Financial Matters

Percentage-based or fixed-fee arrangements may be an acceptable financial arrangement for a shared practice (e.g. for administrative overhead or supervision services) as long as:

• Fees are based on the time spent and complexity of services provided (Standard 15.1 (b)) and
• Financial arrangements are fair and not influenced by differences in authority within the practice. Registrants should not use their professional knowledge, title, or position to gain an improper advantage or benefit, or to exploit any person. (Standard 12. 6 – Avoidance of Exploitation)
• Clients’ needs are the primary consideration for service planning.

Additionally, under O. Reg. 195/23: Professional Misconduct, registrants cannot:

• Receive or offer a rebate, fee or any other benefit in exchange for client referrals (Section 1.26)
• Provide a service unlikely to benefit the client (Section 1.9)

Reflection questions:

• Do the fees collected constitute a referral rebate or benefit to the provider?
• Are the fees based on time spent and complexity of services provided?
• Do the fees charged or received between registrants constitute exploitation?

It depends. The name on the invoice should reflect the service provided and the intended recipient. For example, if the service involves imparting parenting skills to adults, the parents’ names should appear on the invoice. If the service is providing parents with a progress update or information to support a child’s therapy, the child’s name should appear on the invoice, as the service is intended to support the child.

All documents, including invoices or receipts, must be factual and accurate. (O. Reg. 195/23: Professional Misconduct, s.20). If appropriate, additional information may be added on the invoice to clarify details about the service.

Registrants should not involve themselves with insurance coverage matters, including per-person limits. These should be addressed between the client(s) and their insurers.

Reflection questions:

• Who is the recipient of services?
• What is the purpose of the intervention, and who is it targeted towards?
• Could the name on the invoice appear to be false or misleading?

Clients must be informed of any fee increases before services are provided, as part of the informed consent process. This allows clients to consider the increased fees when deciding whether to proceed with a service. Providing adequate notice is also important, as a fee increase may affect the client’s ability to continue services and could require termination of services and a referral. (Standard 15.1)

Yes, registrants may charge a fee for providing access to, or copies of, an individual's personal health information. The fee must be for reasonable cost recovery. The Personal Health Information Protection Act, 2004 (PHIPA), provides guidance on determining what is a reasonable cost recovery, considering the time required to review records and the complexity of the information. For example, more complex records require more time to review, which may result in a higher fee. Simple records require a quick review and, therefore, typically result in a lower fee.

Please refer to the PHIPA DECISION 133 for more detailed guidance when determining fees.

Reflection questions:

• Have I considered the nature, time and complexity required for review in my fees?
• Would my fees be considered “reasonable” considering PHIPA Decision 133?

No. Registrants cannot withhold reports for non-payment of fees (Standard 15.2). Registrants must provide a report or certificate within a reasonable timeframe when requested by the client or their authorized representative (O. Reg. 195/23: Professional Misconduct, s.21)

If you’re concerned that the client may not pay for a service, you can implement a prepayment plan. You may also use collection agencies and other legal means to obtain payment.

Registrants can request prepayment for a service if the funds can be returned if not used. Prepayments for a group session/series are common. Registrants should document that the client has agreed to prepay for the service and when the service is provided. Accepting a retainer for unlimited, on-demand service is not acceptable. (Standard 15.2)

Reflection questions:

• Am I able to identify the amount used and return the funds if required?
• Has the client consented to prepayment of services?
• Is the prepayment for a fixed number of sessions versus an unlimited or on-demand therapy arrangement?

Interest may be charged on an overdue account, provided appropriate consent has been obtained. Interest charged should not be excessive or used in a way that exploits the client. CPBAO doesn’t provide a specific amount or interest rate. The federal government sets legal limits on the interest rate to help guide what is appropriate.

Reflection questions:

• Am I charging an interest rate that could be considered excessive?
• Have I researched what a normal interest rate is for the charge?
• Have I obtained legal advice, and would the charge be defensible?

Ontario Harmonized Sales Tax (HST) requirements are outlined by the Canada Revenue Agency (CRA).

Many healthcare services are HST-exempt, including psychology services. This means that registrants providing psychotherapy, assessment, or treatment of mental health conditions do not charge HST. In contrast, ABA services are generally subject to HST requirements, except for services designed to assist individuals with autism. Learn more.

Some services that fall outside a health treatment plan, such as teaching, administration, consultation, or research, are not HST-exempt. Learn more about HST exemptions. You are encouraged to consult a financial professional to determine whether HST applies to the services you provide.