March 24, 2020
On March 23, 2020, BC’s Provincial Health Officer, Dr. Bonnie Henry, issued a letter to BC health professionals (PDF) setting out “expectations for all regulated health professionals in British Columbia”. This letter also addresses RMTs, who as registrants of CMTBC are regulated health professionals in British Columbia.
CMTBC has heard from a number of RMTs who are uncertain about the meaning of Dr. Henry’s March 23 letter, given that CMTBC issued a “strong recommendation” to cease practice on March 17 and subsequently, after obtaining specific direction and clarification directly from Dr. Henry, CMTBC conveyed the “cease practice” order to RMTs on March 21, 2020.
CMTBC interprets Dr. Henry’s March 23 letter of expectation as superseding (for RMTs) her order of March 21, 2020, as it is directed to all BC health professionals, which includes RMTs. The letter directs that “all non-essential and elective services involving direct physical contact with patients … should be reduced to minimal levels” but adds that this is subject to “allowable exceptions”.
These “allowable exceptions” involve “time-sensitive circumstances” and “emergent, urgent, and/or essential care to avert or avoid negative patient outcomes”. If such care is to be provided, the health professional “must assess and screen patients for symptoms of COVID-19”. If the patient is suspected or confirmed to have COVID-19, Dr. Henry states that “health professionals must use infection control practices including as appropriate personal protective equipment.”
In paragraph 4 of her letter, Dr. Henry sets out a number of “principles” that health professionals must consider – together with guidance from their regulatory college – when they determine whether patient care is permitted. Patient care may occur if it is an “allowable exception” to the directive to minimize non-essential and elective treatment.
One of the principles set out by Dr. Henry is the “harm principle”, which asks health professionals to “limit harm wherever possible, taking into account all available alternatives, and the balance of differential benefits and burdens that result.” For RMTs, this means considering the risk of harm that would be created by providing treatment and weighing that risk against the risk that would be caused by withholding treatment.
After careful review of the March 23, 2020 letter, CMTBC’s position continues to be that RMTs should not practice under any circumstances, until otherwise notified. The risk of transmission of the COVID-19 coronavirus appears to be significant, and transmission can happen either from the patient to the massage therapist or vice-versa. Given the serious and potentially fatal consequences of COVID-19 infection, it is difficult to see how the harm principle justifies massage therapy either before a treatment for COVID-19 is developed or before transmission risk is substantially lower than it appears to be at present. Further, CMTBC is of the view that RMTs may not be in possession of what would be considered appropriate personal protective equipment in the circumstances.
RMTs who believe they are in circumstances justifying an allowable exception due to a potential negative outcome to a patient serious enough to justify the risk of harm, may contact CMTBC at [email protected] for further guidance.
Circumstances will continue to change and CMTBC’s position may evolve, especially as new guidance is provided by the Provincial Health Officer.
CMTBC has also received a number of inquiries from RMTs about “telehealth”, i.e. the delivery of health services by means of online or video communication between a patient and a health professional. CMTBC understands that RMTs communicate with their patients by a variety of means and for a variety of reasons, including the provision of services that are adjuncts to massage therapy treatment. To be clear, there is no concern about RMTs communicating with existing patients in this way, or charging patients for such communications, provided they are not billed as massage therapy.
However, CMTBC’s position has been that massage therapy itself (as distinct from adjuncts to care such as homecare), as defined in the Massage Therapists Regulation, cannot be delivered by online means, because it does not meet the Regulation’s definition of “massage therapy”. CMTBC understands that other professions with different scopes of practice, such as the physical therapy profession, are permitted to use telehealth as a care delivery modality. Such permission, however, is subject to qualifications and limitations, and is based on principles developed and agreed upon with counterpart regulators in other Canadian jurisdictions.
CMTBC has committed to continuing to research and study the telehealth issue, and to bring it to the Board for discussion. However, this will be a complex process and will necessarily require some time, so a final decision should not be expected in the immediate future.