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Frequently Asked Questions

The APA and its employees cannot provide legal advice to members. We can only provide general advice.

The APA policy team is able to discuss general law implications affecting the broader APA membership and profession.

APA members can access complimentary independent legal advice from a lawyer with expertise in the relevant legal area being sought.

Advice on matters relating to insurance and your professional practice

Insured members can access 30 minutes free legal advice per inquiry from Lander & Rogers for questions involving issues such as:

  • privacy and confidentiality
  • conflicts of interest
  • how to respond to requests for information from third parties
  • inquiries from the regulatory body - AHPRA
  • how to respond to a subpoena
  • professional misconduct
  • ethical obligations
  • professional obligations.

To access this benefit, members must contact BMS on 1800 931 068 or at apa@bmsgroup.com

No advice for personal matters is provided.

Other advice - Maurice Blackburn (members only)

Maurice Blackburn is the APA’s preferred legal service partner in the following categories:

  • plaintiff law
  • employment law
  • employment contract reviews
  • superannuation and insurance claims
  • wills and estate planning requirements.

Making a complaint or notification 

As the peak professional body for physiotherapy in Australia, the APA is committed to supporting our members in providing safe and quality services in a professional and ethical manner. If you feel a physiotherapist or health service has not maintained professional and ethical conduct or handled an issue inappropriately, you have a number of options.

What are my options?

A complaint that relates to the immediate health or safety of a person should be made without delay. Complaints about sexual or physical assault should be lodged with the police.

In other cases, we suggest that you first discuss the complaint with the service provider or physiotherapist to see whether they can work with you to resolve the complaint. This link provides some tips for resolving your concerns directly.

If a resolution does not occur, or you are not satisfied with their actions, you may wish to contact the following organisations to discuss your complaint:

Complaint about an APA member

The APA has a governance structure in place to hear complaints about our members. An advisory committee, National Professional Standards Panel (NPSP), oversees the governance. This Panel reports to the Board. It also executes a complaints procedure and makes recommendations to the Board on outcomes of complaints. You may contact the APA with complaints about a physiotherapist, however the APA is only able to consider and hear complaints about APA members. If the physiotherapist is not a member, please consider contacting the HCE organisations listed above. You may phone the APA on 1300 306 622 to find out if the physiotherapist is a member of the APA.

Complaints procedure

The hearing of formal complaints about APA members follows the APA’s approved procedure for managing complaints. If you wish to lodge a complaint, you may do this in one of the following ways:

Managing a complaint or notification

As the peak professional body for physiotherapy in Australia, the APA is committed to supporting our members in providing safe and quality services in a professional and ethical manner.

What do I do if I receive a complaint?

Clients who are dissatisfied with their health service or treatment have a right to complain about their care. The APA advises complainants that complaints relating to the immediate health or safety of a person should be made without delay. Complaints about sexual or physical assault should be lodged with the police.

Complaints lodged with regulation bodies

If the complainant has lodged the complaint with the Australian Health Practitioner Regulation Agency (AHPRA) or the state or territory Health Complaints Entity (HCE), you should contact your insurance company immediately. APA members should also contact the APA and inform us of the notification (contact details below). We also advise you to contact AHPRA or the HCE as soon as possible, comply with the notification and seek independent legal advice.

Complaints lodged with the APA

The APA also receives complaints about members. In this case we may need to contact you further.

What is the complaints procedure?

The APA has a governance structure in place to consider and hear complaints about our members. An advisory committee, National Professional Standards Panel (NPSP), oversees the governance and reports to the Board. This Panel also executes a complaints procedure and makes recommendations to the Board on outcomes of complaints. The hearing of formal complaints about APA members follows the APA’s approved procedure for managing complaints.

What do I do next?

