Bulletin 250304 — Fees for patient records and missed appointments
Centres are reminded of the Integrated Community Health Services Centres Act as it applies to charging for patient records and missed appointments.
To: Integrated Community Health Services Centres
Category: Community surgical and diagnostic centres
Written by: Health Insurance Branch and Health Programs and Delivery Division
Date issued: March 27, 2025
Bulletin Number: 250304
Overview
Community surgical and diagnostic centres licensed under the Integrated Community Health Services Centres Act, 2023 (ICHSCA) must understand how this legislation applies with respect to the complaints process, and fees for administrative costs related to patient records and missed appointments.
Definition of facility costs
The Integrated Community Health Services Centres Act, 2023 (ICHSCA) regulates the charging and payment of “facility costs”. The ICHSCA defines “facility costs” as a charge, fee or payment for or in respect of a service or operating cost that supports, assists and/or is a necessary adjunct to an insured service, and that is not part of the insured service. As per Section 29, facility costs may only be charged to the Minister or a prescribed person.
Fees for the transfer of patient records for the provision of care
If an individual requires a copy of all or part of their patient record, which may include imaging media, for the provision of ongoing care by another health care provider, the community surgical and diagnostic centre must provide a copy of the record(s) at no cost to the individual or health care provider.
All costs associated with producing a copy of all or part of the patient record, where such copy is required for the ongoing care of the patient, are included in the facility costs payable to the licensed centre.
A fee for this purpose would contravene Section 29 of the ICHSCA. Therefore, if an individual was charged, the Ministry of Health (the ministry) may reimburse the individual and take additional steps, pursuant to the ICHSCA, which may include:
- recovering the amount, plus administrative charges, from applicable billings under the Ontario Health Insurance Plan, in accordance with s. 41
- revocation of the licence pursuant to s. 13(1)
- prosecution for provincial offences under s. 63 for breach of s. 29
This is not a new policy or practice. Rather, it reflects the existing interpretation of legislation.
Fees for the transfer of patient records for other purposes
The ICHSCA does not regulate fees related to the costs associated with the transfer of a medical record requested by a patient for purposes other than the provision of ongoing care. Instead, the patient’s ability to request records is regulated by the Personal Health Information Protection Act (PHIPA). The College of Physicians and Surgeons of Ontario (CPSO) regulates the setting and charging of these fees. Details are available on the CPSO’s Medical Records Management webpage.
Fees for missed appointments
The ICHSCA does not regulate whether a community surgical and diagnostic centre may issue a fee to a patient for a missed appointment or procedure.
The CPSO sets policy for the setting and charging of fees. Details are available on the CPSO’s Uninsured Services: Billing and Block Fees webpage.
Public posting of all uninsured services
Under the ICHSCA, community surgical and diagnostic centres are required to post a list of uninsured services both:
- on the centre’s website, if they have one
- in a prominent place visible to members of the public at, or near, the entrance of the centre
This posting would include any charges for:
- the transfer of patient records
- missed appointments
Complaints about charges for OHIP-insured services and illegal facility costs
In Ontario, it is prohibited for a person or entity to:
- charge OHIP-insured persons for an insured service or a component of an insured service.
- pay or receive a fee or benefit from an insured person for providing preferred access to an insured service; or
- require an insured person to pay a block fee in order for that person to receive an insured service (a block fee is a charge that covers a group of uninsured services over a specific period of time).
The ministry investigates complaints of unauthorized payments and illegal facility costs under the Commitment to the Future of Medicare Act (CFMA) and the ICHSCA. If the ministry finds that a person has been charged and paid for an OHIP-insured service or paid an illegal facility cost, the ministry ensures that the full amount is returned to that person.
For general information on the services covered by OHIP and protecting access to OHIP-insured services, you may access the What OHIP covers webpage.
You can also email protectpublichealthcare@ontario.ca with your concerns or questions.
Patient complaints
Every community surgical and diagnostic centre must have a process for receiving and responding to patient complaints pursuant to Section 22 of the ICHSCA. As a first step, patients are advised to resolve the complaint directly with the community surgical and diagnostic centre, but the patient has a right to make a complaint to the Ontario Patient Ombudsman at any time.
The Ontario Patient Ombudsman is an independent, arm’s length organization authorized to receive, respond to, and help resolve complaints from patients about their experience in a community surgical and diagnostic centre.
Integrated Community Health Services Centres Program
For general information on the program, please see the community surgical and diagnostic centres webpage.
Keywords/Tags
ICHSCA; ICHSC; Integrated Community Health Services Centres; IHF; Independent Health Facilities; Community surgical and diagnostic centres;
Contact information
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