committee on Finance and Economic Affairs Pre-Budget Consultations invited written submissions with a focus on input on improving critical public services such as healthcare and education, improving quality of life for Ontarians, creating jobs and attracting business to the province. OPA submitted and highlighted how implementing the outstanding scope of practice for physiotherapists in Ontario would lead to healthcare and system improvements on behalf of patients while bringing no additional costs to the system.
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Joint Submission on Implementing Outstanding Scope of Practice Changes for Physiotherapy
On September 20, 2017, Minister Hoskins announced that the Ministry of Health and Long-Term Care would be moving forward with expanding the scope of practice for regulated health professionals, including physiotherapists. In December 2017, the Ontario Physiotherapy Association and the College of Physiotherapists of Ontario jointly submitted a response to the Ministry’s request for information to facilitate the creation of regulations that would permit physiotherapists to order specific x-rays, diagnostic ultrasound and lab tests within their scope of practice.
The Healing Arts and Radiation Protection (HARP) Act Review
Health Quality Ontario (HQO) formed an Expert Panel to Enhance the Safety and Quality of Energy-Applying Medical Devices in Ontario (“the EAMD Panel”). The mandate of this group was to provide recommendations and advice to HQO on the modernization of the HARP Act. Changes to the HARP Act are needed to allow PTs to order x-rays. OPA was identified as a stakeholder in this process and was invited to provide feedback to the Panel.
Physiotherapy Scope of Practice Changes Proclaimed April 1, 2011
In 2011, the OPA and its advocacy partners celebrated the proclamation of changes to the Physiotherapy Act that expanded the scope of practice of physiotherapists and allowed them to deliver more services, and authorized acts within that scope. Read the Physiotherapy Scope of Practice Announcement.
Most of these changes came into effect September 1, 2011; however, those relating to ordering diagnostics are still outstanding. The OPA continues to advocate for the implementation of the full scope of practice for physiotherapists. To learn more or to get involved please contact the OPA.
View the Physiotherapy Scope of Practice Review submission to the Health Professions Regulatory Advisory Council
OPA Submission on College Governance Changes and Modernization Consultation – March 9, 2022
OPA submitted feedback on the Ministry of Health’s consultation on their proposed changes to College governance and regulatory modernization. The proposed changes would impact all regulatory Colleges of health professions in Ontario, including the College of Physiotherapists of Ontario.
Although modernization is required to strengthen our current model, OPA is concerned that the proposed governance changes do not enable Colleges to meet the requirements, needs, and circumstances for the individual profession(s) and to fulfil their mandate of public protection. Some of our feedback focused on:
- Ensuring and enhancing diversity of representation on Councils, along with adequate turn over of members to enhance diversity of thought and progress over time regarding decision making
- Ensuring a competency-based process to identify a slate of candidates and making elections province-wide
- Supporting time limits for registration decisions.
OPA Submission on Home and Community Care Transformation Consultation – February 23, 2022
OPA met with the Ministry of Health and submitted feedback for their consultation on home and community care transformation, which focused specifically on provider partnerships and improving accountability in delivery in the home and community care sector. Some of OPA’s feedback focused on:
- Greater equity and fairness across many aspects, including compensation between rehabilitation professionals, workplace conditions and safety, funding, along with care coordination and determination of care plans to enhance equitable access to care;
- Ensuring sufficient funding to achieve desired patient outcomes;
- Ensuring processes, contracts, and accountability structures do not add undue complexity or administrative burden;
- Outlining the cost-effectiveness of rehabilitation and advocating for greater investment in rehabilitation;
OPA Submission on the Provision of Health Support Services in Schools Consultation – February 23, 2022
Service in school settings are managed through a tripartite agreement between the Ministry of Education, Ministry of Health, and Ministry of Children, Community and Social Services. OPA submitted feedback on their consultation on the redrafting of Policy/Program Memorandum No. 81, which intends to provide expectations on the delivery of evidence-based health services, rehabilitation services, and other community-based clinical services in schools and to clarify the roles and responsibilities of school boards and community partners as they relate to the provision of these services in school settings in Ontario.
OPA’s feedback focused on ensuring that the document enabled the required collaboration between organizations to optimize local innovations that reflect best practices.
Ontario government Standing Committee on Finance and Economic Affairs’ pre-budget consultation – January 26, 2022
OPA submitted to the Ontario government Standing Committee on Finance and Economic Affairs’ pre-budget consultation.