If a complaint has been lodged with the APA against you, we recommend the following actions:

  • refer to the APA Code of Conduct and the Physiotherapy Board of Australia’s codes and guidelines to make sure you are complying with your professional requirements
  • many physiotherapy services and organisations have a policy and procedure in place to guide complaints management. Please refer to these operational documents to help you map out your response to the complainant
  • if you do not have a policy and procedure to guide your response, it is a good idea to firstly discuss the complaint with the complainant, or to see whether they can work with you to resolve the complaint as follows:
    • acknowledge the client’s right to complain
    • provide information about the complaints system
    • work with the client to resolve the issue, locally where possible
    • provide a prompt, open and constructive response, including an explanation and, if appropriate, an apology
    • ensure the complaint does not adversely affect the client’s care. In some cases, it may be advisable to refer the client to another physiotherapist.
  • if the complainant does not respond to your attempts to resolve the situation please refer to the APA complaints management and hearing procedures. This will explain how the APA manages the process following a complaint lodged with us
  • in any event that you suspect may give rise to a complaint, contact your professional indemnity insurer.

Contacts for the APA and managing complaints

Please address correspondence to the National Professional Standards Panel manager.

Additional resources

RACGP Standards for General Practice 4th edition 2013. Standard 2.1 Criterion 2.1.2 

Who decides the rebates for each PHI claim item code?

Private health insurance rebates to patients are commercial decisions made by individual health funds.

What if my Healthpoint/HICAPS machine terminal rejects a particular item code?

If your Healthpoint or HICAPS terminal rejects a code:

  • the item code may have been repealed and no longer exists
  • the patient’s ancillary cover may not cover that particular item code
  • a specific insurer may not recognise that item code, (eg, HCF does not recognise item code 561 for Class Consultation. Classes with HCF have to be claimed under HCF’s Health Management Program).
  • ensure you are using the correct item number
  • check coverage with the insurance company
  • check with the insurance company that they accept the code you are entering.

Where can I find definitions for each PHI claims descriptor?

You can find definitions for each item code in the tools area of the APA website.

What code do I use for a group or a class?

Item code 560 is used for a group. That means, as a guide, six participants or less in a group. Each of the participants in a group setting must perform individually tailored exercises.

Item code 561 is used for a class. Everyone in a class does the same thing. The number of people in a class is not so significant.

The PHI won’t allow claims for a group or class.

Some insurance companies have different policies related to groups and classes and patients may shop around for insurance companies that meet their needs.

HCF, for example, has clarified that exercise classes for fitness, core strength or wellness are not claimable as either physiotherapy or through HCF’s Health Management Program.

If you run groups or classes, you should ensure that the way you describe your groups or classes matches the following descriptors:

  • Group (Item code 560): Groups typically have six participants or fewer who are being treated with individually designed interventions for the treatment of a specific health condition. Group physiotherapy requires pre-intervention assessment, individually designed interventions for each group participant, re-assessment and clinical record keeping eg, noting improvements and prognosis.
  • Class (Item code 561): Classes may have any number of participants but participants perform the same exercises.

Do I need my own provider number?

Yes. Each physiotherapist must have their own provider number. You cannot use someone else’s provider number. The provider number is practitioner and location specific, so if you move to another practice location or move interstate, you must apply to Medicare to get a new provider number. Physiotherapists can contact Medicare on 132 150.

Can someone else, including a locum use my Medicare number?

A locum (locum tenens) cannot use another person’s Medicare number.

If the locum will be in a practice for less than two weeks and will not be returning there, they should contact the Department of Human Services (provider liaison - 132 150) to discuss their options. Frequently this means the locum will use one of the locum's other provider numbers.

Where a locum will be in a practice for more than two weeks or in a practice for less than two weeks but on a regular basis, the locum should apply for a provider number for the relevant location.

Please refer to the Medicare Benefits Schedule – Note G2.3

Can I request diagnostic imaging?

Physiotherapists may request diagnostic imaging services for which the patient receives a Medicare rebate.

With the exception of the items listed in table 1, Medicare benefits are generally not payable for diagnostic imaging services that are classified as R-type (requested) services on request from a physiotherapist.

NR-type (not requested) diagnostic imaging items can be used by physiotherapists, but the clinical relevance of the service is determined by the diagnostic imaging service provider, so it is a good idea to establish a relationship with the imaging providers in your area.

The APA advises members not to refer for MRI scans if the referring physiotherapist does not have the necessary skills to interpret the MRI data. If a physiotherapist does not have a specific clinical skill, such as interpreting MRI data, refer the patient to a GP and request the radiologist report.

Further, Medicare likely will not cover the costs if an MRI is ordered by a physiotherapist and so the patient would be out-of-pocket.

Can I provide a sick certificate?

Physiotherapists may provide sickness or fitness for work certificates.

