Requirements for time-based services

Education and Prevention Committee Billing Briefs

Education and Prevention Committee (EPC) Billing Briefs are prepared jointly by the Ministry of Health (MOH) and the Ontario Medical Association (OMA) to provide general advice and guidance to physicians on billing matters.

Category: All physicians    
Date Issued: March 31, 2021    
Date Updated: June 27, 2025 – Updated to provide additional information and clarifications to support physician claims for payments. This EPC Billing Brief has also been updated to a web page-based format, replacing the previously published PDF version.

Overview

Some OHIP insured physician services are only eligible for payment if they have been performed for a certain period of time (“time-based services”). Time-based services in the Schedule are one of two types:

1. Services required to be performed for a minimum amount of time to be eligible for payment (“minimum time services”).
2. Services paid based on time-based units or a combination of basic units and time-based units (“unit services”).

This Billing Brief will assist you in understanding the payment requirements for time-based services generally, and minimum time services and unit services specifically, including how to determine the time period that may be claimed and common concerns leading to incorrect submissions.

For additional information, please see EPC Billing Brief Time-based services: Case-based billing examples, which provides case-based examples to illustrate the application of many time-based service requirements and conditions in the Schedule.

Key requirements for time-based services

• Services must be personally rendered by the physician (unless rendered by postgraduate medical trainees in accordance with payment requirements for Supervision of Postgraduate Medical Trainees – see Billing by a Supervising Physician for OHIP Services Provided by Postgraduate Medical Trainees | Education and Prevention Committee Billing Briefs | ontario.ca for more information).
• The time claimed for time-based services must not overlap with time spent providing any other billable service (to the same or any other patient).
• The physician must spend the minimum amount of time specified in the Schedule for each time unit to claim a unit service.
• As stated in the Schedule General Preamble (page GP7, f and g), the physician must record on the patient’s permanent medical record, the times when the time-based service started and ended.
• Unless otherwise specified in the fee code description (example, life threatening critical care), only the time spent in direct contact with the patient while providing a service that is medically necessary is to be used when calculating time.
• Unless otherwise specified in the Schedule in the description of a specific fee code, there must also be direct personal contact between the physician and the patient (and/or caregiver/family if specified for a particular service).
• All other payment requirements associated with the fee code (non-time-based requirements) and all other general requirements for a claim to be eligible for payment must be met.

Common issues with claims for time-based services

• The absence of medical records or the absence of required information in medical records to support claims for time-based services, such as start and stop times not included on the medical record, or a total time instead of the start and stop times (example, wording that does not meet payment requirements “I spent 20 minutes with this patient”, instead of wording that meets payment requirements “Patient assessed from 10:05 am to 10:25 am”).
• Claiming time-based services in amounts of time that exceed typical office hours or a typical number of hours worked in a day.
• Inappropriate delegation of services.
• Errors calculating the time units or number of time units claimed for unit services, or a discrepancy between the number of time units claimed and the time spent with the patient.
• Including time that is not eligible to be included in time calculations of the time-based service (such as time spent reviewing charts, imaging, or documentation), with the exception of life-threatening critical care or other critical care fee codes as described subsequently in this Billing Brief and on page J30 of the Schedule.
• Including time spent providing other insured or uninsured services to the same or a different patient.

Services with minimum time requirements

When a patient-facing service is a minimum time service and has a minimum time requirement specified in the Schedule, the service is only eligible for payment when:

• the period of direct physician-patient contact while providing the service occurs for the minimum period of time required to claim payment,
• the start and stop times of the direct encounter with the patient are documented in the patient’s permanent medical record, and
• the other payment requirements of the service are met.

Services claimed in time-based units

For unit services that are described and claimed using time-based units, the description of the service in the Schedule provides the time that must be spent providing the service to claim one unit. The Schedule will describe any other conditions that must be met to be eligible for payment of those services.

Note that different unit-based services may have different requirements (described in the fee code description) for whether and how a partial time unit period should be claimed.

• Some services may be claimed for “any part” of the time unit (example, surgical assisting).
• Some services require the “greater part” of the time unit (example, psychotherapy, as described below and in Table 2).
• Some services require a “full” time unit (example, K001, detention, requires a full 15-minute unit).

Basic time units for different types of services

The basic unit of time for psychotherapy, hypnotherapy, counselling, primary mental health and psychiatric care and interview services is 30 minutes. To be eligible for payment for the first unit, the physician must personally spend at least 20 minutes with the patient. See the table below for the minimum time required to be spent providing unit services paid in 30-minute increments for each number of units claimed.

Time that is excluded from time unit or minimum time calculations

• Any separately billable services (examples: procedures, CritiCall)
• Specific elements of time-based fee codes that do not require patient-facing time by the physician are not included when calculating time for the purpose of submitting a claim for the service (payment for these elements is included in the pricing of the fee code). Examples include:
  • Completing patient charts,
  • Reviewing patient charts, imaging, or other tests (with the exception of life-threatening critical care and other critical care codes as described below), or
  • Discussions with allied health care professionals (unless related to the care of a critically ill patient as described below) or time spent teaching medical trainees.

Life threatening critical care and other critical care

• The duration of "life threatening critical care" and "other critical care" services that physicians should document is the time they spend evaluating, managing, and providing care to the critically ill or injured patient to the exclusion of all other work.
• For example, time spent with the patient in transport (such as to the ICU or surgery), reviewing laboratory test results or discussing the critically ill patient's care with other medical staff in the unit or at the nursing station on the floor would be included in the definition of critical care, even when it does not occur at the bedside, if this time represents their full attention to the management of the critically ill/injured patient.
• However, time spent performing insured services not included in the list of elements of critical care fee codes (example, chest tube insertion, application of cast, etc.) should not be used to calculate the time spent providing a critical care service.
• Time spent involved in activities in any location other than the bedside, emergency department or hospital floor where the patient is located is not eligible to be paid as a critical care fee code as the physician is not immediately available to the patient.
• Physicians should submit claims with a manual review indicator and written explanation when the total time spent in providing "life threatening critical care" or "other critical care" is greater than two (2) hours.

