Professional Billing

A registered dietitian demonstrates the standard by:

1. Accurately recording dietetic services and products provided and maintaining accurate financial records (e.g., invoices, receipts) in either the client’s health record, the dietitian’s accounting records or both for the secure retention period¹ as noted in the Record Keeping Standard.
2. Charging reasonable fees of an amount that is appropriate and relates to the dietetic service(s) provided and is not excessive in relation to the service(s).
3. Obtaining client-informed consent for fees and payments prior to service provision.
4. Never issuing misleading invoices or receipts (e.g., backdating invoices).
5. Clearly communicating fee schedules for all dietetic visits or services before services are provided. This includes informing clients of all available payment options, any administrative fees, bundles, packages, or block fees, co-payment/deductible for direct billing, and external fees outside of usual visits (e.g., analysis of laboratory tests or other dietetic services like meal planning).
6. Clearly providing payment due date expectations and setting reasonable fees for prepayment, overdue payment or missed or cancelled appointments, if applicable.
7. Providing itemized accounts for services and/or products, if a client or payer requests it, and notification of balances due in a timely manner, including responding to client billing inquiries in a reasonable amount of time (e.g., itemized account requests, refund requests, etc.).
8. Legibly recording invoices and receipts with the following:

a) Name of the dietitian as per the CDO Public Register, clinic/business name (or professional corporation), address (including official business email address for virtual practice), telephone number.

b) College registration number.

c) Name of the client who received the service and their contact information.

• • If providing family-based care, dietitians identify the recipient of services on the invoice and only bill for service in a child’s name or the parent/guardian’s name, not both.

d) Date of service.

e) Services provided.

f) Payments received.

g) Balance owing, as applicable.

h) HST number, if applicable.

i) Any other information required by a third-party funder or insurer.

9. Not suggesting a reduction of fees or other incentives to receive prompt payment.

10. Clearly describe dietetic and non-dietetic services on invoices, receipts, and records, if providing services as another professional (outside of the dietetic scope of practice). This includes indicating services which are not practising dietetics (e.g., yoga, walking groups, psychotherapy).

11. Providing clear written terms to clients if offering bundles, packages or block fees.

Clear written terms include, if relevant:

• volume discounts, including any option for purchasing individual appointments.
• policies for refunds, if any.

• conditions for the bundles, packages and block fees if the relationship is terminated before all services are provided.

Practice Guidelines

Dietitians are encouraged to:

1. Develop written policies on fees, including policies on bundled and package services, refunds, billing practices, billing inaccuracies, errors, and associated documentation. Consider, if warranted to obtain client written confirmation that they have reviewed and understood billing/refund policies.
2. Be mindful of clients’ expectations for discontinuation of dietetic services, especially in the context of refunds for services that are bundles, packages, or block fees.
   • While managing service refunds and expiration dates for bundles, packages, and blocks is at a dietitian’s discretion, dietitians should align their policies with professional, ethical and client-centred care.
3. Take reasonable steps to inform clients of remaining services if a client has purchased dietetic services in a bundle, package or block but has not used the full service. This may include providing reminders of expiration dates for sessions, or of upcoming auto-renewals of subscriptions, if applicable.
4. Seek fee guideline resources for dietetic services and/or products (e.g., fee guidance from professional associations) and be aware of the market/standard rates of dietetic services/products in their area to set fees that are reasonable and appropriate.
5. Clearly state services provided, charges and payments made, and outstanding balance on invoices and receipts.
6. Legibly record on invoices and receipts how the dietetic service was provided (e.g., via telephone or video conferencing).
7. When communicating fee increases to clients:
   • Provide a reasonable notice period to clients for any fee increase.
   • Arrange alternative services for clients who require dietetic services but are unable to pay a fee increase or give the client reasonable notice to arrange alternative services themselves consistent with the Professional Misconduct Regulation.

This resource complements the Billing Standards’ minimum performance expectations and includes advice on common billing questions. The examples are intended solely to provide a general guide to the subject matter.

1. Can I charge fees in advance of providing dietetic services?

Dietitians have the discretion to charge fees in advance of providing services, so long as it relates to the services or products they intend to provide to a client (e.g., an assessment, intervention/treatment plan) and the fee is for the planned service or product.

Dietitians can issue a receipt for advanced payment for a client but should indicate that the service has not been rendered. Once the service is rendered, dietitians should issue an itemized receipt. Be transparent with the client about:

• what is being charged
• when and how the charge will occur
• refund or cancellation conditions

Invoices and receipts should demonstrate a distinction between services rendered, charges, payments made, and any outstanding balance. CDO recommends that any advanced payment charges are clearly outlined in policy shared with clients in advance.