The Fair Work Act 2009 - Subdivision D—Notice and evidence requirements S107 (3) states that an employee who has given his or her employer notice of the taking of (sick) leave must, if required by the employer, give the employer evidence that would satisfy a reasonable person that the paid sick leave is taken because the employee is not fit for work because of a personal illness, or personal injury, affecting the employee. (S97)

Physiotherapists must also ensure they adhere to the PhysioBA code of conduct (8.8 Reports, certificates and giving evidence) when writing such certificates and so provide sick certificates related to their scope of practice.

Some workplaces have policies related to the length of absence covered by a sick certificate they will accept. This is frequently for one week at a time. While not bound by the workplace policies of other organisations, physiotherapists may consider providing certificates for a maximum length of one week’s absence, with review after that time. This may ensure patient adherence to treatment and physiotherapist management of the condition.

Workers' Compensation or Motor Accident Authorities in each state or territory may have specific criteria about sickness or fitness for work certificates. You should refer to these authorities if relevant.

Can I take clients with me if I move practices?

It is common for employees to move practices, or set up their own practice. However, a client’s relationship is with a particular practice, rather than with a particular employee of that practice. Unless provided for in a contract, clients remain a client of a practice unless they choose to move.

It is entirely appropriate for an employee to inform a patient that they will no longer be working at a practice and if asked, to provide further details.

This is a complex matter that may depend on the nature of any employment contract in place and other factors. If you believe an employee is 'poaching' clients, you should seek independent legal advice from a lawyer with expertise in the related field of law.

Premium Principal and Business Affiliate Members of the APA’s Physiotherapy Business group can access our HR in Practice service. This service provides members with free HR and industrial advice. Additional services are available for a fee. Contact HR in Practice on 1300 138 954.

You may also consider speaking to AHPRA, or the Health Care Complaints Commission (HCCC) if you are in NSW, or the Office of the Health Ombudsman (OHO) if you are in Queensland to discuss whether it is a matter they should investigate.

Can I stop treating a patient?

You do not have to treat, or continue the treatment of, a patient. You do not have to give a reason for stopping treatment but you should provide the patient with alternative treatment options, for example the details of another practitioner.

Can I sell or supply medicines and/or supplements?

Refer to Physiotherapy and medicines information.

Can I treat friends or family?

Your liability insurance may exclude the treatment of members of your family or friends. You should refer to your insurance company and your policy for more information.

Registering and protecting a business name

Registering a business name does not give you exclusive trading rights over that name. ASIC provides information about how to protect your business name.

Where can I get advice about employment contracts?

The APA or its employees cannot offer legal advice. We advise you seek independent legal advice related to employment or contract law.

Premium Principal and Business Affiliate Members of the APA’s Physiotherapy Business group can access our HR in Practice service. This service provides members with free HR and industrial advice. Additional services are available for a fee. Contact HR in Practice on 1300 138 954.

You should also refer to the Fair Work Ombudsman for information and advice about your workplace rights and obligations, including award rates.

APA partner Maurice Blackburn offers employment contract reviews for a fee.

My employment has been terminated. What are my rights?

You should always have a contract in writing. Most employment contracts will have clauses relating to termination of employment.

You should seek independent legal advice and seek advice from the Fair Work Ombudsman and your Trade Union, if you are a member of one.

Premium Principal and Business Affiliate Members of the APA’s Physiotherapy Business group can access our HR in Practice service. This service provides members with free HR and industrial advice. Additional services are available for a fee. Contact HR in Practice on 1300 138 954.

How do I become a credentialled diabetes educator?

Physiotherapists can apply for an accredited post-graduate certificate in diabetes education and management courses. Completion of this course leads to accreditation as a diabetes educator.

To gain recognition as a credentialed diabetes educator, physiotherapists must meet minimum criteria in diabetes education, participate in mentoring partnership registered with the Australian Diabetes Educators Association (ADEA) and have a referee report addressing the criteria of the National Core Competencies for Credentialed Diabetes Educators (CDE). All CDE’s must apply to  ADEA to retain their CDE status every three years.

It will enable patients to receive Medicare benefits for group physiotherapy sessions they attend – for five sessions per year under items 81100 to 81125 when the group is run by a CDE physiotherapist.