Services claimed using time-based and basic units

Anesthesia services (surgical service fee codes with C suffix) and surgical assistant’s services (surgical service fee codes with B suffix) are claimed based on the number of basic units associated with each procedure (where applicable) as well as time units calculated for each 15 minutes or part thereof spent providing the service.

To aid in calculating units of time-based services for anaesthesia and assisting at surgery, refer to Appendix H of the Schedule.

Supervision of postgraduate medical trainees providing certain services claimed using time-based units

When Psychotherapy, Psychiatric and Counselling, Interviews, Hypnotherapy, Psychiatric Care or Primary Mental Health Care services are provided by postgraduate medical trainees under supervision, additional rules limiting the number of allowable units are outlined in the Schedule General Preamble (page GP82) and include:

• Any time taken in discussion with the Medical Trainee about the case is not eligible for payment,
• The maximum number of time units payable for a time-based-unit service rendered by the medical trainee(s) to an individual patient is two units,
• The maximum number of time units payable for a time-based-unit service rendered by the medical trainee(s) to a group of two or more patients is four units, and
• Where there is more than one Medical Trainee (under the supervision of the same Supervising Physician) participating in the rendering of a time-based-unit service concurrently to the same patient, only the time units rendered by one Medical Trainee are eligible for payment to the Supervising Physician.
• Where a Supervising Physician is supervising more than one Medical Trainee providing services to different patients, refer to the table on page GP83 of the Schedule and associated payment rules to determine how many concurrent services may be claimed.

For more information please see the related Billing Brief: Billing by a Supervising Physician for OHIP Services Provided by Postgraduate Medical Trainees | Education and Prevention Committee Billing Briefs | ontario.ca.

Surgeons claiming surgical assistant fees when working with a second surgeon

As outlined below, the surgeon(s) providing surgical assistant services should claim payment based on the clinical scenario that applies. This will determine whether or not basic surgical assistant units are eligible for payment.

Scenarios where basic and time units are eligible for payment to a surgeon providing surgical assistant services:

• When elective bilateral procedures are performed by two surgeons at the same time:
  • One surgeon should claim for the surgical procedure.
  • The other surgeon should claim the assistant’s benefit (basic and time units).
• Where two surgeons are working together in surgery in which neither a team fee nor other method of payment is set out in the Schedule, and the two surgeons are both providing components of the main procedure rather than in different specialized fields:
  • One surgeon should identify themself as the operating surgeon and claim accordingly.
  • The other surgeon who is assisting the operating surgeon should identify themself as the surgical assistant and claim the assistant’s benefit (basic and time units).
  • See Example 2, Peripheral nerve surgical procedures EPC Billing Brief.

Scenarios where only time units (not basic units) are eligible for payment to a surgeon providing surgical assistant services:

• If the nature or complexity of a procedure requires more than one operating surgeon, each providing a separate service in his/her own specialized field:
  • This statement applies when the additional procedure(s) are not the usual components of the main procedure (example, a general surgeon resects a tumour and a plastic surgeon performs reconstructive procedure; a hand surgeon reconstructs digital amputation and a facial surgeon repairs facial fractures; etc.).
  • Each surgeon should claim the appropriate surgical fee code(s) for the procedure that they perform primarily.
  • If a surgeon acts as an assistant for the portion of the procedure that they do not perform primarily, they may claim time units for the portion of the procedure spent assisting but may not claim the basic surgical assistant units for that portion of the procedure.

Keywords/tags

OHIP Claims; OHIP Payment; Time Based Codes; Time Based Services; Time Based Units

More Information/Additional Billing Resources

• EPC Billing Brief Time-based services: Case-based billing examples
• Understanding the Schedule of Benefits for Physician Services
• Billing by a Supervising Physician for OHIP Services Provided by Postgraduate Medical Trainees | Education and Prevention Committee Billing Briefs | ontario.ca
• Education and Prevention Committee Billing Briefs
• OHIP InfoBulletins

Contact information

For additional information, please visit the Resources for Physicians and the How to Get Help with Billing Questions pages on the ministry website.

If you have any billing or claims submission inquiries, please contact the Inquiry Services, Service Support Contact Centre (SSCC) by email or by calling 1-800-262-6524.

To provide feedback on EPC Billing Briefs, or to suggest topics for future EPC Billing Briefs, send an email to the attention of the joint MOH/OMA Education and Prevention Committee.

The Ministry of Health (MOH) and the Ontario Medical Association (OMA) have jointly prepared this educational resource to provide general advice and guidance to physicians on specific billing matters.

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Note: This document is technical in nature and is available in English only due to its limited targeted audience. This publication has been exempted from translation under the French Language Services Act. For questions or support regarding this document, please contact the Service Support Contact Centre (SSCC) by email or by calling 1-800-262-6524.

Remarque : Ce document est de nature technique et est disponible en anglais uniquement en raison de son public cible limité. Ce document a été exempté de la traduction en vertu de la Loi sur les services en français. Pour toute question ou de l’aide concernant ce document, veuillez contacter Les Services de renseignements, Centre de contact pour le soutien des services par courriel ou en téléphonant le 1-800-262-6524.