The Situation

The College received a report about a physiotherapist-owned clinic allegedly involved in inappropriate business practices. 
 
A College investigator attended the clinic as a patient and was offered a discount for the services, paid in cash and was given no receipt. She noted patient files were piled on top of the reception counter and on filing cabinets throughout the clinic. 
 
Through a chart audit, the investigator could see that patients were billed and managed differently. Assessment and treatment fees varied. While some records contained no details about how much was charged, how the person paid or had copies of invoices, others did. Only selective information was entered into the computer system.       
 
These observations were confirmed by the receptionist. When the investigator interviewed her, she reported that when someone paid with cash, no receipts were issued and the payment was not entered into the computer system.
 
As in all investigations, the physiotherapist was provided with the information gathered in the investigation and asked whether she wished to make a submission about it to the Inquiries, Reports and Complaints Committee which would be considering what to do, if anything.

The physiotherapist confirmed that patients who paid cash received no receipt and were given a discount to reflect her reduced costs because the transaction took less administrative time. She stressed that all patients are given an invoice if they asked, and they all received the same quality of care. There was no mention of her patient file storage. 

The Consequences

After reviewing the evidence and considering how the physiotherapist’s behavior measured up against the College’s Standards, the Committee did not accept her explanation as sufficient to justify the deviation from the rule.       

Offering discounts is not a breach of the Advertising, Fees & Billing and Conflict of Interest Standards, however the Committee was concerned about the physio’s failure to keep complete financial records for all her patients, her failure to provide receipts and her apparent lack of concern about the confidentiality and privacy of her patient records.

The physiotherapist was required to: 

1.  Complete a practice assessment and hire a practice enhancement coach. When the practice assessment is complete, the Registrar will assess if the physiotherapist met the program requirements. The coaching program must be completed within two years, but can end earlier if the physiotherapist shows that she has made the necessary practice changes.

2.  Submit a reflective paper about patient record security and appropriate record keeping as it relates to fees and billing.

In addition, the Committee indicated that from a risk management perspective, omitting billing details and receipts for services may make a physiotherapist vulnerable to legal and professional challenges. It has the potential to be viewed as a sign of non-compliance with business tax obligations.

Resources

Standard: Record Keeping
Guide: Record Keeping
Record Keeping Checklist
Record Keeping Infographic
Standard: Fees and Billing
Guide: Fees and Billing
Standard: Conflict of Interest
Guide: Conflict of Interst