A family physician in Madoc, Ontario, is criticizing the provincial government after receiving a warning letter regarding his high volume of billed workdays. The Ontario Medical Association claims hundreds of doctors were targeted by the Ministry of Health for "abnormal billing patterns" despite a critical shortage of primary care providers.
The 15-hour threshold for 'abnormal' billing
The Ontario Ministry of Health has defined "abnormal billing" as instances where a physician bills more than 15 hours of services in a single day or treats more than 100 unique patients in one day. According to CTV News,the ministry describes these letters as "educational outreach" intended to communicate OHIP billing practices rather than an accusation of fraud .
However, the tone of these communications has been described as intimidating by the recipients. Dr. Adam Stewart, the Madoc-based physician who first publicized the issue on social media, noted that the letter he received on October 27 did not specify the exact threshold he had crossed, leaving him with a "watch your back" impression.
A $3.4 billion plan clashing with administrative warnings
This administrative crackdown comes at a time when the Ontario government is heavily investing in the primary care sector. As reported by CTV News, the province has implemented a $3.4 billion Primary Care Action Plan, which the government claims has already connected 511,000 patients to primary care providers.
The Ontario Medical Association (OMA) argues that there is a fundamental contradiction in the province's strategy. OMA President Dr. Rebecca Hicks stated that physicians have increased their capacity to help address the fact that 2.5 million Ontarians currently lack a family doctor, only to be rewarded with warning letters for the resulting increase in workload.
How EMR activity triggered Dr. Adam Stewart's warning
A central point of contention is how the Ontario Ministry of Health tracks "days worked." Dr. Adam Stewart, who manages a patient load of approximately 1,700 people, explained that modern medical practice involves constant interaction with Electronic Medical Records (EMRs) to review test results, prescriptions, and referrals.
Because these administrative tasks occur daily—often on evenings, weekends, and holidays—physicians may appear to be working every single day of the year. Dr. Stewart emphasized that being active in an EMR does not necessarily mean a doctor is physically seeing patients in a clinic every day, yet these patterns are what trigger the ministry's flags.
What criteria did the Payment Accountability and Fraud Control Unit use?
The Ontario Medical Association is now demanding transparency regarding the specific selection process used by the ministry's Payment Accountability and Fraud Control Unit. Specifically, the OMA wants to know the exact criteria used to flag these physicians and what the government actually hopes to achieve by sending these warnings.
It remains unclear why the ministry chose to send intimidating letters rather than providing a clear, transparent guide on billing limits before flagging physicians.. The source reporting indicates that the government has not yet provided a detailed explanation of the selection algorithm used to identify "abnormal" patterns.
The FHO+ model and the April 1, 2026 transition
The friction over billing occurs as Ontario transitions to the modernzied Family Health Organization (FHO+) payment model, which the source notes takes effect April 1, 2026. this new model aims to provide hourly compensation for direct patient care, clinical administration, and telephone care delivered outside the office.
While the Ontario Ministry of Health points to its "Patients Before Paperwork" initiative—which it claims has saved physicians over 95,000 hours—doctors like Dr. adam Stewart worry that the current atmosphere of surveillance will discourage physicians from taking on more patients from the province's extensive waitlists.
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