What does personally rendered mean for OHIP billing?

It means the physician delivered the service themselves. The Ministry's billing brief on time-based services states that services must be personally rendered by the physician, with separate rules for supervised postgraduate trainees. A service that was not personally rendered when it had to be is not payable.

When can a delegated procedure be billed to OHIP?

When the procedure is one generally accepted as performable by a non-physician, the delegate is the physician's own employee, the procedure is done in the physician's office or clinic, and the physician is physically present and able to intervene. A short list of procedures, such as venipuncture and injections, does not require the physician to be present.

Can a nurse employed by the hospital perform a delegated procedure I bill?

Not for OHIP payment as a delegated procedure. The OMA guide states that delegated procedures performed by someone employed by a public hospital, long-term care facility, Family Health Team or similar organization are not eligible.

Personally rendered services and OHIP delegation

Q: Which OHIP services cannot be delegated?

According to the OMA's guide to delegated procedures, physician services such as assessments, counselling, therapy, consultations and diagnostic service interpretations cannot be delegated to a non-physician for OHIP payment. They must be personally rendered by the physician.

Q: Who is responsible if staff billed a service under my number?

The physician. The Ministry's October 2026 letters state that physicians are responsible for all claims submitted under their billing number, regardless of who submits them.

The Ministry of Health's high volume billings letters, sent from late October 2026, contain a sentence many physicians will read past. 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."

That sentence matters for any practice that uses staff to extend what the physician can see in a day. This post covers what OHIP requires the physician to do personally, what it allows a delegate to do, and why the distinction sits with the physician. For the letter as a whole, see our explainer on the high volume billings letter.

The rule: physician services are personally rendered

The Ministry's billing brief on time-based services states that services must be personally rendered by the physician. Supervised postgraduate trainees are the main exception, under their own billing rules. The brief lists inappropriate delegation among the common problems it sees in claims.¹

The OMA's guide to delegated procedures is more specific. Physician services, such as assessments, counselling, therapy, consultations and diagnostic service interpretations, cannot be delegated to a non-physician for OHIP payment. They must be personally rendered by the physician to be paid.²

This is a payment rule. If a service that had to be personally rendered was performed by someone else, the claim did not meet OHIP's requirements, however good the care was and whoever signed the note.

What can be delegated

The Schedule's General Preamble allows a narrow category of delegated procedures. According to the OMA guide, a delegated procedure is payable when all of the following hold:²

The procedure is one generally and historically accepted as something a trained non-physician can perform under a physician's supervision.
The delegate is properly trained and is employed by the physician, under an employment contract.
The procedure is performed in the physician's office or clinic.
The physician is physically present and immediately available to intervene.

A short list of procedures can be billed without the physician present, including venipuncture, injections and immunizations, simple office laboratory procedures and simple spirometry. Those still require a trained delegate, the physician's own patient, and a chart note recording that the delegate performed the procedure.

Where specialist practices run into trouble

The rules are clearest in a solo office. They get harder in the settings where specialists actually work.

Staff employed by someone else. The OMA guide states that delegated procedures performed by people employed by a public hospital, a public health unit, a long-term care facility or a Family Health Team are not eligible.² A nurse on a hospital unit or in a long-term care home is not the physician's employee for this purpose.

The physician is elsewhere. A clinic that keeps running while the physician is on the ward, in the operating room or on a call block can produce delegated procedure claims for a time when the physician was not present.

Assessments that staff performed. In a busy clinic, a nurse or physician assistant may take the history and examine the patient, with the physician reviewing and signing. If the claim is for an assessment, the question is who performed the assessment. A co-signature does not change the answer.

College rules and OHIP rules are separate. The CPSO governs when a physician may delegate a controlled act. OHIP's payment rules decide what can be billed. A delegation that is appropriate clinically can still be one that OHIP does not pay for.

Why it lands on the physician

The October letters state that physicians are responsible for all claims submitted under their billing number, "regardless of who submits the claims on their behalf."

Most delegation problems are not decisions. They build up through scheduling: a nurse starting before the physician arrives, a clinic that keeps going while the physician is called to hospital, a billing template that submits an assessment code by default. None of it shows on a remittance. OHIP's automated checks cannot tell who was in the room.

It shows up in a review. Under the Health Insurance Act, a service "not rendered in accordance with" the Act and its regulations is one of the findings that allow the General Manager to refer a matter to the Health Services Appeal and Review Board.³

Knowing where your practice stands

We review the last six months of a specialist's billing. For a team-based practice, that includes which services were billed under the physician's number, on which days, and how they line up with where the physician was. 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.

If you find a problem in your own billing, get legal advice before you contact the Ministry or make voluntary corrections. The CMPA is the usual first call.

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: quick reference guide, updated November 2020.
Ontario Ministry of Health, Summary of physician FFS post-payment audit process, March 2021.
Ontario Ministry of Health, letter "RE: HIGH VOLUME BILLINGS", Payment Accountability and Fraud Control Unit, October 2026 (template wording).

If your practice uses staff to extend the physician's day, start with a free review of your last six months.