Home-visit physiotherapy - documentation and requirements
Ms Katarzyna runs a physiotherapy practice in Kraków, but half her patients are seniors recovering from strokes and hip surgery who can't make it to the practice.
Ms Katarzyna runs a physiotherapy practice in Kraków, but half her patients are seniors recovering from strokes and hip surgery who can't make it to the practice. So she started travelling to their homes instead. Before heading out into the field, she asked herself: "Is a home visit still the same activity I registered? How do I keep records if I don't have my filing cabinet with me?"
This is a very common question. Home-visit physiotherapy is fully legal, but it's governed by a few extra rules. In this article you'll go through everything you need to know: registration, documentation, GDPR on the road, insurance, and billing.
What home-visit physiotherapy means under the law
A home visit is a health service provided at the patient's place of residence instead of at the practice. From the perspective of the Act on Medical Activity (Journal of Laws 2011, No. 112, item 654), you're still performing medical activity -- only the place where you provide it changes.
The key consequence: home-visit physiotherapy isn't a separate form of business. It's an extension of your existing professional practice or medical entity. You don't need to set up a new company, but you do need to correctly describe the place of service provision in the register.
RPWDL registration and home visits
If you're registered in RPWDL (the Register of Entities Performing Medical Activity), you need to make sure the place of service provision is entered correctly.
In practice there are two situations:
- You have a practice + home visits - in RPWDL you enter the practice address as the main location, and report home visits as services provided at the patient's requested location.
- You work exclusively on the move (no practice) - as your place of business you enter the address where you store your documentation and equipment, and where you can be reached (often a home or office address).
| Element | Stationary practice | Home-visit physiotherapy |
|---|---|---|
| RPWDL entry | Practice address | Base address + services at requested location |
| Premises requirements | Full (Sanepid) | Apply to the base, not the patient's home |
| OC insurance | Mandatory | Mandatory, check territorial scope |
| Documentation | Kept at the practice | Kept in the field + archived at the base |
Premises requirements - does a patient's home have to comply?
This is one of the biggest misunderstandings. A patient's home is not subject to Sanepid's sanitary-premises requirements. Responsibility for premises conditions applies to your base - the place where you store equipment, documentation, and prepare for visits.
That doesn't mean you can work under any conditions, though. In a patient's home you must ensure:
- Hand hygiene (disinfectant, disposable gloves)
- Cleanliness of portable equipment (disinfected after every visit)
- A safe treatment setup (a stable surface, no fall risk)
- Proper handling of medical waste, if any is generated
Medical records for home visits
The obligation to keep medical records is identical to a stationary practice - it stems from Article 24 of the Act on Patient Rights and the Patient Rights Ombudsman and the Ministry of Health regulation on medical documentation. A home visit exempts you from nothing.
Every home-visit record should contain:
- The patient's identification details (name, PESEL, address)
- The place where the service was provided (the home-visit address) - important, since it differs from the practice address
- The date and time of the visit
- A description of the patient's condition, treatments performed, and their parameters
- The therapy plan and recommendations
- The patient's or guardian's signature (for consents)
How to keep records in the field
You have two practical options:
- Digital records - an app on a tablet or phone, data synced to the cloud (remember the data processing agreement and GDPR). Most convenient when you do many visits a day.
- Paper records - you fill in the record on site and archive it at your base afterwards. Requires discipline so nothing gets lost along the way.
[Solo] Example - solo practice: You do 6 visits a day. You carry a tablet with a medical app. After every visit you immediately enter a description of the treatment - you don't leave it for the evening, because details get mixed up. Patients sign consents on screen or on paper, which you then scan.
[Group] Example - group practice: Three physiotherapists from one practice travel out for home visits. Each keeps their own records in the same system, and the practice manager sees all the visits. The archive is centralised at the practice, which makes KIF (Chamber of Physiotherapists) and Sanepid inspections easier.
GDPR in home-visit physiotherapy
Home visits increase GDPR risk, because patient data travels with you. You need to pay particular attention to:
- Encrypting mobile devices - tablet and phone protected by password and disk encryption
- Secure transport of paper documentation - a folder that never gets left in the car or the waiting room
- A data processing agreement with your cloud app provider
- A procedure for a lost device or folder - reporting to UODO (the Personal Data Protection Office) within 72 hours
A lost tablet containing 200 patients' data is a serious-scale data breach - which is why encryption isn't optional.
OC insurance for home visits
Mandatory OC (professional liability) insurance for physiotherapists covers the practice of the profession, but check whether your policy has any territorial restrictions or exclusions for services provided outside a practice. Some policies limit coverage to a specific address. Inform your insurer that you work on the move and request written confirmation.
It's also worth considering insurance for your portable equipment (theft from a car) - that's property insurance, not professional OC.
Billing and cash registers
If you accept cash payments in a patient's home, the same fiscal cash register rules apply as at the practice. A physiotherapist can use the exemption up to 20,000 PLN in annual turnover from sales to private individuals, and the exemption for services paid entirely by bank transfer or BLIK (Poland's instant mobile payment system) to a bank account, with clear record-keeping. If you accept cash and exceed the limit, a practical solution for home visits is a portable online cash register - a register in app form is not permitted for physiotherapy. The simplest route, though, is accepting bank transfers/BLIK instead of cash, which simplifies documentation and lets you use the exemption.
Frequently asked questions
Do I need to set up a separate business for home visits?
No. Home-visit physiotherapy is an extension of your existing practice or medical entity. You only need to correctly describe the place of service provision in RPWDL - you don't set up a new company or a new register entry.
Does a patient's home have to meet Sanepid requirements?
No. Sanitary-premises requirements apply to your base (where you store equipment and documentation), not to the patient's private home. In the field you're responsible for hand hygiene, clean portable equipment, and treatment safety.
How do I store documentation from home visits?
For the same length of time as at the practice - medical records are, as a rule, kept for 20 years from the last entry. Records filled in the field are archived at your base, on paper or digitally. It's important that the treatment description is written up on the spot, not from memory in the evening.
Do I need consent for a home visit?
The standard patient consent to treatment is sufficient, but it's worth noting in the record that the service is being provided at the patient's home at their request. For patients who are legally incapacitated or minors, a legal guardian signs the consent.
CTA: Want ready-made home-visit documentation templates, GDPR clauses for mobile work, and a procedure for a lost-data scenario? The STANDARD package includes a full set of documents adapted to physiotherapy - ready to print and sign. See FizjoReady packages →
Related articles:
- RPWDL registration for physiotherapists - step by step
- GDPR in a physiotherapy practice - a practical guide
- OC insurance for physiotherapists - what you need to know