- It is the physiotherapist’s responsibility to know the Standards of Practice and how the Standards apply to their practice.
- Physiotherapists must be familiar with the funding systems that apply to their practice.
- The Funding, Fees, and Billing Standard of Practice (2025) includes updates to performance expectations related to:
- Billing practice
- Pre-payment for physiotherapy services
- Fees for chart copies
- Product sales
It is every physiotherapist’s responsibility to be familiar with the Standards of Practice and how they apply to their own practice. As the 2025 Standards of Practice come into effect in January, there are several changes to the Standards to be aware of. Some of the changes are simple changes of wording, while others are more advanced. In the coming months, the College will be highlighting the changes made and publishing articles and resources to highlight the changes.
In this article we are highlighting updates to the Funding, Fees, and Billing Standard of Practice (formerly Fees and Billing). The intent of the name change was to clearly identify that you have a responsibility to understand the funding needs of the a client. Private practice has potentially more funders such as:
- Insurance companies
- WCB
- Extended health benefits
However, this Standard also applies to those working in public practice as you may:
- Work as an AADL authorizer
- Bill out for products
- Occasionally treat a WCB client
Highlight #1 – Billing Practice
The physiotherapist:
- Does not represent non-physiotherapy services as physiotherapy on invoices or receipts.
- Is responsible for all billing under their registration number, and to identify and correct any errors promptly.
- Promptly provides clients with clear, transparent, accurate and comprehensive invoices or receipts and all explanations required so that the patient understands the fees charged and terms of payment.
These performance expectations were altered to clarify that the physiotherapist is responsible for ensuring that non-physiotherapy services are not billed to patients and third parties as physiotherapy services. The changes also address reports of physiotherapists being unaware of problematic billing practices involving their registration numbers undertaken by other parties within the practice environment. The College of Physiotherapists of Alberta has previously discussed these issues here:
- Good Practice: Is Your Business Keeping Your Client’s Best Interests at Heart?
- Episode 64: Are you Engaged in a Risky Business?
- Good Practice: Separating Physiotherapy and Non-Physiotherapy Services
An important consideration is that physiotherapy services must meet all the expectations found in the Standards of Practice. Physiotherapists should also recognize that insurance companies have also noticed questionable billing practices and have been holding physiotherapists and practice sites accountable for billing practices.
There are many points at which miscommunication could occur around the funding of physiotherapy services, the fees charged to clients, and the billing that is submitted to insurers. It is the physiotherapist’s responsibility to confirm that the client or payor has been provided with “a comprehensive fee schedule that includes transparent and accurate information about billing policies and all potential charges” before they are subject to any fee. It is also the physiotherapist’s responsibility to provide “all explanations required so that the client understands the fees charged and terms of payment.”
Fees and billing policies must be clearly explained to the client in terms they understand. Having a check box in your intake form that tells the client they are responsible for any billing that is not covered by insurance or if their claim is denied does not meet this requirement. The physiotherapist has a duty to ensure that the client understands that they could be on the hook for any unfunded costs of assessment or treatment.
Highlight #2 - Prepayment
The physiotherapist employs policies and measures to mitigate the risks related to pre-payment of services before accepting pre-payment or engaging in bundled service provision, including but not limited to:
- Providing the client with the option to purchase one service at a time,
- Providing refunds for unused physiotherapy services,
- Issuing physiotherapy receipts only after physiotherapy services are delivered.
In the past, the College discouraged pre-payment for bundled services out of concern that the practice could incentivize unnecessary services or fraudulent behaviour, whether intentional or not. With this iteration of the Standards, the College’s stance has shifted to allow pre-payment and bundled services, provided the physiotherapist has measures in place to mitigate the risks of pre-payment.
Physiotherapists may on occasion offer block pricing or bundling of services to their clients. This could be for GLA:D programing, post-op ACL ruptures, TKRs, or other common conditions that typically require a longer, somewhat predictable course of treatment.
With this approach, the client will pay at the beginning of a physiotherapy program or bundle services and receive receipts for physiotherapy services after each or appointment. Often, pricing for physiotherapy programs or bundled services are set at a slight discount when compared to the cost of the same number of treatments paid individually.
Supporters of block or program pricing cite the benefits of clients keeping up with their treatment plans and fewer issues with scheduling clients, however; there are some very important points to consider if you are implementing this business practice to mitigate the risks related to the practice.
There must be clear communication upfront ensuring the client understands how prepayment plans or treatment bundles work. Although the practice may provide an incentive to sign up for the bundle, such as a discount that is clearly communicated on the fee schedule, the client must have the option to pay as they go.
There must also be policies in place to provide refunds of pre-paid services that are unused. Policies about pre-payment, including refund policies, must also be clearly explained so that they are easy for the client to navigate.
Finally, the requirement to issue receipts for physiotherapy services only after each appointment helps to address the risk of fraudulent behaviour as clients can only submit receipts for third-party reimbursement after the physiotherapy service has been delivered.
Highlight #3 - Chart copy fees
Establishes fees for access to client records that are:
- Consistent with the requirements of applicable legislation,
- Reflect the costs of providing a copy of the client record, and
- Are consistent regardless of the party requesting access.
Physiotherapists are expected to know the privacy legislation that applies to their client records and have always been required to adhere to the requirements of privacy legislation. What has changed with this version of the Standard is that the College has specified long held direction to registrants that:
- The fee charged for a chart copy cannot change depending on who is asking for the record. It is not acceptable to charge a lawyer (or any other party authorized by the client to access the record) a fee that differs from the one the client would be charged if they requested the record.
- The fee you charge for a chart copy must reflect the actual cost of producing the record. Remember that the information in the record belongs to the client. Although the physiotherapist can charge a fee for a copy of the record, the fee should not represent a barrier to the client’s ability to gain access to their own information and must not be a source of revenue for the practice. If questioned you should be able to justify the cost to produce the chart such as the time spent by staff and the cost of any resources (i.e., office supplies) that were required.
The College has previously highlighted the different pieces of privacy legislation that can apply to client records and the fees that physiotherapists can charge for chart copies. You can read more about those topics here:
Highlight #4 - Product Sales
- If selling products, [the physiotherapist] must inform the patient that they have the option to purchase the product from another supplier, and that their choice to do so will not affect their physiotherapy services.
As a physiotherapist, you are unable to receive a commission from the sale of any products. This performance expectation lessens the risk of a financial conflict of interest and enables you to give honest and transparent information and recommendations to clients about the products available. Clients need to understand that regardless of whether or where they choose to purchase a product, their decision will not impact the services they receive at your practice site.
The Funding, Fees, and Billing Standard of Practice provides expectations for physiotherapists across many different areas of practice. In the coming months the College will continue to highlight the changes that were made to the Standards of Practice. All physiotherapists need to review and understand the updated Standards. If you do not understand the standards, contact the Practice Advisor for assistance. You can reach them at 780.702.5390 or professionalpractice@cpta.ab.ca
Sean FitzGerald, PT, Practice Advisor