Further information can be found here.

Can I ask for or offer a payment for a referral?

This practice may be against the AHPRA Code of Conduct for the registered professions related to conflicts of interest.

How do I maintain professional boundaries with patients? Can I have an intimate relationship with a patient?

Professional boundaries are addressed in the AHPRA Code of Conduct 8.2 Professional boundaries.

A clear separation should exist between professional conduct to meet the health needs of patients, and a practitioner’s own personal views, feelings and relationships which are not relevant to the therapeutic relationship.

Do I need a Working With Children or police record check?

Your employer may require you to have a valid working with children check as a condition of employment. There is no single national framework setting out the requirements for obtaining Working With Children Checks or Police Checks. Each state and territory has their own procedures and it is necessary to fulfil the requirements in the jurisdiction in which you are working.

Read detailed information here and check with the relevant agency in your state or territory:

National Police CheckAustralian Capital Territory
Working with Vulnerable People Check
The Office of Regulatory Services
Ph: (02) 6207 3000
Email: wwvp@act.gov.au

Australian Federal Police
Ph: (02) 6140 6502

New South Wales
Working with Children Check
Office of the Children’s Guardian
Ph: (02) 9286 7219
Email: check@kidsguardian.nsw.gov.au 

Northern Territory
Working with Children Clearance
Northern Territory Government
Ph: 1800 72 33 68
Email: safent.police@pfes.nt.gov.au

Queensland
Working with Children Check
Blue Card Services
Freecall: 1800 113 611
Ph: (07) 3211 6999

South Australia
Child-related employment screening
Department for Communities and Social Inclusion
Ph: 1300 32 15 92
Email: screening@dcsi.sa.gov.au

National Police Check
South Australia Police
Ph: (08) 7322 3347

Tasmania
Working with Children Registration
Department of Justice
Ph: 1300 13 55 13

National Police Check
Tasmanian Police Department
Ph: (03) 6173 2928
Email: workingwithchildren@justice.tas.gov.au

Victoria
Working for Children Check
Department of Justice and Regulation
Ph: 1300 652 879
Email: workingwithchildren@justice.vic.gov.au

National Police Certificate
Victoria Police
Ph: 1300 88 15 96

Western Australia
Working with Children Check
Department of Child Protection
Freecall: 1800 883 979
Ph: (08) 6217 8100
Email: checkquery@cpfs.wa.gov.au

National Police Certificate
Western Australia Police

How do I create a child safe environment, or comply with the Victorian Child Safe Standards?

Refer to 'Safer communities for children' resource 

Where can I get interpreter or translator services?

You may need to access the services of an interpreter or translator services when you provide healthcare to people whose first language is not English, including for people who use Auslan. Interpreters provide real-time translation in person or by telephone. Translators translate text into different languages.

The Translating and Interpreting Service (TIS National) is an interpreting service provided by the Department of Immigration and Border Protection for people who do not speak English and for agencies and businesses that need to communicate with their non-English speaking clients.

TIS National provides:

  • immediate phone interpreting
  • ATIS voice automated voice-prompted immediate phone interpreting
  • pre-booked phone interpreting
  • on-site interpreting.

The majority of TIS National interpreting services are free for non-English speakers. Generally the organisation being contacted accepts the charges for the service. Some organisations and medical practitioners are eligible for free interpreting through TIS National.

Allied health professionals are not eligible for the free interpreting service through TIS National.

NDIS participants:

People who are receiving services under the NDIS and whose plan identifies a need for interpreting will be funded for those services through their NDIS plan.

Auslan users:

NABS is the National Auslan Interpreter Booking and Payment Service. NABS is funded by the Australian Government to provide Interpreters free of charge to people who use sign language to communicate and would like to book an interpreter for private health care appointments.

Please refer to NABS to book an Auslan interpreter.

What do I need to know about protecting my patient’s confidentiality?

This is general advice. It is not legal advice. You should seek independent legal advice and speak to your insurer.

In most cases in healthcare practice, maintaining patient confidentiality is paramount. This means that any information a patient gives to you about their health status or private circumstances in the course of a professional consultation should be regarded as confidential and not passed on to other people except with the patient’s consent. Patients expect all communications between themselves and health professionals to remain private. Most medical consultations are also protected by a statutory or common law requirement of confidentiality.

