Employee Job Scope at a Physiotherapy Practice - Why Verbal Arrangements Backfire

During a routine sanitary inspection at a physiotherapy practice, the inspector asked a seemingly simple question: who is responsible for disinfecting the treatment table between patients? The practice owner answered without hesitation -- of course the physiotherapists, everyone knows that. The problem was that no document confirmed it. In the inspection report, the inspector noted that the sanitary procedure had no assigned person responsible for it, which formally means a systemic gap on the owner's side, not an individual employee's oversight.

The same mechanism repeats itself in patient claims and employment disputes. When a misunderstanding arises -- a patient complains about not being asked for consent before a procedure, medical records aren't kept up to date, and two employees blame each other -- the lawyer's or inspector's first question is: who was supposed to do this according to the arrangements? If the only answer is "that's how it's always been done" or "I told her that when I hired her," the practice is in a very weak position. In this article we show how a job scope differs from an employment contract, what's worth writing into one at a physiotherapy practice, and how to differentiate it by position.

Job scope vs. employment contract -- what goes where

Many practice owners assume that since the employment contract lists a position -- "physiotherapist" or "receptionist" -- the duties are already defined by that alone. That's a mistaken assumption, born of confusing two different documents with different legal functions.

Under Polish labor law, an employment contract must specify the type of work -- that is, the general category of tasks the employee will perform. That's enough for the contract to be valid, but far from enough to resolve a dispute about a specific action taken (or not taken) on a given day. "Type of work: physiotherapist" says nothing about whether keeping medical records up to date is part of the job, or whether reception handles it separately, nor who is responsible for disinfecting equipment between patients.

A job scope is a separate document -- it can be an attachment to the employment contract or a separate document handed to the employee with acknowledgment of receipt -- that describes in detail the specific tasks, procedures, and responsibilities assigned to a given position. Polish labor law doesn't explicitly require such a document to be drawn up in writing for every position, but the employer is required to familiarize the employee with their job scope before they start work. Writing it down as a document, rather than just an oral introduction, is the only way to be able to prove it later. We cover employment and the required qualifications more broadly in the article hiring a physiotherapist -- contract and qualifications.

Feature	Employment contract	Job scope
Level of detail	General (type of work)	Detailed (specific tasks)
Form	Written, mandatory	Recommended in writing, can be an attachment
Changing content	Requires an amendment or notice of change	Can be updated more flexibly, with acknowledgment
Function in a dispute	Confirms the existence of employment and the position	Determines who was supposed to perform a specific task
Recipient	Employee + Social Insurance Institution/Labor Inspectorate as basis of employment	Mainly the employee, evidence in case of inspection or dispute

Duties specific to a physiotherapy practice worth writing down

Generic job descriptions found online rarely account for the specifics of the medical industry. A physiotherapy practice has several areas where it's worth clearly assigning responsibility to a specific position, instead of leaving it in the realm of "everyone knows who does that."

Keeping medical records up to date

Regulations on medical documentation require it to be kept accurately and on time, but they don't specify who at the practice is actually responsible for it in practice -- the employer has to determine that. It's worth stating explicitly that the patient's chart is updated immediately after the treatment, not in a batch at the end of the day or week, because delays in documentation are precisely what tends to surface during an inspection or a dispute with a patient.

Following sanitary procedures

Disinfecting the treatment table and equipment between patients is one of the most common gaps found during sanitary inspections -- not because no one does it, but because there's no clearly assigned responsibility and no record is kept of it. A physiotherapist's job scope should explicitly identify this duty as part of every visit, not as a separate, "extra" task.

Protecting personal data under a GDPR authorization

Every employee with access to patient data should have a separate authorization to process personal data, and the job scope should reference that document and specify what data the access covers (e.g. only the data necessary to schedule an appointment, as opposed to the full medical record accessible to the physiotherapist).

Reporting adverse events

Situations such as a patient's reaction to a treatment, a fall at the practice, or equipment malfunction require a clear reporting path -- to whom, in what form, and within what timeframe. Without such a procedure in the job scope, everyone will improvise if a real incident occurs, and it's exactly that improvisation that hurts the practice most during any subsequent investigation.

[SP] Example -- Solo practice: Katarzyna runs her practice on her own and employs a part-time receptionist. Instead of a generic description like "reception duties," she writes out a specific scope: scheduling appointments in the system, taking payments, handing the GDPR consent form to new patients before their first visit, and a prohibition on sharing medical records with third parties without her approval.

