Occupational therapists are expected to:
- Engage in fair, equitable and transparent billing practices.
- Communicate any fees and related information upfront to the client.
- Follow the requirements set out in the Standard for Record Keeping, 2023 when maintaining financial records.
As noted in Ontario Regulation 95/07, it is considered professional misconduct if “submitting an account or charge for services that the member knows is false or misleading” or if “charging a fee that is excessive in relation to the service provided”.
The College receives many questions from occupational therapists who work in private practice or need to provide invoices for their services. Responses to some of the most frequently asked questions are provided below.
Question: What is the appropriate rate to charge clients for occupational therapy services?
Answer: The College is not involved in establishing fee guidelines for occupational therapy services. Fee guidelines are typically established by other regulatory and industry organizations. For example:
- The Financial Services Commission of Ontario has established the Professional Service Fee Guidelines for services that are funded by auto insurance.
- If an individual is injured at work, the Workplace Safety and Insurance Board (WSIB) may be involved and set fees for the occupational therapy services.
Occupational therapists can consult with associations such as the Ontario Society of Occupational Therapists (OSOT) and the Canadian Association of Occupational Therapists (CAOT) to assist them in establishing appropriate fees for their private practice.
Question: What information is required on the invoice?
Answer: Financial records are part of the clinical record. Occupational therapists are expected to follow the Standard for Record Keeping when maintaining financial records.
Indicator 9.1 of the Standard states that occupational therapists must ensure that all records related to billing and payment are clear and include:
- Full name and designation of the providers of the services or products
- Full name of the client to whom the services or products were provided
- Full name and address of any third party to whom fees were charged, if applicable
- Items sold or services delivered
- Date of services or purchases
- Fee for services or products
- Method of payment
- Invoice or receipt of payment
- Any differential fees charged for services (for example, reduced fees)
*If requests for a client record are made by persons or organizations such as clients, third-party payers or the College, financial records or invoices are to be included.
Question: How much detail about the occupational therapy service do I need to include on the invoice?
Answer: The level of detail may depend on who the invoice is being submitted to. Third-party payers may have different criteria for the information they require on the invoices. To ensure that billing practices are not perceived as false or misleading, the occupational therapist can inquire or request clients find out from the third-party payers what specific occupational therapy services are covered, and the amount of detail required for billing purposes.
Invoices are considered part of the clinical record. Occupational therapists should ensure the documentation in the client’s clinical session notes is consistent with the information indicated on the invoice for service.
Question: When issuing an invoice for occupational therapy service, can I put the names of other service providers on the invoice?
Answer: The occupational therapist who provided the service should be identified on the invoice with their appropriate name and title/designation. If others were involved in the provision of occupational therapy service, such as a student or occupational therapy assistant, their names and titles should also be included on the invoice. In the circumstance where two health care professionals jointly provided service (for example, two facilitators in a group intervention), both names and titles may be indicated on the invoice for transparency.
The Standards for Record Keeping state that financial records need to include the “full name and designation of the providers of the services or products”.
Question: Can I put a parent or caregiver name on the invoice even though a child or family member was the individual who was receiving occupational therapy service?
Answer: Occupational therapists should not charge a fee in the name of anyone but the client. Occupational therapists need to determine who is the client at the focus of the intervention. Although occupational therapists meet with parents and caregivers to provide them with updates on therapy progress or information to support the client, or have family members participate in a session with a client, the occupational therapy work is being done with and for the client. The billing information should accurately reflect this. Providing written letters or reports to parents and caregivers is another example where the work is being done for the client and therefore the client’s name should be reflected on invoices.
Occupational therapists should not include information on invoices that could be misleading, despite intentions of goodwill to accommodate requests of clients, parents, or caregivers.
Question: My psychotherapy supervisor says that it should be her name on the invoice even though I had the session with the client. What are the expectations for invoicing this situation?
Answer: It is important that occupational therapists are clear when arranging psychotherapy supervisory agreements that under COTO’s Standard, the occupational therapist (the supervisee) remains accountable for the psychotherapy service provided to their clients.
Members of other regulatory colleges may have a different understanding of “supervision” and “consultation” and who is taking accountability for the services provided to the client. Occupational therapists need to be clear in their supervisory agreements and when obtaining client consent for services that psychotherapy is provided under the occupational therapist’s practice, not the supervisor’s. The financial record should reflect this with the occupational therapist’s name and title on the invoice.
The name and title of the psychotherapy supervisor would not be expected on the invoice since they are not accountable for the occupational therapy service nor provide any direct care to the client.
Question: If I am registered as both an occupational therapist and as another regulated profession, how should I be indicating my titles/designations on the invoice?
Answer: If you are an occupational therapist registered with more than one regulatory body, your invoices must clearly show the title and designation for the service provided. This helps clients understand the specific health service they are receiving. While the inclusion of other credentials is permitted, the occupational therapist title and designation must be placed in a position of prominence on the invoice (Standard for Use of Title).
Occupational therapists who provide psychotherapy services must follow the Standard for Psychotherapy and use acceptable titles and designations such as “OT Reg. (Ont.), Psychotherapist” or “Occupational Therapist, Psychotherapist” or “Occupational Therapist, practising psychotherapy” when issuing invoices.
Occupational therapists are reminded that they should not include information on invoices that could be misleading.
For any questions, please contact our Practice Resource Service at 1-800-890-6570 ext. 240 or practice@coto.org.