OPA recommended that the Government:
- Invest in a comprehensive health human resource strategy, including addressing entry-to-practice issues, to address the growing crisis of increasing shortages;
- Implement the scope of practice changes legislatively enabled for physiotherapy and enable physiotherapists to provide a more seamless and cost-effective continuum of care;
- Allow health care clinics and practices to be eligible for pandemic-related, government financial and other supports that apply to small businesses; and
- Increase the amount of Episode of Care Allocation that CPCs can retain in response to pandemic-related reductions in utilization and, for the remaining amount, roll forward non-utilized funds into the following fiscal years to be absorbed through future utilization.
OPA’s Submission to CPO’s Consultation on Registration Regulation
OPA submitted feedback and recommendations to the College of Physiotherapists of Ontario’s (CPO) consultation on their proposed registration regulatory amendments. The submission focused on areas of the regulation and proposed changes that would, or potentially could, create barriers to fair, timely, and safe entry-to-practice for applicants that are not necessary for public protection. Main points included:
- The definition of examination for the purpose of entry-to-practice and the need to ensure that ‘practical component’ is not embedded in the regulation
- How exceptional circumstances are determined
- The roles of Council and the Registration Committee
- The criteria for exemptions
In addition to regulatory changes, OPA advocates for and devotes our resources to achieving pathways to registration for affected candidates. We continue to work with stakeholders involved in this issue to move solutions forward.
Home and Community Care Modernization – Proposed Regulations Engagement – July 13, 2021 Update
OPA was invited to participate in the consultation on the updated summary of proposed home and community care regulations that will be included in the Connecting Care Act, 2019. We were pleased that some of our feedback from previous consultations was incorporated and took this opportunity to address other areas of concerns, including the need for the Ministry to address health human resource issues and funding for home and community care services as part of their key areas for modernizing this sector.
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OPA Responds to Proposed New Regulation Under the Connecting Care Act – July 2020
In July 2020, OPA was given the opportunity to provide feedback on the proposed home and community care regulations related to the Connecting People to Home and Community Care Act, 2020.
Bill 175-Connecting People to Home and Community Care Act, 2020 received Royal Assent on July 8, 2020 and, once proclaimed, it intends to modernize the home and community sector by allowing Ontario Health Teams and health care providers to deliver better integrated home and community care.
The Ministry only provided a summary of the regulations and OPA’s response focused issues of funding, human resources and growing administrative layers that have impacted access to quality care for Ontarians.
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Levels of Care Framework – July, 2016
The MOHLTC’s Levels of Care Framework discussion paper was released in July, 2016 as part of the Patients First Roadmap. The discussion paper outlines a proposal for a province-wide framework that will guide decisions around service levels and access for home and community care. The aim is to improve consistency in access to high-quality care across Ontario. OPA submitted a written response to the discussion paper that highlighted the need for a greater focus on the rehabilitative potential of people receiving care, and the value of early rehab intervention.
Read OPA’s response
Auditor General’s special report on CCACs, 2015
Recently, the Auditor General of Ontario released the special report Community Care Access Centres- Financial Operations and Service Delivery.
Login to read OPA’s comment on the report Auditor General Report on Home Care to learn more about current discussions in home care.
OPA encourages members in all sectors to join the conversation.
On March 6, 2018, Ontario passed new legislation, Rowan’s Law (Concussion Safety), and made amendments to the Education Act. The intent of this new legislation is to address concussion safety protocols for amateur athletes. As indicated on Ontario’s Regulatory Registry, Rowan’s Law establishes mandatory requirements for:
- Annual review of concussion awareness resources that athletes, coaches, educators and parents would be required to review before registering in a sport;
- Removal-from-sport and return-to-sport protocols, to ensure that an athlete is immediately removed from sport if they are suspected of having sustained a concussion; and
- A concussion code of conduct that would set out rules of behaviour to minimize concussions while playing sport.
Public consultation on the legislation was conducted to inform implementation including the drafting of regulations. OPA, in consultation with Sports Physiotherapy Canada and the Canadian Physiotherapy Association, submitted a response on behalf of the profession.
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Following the consultation on the implementation of the legislation, on April 18, OPA submitted a response on behalf of the profession on the draft regulations focusing our response on the Concussion Awareness Resources, Concussion Code of Conduct and Removal/Return-to-sport Protocols.
