GFA Must Verify Foreign Physiotherapists’ Licenses: AHPC’s Directive on Carlos Lozano Romero

The Allied Health Professions Council (AHPC) of Ghana has issued a formal caution to the Ghana Football Association (GFA), demanding the verification and proper licensing of all foreign physiotherapists and assistants affiliated with the national football teams. This directive specifically includes Spanish physiotherapist Carlos Lozano Romero, who recently rejoined the Black Stars’ technical team. The AHPC’s action underscores a mandatory, non-negotiable compliance with the Health Professions Act, 2013 (Act 857), which prohibits the practice of allied health professions without official registration and licensing in Ghana. This comprehensive analysis explores the legal framework, the implications for Ghanaian sports, and the clear steps required for full compliance.

Key Points: The AHPC’s Directives to the GFA

The core of the AHPC’s communication, dated February 16, 2026, and addressed to GFA President Prof. Shirazu Issahaku, contains several critical mandates:

• Mandatory Verification: The GFA must submit the overseas credentials and certifications of all physiotherapists and physiotherapy assistants engaged through the association to the AHPC for verification.
• Legal Basis: The Council explicitly cites Section 21(C) of the Health Professions Act, 2013 (Act 857), which makes it a criminal offense for any person to “practise or profess to practise as an allied health professional” without prior registration.
• Specific Inclusion: Mr. Carlos Lozano Romero and any other foreign physiotherapy personnel must be registered with the AHPC and issued a valid license before undertaking any physiotherapy-related duties in Ghana.
• Universal Application: The Registrar, Prof. Issahaku, emphasized that this standard procedure applies equally to all allied health professionals, whether they are local practitioners or foreign experts, and must be respected by all government agencies and sporting bodies to protect public health.

Background: The Regulatory Framework and the Key Figure

The Allied Health Professions Council (AHPC) and Act 857

Established under the Health Professions Act, 2013 (Act 857), the AHPC is the statutory body responsible for the training, registration, licensing, and regulation of all allied health professionals in Ghana. This includes physiotherapists, audiologists, dietitians, medical laboratory scientists, occupational therapists, radiographers, and speech therapists, among others. The primary mandate of the AHPC is to safeguard the health and safety of the Ghanaian public by ensuring that only qualified, competent, and legally registered professionals provide healthcare services. Section 21 of Act 857 is unequivocal: practicing without registration is an offense punishable by law, highlighting the council’s zero-tolerance stance on unlicensed practice.

The Ghana Football Association’s (GFA) Responsibilities

As the governing body for football in Ghana, the GFA has a duty of care to its players, who are high-performance athletes under significant physical stress. The medical and support staff, including physiotherapists, are critical to player welfare, injury rehabilitation, and performance optimization. By engaging both local and foreign technical staff, the GFA implicitly assumes the responsibility to ensure that every member of its technical teams meets Ghana’s legal and professional standards. This caution from the AHPC serves as a direct reminder that sporting federations are not exempt from national health regulations.

Carlos Lozano Romero: Profile of the Black Stars’ Physiotherapist

Carlos Lozano Romero is a Spanish-certified physiotherapist with significant international experience. He was part of the Ghana Black Stars’ backroom staff during the 2022 FIFA World Cup in Qatar. His reappointment in February 2026 ahead of the 2026 FIFA World Cup (co-hosted by the USA, Canada, and Mexico) was aimed at providing continuity and expertise in player recovery, injury prevention, and physical conditioning. He operates under the authority of Head Coach Otto Addo. The Black Stars are drawn in Group L alongside Panama, England, and Croatia, with preparation matches scheduled against Austria and Germany in March 2026. His role is pivotal to Ghana’s ambition to move beyond the group stage, having been eliminated at that phase in both 2014 and 2022.

Analysis: Legal Implications, Risks, and Broader Impact

Legal and Regulatory Consequences for the GFA

Non-compliance with the AHPC’s directive carries severe legal and reputational risks for the Ghana Football Association:

• Criminal Liability: Under Section 21(C) of Act 857, the GFA, as an entity facilitating unlicensed practice, could face prosecution. Penalties include fines and potential imprisonment for responsible officers.
• Vicarious Liability: Should an unlicensed practitioner cause harm to a player through negligence or error, the GFA could be held vicariously liable in a civil lawsuit, with insurance claims potentially being voided.
• Operational Disruption: The AHPC could seek an injunction to prevent Mr. Lozano Romero and other unlicensed foreign practitioners from working with the team, potentially disrupting World Cup preparations and team cohesion.
• Reputational Damage: Being publicly cited for flouting national health regulations damages the GFA’s image as a professionally managed institution, affecting sponsor confidence and public trust.

Implications for Player Welfare and Sports Medicine in Ghana

This incident highlights a systemic issue in Ghanaian sports: the balance between importing foreign expertise and adhering to domestic regulatory standards. The AHPC’s stance reinforces that player safety is paramount and non-negotiable. It sends a clear message that foreign credentials, while valuable, must be validated within the Ghanaian legal context. This move could elevate the overall standard of sports medicine in the country by ensuring all practitioners, regardless of origin, are subject to the same scrutiny and accountability as locally trained professionals.

