Every medical regulatory body across Canada has a standard or policy for physicians providing virtual care and these standards and policies vary throughout the country. These standards and policies also include instructions and restrictions for how physicians providing virtual care must bill to receive payment for their services.  

Due to the increased need for virtual care throughout the pandemic, several provinces developed temporary systems and codes for physicians to use to bill for virtual care. However, the standards and processes for physicians to receive payments, or even to provide virtual care, continue to vary from province to province. 

Here’s how current policies for virtual care billing in Ontario differ from those policies in British Columbia, Saskatchewan, and Nova Scotia. 

Virtual Care Payment Plans in Canada  

Before analyzing virtual care billing processes in Ontario and across other provinces, it is important to recognize that there are two main types of virtual care billing processes in Canada, alternative payment plans and fee for service (FFS).   

What is Alternative Payment Plan? 

Alternative payment plans operate on the notion that care will be provided most efficiently and effectively for the patient. Payments can be made in a variety of ways, including capitation, bundled payments, block payments, salary, or blended models. Two advantages of alternative payment plans are that they do not restrict physicians from being paid through alternate models, and they readily adapt to changes in patient preferences and technology. Alternative payment plans are currently only in use in the Northwest Territories.    

What is Fee for Service (FFS)? 

 FFS operates on the premise that physicians must use codes for a specific type of care (e.g., communicating with a patient via telephone, email or text) to be eligible for compensation. In some provinces, the billing infrastructure for virtual care is severely lacking; while many physicians are glad to communicate with their patients via video, phone, email or text, they may not be compensated for their time and efforts. While FFS is the more prevalent payment method across the country, the lack of compensation may deter physicians from providing virtual care or communicating with patients.  

 For more information about the alternative payment plans and FFS, please see the Virtual Care Task Force Report.  

 Ontario’s Virtual Care Billing Process  

Ontario’s Virtual Care Program, formerly referred to as the Telemedicine Program, was updated in November 2019 to include direct-to-patient video visits and to modernize virtual care compensation. The complete billing manual is available here.  

 Physicians must submit claims for virtual care through the Ontario Health Insurance Plan (OHIP) claims processing system. A summary of key points from the billing manual follows:  

  • Physicians must complete register via the Ontario Telemedicine Network (OTN) with the Ministry of Health to be eligible to receive payment for virtual care services 
  • Physicians and patients must use an approved OTN video solution 
  • The physician and the patient must be located in Ontario for the physician to receive compensation for virtual care services 
  • The physician must use an appropriate fee code included in the virtual care program 
  • Virtual care claims must be received and processed by OHIP within six months from the date service was provided 

 While the summary above is not exhaustive, it provides a brief overview of the requirements for physicians to obtain payment for virtual care services in Ontario. OHIP released two temporary codes for virtual care services for physicians during the pandemic in late March 2020 and followed up with additional temporary codes in September 2020. 

 Virtual Care Billing Processes in Other Provinces  

 Billing Process in British Columbia 

British Columbia has the most comprehensive approach to FFS for virtual care billing purposes. Ontario’s process ranks second according to the Virtual Care Task Force Report. British Columbia has three permanent categories of virtual care eligible for billing – telehealth (health services delivered by a physician via live image transmission through an approved video technology site), medical management via telephone, and emailing or texting medical advice to patients. British Columbia does not require physicians to be licensed in the province to provide virtual care.  

 Billing Process in Saskatchewan 

In Saskatchewan, payments for telemedicine services are limited to approved facilities and practitioners who must both be located within the province. Telephone fee codes are limited to very specific matters, including remote nurses, monitoring anticoagulant therapy, monitoring patients with diabetes who are on insulin, and remote consultations between physicians. Emails, telephone calls, and faxes from recognized health professionals may be billable as long they meet province-wide criteria. Saskatchewan is currently funding several pilot projects related to virtual care, and this may impact billing processes in the future. According to the Virtual Care Task Force Report, Manitoba observes similar virtual care billing processes. 

 Billing Process in Nova Scotia 

Like British Columbia, physicians in Nova Scotia are not required to have a provincial license to provide virtual care. The province was making substantial progress in offering virtual care; the provincial government had supported a pilot project to provide telephone and e-health services called MyHealthNS. Family physicians who enrolled their patients in the program could receive up to $12,000 per year for using technology to communicate with their patients. Over 320 health-care providers and 38,000 patients used MyHealthNS before this project was sidelined in the spring of 2020 due to the technology provider, McKesson Canada, not renewing their contract with the province. 

 A comparison summary of billing policies in different provinces 

Billing Policy   Ontario  British Columbia  Nova Scotia 
Registeration in province Required  Yes  No  No 
Proivnce approved solution required  Yes  No  No 
Telehealth services  provided Exhaustive  Restricted  Restricted 

 While most provinces are making progress to provide physicians with viable billing policies for services, the processes vary across the country and physicians are providing virtual care services without being reimbursed. According to the Virtual Care Task Force Report, there is a pan-Canadian system of medical service payment with interprovincial reciprocal billing agreements, but it will need to be adapted to meet the changing needs of virtual care for physicians and patients across the country.  

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