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Virtual care billing for Ontario psychiatry: where claims fail

Virtual psychiatry claims rarely reject. They pay at different rates and depend on records OHIP checks later. Where Ontario virtual care claims fall short.

Most virtual psychiatry billing problems never show up as a rejection. The claim pays. The remittance shows a paid line. The problem is a lower payment than expected, or a chart that will not support the claim if the Ministry looks at it later.

This post covers where virtual psychiatry claims fall short in Ontario: the payment difference between video and telephone, the relationship rule, the location rule, and the records time-based services depend on.

Why virtual claims fail without a rejection

OHIP pays comprehensive virtual care by modality. A video service pays the same as the equivalent in-person service. A telephone service generally pays 85% of it.1 Every virtual claim carries a tracking code that tells OHIP which one it was: K300 for video, K301 for telephone.

Neither tracking code triggers a rejection. A session that started on video and finished on the phone, or a booking template that defaults to telephone, pays at the lower rate without any error appearing. The difference sits inside a paid line on the remittance, where a monthly glance at totals will not catch it.

Some counselling and psychotherapy codes are treated differently when delivered by telephone. Which codes, and at what rate, is set out in Appendix J of the Schedule of Benefits. Check the current version rather than a summary.

Consultations are billed by video

The Ministry's billing brief on comprehensive virtual care lists specialist consultations under video only.1 It lists no telephone consultation code. Telephone can be used for follow-up once the relationship exists.

For a psychiatry practice, this matters at intake. A new referral seen by phone because the patient could not join a video call does not bill as a consultation.

The existing relationship rule

Comprehensive virtual care depends on an existing patient-physician relationship. In most cases that means at least one insured in-person service in the preceding 24 months, or a qualifying video consultation in that period.1 Once the relationship exists, virtual follow-up is payable for the next 24 months.

Without it, the visit falls under limited virtual care, billed with separate codes (A101 for video, A102 for telephone). Practices that run largely online, or that inherit patients from a departing colleague, should know which of their patients meet the test. The claim will usually still pay. The question is whether it would hold up on review.

Both of you need to be in Ontario

A virtual service is only insured when both the patient and the physician are located in Ontario at the time.1 Students away at school, patients at a cottage across the border and physicians working while travelling all raise the question. The chart should record where the patient was.

Time-based records do not relax for virtual care

Psychotherapy and psychiatric care are billed in time units, with minimum durations set by the Schedule. The Ministry's billing brief on time-based services requires the start and stop times of direct contact in the patient's medical record.2 A total such as "50 minutes" does not meet that standard. Neither does relying on the EMR's appointment block or the video platform's log.

Only direct contact with the patient counts. Charting after the session, writing prescriptions and coordinating care do not.

Virtual sessions make this harder. There is no walk to the door and no paper chart to close. The next video call starts as soon as the last one ends, and times get estimated at the end of the day. OHIP's claims system does not read chart notes, so an estimated time passes at submission. It only matters if someone reviews the chart. When that happens, a time-based claim without recorded start and stop times can be treated as unsupported and the payment recovered.

Full days of psychotherapy, and the Ministry's new letters

In late October 2026 the Ministry began sending physicians letters about high volume billings. One version flags services to a high number of patients in a single day. The letter points physicians to the time-based services brief cited above, and to the rules on services that must be personally rendered.

A psychiatrist running a full day of virtual psychotherapy is the profile those letters describe. The work can be entirely legitimate. The record has to show it: times that add up within the day, and services billed under the physician's number that the physician delivered. Our explainer covers what the high volume billings letter says and what the OMA has advised.

What a review looks at

When we review a psychiatry practice's billing, virtual care is one of the first places we look. We compare how claims were submitted with how the work was delivered: video against telephone, consultation against follow-up, recorded time against units billed. We also look at what was rejected and never resubmitted. For psychiatrists with a backlog of unpaid claims, our psychiatry claims recovery page explains how that work runs.

The review covers your last six months of billing and costs nothing. You see what we find before you decide anything.

References

  1. Ontario Ministry of Health and OMA Education and Prevention Committee, Virtual care 1: comprehensive and limited virtual care services, billing brief, updated March 2025.
  2. Ontario Ministry of Health and OMA Education and Prevention Committee, Requirements for time-based services, billing brief, updated June 2025.
  3. Ontario Ministry of Health, Schedule of Benefits for Physician Services, including Appendix J.

If you are not sure your virtual claims are paying at the right rate, start with a free review of your last six months.

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