OHIP billing·
Received an OHIP high volume billings letter? What it says and what to do next
The Ministry of Health is sending Ontario physicians letters about high volume billings. What the letter says, what the OMA said, and what is worth checking.
Updated 5 November 2026. We will update this page as the OMA and the Ministry say more.
In the last week of October 2026, the Ministry of Health began mailing Ontario physicians letters headed "RE: HIGH VOLUME BILLINGS." On 5 November the OMA said it was "deeply concerned" and asked anyone who received one to get in touch.
This page sets out what the letter says, what it does not say, and what is worth knowing about your own billing. If you have received one, read it alongside the OMA's guidance.
What the letter says
The letter comes from the Ministry's Payment Accountability and Fraud Control Unit, in the Provider Services Branch in Kingston. It arrives by Canada Post, marked private and confidential. The unit's name is alarming. The letter itself is measured.
It says the Ministry identified billing patterns under your number that are "higher than those typically observed among physicians with similar practice profiles." It then lists the pattern it flagged as a bullet point.
It also says:
- Billing data alone "may not fully capture the circumstances of an individual physician's practice," and there "may be legitimate explanations."
- Patterns of this kind "are uncommon and warrant careful review."
- Physicians are responsible for every claim submitted under their billing number, "regardless of who submits the claims on their behalf."
- The Ministry "encourages" you to review your billing and supporting documentation, take corrective action if you find discrepancies, and bill accordingly from here.
- The Ministry will keep monitoring, and "may undertake further review" if unusual patterns persist.
It asks for no repayment, no records and no reply. It sets no deadline.
Which flag you received matters
The letter is a template. The flagged pattern appears as a bullet, and it differs between physicians. Two versions are known so far:
- Services to a high number of patients in a single day.
- A high number of days worked in a single year. Rosen Sunshine LLP, a health law firm, described this version on 4 November.
Read the bullet in your letter. It tells you what the Ministry's data picked up, and it shapes what is worth checking.
Why the Ministry points to delegation and time-based codes
The letter singles out two areas. It says assessments, consultations and other services "that must be personally rendered" must meet Schedule requirements, and that "certain fee codes are not eligible for payment if delegated." It then links two joint Ministry and OMA resources:
- The Education and Prevention Committee billing brief on requirements for time-based services, which also covers delegation.
- The Ministry's resource on assessments and consultations.
The logic is arithmetic. Time-based codes carry minimum durations. Add up the minimums billed on a single day and the total has to fit inside that day. In a team-based practice, services performed by nurses, residents or other staff can end up under the physician's number. Some of those services can be delegated. Some cannot.
A high patient count is often legitimate. Busy clinics, hospital rounds and long-term care can all produce one. The letter is asking whether the record shows how the day was actually worked.
Why now
The Ministry has not said why it began sending these letters. The timing follows the Auditor General's December 2025 report on oversight of physician billing. The report found that:
- The Ministry paid $19.5 billion to about 35,000 physicians through OHIP in 2024/25.
- More than 100 physicians in each of the last three years submitted claims for all 365 or 366 days of the year.
- At least 59 physicians a year billed more than 24 hours of service in a single day, rising to 82 in 2024/25.
- The Ministry chose audits mostly from tips and complaints, rather than from its own data.
A letter keyed to days worked or patients seen per day is the kind of data-driven screen the report asked for. Those screens are blunt. A physician who works long hours is entitled to bill for them.
How this differs from an audit
A formal post-payment audit begins with a different letter, a Request for Records. That letter names a review period and asks for specific patient charts, usually within 30 days. Our guide to how OHIP audits work walks through that process.
If you receive a Request for Records, contact the CMPA and get legal advice before you send anything.
What the OMA has said
On 5 November 2026, Dr. Andrew Park, the OMA's interim CEO, wrote to members. The OMA said:
- It is seeking answers from the government on how physicians were selected, what criteria were used, and what the Ministry intends to achieve.
- "You are not required to reply to the ministry as a result of receiving one of these notifications."
- Physicians who received a letter should email the OMA at info@oma.org.
- Physicians may also contact their MPP, and the OMA will help them do so.
The OMA is the right first call. It speaks for physicians with the Ministry, and it is collecting letters to make that case.
Your billing number, your responsibility
One line in the letter deserves attention whoever does your billing: you are responsible for every claim under your number, "regardless of who submits the claims on their behalf."
Most physicians who receive this letter have a billing agent, a clinic team or billing software submitting for them. The letter makes their work your exposure. Errors that look small on a remittance can distort the pattern the Ministry sees:
- Service dates keyed wrongly, which add days you did not work.
- Time-based codes billed without start and stop times in the chart.
- Services performed by staff billed as if you performed them personally.
- Duplicate submissions after a rejection, which inflate a day's count.
None of these needs to be deliberate to show up in the data.
Knowing what your own billing shows
Replying to the Ministry is a separate question, and the OMA has answered it. Knowing what your own billing record shows is a private one.
Ontario specialists ask us for a second set of eyes on their last six months of billing. We look at how claims line up with the day they describe, how time-based and delegated services are recorded, and what was rejected and written off along the way. The review is free. You see what we find before you decide anything.
We do not respond to the Ministry on a physician's behalf, and we do not give legal advice. For the letter itself, start with the OMA. For a Request for Records, start with the CMPA.
Sources
- Ministry of Health, letter "RE: HIGH VOLUME BILLINGS", Payment Accountability and Fraud Control Unit, October 2026 (template wording).
- OMA, Update from the CEO, 5 November 2026.
- Office of the Auditor General of Ontario, Oversight of Physician Billing, December 2025.
- Rosen Sunshine LLP, When working too much gets you flagged by OHIP, 4 November 2026.
- Ontario Ministry of Health, Education and Prevention Committee billing brief: requirements for time-based services.
- Ontario Ministry of Health, Assessments and consultations resource, May 2023.
- Ontario Ministry of Health, Resources for physicians.
If you received a letter and want to know what your billing shows, start with a free review of your last six months.