Doctors flagged for high billing volumes say letters penalize hard work
A letter dated Oct. 27, 2026, from Ontario’s Ministry of Health told doctors their billing showed a “high number of days worked in a single year.” The Ontario Medical Association (OMA) says the warning punishes physicians for doing more work.
The letter came from the ministry’s Payment Accountability and Fraud Control Unit, and the OMA told CTV News it has reached “hundreds” of physicians. Elyse Sunshine, a health lawyer at Rosen Sunshine LLP in Toronto, wrote that the letters concern what the ministry describes as “HIGH VOLUME BILLINGS.”
Physicians mostly bill the Ontario Health Insurance Plan (OHIP) as independent practitioners, but the letter’s wording offers HR leaders a case study in how workload monitoring, framed poorly, can alienate an organization’s hardest workers.
What does the letter say?
The letter states that physician billing is monitored “to support the integrity, accountability, and sustainability” of OHIP, CBC News reported after reviewing a copy. It flags “anomalous behaviour” – billing higher than that of physicians with similar practice profiles.
Its language is pointed. The letter calls the pattern “uncommon” and says it warrants “careful review,” CTV News reported. It also reminds recipients they are “responsible for all claims” under their billing numbers.
Yet it also concedes that “billing data alone may not fully capture the circumstances of an individual physician’s practice,” Healthy Debate reported. Recipients are asked to review their claims, and further review may follow.
What does the letter leave out?
What it does not include is any number. Dr. Adam Stewart, a family physician in Madoc, Ont., told CTV News his letter did not state how many days he worked or what threshold he crossed.
“Do they really want us to work less days?” he said.
The ministry explained its thresholds only to the media. It told CTV News that abnormal billing means more than 15 hours of services, or more than 100 unique patients, in one day, and that the outreach “does not assume billing was inappropriate.”
Why the timing stings
Those reassurances arrived as the OMA argued that physician capacity is already stretched thin. On Nov. 2, 2026, it released Ipsos polling showing one in three Ontarians reported longer specialist wait times over the past year.
The OMA linked those delays to rising overhead, administrative burden and staffing shortages. Among Ontarians with a chronic condition, or a household member with one, 22% waited six months or longer after their latest specialist referral.
Against that backdrop, the letters stung. The OMA told Healthy Debate they will have a “chilling effect” on doctors’ willingness to work additional hours.
Takeaway for HR leaders
Sunshine warned that dedicated physicians may become nervous or cut back rather than risk an audit. “The system needs to be able to tell the difference,” she wrote, urging recipients to learn exactly what triggered the flag.
That advice translates directly to employers. In Ontario, the Employment Standards Act, 2000 (ESA) already requires employers with 25 or more employees to keep a written policy on electronic monitoring – so staff know how and why they are monitored. Disclosing the thresholds behind any productivity flag follows the same logic.
Tone matters too. The National Standard of Canada for Psychological Health and Safety in the Workplace lists recognition and reward and workload management among 13 workplace factors affecting employee mental health.
A 2025 Robert Half survey found HR and legal professionals report the highest burnout levels in Canada. That finding, and our coverage of how burnout among Canadian workers is intensifying, show that overlooking those factors carries real costs.
The same point is echoed in earlier reporting on how HR can help burned-out Canadian employees.