However, there are some exceptions to this requirement for strict adherence to patient confidentiality. It is lawful for a health professional to disclose information if:

  • some other law requires disclosure – for example reporting cases of suspected child abuse under chapter 4 of the Children, Youth and Families Act 2005 (Vic)
  • you receive a subpoena from a court
  • it can be argued that the person has provided express consent to disclose information; or the consent for disclosure is implied– for example, in situations where the practitioner is giving information to another health provider as part of the referral process to another practitioner, and reports provided for the purpose of insurance where the person has been examined at the request of the insurer. In situations where consent is implied the APA advises members to inform the patient and record this
  • it may be in the public interest for the information to be disclosed, for example where there is a serious risk to the patient or another person.

You should call the police if in your professional judgement there is a serious and immediate risk of harm to a patient or another person.

Do my staff need CPR and first aid training?

A person conducting a business or undertaking must ensure that an adequate number of workers are trained to administer first aid at the workplace, or that workers have access to an adequate number of other people who have been trained to administer first aid.

Given the risk in a health practice our position is that all staff should have up to date first aid and CPR training.

First aid training is usually repeated every two years. CPR training is usually repeated each year.

I need help with my advertising

The APA can only provide general advice about advertising. You should refer to the national law and the AHPRA guidelines and seek independent legal advice.

Who regulates advertising?

Advertising health services is regulated either by AHPRA, or The Australian Competition and Consumer Commission (ACCC). You may be able to make a complaint to either or both regulators, depending on circumstances.

The ACCC legislation means it is illegal for a business to make false and misleading claims[JD3] . This applies to their advertising, and any information provided by their staff. It also applies to any statements made by businesses in the media or online.

Similarly, under the National Law a person must not advertise a regulated health service, or a business that provides a regulated health service, in a way that is false, misleading or deceptive or is likely to be misleading or deceptive. For example, although the word ‘physio’ is not protected, the National Law states that ‘a title, word or description (must not) induce a reasonable person to believe this person is a physiotherapist.’

I’ve noticed inaccurate advertising about a physiotherapist

The national law and AHPRA’s advertising guidelines establish how and what registered practitioners may advertise.

Advertising in any medium must not mislead, offer inducements such as a gift or discount (unless the relevant terms and conditions are also included), use testimonials, and/or create unreasonable expectations of beneficial treatment, or encourage the indiscriminate or unnecessary use of a service.

The APA may contact a member to remind them of their obligations. You can also notify AHPRA, or the Health Care Complaints Commission (HCCC) if you are in NSW or the Office of the Health Ombudsman (OHO) if you are in Queensland to discuss whether it is a matter they should investigate.

Further information is available here.

Another practice is offering physiotherapist services, but no physiotherapist works there.

Only registered physiotherapists may use the title ‘physiotherapist’ or ‘physical therapist’. No advertising may cause a reasonable person to infer that someone is a physiotherapist if they are not.

How should I store records and data, and can I use the cloud?

You should ensure any method of storage meets the requirements of the Privacy Act. You may use the cloud to store data - the Office of the Australian Information Commissioner provides guidance on storing data in the cloud.

What should be in clinical records?

  • clinical records must contain sufficient information to allow a physiotherapist of similar skill to continue the treatment of that patient if required
  • all abbreviations, terminology and symbols recorded in the clinical record should be recognisable by physiotherapy peers
  • physiotherapists must accurately document all consultations
  • records must document each attendance and be completed as soon as practicable after treatment
  • clinical records must be dated, and if appropriate, include the time of the consultation
  • they must be legible and signed by the treating physiotherapist with the physiotherapist’s name clearly printed
  • where a service is provided by a physiotherapy student, the records must be countersigned by the supervising physiotherapist.

How long should I keep patient records?

A record must be kept for at least seven years from the date of last entry in the record, unless the patient was less than 18 years old at the date of last entry in the record. If the patient was less than 18 years old at the date of last entry in the record, the record must be kept until the patient attains or would have attained the age of 25 years.

The date of last entry in the record means the date the patient concerned was last provided with medical treatment or other medical services by the medical practitioner or medical corporation who provided that treatment or those services.

A physiotherapist is not keeping proper records. What can I do?