2. Can I charge fees for missed or cancelled appointments?

Yes, however, dietitians are encouraged to create a policy on missed or cancelled appointments and communicate the policy clearly to clients in advance. The fee should reflect reasonable cost recovery. Consider the financial burden for clients and whether there are instances to reduce, waive or allow flexibility on compassionate grounds, including granting exceptions when reasonable to do so (e.g., first incident, intervening circumstances).

3. Can I provide an estimate of dietetic services?

Yes. Clearly communicate fee schedules before providing services. Estimates can be:

• discussed verbally
• shared in writing (e.g., email, printed material).
• posted online or in your office

Ensure estimates are clearly distinguishable from billing invoices.

4. What does setting “reasonable fees” mean?

The Standard highlights that dietitians must charge reasonable fees. Reasonable fees are not defined in the legislation, so it is expected that dietitians use professional judgment and consider:

• Guidance from professional associations on dietitian fee suggestions (e.g., Dietitians of Canada, Dietitians in Private Practice: A Guide for the Consultant).
• An environmental scan to determine fees for dietitian services in their geographic area (or comparable jurisdictions/areas), area of practice, and experience level.
• What the dietetic service entails when setting fees (e.g., nature and complexity of the service, the time spent, cost of materials, any travel time, etc.).
• Consulting with other dietitians on fee guidance.
• Information from a third party (e.g., insurance company) to verify the range of fees.
• Documenting the process on how fees are calculated and justified, providing clear explanation of any fee changes.
• Regularly reviewing and updating the fee structure. This may be done in conjunction with an annual audit of billing practices and policies for currency.

The College does not set renumeration systems, billing models or fee guidance for dietetic services, nor does the College determine or approve fees.

5. What is “reasonable notice” for a fee increase?

There is no specific period of notice for a fee change set out in any regulations or in the Standard as this is a matter of professional judgment. Consider what time frame would be adequate to notify clients ahead of any fee increases so they have time to make alternate arrangements if they are no longer able to continue service.

6. How should I manage digital security for personal information like credit card numbers?

Obtain consent for collection, use and disclosure of personal information, including credit card details. Implement safeguards to protect personal information, including secure disposal. The Privacy Toolkit may be helpful to review.

Dietitians are encouraged to research digital security requirements and agreements, especially when client personal information is shared with third-party payment processors. Agreements should outline how personal health information will be handled, including transfers and disclosures. Dietitians must comply with the Personal Information Protection and Electronic Documents Act to ensure their practice handles personal information in a safe and secure manner.

7. Should I have a refund policy?

Yes, a written refund policy is recommended. It should be:

• clear and accessible
• aligned with ethical and client centred care (e.g., to reduce confusion for clients about conditions for refunds)
• provided in advance, especially for packages and bundles

Consider obtaining written acknowledgement from clients, if needed.  

The practice guidelines suggest that dietitians should be mindful of clients’ expectations for discontinuation of dietetic services, especially in the context of refunds for services that are bundles, packages, or block fees.

8. Can I charge clients a credit card processing fee?

Yes, charging a credit card processing fee is at the discretion of a dietitian but consider the following guiding questions:

Does a credit card processing fee unduly restrict payment or create inequity?

If a client pays by credit card, passing on the credit card processing fee to the client may create inequitable payments for clients paying with a credit card versus clients who pay using another method (e.g., cash, e-transfer). Depending on the significance of the fee, does this increase the charge of service for certain clients (those with credit cards versus those without)?

Are there potential impacts to client satisfaction?

An additional charge may create dissatisfaction, especially for clients who have already paid by credit card in the past and were not charged a processing fee.

Could this be considered “offering or giving a reduction for prompt payment” for cash/e-transfer payments vs. credit card?

Dietitians need to consider whether this practice falls under an act of professional misconduct regarding “offering or giving a reduction for prompt payment of an account,” such that other forms of payment that are more promptly paid (e.g., cash, e-transfer) do not incur additional fees.

Offering a reduction for prompt payment of dietetic services is not permitted by law. This provision in the Professional Misconduct Regulation suggests that those with financial means will be able to take advantage of the reduction, while those with modest means may end up paying more for the same service. This does not prevent an RD from charging interest on overdue accounts.

Are there other alternatives to processing fees?

If processing fees are unsustainable as a business expense, are there ways to manage it, such as only accepting cards that have lower processing fees? Adjusting your fees to cover additional business costs? What are the pros and cons of accepting credit cards as a payment option altogether?

Other considerations:

• How will it be communicated/displayed (e.g., advance written notice, oral communication to clients).
• Are there any consumer protection laws and payment card network operators’ rules (e.g., on certain prepaid cards surcharges may not be permitted)?
• Additional details can be found (but not limited to) here.

