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COVID Alert Level 3


(non-DHB settings)

UPDATE as at 15 October 2021


In recent weeks we have received many enquiries from physiotherapists asking what services they can provide under changing COVID-19 Alert Levels. Until now our advice has been to follow the Ministry of Health guidance.

The Ministry of Health rules regarding the provision of health services (including physiotherapy) are set out in Alert Level Requirements orders made by Minister for COVID-19 Response.

Mandatory requirements

Regulatory requirements

Current Alert Level requirements are set out in an Order that commenced on 21 September 2021. The  Order specifies mandatory legal requirements for individuals, businesses, and services at various alert levels. Requirements for business and services include matters such as the number of customers and clients allowed in a workplace, physical distancing rules, and contact record rules.

Importantly, apart from a few specific exceptions, nothing in the current Order applies to health services (including physiotherapy). In other words, the Order enables physiotherapists to provide health services to the public provided they comply with those exceptions.

In summary, the exceptions require physiotherapists to take the following actions:

Under all Alert Levels

Under Alert Levels 2 and 3

The person in control of a workplace of any health service must have systems and processes in place to ensure, so far as is reasonably practicable, that each person aged 12 years or older who enters the workplace—

  1. scans the QR code for the workplace or otherwise makes their own contact record; or
  2. provides a contact record that the person in control of the workplace collects

but only in relation to people other than workers of the health service.

Every person who is not a patient or worker of the health service must wear a face covering on the premises of the health service.

Ethical and other legal requirements
When deciding whether to provide face-to-face services where COVID-19 alert levels apply physiotherapists must consider their ethical obligations to patients. This includes ethical principle 2.1, which states that physiotherapists must consider the health and wellbeing of the patient to be their first priority.

This principle requires the physiotherapist to apply their clinical judgment to balance the treatment needs of the patient against the need to take appropriate steps to keep the patient, and others who may be in the workplace, safe from the risk of infection.

Always conduct a suitable risk assessment and take appropriate measures to mitigate identified risks having regard to:

  • the nature of the presentation,
  • the health condition and vulnerability of the patient and others present,
  • alternative treatment options
  • implementation of hygiene measures such as hand sanitation, mask wearing, and ventilation.

The risk assessment, measures taken, and clinical reasoning for decisions made should be documented in each case.

Physiotherapists who are persons conducting a business or undertaking (PCBU) for the purposes of health and safety legislation should also consider their obligations to ensure, so far as is reasonably practicable, the health and safety of their workers and others who could be put at risk by the work of the business, for example customers, visitors, children and young people, or the general public.

Guidance (non-mandatory)

The Physiotherapy Board, Physiotherapy New Zealand and other Allied Health organisations have been working with the Ministry of Health in an effort to develop a consistent set of guidance for Allied Health. Unfortunately, the Board was unable to reach agreement with the Ministry on guidelines we consider would be suitable for physiotherapists providing services to meet the health and safety needs of the public.  However, physiotherapists may consider the current Ministry guidance and apply it where considered appropriate.

What does this all mean?

The mandatory requirements identified above are the law and must be followed in all cases to which they apply.

There are no restrictions on whom you choose to provide physiotherapy services.  It is your clinical judgement whom you choose to see.

The Ministry of Health guidelines may help inform your clinical decision making.

Future updates

The rules relating to COVID-19 Alert Levels are not made by the Board and are constantly changing. Therefore, we should all expect further changes to be made to the rules as the COVID-19 pandemic continues to progress. We will try to keep you informed if changes are made to the current order.


This document provides a brief summary of the current rules as we understand them. You should refer to the Order at the link provided above and consult the Ministry of Health for more detailed information. Please note that the advice we provide is general in nature and is not a substitute for legal advice. You should seek advice from a lawyer should you wish to understand how the rules apply to your specific circumstances.



Advice: Seeing patients Alert Level 3 – Step 1 (non-DHB setting)

Last updated 15/10/21

Physiotherapists use their clinical judgement and reasoning when considering seeing a patient face-to-face for a consultation.