[GR] Example -- Group practice: At a practice employing four physiotherapists, the owner prepares two versions of the job scope -- one for reception staff, one for physiotherapists -- plus a disinfection procedure with a signature confirming that each employee individually acknowledged it, to avoid a "I thought someone else was doing it" situation.

How a job scope protects the employer in a dispute or inspection

Back to the question about disinfecting the treatment table. If the practice had a written job scope, signed by the employee, clearly stating that disinfecting equipment between patients is the responsibility of the physiotherapist performing the treatment, the inspection would have gone very differently. The inspector could then have found an individual oversight by a specific person, rather than a systemic organizational gap that falls on the practice owner -- and that's a fundamental difference in terms of liability and any post-inspection recommendations.

The same logic applies to a patient claim. If a patient claims they weren't informed of contraindications before a treatment, and the physiotherapist's job scope explicitly states the duty to obtain informed consent before every treatment, the employer has grounds to demonstrate that the procedure existed at the practice -- any failure to follow it is a matter of individual employee action, not a lack of a system. Without such a document, it's hard to distinguish employee fault from organizational fault on the employer's part, and it's the latter that's far harder to defend against the National Labor Inspectorate or in labor court.

It's also worth remembering that a written job scope works both ways. It protects the employer, but it also clearly communicates to the employee the boundaries of their responsibility -- which can be helpful in disputes about whether a given task was even part of their job, especially when the form of employment is something other than a standard employment contract. We cover the differences between employment contracts and contract-based cooperation (B2B), and their impact on job scope, in the article physiotherapist -- contract or employment.

Different versions of the job scope depending on the position

A single universal job scope template for the whole practice is a mistake that, in practice, resolves nothing -- because it doesn't answer the question of who is specifically responsible for what. A job scope should be prepared separately for each role at the practice, reflecting the real division of labor.

Receptionist's job scope

For the reception position, it's worth including: assisting patients at check-in and during the visit, scheduling and confirming appointments, taking payments, protecting personal data within the scope of registration (without access to full medical records, unless necessary), handing GDPR documents to new patients, and the procedure for handling a patient complaint.

Physiotherapist's job scope

For the physiotherapist position, key elements include: keeping medical records up to date after every treatment, following treatment and sanitary procedures appropriate to the given type of therapy, obtaining the patient's informed consent before treatment, complying with data protection rules under their authorization, and the duty to report adverse events to a supervisor.

This distinction is also directly relevant at the onboarding stage -- the job scope is worth handing over on day one, together with the other onboarding documents, not only once a problem arises. We've put together a complete list of documents needed when onboarding a new employee in the article onboarding at a physiotherapy practice -- documents.

Frequently asked questions

Does the job scope have to be a separate document, or is a note in the employment contract enough?

It can be an attachment to the employment contract or a separate document handed to the employee with acknowledgment of receipt -- the form isn't strictly dictated by regulations. What matters is that it's detailed enough to resolve specific disputed situations, which the employment contract alone, with its general "type of work," doesn't provide. It's also key to have the employee confirm they've read it -- ideally with a signature and date.

Can the job scope be changed without an amendment to the employment contract?

Yes, as long as the change doesn't go beyond the type of work defined in the contract -- meaning it doesn't materially change the nature of the position. Refining or expanding specific tasks within the same type of work usually doesn't require an amendment, but every update should still be given to the employee in writing with confirmation of acknowledgment.

Does a receptionist's job scope need to mention GDPR?

Yes, if the receptionist has any access to patients' personal data -- and in practice they almost always do, if only when scheduling an appointment. The job scope should specify what data they have access to and reference a separate authorization to process personal data, which the receptionist should sign individually.

What if an employee refuses to sign the job scope?

Being informed of one's job scope is part of being cleared to start work, not an extra perk open to negotiation. In practice, it's worth handing over the document in writing and asking for written acknowledgment -- if the employee refuses to sign, it's worth documenting the fact that the document was handed over (e.g. in front of a witness) and considering legal consultation, especially if the refusal concerns duties critical to patient safety.

CTA: Organizing your practice's HR documentation and not sure where to start beyond the job scope? The PREMIUM package includes complete HACCP/GMP/GHP and GDPR documentation for your physiotherapy practice, which you can use as a foundation for building consistent internal procedures. See FizjoReady packages →

Related articles:
- Hiring a physiotherapist -- contract and qualifications
- Physiotherapist -- contract or employment
- Onboarding at a physiotherapy practice -- documents