Dual Registration

Background

The practice of more than one profession by the same practitioner raises issues regarding the regulation and accountability of a practitioner who is functioning in dual roles. In these circumstances there is potential for clients to be misled about the qualifications or role of the service provider. Massage therapists must give careful consideration to whether they are using their additional skills and knowledge within the scope of practice of Massage Therapy.

Therapists who practice in more than one profession must be held accountable for their decisions about when they may include a treatment or modality in their Massage Therapy practice and when it is appropriate to separate their practice and cease to hold themselves out as Massage Therapists. This will also reduce confusion or misunderstanding by members of the public as to which of the two professions the therapist is practising.

Some modalities are shared between more than one profession and the question therefore arises as to when it is appropriate to cease to hold oneself out as a Massage Therapist and to instead declare oneself as a practitioner of another regulated health provider group. The mandate of the College is to protect the public and the College therefore has an obligation to ensure that its members conform to an appropriate standard. Dual practice by registrants of the College creates confusion around issues of jurisdiction and impairs the resolution of complaints in the public interest.

Through the appropriate separation of practice, members will ensure that the public and insurance providers are fully aware of the profession they are practising at any given time and also which College the practitioner is responsible to for his or her practice. In addition, if a complaint is lodged, the College is more readily able to determine to what extent it should scrutinize the alleged conduct.

Dual registrants must keep in mind that the client’s perception as a recipient of treatment is of critical importance and that clients cannot be expected to understand either the Regulations or the scope of practice for the different health professions.

The therapist must ensure that clients understand when and in what circumstances they are receiving treatment from the practitioner in his/her capacity as a Massage Therapist and when and in what circumstances they are receiving treatment from the practitioner which is outside the scope of practice of a Massage Therapist and within the scope of practice of the other health profession in which they are regulated.

Policy

Dual Registrant

Dual registrants are members who are registered with the College and also registered with another health profession in Ontario under the Regulated Health Professions Act, 1991 or regulated under the Drugless Practitioners Act (e.g. naturopathy).

Registrant Accountability

members must declare on their annual renewal of registration any other health College/Board with which they are registered. (By-Law No. 8, Section 5(b)) Registrants are responsible for ensuring that they have the knowledge, skills, and abilities to perform treatments within their Massage Therapy practice. They are also responsible for ensuring that they are functioning within the scope of practice of Massage Therapy when using the title Massage Therapist. The application of any skill/modality/technique for treatment purposes, which does not fall within the scope of practice of Massage Therapy, is not Massage Therapy and a Massage Therapist should not perform the skill/modality/technique in his/her capacity as a Massage Therapist.

Practice Hours

When signing the Mandatory Declaration at the time of renewal of registration each year, the registrant is permitted to include only hours practised as a Massage Therapist.

Controlled Acts

Massage therapists are not authorized to perform any controlled acts under the RHPA. If a therapist is registered with another health regulatory college in Ontario, which has authority to perform a controlled act, the therapist should separate his/her practices and not hold him/herself out to be a Massage Therapist when performing the controlled act.

Receipts

Massage therapists will comply at all times with the College’s Receipts Policy for all receipts issued for Massage Therapy treatment. Registrants cannot issue and sign a receipt for services performed outside the scope of practice of Massage Therapy and identify it as a receipt for Massage Therapy. Registrants will issue separate receipts for treatment provided in the role of the other health profession in which they are regulated according to that College’s/Board’s receipt requirements.

Conflict of Interest

The potential for conflict of interest to arise is heightened in dual practice. The College expects its members to act ethically when recommending additional services. members must ensure that an additional service does not appear to have been recommended solely to increase the member’s business revenues.

Dual Registrants’ Requirements

  1. inform clients if any part of a proposed treatment is outside the scope of practice of Massage Therapy,
  2. inform clients when a proposed treatment would not be administered in the registrant’s capacity as a Massage Therapist;
  3. inform clients that treatment outside the scope of practice will not be included on any receipt completed by the therapist for Massage Therapy treatment;
  4. before consent to treatment is received, inform clients of the therapist’s dual role as a Massage Therapist and as a provider of another area of healthcare practice;
  5. provide sufficient and appropriate information to clients to enable them to make an informed choice about which treatment(s) they wish to receive;
  6. maintain records for the Massage Therapy practice separate from the records of the practice of the other health profession; and
  7. take all reasonable steps to ensure the client understands the registrant’s dual role.

Approved: June 24, 2002