OHIP billing·
Flagged for a high number of patients in a day? What OHIP compares
The Ministry is flagging physicians for services to a high number of patients in a single day. What the flag compares, and what the record needs to show.
Some of the Ministry of Health's high volume billings letters, sent from late October 2026, flag one pattern in particular: "services provided to a high number of patients in a single day."
The letter says the pattern is higher than those "typically observed among physicians with similar practice profiles." It also says billing data alone "may not fully capture the circumstances of an individual physician's practice," and that there "may be legitimate explanations." It asks for no repayment and no records.
Busy clinics, hospital rounds and long-term care can all produce a high patient count on a legitimate day. This post covers what the Ministry can compare when it looks at one, and what the record needs to show. For the letter as a whole, and the OMA's response, see our explainer on the high volume billings letter.
What the Ministry has and has not said
The Ministry has not published the number of patients that triggers the flag, the peer groups it uses, or how it selected physicians. The OMA has asked the government exactly those questions.
What the letter does say is where the Ministry wants physicians to look. It points to two joint Ministry and OMA resources: the billing brief on requirements for time-based services, and the resource on assessments and consultations. It also says that services "that must be personally rendered" must meet Schedule requirements, and that "certain fee codes are not eligible for payment if delegated."
Those two references describe the two ways a busy day can fail to add up.
Time-based codes have to fit inside the day
Many fee codes are paid by time. Psychotherapy and counselling are billed in units with minimum durations set by the Schedule. Other codes require a minimum time before they can be claimed at all.1
The time-based services brief sets three rules that matter on a busy day:
- Only direct contact with the patient counts, unless the fee code says otherwise. Charting, reviewing results and discussions with other staff do not count.
- The start and stop times must be recorded in the patient's medical record. A total such as "spent 20 minutes" does not meet the standard.
- Time claimed for one service must not overlap with time spent providing any other billable service, for the same patient or a different one.
Put together, the minimum times billed on a single day have to fit inside that day, without overlapping. A reviewer can check that from the claims and the charts. On a day with a full clinic list and several timed services, the margin can be smaller than it feels at the time.
Work by others can end up under your number
The second way a day's count climbs is team-based care. A practice with trainees, nurses, nurse practitioners or other staff can bill a day's work under one physician's number. Some of that is allowed. Some is not.
The time-based services brief states that services must be personally rendered by the physician, with defined rules for supervised postgraduate trainees.1 The OMA's guide to delegated procedures sets out the narrow exception: certain procedures performed by the physician's own employee, in the physician's office, while the physician is physically present and available to intervene. Assessments, counselling, consultations and diagnostic interpretations cannot be delegated for OHIP payment.2
If a day's claims include assessments that staff performed and the physician co-signed, the count on that day reflects the team's work while the claims say the physician did it. That is the pattern the letter's reference to delegation is pointing at. We cover the rules in more detail in what OHIP means by personally rendered services.
Legitimate busy days
Many high counts have a straightforward explanation. A specialist covering a ward, running a procedure list or rounding in long-term care can see far more patients than a typical clinic day, with every service delivered personally and documented properly.
The letter acknowledges this. What it asks is whether the record shows it: times that add up within the day, and services under the physician's number that the physician delivered.
Your billing number, your claims
The letter states that physicians are responsible for all claims submitted under their billing number, "regardless of who submits the claims on their behalf." That holds whether the claims come from a billing agent, a clinic team or billing software.
Small errors raise a day's count without anyone intending it. Duplicate submissions after a rejection, claims dated to the wrong day, and services entered under the wrong physician in a group practice all add patients to a day in the Ministry's data.
What we look at
We review the last six months of a specialist's billing. For a practice that has received this letter, that means looking at the busiest days: how the timed services line up, which services were billed under the physician's number, and whether duplicates or misdated claims are inflating the count. We also look at what was rejected and written off along the way. The review is free, and you see what we find before you decide anything.
We do not respond to the Ministry for physicians, and we do not give legal advice. For the letter itself, start with the OMA. If you receive a request for records, contact the CMPA.
References
- Ontario Ministry of Health and OMA Education and Prevention Committee, Requirements for time-based services, billing brief, updated June 2025.
- Ontario Medical Association, OHIP payments for delegated procedures.
- Ontario Ministry of Health, Assessments and consultations resource, May 2023.
- Ontario Ministry of Health, letter "RE: HIGH VOLUME BILLINGS", Payment Accountability and Fraud Control Unit, October 2026 (template wording).
If your practice received this letter, start with a free review of your last six months.