Are we facing a total paralysis of inpatient rehabilitation? All because of...

The KIF strongly opposes the imposition of an obligation on physiotherapists to use the FSR application, which the NFZ president intends to introduce by order. As the NIF stresses, the implementation of the application, not preceded by any consultation with the professional self-government of physiotherapists, will result in a complete paralysis of inpatient, outpatient, home rehabilitation and day care centers. The National Council of Physiotherapists has taken a critical stance on the NHF's idea. The chamber has submitted comments on specific points of the order and has asked the Minister of Health to intervene.

The draft Order of the President of the National Health Fund dated December 29, 2023, on defining the terms and conditions for concluding and implementing contracts in the types of inpatient rehabilitation and health programs for the treatment of children and adults with coma, which includes provisions on the FSR application, would take effect as early as April 1. A comment period was set until January 19. No consultations were held before then.

- What does the app do? It boils down to the time-consuming collection of data unrelated to the health problem a patient presents to a physiotherapist with. It would only be the responsibility of physiotherapists, and would not apply to any other medical profession. The very scope of data collection is not relevant to physiotherapy services, physiotherapy interventions, so "pushing" this obligation on physiotherapists is absurd. The National Health Service has provided for this only for one independent medical profession - the profession of physiotherapist. We can't agree to something like this, the data is not needed by physiotherapists, we are not there to bail out the system," said KRF President Dr. Tomasz Dybek.

As KIF points out, according to legal analyses, the completion of data in the application by physiotherapists would be incompatible with the Law on the Physiotherapy Profession Article 4 - the assessment of psychological, nursing functions is not within the competence of a physiotherapist, the questions defined in the FSR application are beyond the scope defined in the Law on the Physiotherapy Profession. The aspect of producing medical records in the context of the binding law conflicts with this law. The comments flagged the issue of conflict with the planned regulations of the Ministry of Health.

It should be added that filling out the data in the application will not translate into improved patient situation, better care for the patient, and on the contrary, will end up limiting accessibility to a physical therapist. The proposed application will in no way introduce better quality and increase the safety of patient treatment, since the ICF is a tool (as mentioned in the justification for the draft order) for collecting data on functional status. Clearly, the broad scope of non-physiotherapy-related data collection juxtaposed with the imposition of data entry on the physiotherapist for physiotherapy itself will be something detrimental - it will be at the expense of time for patients. Bureaucracy will push the patient into the background.

In addition, the KIF's assessment does not take into account securing facilities with equipment to use the app.

Imposed, without consultation and dialogue, the application does not allow any modification and imposes a rigid framework of interviewing in advance, without justification based on clinical diagnosis, which is inconsistent with Article 2 of the Law of September 25, 2015 on the profession of physiotherapist.

According to the National Health Service, there are 776,621 people waiting for physiotherapy and therefore, moving physiotherapists away from providing services will significantly lengthen the queue.

The effect of the analysis of the provisions carried out by the National Council of Physiotherapists, in the form of an official position of the NCF, was sent by NCF President Dr. Tomasz Dybek to National Health Fund President Filip Nowak. The National Health Fund president received specific comments on specific provisions of the order. The KRF president sent a letter requesting a response to Health Minister Izabela Leszczyny, enclosing the council's position and comments.

Source: KIF