Whew! Ran to mail my taxes to the IRS, so now I have time to catch up on a much more urgent civic duty - the massage regulations in WA State. COMMENTS ARE DUE BY 5PM ON APRIL 20TH. Please! Make your voice heard. Links to comment are included below
In reviewing the comments already posted, there is significant out cry from the event massage community. It seems there needs to be a more significant exception for recordkeeping at public events. I don't see how it is possible to secure these records according to HIPAA standards while running from client to client. A brief sign-in form with name, email, check boxes and a signature might fit the bill. But it would have to include room for the therapists' notes on what they did and where they did it, their printed name and their signature, date and time spent. Lots of time, loads of paper.
And then what does one do with this pile of forms? Who maintains them? If a person is receiving a massage in a public arena, there should be different standards for privacy requirements. One commenter questioned how to handle clients at the airport who do not speak or read English. This arena deserves to be better addressed for all of these issues.
In addition, I am completely opposed to the additional recordkeeping requirements in section (J) regarding massage for "treating a health condition". It is WAY overbearing! I request the change from “IS REQUIRED” to “MAY BE INCLUDED”.
Further, The opening section stating “…Documentation should be appropriate to the venue, the type and complexity of those services, and in sufficient detail to support and enable anticipated continuity of care.” is sufficient to indicate the intent of the Board, without creating a situation where therapists can be nit-picked or inappropriately brought up on sanctions by malignant clients who, for example, do not get the insurance benefits they were seeking and want someone to suffer for it.
There are FOUR sections that I am commenting on. You can scroll down to see the copy of the text I am sending to the Board of Massage. You will also find a copy of the full text of WAC Chapter 246-830 on the Massage Regulations page so you can download it for yourself.
If you would like to see what comments other citizens are making, please go to the Rules Comments page at https://fortress.wa.gov/doh/policyreview/ . The "Massage Practitioners" link (soon to be "Massage Therapists") is the 7th one down. This is also where you can post your comments (click on "Add Comment"). If you scroll down, you can copy and personalize any of my comments. It is best to make separate posts for each comment. Please read some of the great comments already posted! They are posted confidentially without your name or contact information attached.
I'm so grateful for the technology that allows us to fully participate in this government process and protect our rights to access safe massage therapy.
The only change I am asking for the breast massage section is that they amend "written AND VERBAL consent..." to the procedures. Many clients sign documents without reading them, so this is an important step in the process of professional communication.
I'm asking for significant changes regarding perineal massage being delineated in our scope of practice. Due diligence has not been performed in this arena. It was asked that perineal massage be added with substantively the same requirements as breast massage. However, this is not what has happened. Perineal massage has not been clearly incorporated into WAC 246-830 as it has for breast massage. I am advocating perineal massage have its own section, similar to breast massage so there is no question about its legitimacy. For example, there needs to be a subsection requiring gloves, similar to the intraoral section.
And in the draping section, there needs to be mention of temporarily undraping around the perineum with written consent. This is an extraordinarily delicate area, but if the the aestheticians can manage bikini waxes in a professional manner, I'm sure it can be done. Now that this treatment will be properly regulated, I plan on adding pelvic massage training to my repertoire.
Here is a link to a powerpoint lecture on BreastRemedySeattle.com, which I gave in Wenatchee this month on the current updates and my position on them, with some ethical considerations around breast massage thrown into the mix.
Follow the instructions below and enjoy the democracy!
- Please go to: https://fortress.wa.gov/doh/policyreview/
- Click on "Add Comment" next to Chapter 246-830 WAC Massage Practitioners
- Please make separate comments for separate issues.
I am NOT fully in support of the recordkeeping section in that I do not find it necessary for there to be separate requirements for “massage therapy where the focus is on treating a health condition…” [section 1 (j)]. I request changing the verbiage in this section from “IS REQUIRED” to instead be “MAY BE INCLUDED”.
These additional requirements are onerous and may not apply to every massage every time. In addition, every massage could be considered to be for a “health condition” in that all massage has been defined as being therapeutic by its inclusion in the licensing through the Department of Health. Massage therapists should be treated as health care practitioners and be allowed to make professional decisions as to what needs to be in a chart note and what does not. This will also allow therapists some latitude in discerning what might be confidential information that clients wish withheld from their charts.
RE: Recordkeeping for Event Massage
I am NOT fully in support of the recordkeeping section in that it is unnecessary to put HIPAA requirements on documentation for a service that is performed in a public venue. This puts an onerous burden on the massage therapists while offering limited, in any, protection for the public. I am in favor of a much reduced requirement for documentation, including a delineation for clients to choose to be treated anonymously.
RE: Breast Massage
I am in support of the breast massage section and I am grateful that the Board has seen fit to treat this section with such diligence. However, I feel that adding in section (1)(a) to require written AND VERBAL consent is necessary. Many clients do not read intake forms and policy pages and may not sufficient reading comprehension to understand these written forms. Written and verbal consent needs to be made standard procedure to keep this valuable treatment safe for clients.
RE: Perineal Massage
I am in support of including perineal massage in the scope of practice for licensed massage therapists. However, this treatment would benefit from being delineated in a separate section, similar to the Breast Massage section, with the same requirements, such as being able to have a witness present, and being able to discontinue treatment at any time, etc.
I propose adding a separate section after the Breast Massage section with most of the same requirements. In addition, in the draping section, there needs to be acknowledgement that the perineal area may need to be temporarily undraped for treatment with written and verbal consent.