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Providing virtual service involving other jurisdictions

Providing virtual service involving other jurisdictions


Rosella works on a family health team in northern Ontario. When the pandemic started, she provided virtual occupational therapy service to her clients when in-person service was deemed unsafe. Over time, Rosella has noticed that more clients are requesting ongoing virtual services, including clients who live more remotely. This shift in her clinical work has led Rosella to think about travelling outside the country to stay with a friend for a few months. She is wondering if she can continue to provide virtual occupational therapy services to her clients while she is residing outside of Ontario.


Rosella reviews COTO’s practice guidance document on Virtual Services and considers the following:


  • Other jurisdictions may have different requirements for providing virtual services. Ontario occupational therapists should contact the regulator in the province or country where they will be located to confirm requirements to deliver virtual services. 

  • While located in another jurisdiction, occupational therapists registered in Ontario are still accountable to COTO. If there is a concern or complaint about the services, COTO will be responsible for the investigation.


  • Consent conversations for virtual services should cover the same elements as for in-person services, outlined in the Standards for Consent, 2017, including knowledgeable consent for the collection, use, and disclosure of personal information and personal health information.

  • For the provision of virtual services, there may need to be additional discussions about:
    • Any adjustments or modifications to the virtual service plan, including the change of location of the occupational therapist
    • Consents about emergency contacts and procedures
    • Risks, benefits, and limitations of participating virtually and with the occupational therapist being in a different jurisdiction
    • Risks and limitations associated with the use of technology and other features of the platform
    • Others involved in virtual occupational therapy services and their role (for example: occupational therapist assistants [OTAs] or students, vendors, caregivers, interpreters etc.)
    • Any restrictions around recording sessions
    • Any fees associated with the virtual services
    • Communication protocols during a virtual session

Security and confidentiality

Client safety and contingency planning

  • Adverse or unanticipated events such as medical emergencies or the deterioration of the client's physical, emotional, behavioral, or cognitive condition may occur during the session. Occupational therapists providing virtual services from outside of Ontario will need to consider whether they can establish a safety plan with the client to deal with unexpected events that occur at the client’s location.


  • Rosella decides to first look at COTO’s requirements for the provision of virtual services as well as the regulation requirements in the other jurisdiction. She determines that COTO does allow registrants located in another country to provide virtual services to Ontario clients, but that the occupational therapist regulatory body in that country also has local requirements, such as obtaining registration and professional liability insurance. 

  • At the same time, Rosella speaks to her manager at the family health team to determine if there are any organizational policies or restrictions regarding the provision of virtual services to their clients from outside the country. She asks if there are any employment contract considerations.

  • Rosella considers that she will be staying at a friend’s home for an extended period of time. Although she will have reliable internet, she may not consistently have a private space to conduct the sessions and document confidential information. 

  • Rosella reviews her caseload and considers that most of her clients have complex health conditions, are at risk for falling and live alone with few supports. She considers whether she will be able to execute a contingency plan (such as calling 911) from outside the country, should an adverse event occur during the virtual session. 

  • After careful consideration and conducting her own risk analysis, Rosella decides to not offer virtual services to her clients while residing at her friend’s home outside of the country.


With increasing acceptance of video technology and more people having mobile working and living arrangements, there have been greater requests for, and delivery of, virtual occupational therapy services.  While there can be risks and drawbacks to service delivery that is not “in-person,” the benefits include increasing access to occupational therapy across the province and improving continuity of care when people relocate. 

Occupational therapists who want to relocate temporarily and deliver virtual services from outside of Ontario will need to consider COTO regulatory requirements as well as requirements of the other province or country. This may include confirming registration requirements and the need for out-of-country professional liability coverage. 



If you have questions about the application of College Standards and resources, contact the Practice Resource Service: 1.800.890.6570/416.214.1177x240 or

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