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Council Meeting/Documents/Operational Requirements for Establishing a Natural Asset Inventory Program
Staff Report

Operational Requirements for Establishing a Natural Asset Inventory Program

March 17, 2026Pages 107–1129 sectionsOriginal PDF

A report from the Director of Engineering regarding the necessary steps and requirements for creating a natural asset inventory program.

February 26, 2026Director of EngineeringNatural Asset Inventory Program

PTs already diagnose and manage diseases, disorders, and conditions but are not permitted to order the very imaging they need to confirm diagnoses. This regulatory gap creates unnecessary delays, duplicate visits, and missed opportunities for early intervention.

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System-Level Alignment

This proposal directly aligns with the health care optimization strategies of both the Doctors of BC and the BC Ministry of Health, supporting more efficient, team-based, and patient-centered care delivery.

1. Doctors of BC – Team-Based Care Advocacy

Doctors of BC has long emphasized the importance of integrated, team-based models to improve continuity and access. Their 2023 Scope of Practice for Health Professionals Policy Statement advocates for utilizing all regulated health professionals to their full training and scope to ease system overload and support collaborative care.

2. BC Ministry of Health – Primary Care Strategy

The Ministry of Health’s 2025 Strengthening Primary Care report highlights a system-wide transition toward Primary Care Networks and Urgent and Primary Care Centres—models where allied health professionals, including PT, play a vital role in closing attachment gaps and improving access to culturally safe, timely care.

The Ministry’s 2025/26–2027/28 Service Plan further emphasizes scope optimization and enhanced team-based care as critical strategies for system transformation. Enabling PTs to order diagnostic imaging within these models reflects the Ministry’s commitment to delivering comprehensive, coordinated, and integrated care that meets patients where they are.

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Jurisdictional Snapshot: PT Diagnostic Imaging Authority in Canada

  • British Columbia: Previously, PTs were able to order diagnostic imaging through delegated authority from physicians. However, this practice was recently halted by the College of Physicians and Surgeons of BC, leaving PTs without direct or delegated access.
  • Alberta: Since 2011, PTs with advanced training have been authorized to independently order X-rays, MRIs, and ultrasounds, under a clearly defined regulatory framework.
  • Nova Scotia: In 2024, PTs in private practice were granted authority to order X-rays. PTs in public practice already had access to diagnostic imaging under existing models, improving consistency across sectors and streamlining care.
  • Quebec: Since 2020, ordering diagnostic imaging has been a formally authorized act within PT scope.
  • Prince Edward Island & Yukon: PTs in both jurisdictions have been granted diagnostic imaging privileges, contributing to timely access to care in smaller and often underserved regions.
  • Ontario: A recent public consultation concluded with strong support for expanding PT scope. A legislative amendment is expected in the near future, further aligning the province with international and national trends.
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Recommendation

The Physical Therapists Regulation should be updated to include ordering diagnostic imaging within the scope of practice for PTs in British Columbia. It is PABC’s position that it is not within the scope of authorized PTs to interpret diagnostic imaging. This responsibility lies with the radiologist who provides a report to the referring therapist.


Expanding Diagnostic Imaging Access in British Columbia: How Physiotherapists Can Support Timely, Cost-Effective, and Integrated Care

