Regulation Matters 2018 - Issue 1

Professional Billing Practices

Billing practices reflect a dietitian's professionalism. Invoices, receipts and accounts must all accurately record the dietetic services that were provided. Fees must be clearly communicated to clients and a dietitian must ensure that the client understands the information before a treatment is implemented.
A failure to maintain honest and informed billing would be considered professional misconduct. There are several provisions in the Professional Misconduct Regulation that apply to an RD’s billing practices:

“22. Failing to keep records as required.
27. Submitting an account or charge for services that the member knows is false or misleading.
28. Charging a fee that is excessive in relation to the service charged for.
29. Failing to itemize an account for professional services if requested to do so by the client or the person or agency who is to pay, in whole or in part, for the services.
30. Offering or giving a reduction for prompt payment of an account.
31. Failing to inform the client of all available payment options.”

Keep Accurate and Transparent Financial Records

As per the Professional Practice Standards for Record Keeping, Standard 4, RDs must maintain financial records whenever billing occurs in dietetic practice. Receipts must be issued for dietetic services and/or products sold to clients, either directly or indirectly through a third party. Records of any receipts issued and payments received must be documented in either the client health record, the RD’s accounting records or both (as applicable).

Secure Financial Records for the Full Retention Period

RDs also need to ensure a system is in place for the secure retention of financial records for individual counselling services for at least 10 years after the date of the client’s last visit; or if the client was younger than 18 on their last visit, at least 10 years after the date that the client turns, or would have turned, 18 years of age.

Charge Reasonable Fees

RDs should ensure that their billing practices are accurate, transparent and reflective of the dietetic services provided. Charging a fee that is excessive for the dietetic service provided could be considered professional misconduct. While the College doesn’t have fixed charges or specified maximum fees for dietetic services, at some point a high fee can become excessive. Charging a very high fee becomes particularly concerning where a client is financial vulnerable or incapacitated.

Have a Transparent Fee Structure

RDs should establish a process for itemizing receipts issued to clients and/or third party insurance companies. Clear policies surrounding volume discounts (e.g. purchasing three follow-up visits together), including options for purchasing individual appointments as well as policies for refunds for unused sessions, should be clearly communicated to clients to ensure they fully understand these billing practices.

Offer Fair Payment Options

Offering a reduction for prompt payment of dietetic services is not permitted. This provision in the Professional Misconduct Regulation suggests that those with financial means will be able to take advantage of the reduction, while those with modest means may end up paying more for the same service. This does not prevent an RD from charging interest on overdue accounts. RDs should also inform clients of all the payment options they have available.
NOTE: As regulators of the dietetic profession in Ontario, the College does not set or recommend fee schedules for dietetic services. The Consulting Dietitians Network of Dietitians of Canada conducts periodic environmental scans of dietetic private practice fee schedules. Dietitians can refer to this information as a resource.