The College receives many questions from occupational therapists who work in private practice or must provide invoices for their services. Responses to some of the most frequently asked questions are provided below.

• Occupational therapists are expected to communicate any fees upfront to the client 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.”
• Occupational therapists are expected to engage in fair, equitable and transparent billing practices.  Follow the requirements set out in the Standards for Record Keeping when maintaining financial records. 

 
Question: When issuing an invoice for occupational therapy service, can I put another service provider’s name on the invoice?

Answer: The occupational therapist who provided the service should be identified on the invoice with their appropriate name and title/designation.

The Standards for Record Keeping state that financial records need to include “a clear identification of the person(s) who provided the product or service and his or her title.”  

In some instances, service may have been jointly delivered by two health care professionals (for example, two facilitators in a group intervention). In this case, both names and titles may be included on the invoice. 

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 need to determine who is the client or individual at the focus of the intervention and identify them on any invoice. Although occupational therapists meet with parents and caregivers to provide them with updates on therapy progress or information to help support the individual, the occupational therapy work is being done with and for the client. Therefore, billing information should accurately reflect this.

The Standards for Record Keeping state that financial records need to include “a clear identification of the client to whom the service or product was provided, for example, client’s full name and address and unique identifier if applicable.”

Occupational therapists should not include information that could be misleading, despite intentions of good will to accommodate requests of clients, parents, or caregivers. 

Question: How much detail about the occupational therapy service do I need to include on the invoice?

Answer: Third-party payers may have different criteria for the information they require when submitting 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.

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: 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 in this situation? 

Answer: Prior to working with the client, the occupational therapist needs to confirm who is taking accountability for the service. Occupational therapists can only practice psychotherapy within the scope of practice for occupational therapy.  Is the client receiving occupational therapy services? If so, the billing information for occupational therapy service should be clearly reflected. 

Occupational therapists practicing in psychotherapy may have supervisory agreements with other health professionals. As other health professions may have different definitions of supervision and consultation when describing who is accountable for service, occupational therapists should check with the regulatory college of their supervisor, clarify who is accountable for the service provided, and ensure that the financial record reflects the information accurately.

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: If I am registered as both an occupational therapist and as another regulated profession, do I need to indicate both titles/designations on the invoice?

Answer: Occupational therapists are expected to be transparent with clients about their accountabilities and should therefore indicate both of their titles/designations on invoices. 

For any questions, please contact our Practice Resource Service at 1-800-890-6570 ext. 240 or [email protected].