What’s possible
What Canadian law and medical regulators allow a virtual clinic to do, the conditions attached, and how the platform handles each. A planning summary for counsel review, not legal advice.
Licensure follows the patient’s physical location at the time of the visit. The physician must meet the same standard of care as in person and arrange in-person care when needed.
Clinically allowed when phone is appropriate for the concern. Several provincial plans pay less for phone, or limit insured phone care to patients with an existing relationship.
Acceptable when the physician can meet the standard of care in writing. Usually not insured as a standalone service, so it is either bundled into an insured visit or offered only for genuinely uninsured services.
Not permitted without a licence in the patient’s province. The Atlantic Physician Register lets physicians licensed in Nova Scotia, New Brunswick, PEI or Newfoundland and Labrador practise across those four provinces; some colleges allow limited follow-up of existing patients. Each exception needs confirmation.
Foreign medical-practice laws apply where the patient is, and provincial plans generally do not pay. We do not offer it.
Needs a Collège des médecins du Québec licence, a RAMQ billing arrangement, French-language service and compliance with Québec’s Law 25, including a privacy impact assessment before data leaves Québec.
Consent depends on capacity rather than a fixed age in most provinces; Québec allows consent from 14. Parent or guardian involvement for younger patients.
A virtual clinic is not an emergency service. Red-flag symptoms must be redirected to 911, emergency departments or 9-8-8.
Only with express, informed consent; the recording becomes part of the medical record and is kept and protected like one. Default off.
Allowed with patient consent, physician review of every note, a privacy impact assessment and a vendor that keeps data in Canada.
Allowed after an appropriate assessment, with the same documentation and follow-up expectations as in person.
Federal law allows practitioners to prescribe them, but colleges set stricter virtual-care expectations and the risk of diversion is high. We do not prescribe them to virtual-only patients.
The physician still has to assess. A message-based renewal is acceptable for stable, low-risk medications when the history is adequate.
Patients choose their pharmacy. Payments or benefits for directing prescriptions are conflicts of interest under college and pharmacy rules.
Secure fax to the patient’s pharmacy works everywhere. E-prescribing networks vary by province, and the national PrescribeIT service was reported shut down in May 2026, so confirm options per province.
Extra-billing and user charges for insured services are prohibited, including access fees, “priority” fees or making a paid document the price of an insured visit.
Allowed when the fee is reasonable, disclosed before the service, and the patient can decline. Hardship consideration is expected; fees may not depend on the outcome.
Visitors, new residents in a waiting period and others without coverage can be charged. Canadians covered by another province are usually billed through reciprocal or out-of-province arrangements, which vary for virtual care.
Only for uninsured services, with an à-la-carte option, and never as a condition of insured care. Ontario calls these block fees and sets rules for them.
Third parties can pay for documents, return-to-work assessments and education. The patient controls what health information is shared.
Allowed as general education. Sessions must not become individual medical advice, and recordings need presenter consent and no patient information.
Disclosed sponsorship, physician control of content, no product promotion presented as medical advice. College conflict-of-interest rules apply.
Incentives tied to issuing documents or prescriptions compromise clinical independence. Pay per session, per hour or per completed service regardless of outcome.
A fair-market fee for real administrative services is common. Fee-splitting that rewards referrals or volume is not allowed. Structure it with counsel.
Most health care is exempt, but some reports and certificates for non-health purposes (for example insurance or legal reports) are taxable.
A technology and administration company can serve physicians. Rules for who can own a medical practice or professional corporation vary by province, so clinical services are usually delivered by a physician-owned entity.
Must be accurate and verifiable. Several colleges prohibit patient testimonials, guarantees and claims of superiority.
Transactional reminders are fine with minimal content. Promotional messages need consent under CASL.
Health information is only used for care and the purposes the patient agreed to. No sale, no lead sharing.
Tracking scripts can leak health information to ad platforms. Keep them off intake, portal and clinical pages.
Not banned for most private clinics, but custodians stay accountable, Québec requires an assessment first, and public-sector partners often require Canadian residency. Canadian hosting avoids the problem.
Every document needs a physician’s assessment and judgment. No outcome can be sold.
A physician may record what the patient reports, but the note must show the real assessment date and must not certify what the physician didn’t observe.
Ontario, B.C., Nova Scotia and federal workplaces restrict when a note can be demanded for short absences. Patients are told before paying.
How the money works
Every dollar maps to a payer that is allowed to pay for that service. Insured care is never a private charge.
| Lane | Who pays | The rule that keeps it lawful | Example |
|---|---|---|---|
| Insured virtual visits | Provincial plan | Physician bills the plan; patient pays nothing. | OHIP, AHCIP, MSP fee codes |
| Uninsured documents | Patient | Reasonable fee disclosed first; charged only when delivered. | C$35 absence note, C$75 return-to-work letter |
| Employer and insurer work | Employer or insurer | Patient consents to what is shared; invoice the third party. | Return-to-work assessment, insurance report |
| Uncovered patients | Patient | Only when no plan covers them where they are. | Visitors, waiting-period residents |
| Education | Attendee or sponsor | General education, disclosed sponsorship, no individual advice. | C$25 webinar, employer wellness session |
| Platform administration | Physician group | Fair-market fee for real services; no per-note or referral incentives. | Scheduling, billing, records, support |
Province by province
Booking opens in a jurisdiction as soon as an active physician licensed there joins. Each one needs its own billing set-up.
| Jurisdiction | Plan | Regulator | Local rules |
|---|---|---|---|
| British Columbia | MSP | CPSBC | Read guidance |
| Alberta | AHCIP | CPSA | Read guidance |
| Saskatchewan | Saskatchewan Health | CPSS | Read guidance |
| Manitoba | Manitoba Health | CPSM | Read guidance |
| Ontario | OHIP | CPSO | Read guidance |
| Quebec | RAMQ | CMQ | Read guidance |
| New Brunswick | NB Medicare | CPSNB | Read guidance |
| Nova Scotia | MSI | CPSNS | Read guidance |
| Prince Edward Island | PEI Medicare | CPSPEI | Read guidance |
| Newfoundland and Labrador | MCP | CPSNL | Read guidance |
| Yukon | YHCIP | Yukon Medical Council | Read guidance |
| Northwest Territories | NWT Health Care Plan | NWT Registrar | Read guidance |
| Nunavut | Nunavut Health Care Plan | Nunavut Registrar | Read guidance |