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Notice on Point Injection Therapy (PIT)

December 4, 2020

This notice addresses the issue of whether point injection therapy (“PIT”) and related injection therapies fall within the scope of practice of CTCMA registrants.


In 2008, the Board established a PIT Task Force to study the alignment of PIT within the provisions of the Health Professions Act (the “Act”). The Board concluded at that time that PIT practices were not authorized by the Traditional Chinese Medicine Practitioners and Acupuncturists Regulation (the “Regulation”) and, in fact, appeared to be restricted activities under the Act.

On September 12, 2009, the College Board passed the following resolution that was released to College registrants:

That the ‘Restricted activities’ as listed in the Traditional Chinese Medicine Practitioners and Acupuncturists Regulation does not currently include intra-articular injection including synovial fluid replacement therapy/prolotherapy; mesotherapy/injection lipolysis; or intravenous therapy including intravenous injection, infusion; or nerve blocks of any type. A CTCMA registrant may practice such procedures only if the registrant holds current dual registration with a second College whose Regulations do include such ‘Restricted activities’.

Not long after this resolution, the Board authorized the work necessary to propose amendments to the Regulation. The Board’s resolution stated:

That CTCMA seek a new regulation with respect to restricted activities and/or amendments to ss. 1 and 4-6 of the [Regulation] pursuant to section 55(1) of the [Act] with respect to restricted activities and changes to the Schedules.

In July 2015, the College proposed an amendment to the Regulation, noting that the gap between the current scope of practice and the legal authorization for restricted activities under the Act was an urgent matter with respect to protecting the public interest. The primary goal of the Regulation Amendment Proposal was to ensure that the College continues to be able to effectively regulate TCM practitioners with respect to public protection. The College proposed the expansion of TCM restricted activities that would allow registrants to administer, among other things, “a substance by injection for the purposes of traditional Chinese medicine therapy, including Point Injection Therapy”.

The proposal submitted by the College has been filed with the Ministry of Health for consideration.

The College’s Position on PIT

Given the fact that amendments to the Regulations have not yet been madethe College Board reaffirmed the position that PIT and other injectable therapies are not included in the scope of practice of College registrants and that these treatments are therefore unauthorized by the current Regulations.

Without such an amendment, administering injectables is not within scope of practice for traditional Chinese medicine practitioners and acupuncturists in British Columbia. As such, the College must enforce the scope of practice set out by the Minister of Health under sections 1 and 4 of the Regulation.

An acupuncturist may practise acupuncture, including:

a) the use of traditional Chinese medicine diagnostic techniques, and

b) the recommendation of dietary guidelines or therapeutic exercise.

“acupuncture” means an act of stimulation, by means of needles, of specific sites on the skin, mucous membranes or subcutaneous tissues of the human body to promote, maintain, restore or improve health, to prevent a disorder, imbalance or disease or to alleviate pain and includes:

a) the administration of manual, mechanical, thermal and electrical stimulation of acupuncture needles,

b) the use of laser acupuncture, magnetic therapy or acupressure, and

c) moxibustion (Jiu) and suction cup (Ba Guan);

A traditional Chinese medicine practitioner may practise traditional Chinese medicine.

“traditional Chinese medicine” means the promotion, maintenance and restoration of health and prevention of a disorder, imbalance or disease based on traditional Chinese medicine theory by utilization of the primary therapies of

a) Chinese acupuncture (Zhen), moxibustion (Jiu) and suction cup (Ba Guan),

b) Chinese manipulative therapy (Tui Na),

c) Chinese energy control therapy (Qi Gong),

d) Chinese rehabilitation exercises such as Chinese shadow boxing (Tai Ji Quan), and

e) prescribing, compounding or dispensing Chinese herbal formulae (Zhong Yao Chu Fang) and Chinese food cure recipes (Shi Liao);