CMTBC advises registrants that the use of an RMT’s feet for the delivery of treatment to a patient is not within the scope of practice for massage therapy.

Effective immediately, registrants who currently provide and bill for massage using the RMT’s feet as part of the provision of massage therapy services are advised to cease doing so.

Scope of Practice

“Scope of practice” refers to the activities that registered massage therapists are educated and authorized to perform, which are established by reference to the legislated definition of “massage therapy” in section 1 of the Massage Therapists Regulation (the “Regulation”).

The Regulation states that registrants of the College may practise massage therapy. Massage therapy is defined as meaning the health profession in which a person provides, for the purpose of developing, maintaining, rehabilitating or augmenting physical function, or relieving pain or promoting health, the services of

• assessment of soft tissue and joints of the body, and
• treatment and prevention of physical dysfunction, injury, pain and disorders of soft tissue and joints of the body by manipulation, mobilization and other manual methods.

Registrants must practice within their scope of practice, like all regulated health professionals.

CMTBC is aware that there are various techniques and modalities that involve use of the practitioner’s feet to apply pressure to a patient’s body. These include, but are not limited to, Ashiatsu, Thai-Mashiatsu/Mashing and Ki-Hara.

All forms of treatment delivered through the use of an RMT’s feet fall outside the scope of practice for massage therapy as established by section 1 of the Regulation.

Registrants may still provide services that fall outside the scope of practice of a registered massage therapist if they comply with section 78.91 of Part F.1 of the College’s Bylaws, which states as follows:

Advertising of services that fall outside the scope of practice

78.91 If a Registrant is also trained to provide a service or technique that falls outside the scope of practice of a massage therapist as prescribed by the Regulation

1. 1. that Registrant may advertise that service or technique so long as
      
      1. that non-massage therapy service is not linked to or associated with her status as a Registrant, and
      2. there is a clear separation of professional services that fall within and outside the scope of practice of Registrants,
   2. that Registrant must use separate letterhead, business cards, statements of account and similar documents for her non-massage therapy service, and
   3. that Registrant must not bill for massage therapy services while using an occupational title of the non- massage therapy profession.

In simple terms, this means that RMTs may provide a “service or technique” that is not massage therapy, but must not do so in a way that identifies them as RMTs or suggests that they are relying on their RMT status.  Also, they are not permitted to bill for such services as massage therapy.

As set out in section 78.9(1) of Part F.1 of the Bylaws, RMTs may only describe their massage therapy practices by listing:

1. the professional services that RMTs are trained in and capable of providing as registrants of CMTBC;
2. the techniques that RMTs have been trained to provide as registrants of CMTBC; or
3. the typical types of injuries or health problems that RMTs are trained to assess and treat as registrants of CMTBC, providing however that the professional services or techniques or the types of injuries or problems so listed fall within the scope of practice of a massage therapist as prescribed under the Regulation. (emphasis added)

Provision of Treatment Through the Use of the RMT’s Feet

The use of (and billing for) treatment provided through the use of an RMT’s feet as part of the provision of massage therapy services violates section 9(d) of the College’s Standards of Practice (Schedule “D” to the College’s Bylaws), which requires that registrants maintain awareness of, and practice within, the current scope of practice of massage therapy in British Columbia. A violation of the College’s Standards of Practice may be subject to investigation and professional discipline under the Health Professions Act.

CMTBC advises registrants who currently provide and bill for the provision of massage using their own feet as part of the provision of massage therapy services to stop doing so, effective immediately.

Correction of Advertising and Marketing Activities and Effective Date

CMTBC also advises registrants to amend their advertising materials and marketing activities immediately if they contravene Part F.1 of the Bylaws. CMTBC acknowledges that it is not possible to correct all advertising and marketing activities instantaneously. For this reason, Part F.1 of the Bylaws will be enforced in relation to massage using the RMT’s feet from February 1, 2022 onward. Any registrants found to be contravening Part F.1 of the Bylaws in relating to the use of an RMT’s feet after February 1, 2022 will be forwarded to the Inquiry Committee, which may initiate an investigation into a registrant’s contravention of the Bylaws, under subsection 33(4)(a) of the Health Professions Act.

Please note that if you are a registrant and you have a concern about another registrant’s advertising and marketing activities, you may submit a formal complaint to CMTBC; however, CMTBC encourages you to first consider discussing your concerns with the registrant involved, which may resolve the matter without engaging the formal complaint process set out in the Health Professions Act.

Questions

If you have any questions, please contact CMTBC’s Practice Advisor at 604.736.3404 (ext. 301) or at [email protected].