A physiotherapist must keep accurate records. The Physiotherapy Board of Australia code of conduct sets out requirements.

The APA can contact a member to remind them of their obligations. You can also notify AHPRA, or the Health Care Complaints Commission (HCCC) if you are in NSW or the Office of the Health Ombudsman (OHO) if you are in Queensland to discuss whether it is a matter they should investigate.

Should I keep clinical notes for a group and a class?

Yes. Clinical records must be kept for participants in groups and classes, with sufficient notes on each patient’s file.

Notes must be accurate and clinically justify the interventions provided to the client, as well as anything else of significance to the patient’s progress to date and clinical goals. 

A patient has asked for their medical records. Can I provide them?

The Australian Privacy Principles and other state and territory legislation regulate information gathered and held by organisations, and Australian Government (and Norfolk Island Government) agencies.

The Privacy Principles require you to provide access to a patient’s health information without unreasonable delay or expense, and give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.

If medical records are held by a private sector organisation, like a physiotherapist in private practice or by a private hospital, as a general rule, patients have a right to gain access to all the information held about them. If the medical records are held by a Commonwealth agency, patients also have a right to access those records, unless the agency is required or authorised to refuse access to that information under the Freedom of Information Act 1982 or another Commonwealth law.

A patient may:

  • look over the records
  • take a copy of those records
  • have them explained
  • have information corrected if it is wrong.

There are some limitations on the right of access. These may apply, for example, to:

  • where giving access would pose a serious threat to the life and health of anyone
  • where refusing access is required by law.

Can I charge for providing a patient access to their records?

You are not required to charge a patient for access and you should consider whether it is reasonable, fair or good service in the circumstances. The Australian Privacy Principles state that you may charge for providing a patient access to their records, unless you are a government agency. The charge must be reasonable. You must not charge someone for asking for their records or for correcting information. However, state and territory legislation may differ. For example, Victoria has maximum fees. In all cases, any fee should be reasonable.

Can I charge lawyers or other companies for providing records?

You may charge companies, including lawyers, for providing copies of patient records. You should contact the third party requesting the records to discuss what you intend to charge. Some government entities, or entities with which you may have a contractual obligation to provide information, like insurance companies, may not pay for information.

A third party, like a private health insurer, wants to see clinical records. What should I do?

You should seek written consent from the patient. You could get consent by letter or email, or when the patient joins your practice.

The third party (eg, private health insurer) should provide sufficient notice to get patients’ consent and make necessary arrangements for inspection eg, retrieving files, setting up an area to inspect the files.

The patient has a right to deny consent but the patient accepts the risk that, if they deny consent, the third party (for example a private health or workers compensation insurer) may refuse to pay for a service.

I have received a subpoena to produce my clinical records. What should I do?

You may receive a subpoena to produce your clinical records to a Court of Law or the police. A subpoena is a legal document and you must comply with a subpoena request and the conditions, for example to produce records 'from 15 July 2013 to 12 May 2014 only'. You should also consider seeking legal advice.

Can I claim expenses for attending court or giving evidence?

The court does not pay witnesses for pre-trial phone conferences or for attendance as expert witness.

However, you are entitled to be compensated for costs and loss of earnings which you have incurred as a result of coming to court. You should discuss in advance compensation with the person or lawyer who has called you to give evidence.

You may be compensated for:

  • any cost of travelling to and from the court
  • the cost of overnight accommodation (if necessary)
  • a reasonable amount to compensate you for any wages or income you may lose when you attend the court
  • if you are an expert witness, payment for the time you have spent preparing a report.

Who do patient files belong to?

While the physical written patient files belong to the practice, a patient has a right to see the files, and to have those files, or copies of those files, transferred to another practitioner on their request without unreasonable delay.

Depending on any contractual arrangements, patient files do not belong to individual practitioners within a practice. You may not take the patient files with you after you cease employment, unless stated in a contract. In a case where you bring patient files to a practice, you should negotiate a prior agreement and write up a contract that specifically covers that you will take the files you originally brought into the practice when you leave. You should always have a contract in writing.

Can I charge for writing a report?

You can charge by the hour for writing a report, for example to a solicitor or compensable body. Charges should be reasonable. You should discuss fees or compensation with the person or authority that has requested information. Some bodies, like tribunals, may not compensate you for providing evidence but you may be required by law to provide that evidence. Other entities may have fixed amounts for compensation.