Advice for face-to-face contact appointments

  1. Risk Assessment and Screening

Screen and risk assess patients and any support persons (if required) for risk of COVID-19 prior to face-to-face consultations. Patients should be screened when booking the appointment and then re-screened when they arrive at the clinic, or you arrive at their place of residence.

PDF version here.

When making an appointment for a face-to-face consultation, advise patients if they do develop symptoms between booking and attending their consultation, they must call to cancel the face-to-face consultation and seek medical advice.
Document in the patient clinical record the clinical decision on whether to see a patient face to face or otherwise.

  1. Pre preparation

  • Physiotherapist and practice staff/contractors are encouraged to be fully vaccinated (note: mandatory vaccination Order yet to be finalised by Parliament)
  • have knowledge of current Health and Safety procedures and guidance from Ministry of Health including ‘advice for all health professionals’ and the Board’s Serious Event Standard
  • have a plan in place for your premises e.g., identifying which door patients will enter and leave from
  • select PPE as recommended by Ministry of Health, source PPE and retrain staff on its use, including donning, removing and disposing of PPE
  • have cleaning materials and PPE sourced and in stock at the clinic
  • cleaning plan developed and implemented
  • all physiotherapists and support staff retrained in new clinic procedures and all procedures provided to them
  • ensuring meeting the physical distancing requirements
  • set up a register of all people who have been in the clinic/service with current contact details confirmed such as staff members, delivery/pick up personnel and cleaning staff, in case contact tracing is later required.
  1. Preparation

  • patient and required support person and those in their bubble whānau screened for COVID-19 signs or symptoms by phone or telehealth prior to offering a consultation in the clinic. See flowchart here
  • when making the appointment give clear instructions to patients regarding where to come, what to expect when they arrive, and how things differ from their usual visits
  • you must have and use a QR code for your place of work
  • ensure appropriate PPE is in place ready to be used (all staff to be retrained as above)
  • have one physiotherapist using one room per shift
  • limit points of entry to the clinic – preferably patients can enter one door and leave from another
  • all unnecessary items should be removed from the waiting room and surfaces kept clear and clean, including excessive furniture, waste bins, water coolers etc.
  • areas of known contamination should be cleaned and disinfected
  • make it clear at the entrances that no walk-in appointments off the street are available.
  1. During visit

  • patient and if required support person and bubble whānau again screened for any COVID-19 signs or symptoms prior to entering the clinic or place of residence
  • if visiting a patient at place of residence scan in using the QR code or record your visit details within your management system
  • require patient, and others, to scan QR code and hand sanitise on arrival and sanitise on departure from the clinic
  • physiotherapists fill out any paperwork and forms for the patient (sign with cleaned pen) – if possible, use contactless methods
  • if possible, allow only the patient to be present for the consultation
  • confirm contact details for the patient and each person accompanying the patient and inform them that these details may be used for contact tracing, if required
  • maintain physical distancing where possible, for instance, during the subjective examination
  • follow PPE protocol as advised by the Ministry of Health
  • minimise close contact time
  • follow all hand and hygiene practices
  • keep doors and windows open, ventilation systems on (to the clinic, treatment doors if possible)
  • close the clinic toilet to patients, and advise patients when making the appointment
  • minimise the use of equipment such as pillows for instance, which are not easy to clean or replace. Alternatively use single use coverings for the pillows and plinths such as towels or paper towels.
  1. Post Visit

  • clean all equipment, pillows and plinths after each patient contact
  • clean keyboard, mouse and computer screens after each patient contact
  • carry out correct steps for safe removal and disposal of PPE
  • follow cleaning protocol – wiping down all hard surfaces with detergent and hot water and then use a disinfectant
  • appropriate PPE should be worn for cleaning the room
  • PPE and waste should be disposed in a closed clinical waste bin and in accordance with clinical waste requirements
  • Ventilate room.
  1. End of shift

  • physiotherapist showers, changes clothes and shoes at workplace
  • alternatively, the Physiotherapist showers at home, cleans the shower before contacting anyone in their home bubble whānau and hot washes their clothes and towels etc.
  • physiotherapist leaves clinic through different doors if possible (the clean side of clinic)
  • ensure door handles, keys and high touch surfaces are cleaned before leaving.

Further resources