A Precedent for Other Sporting Bodies

This caution is not solely a GFA matter. It serves as a definitive precedent for all sports federations, clubs, and private sports clinics in Ghana that employ foreign allied health professionals—from physiotherapists and sports physicians to nutritionists and psychologists. The message from the AHPC is that the registration and licensing of foreign healthcare professionals in Ghana is a universal requirement, not a discretionary best practice.

Practical Advice: Steps for Compliance

For the Ghana Football Association (GFA)

1. Immediate Audit: Conduct a comprehensive audit of all foreign physiotherapy and assistant staff currently engaged by any of the GFA’s national teams or affiliated bodies.
2. Document Collection: For each individual, collect complete, notarized copies of their primary physiotherapy qualification, professional certification from their home country, proof of professional experience, and a police clearance report from Ghana (or an equivalent document).
3. Formal Application: Submit these verified documents to the AHPC via their official channels, accompanied by the prescribed application forms and fees as stipulated on the AHPC website.
4. Engage in Dialogue: Proactively communicate with the AHPC Registrar to understand processing timelines and any additional requirements specific to sports practitioners.
5. Implement a Policy: Establish a standing policy that no foreign allied health professional can be contracted or deployed for any duty in Ghana without a confirmed AHPC license or a receipt acknowledging a pending, complete application.

For Foreign Physiotherapists (e.g., Carlos Lozano Romero)

1. Initiate Process Early: Do not wait for an official caution. Upon contract signing or assignment to Ghana, immediately begin the AHPC registration process.
2. Document Preparation: Ensure all academic certificates, professional licenses from the home country (e.g., from the Spanish Physiotherapy Council), and letters of good standing are available in English or with certified translations.
3. Understand the Scope: Be aware that AHPC licensing may require supplemental examinations or assessments to align with Ghanaian clinical standards and practices.
4. Maintain Communication: Keep both the employer (GFA) and the AHPC updated on the status of your application to manage expectations and scheduling.

Frequently Asked Questions (FAQ)

What is the legal penalty for practicing physiotherapy without an AHPC license in Ghana?

According to Section 21 of Act 857, a person convicted of the offense is liable to a fine or to imprisonment for a term not exceeding two years, or to both. The specific fines are determined by the courts.

Can a foreign physiotherapist work temporarily while their AHPC application is processed?

Act 857 does not provide for a provisional or temporary practice permit for unregistered individuals. Practice is only legal after the AHPC has granted registration and issued a license. The GFA must ensure no work is performed until this license is physically issued.

Is the AHPC license a one-time requirement?

No. Registration with the AHPC requires annual renewal. Practitioners must meet continuing professional development (CPD) requirements and pay annual fees to maintain an active license.

Does having a physiotherapy license from another country (e.g., Spain, UK, USA) exempt one from AHPC registration?

No. There is no automatic reciprocity. While foreign qualifications are considered during the verification process, the AHPC has the sole authority to assess equivalency and grant registration. All practitioners must be registered with the AHPC to practice legally in Ghana.

What is the typical timeline for AHPC registration for a foreign-qualified professional?

Timelines vary based on the completeness of the application and the need for credential evaluation. It can range from several weeks to a few months. The GFA and the individual must factor this into their planning to avoid last-minute disruptions.

Does this directive only apply to physiotherapists working for the Black Stars?

No. The AHPC’s caution explicitly refers to “all physiotherapists and physiotherapy assistants who’ve been engaged via the affiliation” of the GFA. This includes staff for the Black Stars, Black Satellites (U-20), Black Starlets (U-17), and any other national teams under the GFA umbrella.

Conclusion

The AHPC’s caution to the GFA is a critical enforcement action rooted in the Health Professions Act, 2013 (Act 857). It is not a mere formality but a legal imperative designed to protect patients—in this case, Ghana’s elite athletes—from unqualified practice. For Carlos Lozano Romero and any other foreign physiotherapist, the path is clear: complete AHPC registration and obtain a physical license before touching a player. For the GFA, the mandate is to act as a compliant employer, rigorously vetting the credentials of its entire technical staff. This situation transcends one high-profile appointment; it is a test of institutional adherence to national law and a commitment to the highest standards of athlete healthcare. Failure to comply not only risks legal sanction but also undermines the very integrity of Ghanaian sports medicine. The prudent and only acceptable course of action is immediate, transparent cooperation with the AHPC to verify all credentials and secure the necessary licenses, ensuring the Black Stars’ World Cup campaign is built on a foundation of both excellence and legality.

Sources

• Allied Health Professions Council (AHPC), Ghana. Communication to the Ghana Football Association (GFA). Letter dated February 16, 2026.
• Health Professions Act, 2013 (Act 857). Parliament of Ghana. Particularly Section 21(C) on unlawful practice.
• Ghana Football Association (GFA). Official announcements on technical staff appointments for the 2026 FIFA World Cup cycle.
• FIFA. 2026 World Cup Regulations and Guidelines on Team Staff.
• Life Pulse Daily. Original news report: “Allied Health Professions Council cautions GFA at the follow licence of Black Stars’ physiotherapist Carlos Lozano Romero.” Published February 18, 2026.