Notice: Physiotherapists are legislatively authorized to perform invasive procedures on body tissue or below the dermis, including injections, provided that the injection is for the specific purpose of wound debridement and care.
Physiotherapists are not permitted to perform injections for any other purpose.
The College of Physiotherapists of Alberta is advising registered physiotherapists who provide wound debridement and care of a change in interpretation related to the performance of injections for the purpose of wound debridement and care.
Legislation
The Health Professions Act, Part 0.1, Section 1.3(1) identifies several activities that, when “carried out in relation to or as part of providing a health service, are restricted activities.” This includes the activity:
(a) to cut a body tissue, to administer anything by an invasive procedure on body tissue or to perform surgical or other invasive procedures on body tissue
(i) below the dermis or the mucous membrane or in or below the surface of the cornea,
Sections 52 and 53 of the Health Professions Restricted Activity Regulation identifies the restricted activities authorized to the physiotherapy profession in Alberta and the related requirements for authorization and performance of the activities.
Section 52 of the Health Professions Restricted Activity Regulation states:
52 For the purposes of section 1.3 and Schedule 20 to the Act, a regulated member on the general register, provisional register or courtesy register, in the practice of physiotherapy, may perform in accordance with standards of practice the following restricted activities:
(a) to cut a body tissue, to administer anything by an invasive procedure on body tissue or to perform other invasive procedures on body tissue below the dermis or the mucous membrane for the purpose of wound debridement and care;
The College has conducted an extensive review of the history and interpretation of the wording of Section 52 in relation to the performance of injections of local anesthetic or pain medications by physiotherapists for the purpose of enabling wound debridement and care.
History of Restricted Activities in Alberta
The restricted activity framework applied to regulated physiotherapists in Alberta dates back to 1996 when the Government of Alberta first introduced the concept of restricted activities, which were described as activities where “the risk of harm associated with these activities is such that they can be safely provided only by regulated practitioners, who demonstrate required skills and experience.”
As the Government of Alberta worked to legislate restricted activity provisions under the then Government Organization Act and to transition health professions to be governed by the Health Professions Act, it required that “the profession must authorize, in regulation, the restricted activities that will be performed by members of the profession. All proposed authorizations are to reflect the current practice of physical therapists.”
Accordingly, the College undertook to identify those activities listed in the Government Organization Act which were being performed by physiotherapists, and how physiotherapists acquired the competencies to perform the identified activities. This work was undertaken between 1999 when the Health Professions Act was introduced, and 2004 when the College of Physiotherapists of Alberta Committee on Restricted Activities provided its report to Alberta Health. It was the work of this committee that led to the authorization requirements established for different restricted activities:
“A restricted activity that does not require post graduate education/practice will require basic authorization. All physical therapists have the ability to perform the restricted activity as it is part of a physical therapist’s scope of practice at the undergraduate level. The competencies to carry out the activity are acquired in a university physical therapy program.
A restricted activity that requires post graduate education/practice to ensure competence will require advanced authorization from the CPTA prior to incorporating this activity into practice. These are the activities that are acquired through postgraduate education and study. Typically, these would be activities not common to everyday practice.”
The CPTA relied on this categorization of restricted activities, entry to practice training, and descriptions of physiotherapy practice at the time, to inform authorization requirements as regulations were developed in preparation to come under the Health Professions Act, which ultimately occurred in 2011.
Previous Interpretation
Given that the performance of wound debridement and care was categorized as a basic restricted activity, authorized to all physiotherapists of the College of Physiotherapists of Alberta, on the basis of their entry to practice education,
AND
Given that entry to practice physiotherapy education does not include medication administration via injection for any purpose,
The College’s previous interpretation was that physiotherapists were not able to autonomously perform injections as part of wound debridement and care.
2025 Updated Interpretation
In response to repeated queries regarding what activities are authorized to physiotherapists for the purpose of wound debridement and care, the College:
- Conducted an extensive historical review of restricted activities.
- Sought a legal opinion as to the interpretation of the provisions of HPRAR Section 52(a).
The result of this review is the determination that there is no legislative barrier to a physiotherapist’s performance of injections as part of wound debridement and care.
Physiotherapists are not permitted to perform injections for any other purpose, due to the specific wording of the HPRAR.
This change represents a change in interpretation of section 52(a) of the Health Professions Restricted Activity Regulation based on evolving physiotherapy practice, circumstances in the health sector, and interpretation of legislation. It does not represent a change in the legislation.
Is It Physiotherapy?
The College of Physiotherapists of Alberta employs the “Is It Physiotherapy? Tool” when asked to review activities proposed or performed by physiotherapists.
The assumptions underlying the tool include:
- Public protection has top priority.
- Healthcare practice (including skills, services and technology) evolves continually.
- Regulation supports evolving quality practice.
- The scopes of various health professions overlap. No one profession owns a skill or activity.
- Collaboration and innovation in the use of all types of clinicians to meet population needs in the most effective and efficient way should be encouraged.
- A physiotherapist is accountable to demonstrate that they have the requisite training and competence to provide a service.
The tool includes five steps and related guiding questions to determine if an activity is consistent with the scope of practice of the physiotherapy profession.
- Define the issue
- Legislative and regulatory considerations
- Consider the evolution of the profession
- Consider the profession’s knowledge, skills, and judgment
- Consider the evidence.
There is no legal barrier to the performance of injections by physiotherapists in the context of wound care; however, other aspects of the “Is It Physiotherapy?” analysis bear consideration.
Evolution of the Profession
Pain relief has long been an essential consideration for wound debridement and care.
In some practice contexts the performance of this activity by physiotherapists may represent a safe evolution of practice, due to the knowledge and experience of the physiotherapists involved and the enabling context of practice.
The context of practice is a key consideration when assessing the safety and appropriateness of the activity.
Knowledge, Skills and Judgment
The performance of wound injections is not part of the curriculum of entry to practice physiotherapy programs. As such, physiotherapists will need to develop their knowledge and skills in the performance of the activity through post-professional training.
Physiotherapists seeking to perform the activity will need to identify and complete training programs that enable the development of relevant theoretical, practical and safety knowledge and skills, as is the case with other restricted activities authorized to physiotherapists. Physiotherapists will also need to identify mechanisms by which their knowledge and skills are validated or confirmed.
It is the Physiotherapist’s responsibility and accountability to demonstrate they have the competence to perform the activity.
The physiotherapist is responsible to demonstrate how they acquired the skills for this specific task.
The physiotherapist is responsible to address questions of professional liability insurance and legal liability with their personal professional liability insurance provider.
The College recognizes that physiotherapy practice, and entry to practice physiotherapy education have both evolved since the development of the restricted activity categorization, and regulations. The College committed to continue to refine regulatory policy and practice when physiotherapists became regulated under the Health Professions Act in 2011. This remains a priority as is evident in the strategic plan of the College which includes regulatory responsiveness and enhancing capacity to change and be agile in order to improve the regulatory model.
