Education and Prevention Committee Billing Briefs

Education and Prevention Committee (EPC) Billing Briefs are prepared jointly by the Ministry of Health (MOH) and the Ontario Medical Association (OMA) to provide general advice and guidance to physicians on billing matters.

An overview of select new payment rules and processes relevant to new Virtual Care Services (effective December 1, 2022)

Category: All physicians
Date of publication: November 24, 2022
Date updated: April 6, 2023 - Updates made to Schedule of Benefits page references

Claims Tips: As with all insured services listed in the Schedule, general payment rules apply to Virtual Care Services. The December 1, 2022, version of the Schedule of Benefits introduces a new section for Virtual Care Services within the Consultations and Visits section starting on page A66. This new section outlines additional specific payment rules and provides commentary related to these services. Please see EPC Billing Brief Virtual Care 1 for an introduction to the OHIP insured Virtual Care Services.

Initiating a Virtual Care Service

A Virtual Care Service is not eligible for payment unless the physician service is initiated by the patient or the patient’s representative, or the service represents a medically necessary follow-up visit to a preceding visit initiated by the patient or the patient’s representative.

For clarity, administrative staff may coordinate appointments and organize care in a manner analogous to in-person encounters. Similarly, medically necessary follow-up services may be organized by the provider (or by their staff).

However, a physician-initiated call to check in on a patient would not be eligible for payment, nor would any Telephone calls or Video encounters conducted for administrative purposes (such as to inform patients of clinic closures or the availability of remote services).

Furthermore, services are not eligible for payment when initiated by the physician (or the physician’s staff) without a clear and medically necessary reason for doing so. As described in the following section, the communication of normal lab work, unless medically necessary (in so far as the clinical management of the patient is altered), should not be billed.

Specific Elements of Existing Services

Existing services that pre-date December 1,  2022 include:

  • discussion with, and providing advice and information, including prescribing therapy to the patient or the patient’s representative, whether by telephone or otherwise, on matters related to the service and in circumstances in which it would be professionally appropriate that results can be reported upon prior to any further patient visit, the results of related procedure(s) and/or assessment(s), and
  • monitoring the condition of the patient and intervening, when medically indicated, until the next insured service is provided.

Physician-initiated communication to provide advice or guidance regarding a previously rendered insured service is not separately eligible for payment/billable. A common example of this would occur when a patient is provided with a prescription along with instruction to fill it only upon receipt of a positive test result. The call to inform the patient of the test result is not eligible for payment as it would be considered a Specific Element of the initial assessment (please refer to item F, page GP15, Schedule of Benefits).

As a general rule, the provider should consider whether the remote encounter would have occurred in their in-person practice.

In circumstances where an in-person encounter would not have taken place, it is unlikely that a claim for a virtual service could be supported.

Virtual Care Services may not be delegated for payment purposes

Virtual Care Services are not eligible for payment unless personally performed by the physician or rendered in accordance with the payment rules regarding supervision of a Medical Trainee specified in the General Preamble.

The required elements of service for consultations and assessments apply to Virtual Care Services including physical examination

While virtual care does not require a direct physical encounter (i.e., in person contact), all other requirements and conditions for the appropriate service as described in the Schedule of Benefits (the Schedule) must be met, including a physical examination when required for an assessment or consultation (see page GP15, Specific Elements of Assessments). This means that not all consults and assessments are eligible for payment when delivered virtually.

The ability to perform a clinically appropriate physical examination and the clinical scenario will inform a physician’s decision to provide a virtual or in person visit as well as the appropriate choice of modality (video or telephone), if virtual. Physicians should use their professional judgement and follow appropriate clinical guidelines when choosing the modality of service delivery.

It is possible to perform some (but not all) aspects of a physical examination virtually. When the appropriate examination is possible, and other payment parameters are met, the related insured service would be eligible for payment when provided virtually.

For example:

  • visualization of skin lesions, surface anatomy, edema or deformity as well as other observations, may be possible with the use of video technology
  • telephone may be used to conduct a mental status examination (but may not be sufficient in all cases)
  • enhanced peripheral electronic tools may permit auscultation or visualization of specific anatomic areas

Virtual consultations may only be provided using a Verified Video Solution.