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Health Quality Ontario (HQO), now Ontario Health (Quality) engages in public consultation on their draft Quality Standards and Health Technology Assessments (HTA). Quality Standards and HTAs have an impact on the health system and the physiotherapy profession. OPA monitors these consultation opportunities and brings relevant standards to the attention of the profession so that PTs can provide feedback to inform Ontario Health (Quality)’s work in this area. The following are submissions from OPA with our feedback sent on behalf of the profession and our membership:
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- Heart Failure Quality Standard
- Compression Stockings for the Prevention of Venous Leg Ulcer Recurrence
- Structured Education and Neuromuscular Exercise Programs for Hip and/or Knee Osteoarthritis
- Low Back Pain Quality Standard: Care for Adults with Acute Low Back Pain
- Health Technology Assessment: Continual Long-Term Physiotherapy After Stroke
- OPA Response to HQO Consultation on Diabetes Standards
- OPA Response to Patient Transition Quality Standard
- Quality Standard and Patient Guide for Concussion
In April 2019, as part of the Ontario Budget, the Government released their Blueprint for Putting Driver’s first, a plan to reform the auto insurance industry in Ontario. This plan focuses on addressing high costs for insurance and barriers to participating in/accessing programs and services for those injured in a car accident. As Co-Chairs of the Coalition, OPA has been at numerous tables participating in an advisory capacity. The Coalition has also been responding to consultation opportunities. Recent submissions are below:
Response to The Marshall Report – Fair Benefits, Fairly Delivered: A Review of the Auto Insurance System in Ontario
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Response to FSCO’s report on Minor Injury Protocols, August 2015
Read OPA’s response to FSCO’s Final report titled ‘Enabling Recovery from Common Traffic Injuries: A Focus on the Injured Person, Ontario Protocol for Traffic Injury Management Collaboration’ and our response to the Common Traffic Impairment Guideline.
As co-chair of the Coalition of Health Professional Associations in Automobile Insurance Services (The Coalition), OPA participated in both the Coalition Response to MIG Final Report and the Coalition CTI Guideline Response. The draft CTI guideline is the first step in the development of policy based on the Final Report. OPA will remain involved in any further consultation opportunities with FSCO and the Ministry of Finance regarding this guideline and implementation plan.
FSCO Annual Statement of Priorities, 2015
FSCO is required by law to release an annual Statement of Priorities (“Statement”) outlining its proposed activities for the coming year. These priorities are made available for comment prior to being finalized.
Proposed Changes to the SABS, 2015
The 2015 Ontario Government Budget announcement included areas specific to auto insurance that would require a number of amendments to the Ontario Regulation 34/10 (Statutory Accident Benefits Schedule) of the Insurance Act.
In December 2015, the Minister of Health and Long-Term Care released a proposal to address structural issues that will improve inequities and access to care. Stakeholders were invited to provide a written response as part of the consultation phase to this proposal.
OPA submitted a response on behalf of its members at the end of February. This response touched on key issues for the profession including:
- The importance of sound transition planning
- The need to optimize the role and scopes of practice for physiotherapists, especially in primary care
- The need to remove barriers to integration and funding for services across the system and
- The need for a set provincial standards and definitions of care and establish an evaluation system.
Read OPA’s full response
OPA Response to CPO’s Consultation on Revised Standards
OPA has submitted a response to the CPO consultation on the revised Standard for Advertising. We thank members who took time to share their thoughts about the revised Standard.
Read OPA’s Response
Performing Controlled Acts and Other Restricted Activities and Physiotherapists Working with Assistants
OPA has submitted a response to the CPO’s consultation on revised professional standards for Performing Controlled Acts and Other Restricted Activities and Physiotherapists Working with Assistants. We thank members who took time to share their thoughts with us about the revisions. Many noted concerns regarding the delegation of controlled acts by physiotherapists. The ability to delegate controlled acts has been in place for some time for physiotherapists but the revision of the standard made this more clear. As with physicians and most other regulated professions, we believe that physiotherapists have the knowledge and judgement to be able to decide whether delegation of a controlled act is appropriate. We do understand members’ concerns and for this reason have recommended that the standard include reference to the regulation that states that it is professional misconduct to delegate to someone who isn’t appropriate in competence or judgement so that all understand the elevated risk of delegation.
Read OPA’s Response
OPA closely monitors reductions and/or closures of physiotherapy services in the public sector. Reductions and closures affect physiotherapists and patients, the profession as a whole, as well as the entire health care system. When reductions to physiotherapy services are announced the OPA takes a series of steps to advocate on behalf of physiotherapists and their patients.
Login to read the important steps and view the current list current list of Reductions in Physiotherapy in Hospitals by LHIN (2008-Present)
Learn about these important steps: OPA Outpatient closure procedures
In response to the feedback survey and consultation conducted on the New Government-wide Seniors Strategy consultation, OPA submitted feedback on the 2019 Seniors Strategy report. We highlighted the importance of developing a strategy that enables seniors to live safely and healthy so they can stay in their community and live as independently as possible for as long as possible.
