A Warning Letter for Hard Work
Dr. Adam Stewart, a family physician in Madoc, Ont., recently received a notice from the Ministry of Health’s Payment Accountability and Fraud Control Unit flagging his billing activity as “abnormal.” The letter, received on Oct. 27, cautioned the doctor regarding a “high number” of days worked over the past year, sparking a sharp backlash from medical professionals regarding the province’s expectations for primary care providers. The Ontario Medical Association tells CTV News that they believe “hundreds” of similar letters have been sent to physicians across the province.
Defining the Threshold of “Uncommon”
The correspondence identified patterns of service it labeled “uncommon,” yet failed to provide specific thresholds for what constitutes an acceptable number of work days. It served as a reminder that Dr. Stewart remains responsible for all claims submitted under his billing number. “Do they really want us to work less days?” Dr. Stewart asked publicly. He noted that his workload routinely stretches beyond patient appointments to include administrative duties such as reviewing hospital reports and managing electronic medical records. Dr. Stewart emphasized that unless he leaves the country and purposely disconnects from his digital tools, he is accessing his electronic medical records every single day, even when not physically seeing patients.
OMA Calls for Accountability
The Ontario Medical Association (OMA) has labeled these warnings “incredibly disheartening.” With approximately 2.5 million Ontarians currently lacking a family doctor, OMA President Dr. Rebecca Hicks pointed out that physicians are regularly working evenings and weekends to fill the gap. “To have a physician who is doing exactly what the system is designed to do be flagged for an unusual billing pattern is disappointing,” she said. The OMA is now seeking formal clarification on the selection criteria used to flag these patterns and has requested an apology. CEO Dr. Andrew Park has encouraged members to contact their local MPPs to address how these communications are being perceived as threatening.
The Ministry’s Stance on Audits
The Ministry of Health insists its outreach is strictly “educational” rather than an accusation of improper billing. According to the ministry, these reviews trigger when data exceeds specific thresholds: more than 15 hours of billed services or 100 unique patient encounters in a single day. Health Minister Sylvia Jones stated on Oct. 5, 2026, that these reviews are standard practice and assured physicians they will not face disciplinary action if services were rendered and billed appropriately.
Conflicting Pressures in Primary Care
These tensions arise as Ontario implements the modernized Family Health Organization (FHO+) payment model, which launched on April 1, 2026. The system is designed to support primary care by providing hourly compensation for clinical administration and indirect patient care alongside traditional capitation. While the government’s $3.4 billion Primary Care Action Plan has reportedly connected more than 500,000 patients to providers, physicians argue that the push to increase capacity sits in direct contradiction to receiving notices that scrutinize their high activity levels. The government maintains it has “made significant progress” in the second year of this plan, having recently touted that 511,000 patients have been connected to a primary care provider.
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