  • For specialist Video Consultations, the specialist is required to perform the physical examination elements specified in the description of a specific, or medical-specific assessment.
  • For other insured Video Consultations (and similar services such as Optometrist-Requested Assessment), physical examination requirements are listed in the description of each Virtual fee code.
  • GP Focused Practice* Video Consultations require a full, relevant history of the presenting complaint and detailed examination of the affected part(s), region(s), or system(s) needed to make a diagnosis, and/or exclude disease, and/or assess function.

Physicians should review the requirements for assessments and consultations found in the General Preamble in order to confirm their understanding of physical examination requirements for specific services. In some circumstances, it will not be possible to conduct the appropriate physical examination virtually (for example, general assessment; Level 2 paediatric assessment for well-baby care; assessment for a patient condition where auscultation, palpation or other hands-on assessment maneuver would be generally accepted to be required to complete the physical examination; etc.) and in those cases, an in-person visit would be required for the service to be eligible for payment.

* GP Focused Practice Physician means, for the purpose of eligibility to provide a focused practice consultation by Video (A010, A011, A906, A913, A914), a physician who has been designated by the bi-lateral Ministry of Health (MOH)/Ontario Medical Association (OMA) GP Focused Practice Review Committee or a physician who is eligible for the focused practice psychotherapy premium.

Visits that require a direct physical encounter

Virtual Care Services are not eligible for payment (defined in General Preamble) where it is not medically appropriate to provide the specific service without a direct physical encounter. If, during the course of a Virtual Care Service, it becomes apparent that the service cannot be appropriately completed without a direct physical encounter, the Virtual Care Service is not eligible for payment (only the service with a direct physical encounter is eligible for payment).

Services involving a direct physical encounter must be made available by the physician providing Comprehensive Virtual Care Services, or by the physician’s group within a clinically appropriate timeframe:

  • if it becomes apparent during a Virtual Care Service that a service involving a direct physical encounter is medically necessary; or,
  • if at the time of scheduling the service the patient expresses preference for a service involving a direct physical encounter.

Definition of physician’s group when patients require a direct physical encounter

For the purpose of this provision, a physician’s group must have shared access to the patient’s medical record and is defined as:

  • For Specialist and GP Focused Practice Physicians,
    • physicians in the same hospital specialty call rotation, or
    • physicians who are co-located in shared clinical physical space.
  • For family and general practice physicians:
    • Patient Enrollment Model physicians who are signatory or contracted to the same specific group contract (i.e., as identified by the same group billing number); or,
    • physicians who are co-located in a shared clinical physical space

Technology options for Virtual Care Services

Many Virtual Care Services may be provided by Telephone (synchronous audio-only communication - no visualization) or Video (2-way synchronous video-conference - audio and video visualization).

Consultations and some other “initial visit” services may only be provided by video. See Appendix J of the Schedule for a full list of codes that may only be provided by video. Under the new model, physicians will continue to submit claims for Virtual Care Services with modality indicators to identify the technology used to deliver the service.

Video services are only eligible for payment when performed using a Verified Video Solution, as defined by Ontario Health. The delivery modality must be documented on the patient medical record.

When more than one modality is used during a Virtual Care Service

If modality changes during the course of a Virtual Care Service, (for example, a Telephone service transitions into a Video service), only the service performed by the modality that represents the greater part (more than 50%) of the time spent providing the Virtual Care Service is payable.

For time-based services, the combined time of both modalities will be used to calculate the number of time units eligible for payment.

Fee codes to use when submitting claims for Comprehensive Virtual Care Services

Comprehensive Virtual Care Services rendered within an Existing/Ongoing Patient-Physician Relationship must be claimed using the fee codes listed in Appendix J-Section 1 of the Schedule of Benefits. This includes initial visits/consultations which serve to establish the relationship in some cases as well as follow-up care.

Indicating the modality used for Comprehensive Virtual Care Services

Claims submitted for Comprehensive Virtual Care Services must include the modality indicator that identifies the technology used to deliver the service:

  • K300A-identifies Video technology used during the service
  • K301A-identifies Telephone technology (audio only) used during the service

Note that the B203, B204 and B209 indicator codes and the OTN Service Location Indicator (SLI), previously used for OVCP claims, can no longer be submitted.

