Occupational therapists are expected to: <\/p>\n\n\n\n
As noted in Ontario Regulation 95\/07, it is considered professional misconduct if \u201csubmitting an account or charge for services that the member knows is false or misleading\u201d or if \u201ccharging a fee that is excessive in relation to the service provided\u201d. <\/p>\n\n\n\n
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. <\/p>\n\n\n\n
Question: What is the\u00a0appropriate rate\u00a0to charge clients for occupational therapy\u00a0services?<\/strong>\u00a0<\/p>\n\n\n\n Answer:<\/strong> The College is not involved in\u202festablishing\u202ffee guidelines for occupational therapy services.\u202fFee guidelines are typically established by other regulatory and industry organizations. For example: <\/p>\n\n\n\n Occupational therapists can consult\u202fwith associations such as the Ontario Society of Occupational Therapists (OSOT) and the Canadian Association of Occupational Therapists (CAOT) to\u202fassist\u202fthem in establishing appropriate\u202ffees for their private practice.\u202f <\/p>\n\n\n\n Question: What information is required on the invoice?<\/strong> <\/p>\n\n\n\n Answer:<\/strong> Financial records are part of the clinical record. Occupational therapists are expected to follow the Standard for Record Keeping<\/a> when maintaining financial records. <\/p>\n\n\n\n Indicator 9.1 of the Standard states that occupational therapists must ensure that all records related to billing and payment are clear and include: <\/p>\n\n\n\n *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. <\/p>\n\n\n\n Question:\u202fHow much detail about the occupational therapy service do I need to include on the invoice?<\/strong> <\/p>\n\n\n\n Answer:\u202f<\/strong>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. <\/p>\n\n\n\n Invoices are considered part of the clinical record. Occupational therapists should ensure the documentation in the client\u2019s clinical session notes is consistent with the information indicated on the invoice for service. <\/p>\n\n\n\n Question<\/strong>:\u202fWhen issuing an invoice for occupational therapy service, can I put the names of other service providers on the invoice?<\/strong> <\/p>\n\n\n\n Answer<\/strong>: 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. <\/p>\n\n\n\n The Standards for Record Keeping state that financial records need to include the \u201cfull name and designation of the providers of the services or products\u201d. <\/p>\n\n\n\n Question:\u202fCan 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?<\/strong> <\/p>\n\n\n\n Answer:\u202f<\/strong>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\u2019s name should be reflected on invoices. <\/p>\n\n\n\n Occupational therapists should not include information on invoices that could be misleading, despite intentions of goodwill to accommodate requests of clients, parents, or caregivers.\u202f <\/p>\n\n\n\n Question:\u202fMy 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?\u202f<\/strong> <\/p>\n\n\n\n Answer:<\/strong> It is important that occupational therapists are clear when arranging psychotherapy supervisory agreements that under COTO\u2019s Standard, the occupational therapist (the supervisee) remains accountable for the psychotherapy service provided to their clients. <\/strong> <\/p>\n\n\n\n Members of other regulatory colleges may have a different understanding of \u201csupervision\u201d and \u201cconsultation\u201d 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\u2019s practice, not the supervisor’s. The financial record should reflect this with the occupational therapist\u2019s name and title on the invoice. <\/p>\n\n\n\n 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. <\/p>\n\n\n\n Question:\u202fIf I am registered as both an occupational therapist and as another regulated profession, how should I be indicating my titles\/designations on the invoice?<\/strong> <\/p>\n\n\n\n Answer:\u202f<\/strong>If you are an occupational therapist registered with more than one regulatory body, your invoices must clearly show\u00a0the\u00a0title and designation for the service provided. This helps clients understand the specific health service they\u00a0are receiving.\u00a0While\u00a0the inclusion of\u00a0other credentials\u00a0is\u00a0permitted,\u00a0the occupational therapist\u00a0title\u00a0and designation must be placed\u00a0in a position of prominence\u00a0on the invoice\u00a0(Standard for Use of Title<\/a>).\u00a0<\/p>\n\n\n\n Occupational therapists who provide psychotherapy services must follow the Standard for Psychotherapy and use acceptable titles and designations such as \u201cOT Reg. (Ont.), Psychotherapist\u201d or \u201cOccupational Therapist, Psychotherapist\u201d or \u201cOccupational Therapist, practising psychotherapy\u201d <\/em>when issuing invoices. <\/em> <\/p>\n\n\n\n Occupational therapists are reminded that they should not include information on invoices that could be misleading. <\/p>\n\n\n\n\n
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