9. Can I provide discounted, “pro bono” or “sliding scale” services?

Yes. Dietitians may provide discounted, free, or sliding scale services at their discretion. Sliding scale payments refer to an agreement made between a dietitian and client to pay a reduced rate for dietetic services.

Dietitians use their professional judgment and ensure fee changes:

• do not compromise care
• reflect client need
• are discussed and agreed upon in advance

As with all services, dietitians should come to an agreement on the services to be provided to the client, including the fees charged, and billing arrangements. Discuss any changes with clients in advance.

If a client requests a discount and a dietitian is unable to provide a discount (e.g., do not provide sliding scale payments), discuss this with the client and give options on how they could find another dietitian to continue their dietetic treatment. This article provides guidance on several practice scenarios including discounted services and reduced rates for bundled services.

1. Do I need to charge tax on my invoices?

Charging tax for dietetic services may depend on the type of service being provided. Most dietetic services fall within basic healthcare and are typically tax exempt. The decision as to whether dietetic service is taxable or not lies with the Canada Revenue Agency (CRA) and as such, CDO cannot provide this type of guidance.

Dietitians are advised to check with an accountant, the CRA or review the Excise Tax Act, to ensure most dietetic services are still exempt from the sales taxes. However, services that are provided solely for non-healthcare purposes, even if supplied by healthcare professionals, may not be eligible for tax exemption. Dietitians are responsible for researching this and complying with the requirements of the CRA as tax laws can change.

2. I provide only virtual care. What address should I include on client invoices?

If dietitians are only offering virtual services, and no in-person dietetic services (and do not have a physical business location), then they can request to display a business email address only by emailing the Registration Program at registration@collegeofdietitians.org.

Dietitians are required to post their name, business address and business telephone number on the public register. Section 13 of Bylaw 1: General states a business address is the primary business where the dietitian practices in Ontario including any other business and location at which a dietitian regularly practises in Ontario (including their position at those businesses or locations).

(Standard 1, h, ix. states what dietitians must include on their invoices/receipts. Dietitians must include any other information that insurers require on their invoice. If an insurer requires a physical address, the dietitian must provide it. Dietitians must also indicate how the virtual dietetic service was provided on their invoices (e.g., via telephone or video conferencing) as per the Virtual Care Standards and Guidelines.

3. I may be joining an interdisciplinary practice with other healthcare professionals. What should I consider regarding billing and fee-sharing/splitting?

Before signing a contract, dietitians may wish to consider a partnership agreement which clearly describes the conditions for fee-sharing (or profit sharing) and billing responsibilities among members of the practice. Consider ways to avoid conflict of interest related to billing and fee-sharing/splitting as noted in the Conflict of Interest Standard (e.g., avoid accepting financial incentives for referring a client to any other person, service or program and avoid offering or giving a financial incentive for receiving a client referral).

4. I provide family-based treatment. What should I consider when preparing client invoices?

A dietitian should consider principles such as accuracy and truthfulness when deciding what information to put on an invoice or receipt. It is important to ensure that an invoice or receipt cannot reasonably be seen as, 25. Signing or issuing, in the member’s professional capacity, a document that the member knows contains a false or misleading statement, and/or 27. Submitting an account or charge for services that the member knows is false or misleading.

Identifying the recipient of dietetic service (e.g., client vs parent/caregiver)

In cases where multiple members of a family are treated at different times and in different situations, it would be reasonable to identify the recipient of the dietetic service on the invoice, regardless of the wishes of the client or what their insurance coverage allows.

For example, if an intervention is intended to impart parenting skills to the parent, it might be reasonable to assume that parenting work is intended to help the parents change their behaviour and consider that the services were provided to the parents. This would be different than meeting with the parents to provide them with information that supports the work being done individually with their child (who is the principal client). It may be helpful to determine who the client is at the focus of the intervention and should be identified on any invoice.

Wherever possible, ensure an invoice provides clear information about the nature of the service and identifies to whom the service was provided. If a person to whom the service was provided is different than the person who is the focus of the treatment, it may be appropriate to note on the invoice something like dietetic services provided to Mr. and Ms. Singh re: the treatment of their child Javeed Singh. 

1. How can I help prevent insurance fraud?

• Be aware of the conditions and dollar amounts being billed for your professional services, if the billing is done on your behalf.
• Never sign blank treatment plans or forms.
• Be cautious when asked to provide an electronic signature to someone else (e.g., clinic, client). Understand how it will be used and who will have access to it.
• When you leave a practice, ensure you update the employment and/or contact information for the College’s public register as soon as possible (within 30 days).
• Before signing a new contract, discuss your professional obligations to understand the business’s billing practices. Be clear that your name and registration number should not be used for care or services you do not provide.
• Be selective about the jobs you accept in case of inappropriate or questionable business practices by clinic owners.