Fee values to use when submitting claims for Comprehensive Virtual Care Services

Submit claims for Comprehensive Virtual Care Services using the in-person fee value regardless of whether the service is rendered by Video or Telephone. Comprehensive Virtual Care Services rendered by Video are payable at fees that are equivalent to the corresponding in-person fees for those services. The amount payable for Comprehensive Virtual Care Services rendered by Telephone is 85% of the corresponding in-person fee except for K007, K005, K197 and K198, which will be payable at 95% of the corresponding in-person fee.

Fee codes to use when submitting claims for Limited Virtual Care Services

Limited Virtual Care Services rendered outside of an Existing/Ongoing Patient-Physician Relationship must be claimed using the following fee codes (also listed in Appendix J-Section 2 of the Schedule):

  • A101-Limited Virtual Care Service, video
  • A102-Limited Virtual Care Service, telephone

Please note that the modality indicators (K300A, K301A) are not required to be submitted with Limited Virtual Care Service codes.

Calculating the time that may be claimed for time-based Virtual Care Services

Only time spent in direct communication with the patient or the patient’s representative in the provision of the insured service will be used to calculate the number of time units eligible for payment for time-based services

Premiums that apply to Virtual Care Services

  • The applicable premium(s) listed in the Premiums Table in the Virtual Care Services section of the Schedule of Benefits (page A75) are payable to physicians when providing eligible Comprehensive Virtual Care Services.
  • Premiums are not applicable to Limited Virtual Care Services.

Management fees that apply to Virtual Care Services

  • Comprehensive Virtual Care Services are included as a consultation or assessment for the purposes of meeting the requirements for payment of the applicable management fee(s) listed in the Management Fees for Services by Telephone or Video Table in the Virtual Care Services section of the Schedule of Benefits (page A76).
  • All requirements and conditions for the appropriate management fee as described in the Schedule of Benefits must be met, with some management fees (for example., K030-Diabetic management assessment) requiring a component of in person services.
  • Physicians claiming management fees that include phone management (for example, G500; G512; K090; K091; K682; K683; K684; W010; etc.) should continue to claim these for virtual communication with patients/families/other professionals using the existing management fees rather than the new Virtual Care Fee Codes.
  • See also: EPC Billing Brief Virtual Care 1, section titled Virtual Care Fee Codes that pre-date March 2020”.

Future Billing Briefs related to Virtual Care Services

The Education and Prevention Committee (EPC) will publish a case-based EPC Billing Brief illustrating scenarios where the above payment rules and conditions apply. The EPC welcomes feedback about future topics or focused briefs (for example, designed for a specific type of practice or group of physicians) to assist in the understanding of the new Virtual Care Services.

If you have suggestions for topics, please send an email to the attention of the joint Ministry of Health/OMA Education and Prevention Committee.

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Keywords/tags

Virtual Care; Comprehensive Virtual Care Service; Limited Virtual Care Service

More Information

Contact Information

For additional information, please visit the Resources for Physicians and the How to Get Help with Billing Questions pages on the ministry website.

If you have any billing or claims submission inquiries, please contact the Inquiry Services, Service Support Contact Centre (SSCC) by email or by calling 1-800-262-6524.

To provide feedback on EPC Billing Briefs, or to suggest topics for future EPC Billing Briefs, send an email to the attention of the joint MOH/OMA Education and Prevention Committee.

The Ministry of Health (MOH) and the Ontario Medical Association (OMA) have jointly prepared this educational resource to provide general advice and guidance to physicians on specific billing matters.

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Note: This document is technical in nature and is available in English only due to its limited targeted audience. This publication has been exempted from translation under the French Language Services Act. For questions or support regarding this document, please contact the Service Support Contact Centre (SSCC) by email or by calling 1-800-262-6524.

Remarque : Ce document est de nature technique et est disponible en anglais uniquement en raison de son public cible limité. Ce document a été exempté de la traduction en vertu de la Loi sur les services en français. Pour toute question ou de l’aide concernant ce document, veuillez contacter Les Services de renseignements, Centre de contact pour le soutien des services par courriel ou en téléphonant le 1-800-262-6524.