Published December 18, 2025

Page 107–112

Executive Summary

  • British Columbia’s (B.C.) health care system faces unprecedented pressure with emergency department (ED) closures, long specialist wait times, and one in four residents without access to a primary care provider. At the same time, health care expenditures are rising exponentially annually.
  • Expanding the scope of physiotherapy (PT) practice to include diagnostic imaging access offers a practical, evidence-supported way to improve patient flow and reduce duplication—complementing, not replacing, the work of physicians, nurse practitioners, and other providers.
  • PTs are university-trained, regulated professionals who already diagnose and manage diseases, disorders and conditions. Other provinces (e.g., Alberta, Nova Scotia) and countries (e.g., United Kingdom, Australia) have effectively integrated diagnostic imaging into PT practice.
  • A scoping review found the following major themes: a) PTs order imaging judiciously and in-line with best practices, b) PTs have high diagnostic agreement with specialists and radiologists, c) Integrating PTs into team-based care models (e.g., EDs, primary care, surgical triage) improves access, costs, and enhances patient outcomes, and d) Patients, other health care professionals and interest holders support granting PTs the ability to order diagnostic imaging.
  • The scoping review also identified that advanced training improves diagnostic imaging accuracy and appropriateness. Despite limited professional competency standardization there are existing national and international regulatory frameworks that could guide the expansion of B.C.’s Physical Therapists Regulation to include diagnostic imaging.
  • Regionally, there is physician support for PTs with advanced training to order diagnostic imaging, including—but not limited to—the BC Children’s Hospital Orthopaedic Clinic and the Brenda and David McLean Integrated Spine Clinic (Appendix A).
  • The University of British Columbia’s Department of Physical Therapy has confirmed its commitment to designing and implementing post-graduate diagnostic imaging training.
  • The College of Health and Care Professionals of British Columbia has confirmed its preparedness to regulate this activity once the legislation is amended.

PABC makes the following key recommendations:

  1. Legislative alignment: Amend B.C.’s Physical Therapists Regulation to authorize PTs to order diagnostic imaging. To ensure the highest standards of care, it is PABC’s position that ordering diagnostic imaging should be a restricted activity if authorized.
  2. Public coverage: Ensure imaging ordered by PTs is eligible under MSP.
  3. Certification and oversight: Allow reasonable time for the College of Health and Care Professionals of British Columbia (CHCPBC) to develop appropriate education pathways and competency standards.
  4. Program Evaluation: Evaluate the program two years after implementation.
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I. Purpose

The Physiotherapy Association of British Columbia (PABC) advocates for PTs with advanced training to be granted the authority to order diagnostic imaging as part of their full scope of practice. Empowering PTs in this way would contribute meaningfully to addressing several pressing challenges in B.C.’s health care system, including ED closures, funding constraints, long wait times for specialist consultations, and limited access to primary care providers.

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II. Background

The Challenges: The Health Care Crisis & Economy

Emergency department closures, long waitlists for specialist consultation and a lack of access to primary health care providers are persistent challenges frequently highlighted by national and provincial media outlets.1,2,3 There is a widely held belief among experts, forecasters, researchers and the public that we are in a crisis. A 2023 international survey of 10 high-income countries revealed that Canada had the lowest proportion of adults (86%) who reported having a regular doctor or place to receive medical care—well below the average of 93%, and significantly lower than comparable countries such the Netherlands, which reported 99%.4 In B.C., the proportion of individuals attached to a primary care provider ranges from 73% to 82% .4-6

Health care spending remains one of the largest government expenditures.7 As noted in the 2025 B.C. Budget,8 the province faces an uncertain economic environment. In response, the B.C. government issued mandate letters in January 2025 directing ministries to review expenditures and improve efficiency,9 and a comprehensive review of all health authorities is currently underway.10 With the provincial government recently announcing a record $11.6 billion deficit in September 2025,11 optimizing health care delivery is more critical than ever.

PTs are key members of the medical system in B.C., providing expert knowledge and skills in the assessment, treatment and management of physical injuries and illness. Despite their expertise, PTs remain an underutilized resource in this province. Greater integration of PTs into the health care system could help reduce costs, alleviate pressure on other providers, and improve patient outcomes.

Table 1. PABC Member Front-Line Experience: Red Flag Screening

Section Content
Situation A 60-year-old woman with diabetes presented with shoulder stiffness typical of a frozen shoulder.
Action The PT noted an atypical finding—normal internal rotation—and suspected another cause. Without authority to order imaging, the PT advised the patient to check in with their physician to get a requisition. The patient couldn’t get in to see their doctor for a few weeks, but eventually had the image taken. Five weeks after her initial PT appointment, the X-ray revealed an osteosarcoma.
Impact Critical diagnosis was delayed, extending suffering, diagnostic uncertainty, and increasing downstream costs. PT ability to order diagnostic imaging could have detected the malignancy earlier.
Lesson PTs often identify red-flag patterns early. Imaging authority enables faster detection of serious conditions.
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III. Analysis

Diagnostic Imaging

Diagnostic or medical imaging encompasses a broad range of modalities—such as Computed Tomography (CT), Magnetic Resonance Imaging (MRI), Ultrasound, and Radiography—that enable visualization of the internal structures and functions of the body.12 These tools support accurate diagnosis, treatment planning, and monitoring of various health conditions.12 Diagnostic imaging is essential for timely diagnosis and care planning and without timely access, patients face delays in accessing treatment, unnecessary referrals, and higher costs.