2. I have had my name and registration number used by others for fraudulent billing. What should I do?

If a client made a fraudulent claim, dietitians should comply with the insurer’s investigation. Document the information received from the insurer. First, seek guidance from the insurer. Dietitians may discuss the matter with their employer if the issue happened at work and consider if calling their professional liability insurance provider for guidance on fraud and/or associated legal advice.

It can be distressing if a dietitian’s name and CDO registration number is misused, but dietitians can contact the Practice Advisory Service at the College for advice. You may need assistance with filing a complaint if it is a dietitian or another regulated professional using your credentials fraudulently.

Lastly, dietitians may want to consider if local police and/or the Insurance Bureau of Canada or others need to be notified. The Équité Association, is a national, independent group that aims to reduce insurance fraud. Visit www.equiteassociation.com or call their hotline at 1-877-422-TIPS (8477). 

Adapted from the College of Physiotherapists of Ontario (2025). Your name and registration number have been misused. Retrieved from https://collegept.org/resource/inappropriate-business-practices/misused-registration-number/ and College of Speech Language Pathologists and Audiologists (2025). Protecting your credentials when billing. https://caslpo.com/about-caslpo/media-and-publications/express/current-issue/the-wave-july-2025#article2

3. Can I change the service date on a client’s invoice?

No, dietitians should not change service dates on invoices, however, mistakes can happen, and dietitians can amend an invoice if a date was written in error and give the reason for the revision. Dietitians should never issue misleading invoices, including backdating invoices intentionally. This article provides more details.  

 While clients may ask for help to maximize their insurance coverage, insurers could deny benefits to the client and potentially contact the dietitian or the College. Dietitians must be careful not to issue an invoice that could be seen as misleading. It should be left to the client(s) and their insurers to work out issues about insurance coverage limits. This may be best discussed before any treatment sessions for transparency and clarity.

4. What should I consider when auditing billing practices?

Dietitians, in a shared clinic setting, should regularly audit any billing/claim forms that have been submitted on their behalf (i.e., using their name and registration number). Some considerations for an audit:

• Determine sample billing to be reviewed based on the volume of clients seen and billing risks.
• Check that the fees that have been charged are correct, accurate and reasonable.
• Check that billing and accounts are accurate (e.g., invoice matches information in patient’s file, RD name and registration number, the date of service provision, the costs for services or products).

Adapted from the College of Physiotherapists of Ontario (2025). Written Process for Auditing Billing. Retrieved from https://collegept.org/standard/fees-billing-and-accounts-standard/resources/written-process-for-auditing-billing/

Block fees: Block fees are agreed upon fees covering multiple services over a set period (e.g., ten visits over a period). It is charged for the provision of services, and it may not be possible to know how many, if any, services are needed at the time of setting a block fee.

Bundles and packages: Bundles and packages are a set of services provided during a predetermined period (e.g., an initial assessment and two follow-up sessions over an x-month period). Bundles and packages may include other components of dietetic care not provided during a counselling session (e.g., individualized meal planning or comprehensive vitamin and mineral assessment). Typically, the fee charged for bundles, packages and block services are less than if services were paid for individually, and they are often paid for by the client in advance of the service.

Client: the recipient of dietetic service regardless of setting (e.g., an individual, population, employee, business, employer, or agency).

Itemized account: a statement which lists a client’s record of services/products including fees, payments, and any outstanding balances.

Itemized invoice: a statement which provides details on the dietetic service(s) and/or product(s) provided, with specific information about the service(s) or item(s) for which payment has not yet been made.

Itemized receipt: a statement which confirms payment has been received.

Fee schedule: A list of services and/or products and their proposed charges to clients.

Fee-sharing: refers to the division of client fees, or fee splitting, when a dietitian shares the fee paid by the client for dietetic services provided with another person.

Referral fee: a sum of money paid for a client referral. It may be such that a provider receiving the referral pays the fee, or another professional making the referral is paid a fee. Referral fees are not permitted as per the Conflict of Interest Standard.

College Standards, Guidelines, and other articles

• Code of Ethics
• Advertising and Marketing Standards and Guidelines
• Conflict of Interest Standard
• Record Keeping Standard
• Practice Question: Accepting referrals in practice
• Practice Question: Is backdating an invoice, ok?
• Practice Question: Can I discount my services?
• Article: Professional Billing Practices

Legislation

• Health Care Consent Act, 1996. Available from: http://www.ontario.ca/laws/statute/96h02  
• Professional Misconduct Regulation, 1991. Available from: https://www.ontario.ca/laws/regulation/930680
• Personal Health Information Protection Act, 2004. Available from: https://www.ontario.ca/laws/statute/04p03