What titles can a physiotherapist use?

The National Law regulates the use of certain titles. Misuse of a protected title is an offence under this law.

Only registered physiotherapists may use the title ‘physiotherapist’ or ‘physical therapist’. No advertising may cause a reasonable person to infer that someone is a physiotherapist if they are not.

Please also refer to the answer given in the Complaints and Notifications section: 'Someone is using a title they are not entitled to use – use and protection of title.

The National Law does not allow the use of the word ‘specialist’ and associated words (e.g. specialising) to refer to a registered practitioner, unless they are a ‘specialist’ recognised by the National Law - it’s a protected title. Other titles, such as ‘sports physiotherapist’ are also not allowed under the National Law. Click here for more information about the national law and the use of specialist titles.

However, the Physiotherapy Board of Australia (PhysioBA) recognises the established history of physiotherapy practice, achieved through recognised higher education through the Australian College of Physiotherapists.

By exception, the APA secured the agreement of the PhysioBA to allow the following tier 2 or tier 3 titles awarded only by the APA and the Australian College of Physiotherapists to APA members who meet the requirements.

Tier 2 titling:

The titles awarded by groups are:

  • APA Musculoskeletal Physiotherapist
  • APA Sports Physiotherapist
  • APA Animal Physiotherapist
  • APA Gerontological Physiotherapist
  • APA Neurological Physiotherapist
  • APA Occupational Health Physiotherapist
  • APA Cardiorespiratory Physiotherapist
  • APA Continence and Women's Health Physiotherapist
  • APA Paediatric Physiotherapist

Those awarded these titles may only use the following format: 'Mr J Brown, APA Sports Physiotherapist'

Tier 3 titling:

Australian College of Physiotherapists confers Fellowship by Specialisation in the following disciplines:

  • Cardiorespiratory
  • Continence and women’s health
  • Gerontology
  • Musculoskeletal
  • Neurology
  • Occupational Health
  • Paediatrics
  • Sports and Exercise

By exception, the APA secured the agreement of the Physiotherapy Board of Australia to allow those awarded the above to use the following format:

  • 'Mrs P. Smith, Specialist cardiorespiratory physiotherapist (as awarded by the Australian College of Physiotherapists in 20YY)'

Physiotherapists who do not have this title may not use the word specialist or associated words.

The word ‘expert’ isn’t protected. The APA does not believe that using the word ‘expert’ implies the person holds the protected ‘specialist’ title.

We remind all members that you must not use the word ‘specialist’ or its derivatives. You risk enforcement action from AHPRA if you use a protected title. We strongly advise members to comply with the National Law and remove the word ‘specialist’ and its derivatives from notices and advertising.

If a member is not using the correct titles, the APA can contact a member to remind them of their obligations. If this is not corrected we advise you to notify AHPRA, or the Health Care Complaints Commission (HCCC) if you are in NSW or the Office of the Health Ombudsman (OHO) if you are in Queensland to discuss whether it is a matter they should investigate.

I’m a physiotherapist. What’s my scope of practice?

If you are unsure whether the work you are undertaking is within the scope of physiotherapy practice, we ask our members to consider the following:

  • Have you learned to do the task? That is to say is the task within your competence (skills, knowledge, qualifications, position description)
  • Is it within the law?
  • Are there appropriate safeguards in place in your work environment?
  • Would your professional colleagues agree that you are competent?

If you answer no any of these questions you may be outside of scope of practice. Members have a professional obligation for ensuring that they work within scope of practice – so members may need to take some time to investigate further.

Scope of practice is dynamic, and differs from practitioner to practitioner depending on training and experience. Some physios work at the cutting edge of physiotherapy practice and therefore need to utilise the collective knowledge of the profession when assessing the safety of their practice.

A regular assessment of your competence, an awareness of the laws, and a regular check of the safeguards are crucial to assessing scope of practice. Scope of practice is dynamic, and to reflect this we use a dynamic approach in describing scope of practice to highlight the opportunities and innovation available for individuals, the profession, and the health system.

Members may want to consider utilising the resources we have developed, such as our position on scope of practice, the self-assessment toolkit, and the case-studies.

Please refer to the APA scope of practice resources

APA Partners