Diagnostic imaging is widely recognized in the literature as a key enabler for PTs to work to their full scope of practice. In British Columbia, PTs have had direct access legislation since 1999, allowing individuals to seek PT services without a physician referral. Notably, a survey of the World Confederation for Physical Therapy Nations found that countries with direct access to PT are 7.4 times more likely to authorize PTs to order musculoskeletal imaging.13 This correlation underscores the importance of aligning diagnostic imaging authority with existing direct access legislation to fully leverage the capabilities of PTs in B.C.’s system.

Table 2. PABC Member Front-Line Experience: Acute Ankle Injury

Section Content
Situation A 35-year-old soccer player twisted her ankle. The PT applied the Ottawa Ankle Rules and determined imaging was required.
Action Without PT diagnostic imaging ordering authority, the patient faced two options because there was no walk-in clinic in her community: wait about two weeks to see her doctor, get an X-ray, have the report sent back to the doctor, and then book another follow-up for results—or spend 6–8 hours in the ED to get imaging the same day.
Impact Granting PTs access to imaging would eliminate two unnecessary physician visits, accelerate diagnosis from weeks to days, reduce health care costs, minimize lost work time, and significantly lessen patient distress.
Lesson PT imaging access turns a two-week cycle of uncertainty into a two-day path of clarity, faster recovery, and lower system cost.

Regional, National, & International Context

The above noted survey of World Confederation for Physical Therapy Nations found that 38% of member nations reported having some level of PT musculoskeletal imaging authority.13 Notably, United States military PTs and New Zealand PTs have had diagnostic imaging privileges since 1972 and 1999 respectively.14,15 Countries such as Australia, the United Kingdom, Norway and South Africa have integrated diagnostic and procedural imaging into PT practice.16

In Canada, Alberta became the first province to authorize PTs to refer for diagnostic imaging in 2011.17 Currently, ordering diagnostic tests is within the PT scope of practice in Alberta, Quebec, New Brunswick, Nova Scotia, Yukon,18 and Prince Edward Island.19 Regulatory changes are also currently under review in Ontario.20 The Canadian Physiotherapy Association has recommended that the federal government actively encourage all provinces and territories to adopt policies that allow PTs to order diagnostic imaging nationwide.21

Despite progress elsewhere, and substantive changes to the Physical Therapists Regulation already planned for April 1, 2026, diagnostic imaging is not part of these changes. This omission will continue to limit PTs in B.C. from practicing to their full scope of practice. Compared to other health professions in B.C., PTs have not seen the same level of advancement or innovation in scope expansion. For instance, in 2023, nurse practitioners were granted extended scope to conduct mental health and capacity assessments,22 and pharmacists gained authority to diagnose and prescribe for minor ailments and contraception.23 Expanding PTs’ scope to include the ability to order diagnostic imaging is a logical and necessary step, particularly given that BC regulations already authorize PTs to diagnose diseases, disorders, and conditions.24 For PTs working in settings such as primary care or surgical triage, access to diagnostic imaging can significantly enhance clinical decision-making by refining differential diagnoses and ruling out serious pathologies.25, 26

Table 3. PABC Member Front-Line Experience: A Missed Hip Fracture

Section Content
Situation A 25-year-old man fell from height at work and was treated for a soft-tissue injury.
Action Despite persistent pain and limited motion, two PT requests for imaging were declined. Three weeks later, ED X-rays confirmed a displaced femoral-neck fracture requiring urgent surgery.
Impact Weeks of ineffective rehabilitation and surgical delay increased cost and risk.
Lesson PTs monitor recovery longitudinally and recognize when progress deviates from anticipated timelines. Imaging authority would prevent prolonged disability.
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Expert Opinion & Scoping Review Themes

