DC FAQs
By WSCA Staff
There’s a modality that I’ve seen offered by non-licensee staff at spas and other non-healthcare facilities. The modality is not within the chiropractic scope of practice. Can I have my non- licensee staff use the modality in my stead?
No. You cannot delegate any services that are not within your scope. WAC 246-808-535 spells out exactly what services you can delegate to your non-licensee staff. That WAC divides those staff into three categories: clinical postgraduate trainees, regular senior students, and auxiliary staff. Clinical postgraduate trainees are DCs who are not licensed. Regular senior students are chiropractic students in the final term (quarter or semester) of their degree program. Auxiliary staff are everyone else in the clinic who does not have a healthcare provider license. Although each category has different services they can provide, all of those services are within the chiropractic scope.
It doesn’t matter that laypeople in other businesses offer those services. Those businesses are not regulated healthcare facilities, and so they are not subject to the same restrictions you are. By choosing to practice a discipline that requires a license, you agreed to be bound by the limits of your professional scope. And everything that your staff does in your clinic is an extension of you doing it yourself; thus, they cannot do anything you are prohibited from doing.
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Now, if you’re in a multidisciplinary clinic, your staff may be able to provide those services, but it will depend on what other types of providers practice there and what they’re allowed to delegate. Let’s say you own a clinic along with with a PT. The PT may be able to provide those services within their scope, and it may be that they can delegate those services too. That would depend on the PT scope of practice; but for the sake of argument, let’s say that they can. In that instance, your staff could provide the service, but it wouldn’t be you delegating it to them—it would have to be the PT.
Likewise, if you employ a licensed healthcare provider whose scope includes those modalities, they can provide the service; but again, it wouldn’t be you delegating the task—it would be the employee practicing under their own license and within their own scope. In other words, even though laypeople can provide a service in a non-healthcare setting, they cannot do so within a healthcare setting whether they do it on their own or at your direction.
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