In conjunction with the Ontario Society of Occupational Therapists (OSOT), the OPA responded to an invitation by Dr. Samir Sinha to provide a submission on the importance of the inclusion of physiotherapy and occupational therapy services within the Ontario Government’s Seniors Care Strategy. The Seniors Care Strategy is part of Patient’s First: Action Plan for Health Care and aims to help seniors live healthier and longer within their homes.
Read the Seniors Care Submission
Ontarians need more physiotherapists now and it is time for a Plan B for entry to practice process in Ontario!
1. Close to 1000 qualified physiotherapy candidates are waiting to practice their chosen profession
- It has been impossible for new graduates and internationally educated to register with the College of Physiotherapists so they can enter independent practice in Ontario since November 2019 when the last clinical component of the national examination* was held.
- June 2020 and the November 2020 exams were cancelled as pandemic restrictions prevented in-person exams.
- The March 2021 virtual exam was cancelled due to technical issues and others scheduled for June and November also cancelled.
- At the earliest, virtual exams by CAPR are expected to start by the end of August or early fall but it will take time to address the backlog which, in Ontario, will be well over 1300 by fall of 2021.
*The exam used for registration purposes by physiotherapy regulators in Canada, including the College of Physiotherapists of Ontario, is offered by the Canadian Alliance of Physiotherapy Regulators (CAPR). The exam has two components, written and clinical and passing both components is the current requirement for registering for independent physiotherapy practice in Ontario.
2. Physiotherapists are needed now to address the current health care crisis and future needs of Ontarians.
- We are experiencing an unprecedented shortage of physiotherapists in Ontario just at a time that demand is expected to grow tremendously due to the backlog of surgeries and other procedures and the impact of long COVID-19 restrictions.
- In a survey OPA recently conducted, 87 respondent organizations reported 133 vacancies for physiotherapists – in private clinics, hospitals, home care and in urban and rural and northern – no area of the province has not felt the impact of the lack of available physiotherapists.
- 43% of respondents indicated that delays in the clinical exam have impacted their health human resources.
3. Time is now for the College of Physiotherapists of Ontario to put forward an interim ‘Plan B’.
- The importance of a national approach to entry level competencies and registration for practice is not in question but relying on one option with no alternative or plan B should the exam not be available has limited entry to practice for qualified candidates when they have been most needed by r Ontarians.
- The College has a legislated duty, as a matter of public interest, to ensure that the people of Ontario have access to adequate numbers of qualified, skilled and competent regulated health professionals (RHPA Schedule 2 Health Professions Procedural Code). They also have the authority to set or approve the registration examination (Regulation 532/98) and are not obligated to rely solely on the Alliance exam.
- There are viable solutions that mitigate risk, address public safety and can be implemented while the CAPR clinical examination is not available now or any time in the future.
- Physiotherapy Alberta – the regulatory college has engaged the Faculty of Rehabilitation Medicine Continuing Professional Education Unit University of Alberta to administer an in- person, hands-on, 12 station exam based on the CAPR exam blueprint. The exam will be available to those who have been under provisional licence since March 2020 and will offered June 11 and 12.
- College of Physical Therapy of BC has expedited bylaw changes supported by the Ministry of Health to be able to substitute a clinical evaluation administered by UBC that assesses entry level competence when the clinical component of the CAPR exam is not available – they will run their exam on June 24.
- The CPO has just completed a multi-year review and update of their quality assurance program which includes an online screening review and onsite assessments. Both of which can be expedited for any individual or group to mitigate any risks in advancing to independent practice those who have passed the qualifying written examination and have only the clinical component left to meet the current registration requirements.
- Waiting any longer is not an option for needed health human resources for the physiotherapy and, more importantly, the health of Ontarians.
On February 2, 2015, the Honourable Dr. Hoskins, Minister of Health and Long-Term Care released Patient’s First: Action Plan for Health Care. OPA supports this next phase of the Plan, specifically as it relates to the access to physiotherapy in primary care and increased services for seniors. The Plan also speaks to the importance of the expanding scope of practice and removing barriers to health care professionals practicing to their full scope.
Ontario’s Premier, Kathleen Wynne released 30 letters, one to each member of the cabinet and their ministry, outlining each ministry’s mandate as well as the government’s collective priorities and objectives.
OPA has selected several points from the Premier’s letter to Dr. Eric Hoskins, Minister of Health and Long-Term Care, as areas of particular interest to our members.
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