Expert consultation and a scoping review were conducted. For detailed methodology see Appendix B. Ninety-seven articles and resources were found pertaining to PTs and diagnostic imaging. See Appendix C for a full summary of findings. The following themes emerged:

  1. Judicious PT Imaging Rates: Evidence consistently shows that PTs order imaging judiciously and in-line with best practice.17,27-47
  2. High Levels of Diagnostic Accuracy and Appropriateness: PT diagnostic imaging referrals are commonly cited as being appropriate and align with established guidelines such as the American College of Radiology Appropriateness Criteria.27,28,48,49
  3. Treatment Plan Changes: PTs consistently demonstrate a conservative threshold for ordering diagnostic imaging; however, when imaging is deemed necessary, it frequently reveals clinically significant findings (e.g., a fracture) that lead to appropriate changes in patient management.32,50-56
  4. Strong Interprofessional Concordance: Interprofessional diagnostic imaging concordance studies demonstrate that PTs’ clinical decision-making aligns closely with that of physicians. 29,30,32,53,57-63
  5. Reduced Health Care Costs: Consistent and growing evidence demonstrates that integrating PTs into team-based care models—particularly in EDs, orthopaedic triage, and primary care—reduces overall health care costs. 32-38,44,48,64-69
  6. Increased Physician Capacity and Decreased Waitlists: There is consistent evidence that shows that PTs in advanced practice roles manage the majority of their cases independently.56,70-72,82 and increase access to care by decreasing waitlists and increasing physician capacity.32,33,39,42,48,67,68,72-87
  7. Lack of Professional Competency Standardization: Despite the growing integration of diagnostic imaging into PT practice, there remains no clear standardization of training or competency assessment across educational and professional settings.88-92
  8. Advanced Training Improves Competence: Evidence consistently shows that advanced training significantly improves PTs’ diagnostic and management competencies.60,93-96
  9. Existing Regulatory Frameworks: Although professional competencies in diagnostic imaging for PTs are not standardized, the literature outlines some diagnostic imaging competencies88 and frameworks.97
  10. Key Safeguards for Implementation: Key safeguards have been identified to support the safe and evidence-based integration of diagnostic imaging into PT practice: a) interpretation of results, b) responsibility of results, c) medical imaging catastrophizing, d) unregulated use, e) radiation exposure, and f) patient responses to medical imaging.
  11. Team-based Models of Care: Evidence, Interest-holder Support & Future Directions: There is a consistent and growing body of evidence that both patients and health care professionals report favorable experiences when PTs are integrated into team-based models of care across various clinical settings, including when PTs can order diagnostic imaging. High patient satisfaction has been reported in multiple studies, particularly in musculoskeletal care,29,32,38,42,48,56,59,68,98-104 rheumatology79 and women’s health.80 Health care staff, physicians, and system stakeholders consistently report high satisfaction, strong appreciation, confidence in clinical competence, and significant system benefits when PTs are integrated into team-based care models.72,100,101,105-107

Regionally, there is physician support from the BC Children’s Hospital Orthopaedic clinic and the Brenda and David McLean Integrated Spine Clinic for PTs with advanced training to order diagnostic imaging.

The University of British Columbia’s Department of Physical Therapy has confirmed its commitment to designing and implementing post-graduate diagnostic imaging training.

The College of Health and Care Professionals of British Columbia has confirmed its preparedness to regulate this activity once the legislation is amended.

Table 4. PABC Member Front-Line Experience: A Motor-Vehicle Accident with No Primary Care Provider

Section Content
Situation A 62-year-old man presented one day after a motor-vehicle collision with thumb swelling and severe mid-back pain. He did not have a primary care provider and was unable to access urgent care, so he sought PT directly.
Action The PT identified probable fractures and advised urgent imaging but could only recommend—not requisition—it.
Impact Diagnostic delay and uncertainty increased patient stress and ED use.
Lesson Allowing PTs to order imaging would streamline post-trauma care, reduce unnecessary ED visits, and improve coordination between clinicians.
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Extracted from: 2026 03 17 Council Meeting - Agenda - Pdf(160 pages total)