Doctors Manitoba Advice on Virtual Care Across Borders

Since the COVID-19 pandemic began, the rapid adoption and growth of virtual medicine has been beneficial for physicians and patients alike. However, patients may have high expectations about accessing care while working, studying, or travelling outside of Manitoba. Practicing virtual medicine across borders raises licensing, insurance, and billing issues. 

Any physician practicing virtual medicine should be familiar with the direction of The College of Physicians and Surgeons of Manitoba. The Standard of Practice for Virtual Medicine was most recently updated effective September 29, 2022. The Standard, together with updated Contextual Information and Resources, Frequently Asked Questions, and Information on Virtual Medicine Across Provincial and International Borders, can be found here.

The CPSM’s primary rule is easily understood: the location of the patient determines where the practice of medicine occurs. 

There are certain limited exceptions to this rule, which may allow Manitoba physicians to practice virtual medicine for some patients located outside of Manitoba.

There is already an agreement between Manitoba and Nunavut which allows Manitoba physicians to provide care, including virtual medicine, to Nunavut residents and be paid through reciprocal billing. Physicians should use existing virtual medicine tariff codes.

For the duration of the pandemic, CPSM confirms Manitoba physicians can provide virtual medicine to their patients located in Northwestern Ontario and Saskatchewan. Manitoba Health confirms these virtual medicine appointments can be billed, although this will be reviewed in the future. Physicians should use existing virtual medicine tariff codes.

Physicians should not provide virtual medicine appointments to patients located outside of Canada. The tariff codes for virtual medicine may not be used for any Manitoba patient located in the United States or any other country.

Physicians may consider whether to provide virtual medicine to other patients located in Canada but outside of Manitoba. The CPSM guidelines state many Canadian provinces require physicians to hold a licence and have liability insurance to treat a patient located in that jurisdiction. Manitoba Health will generally refuse to pay for virtual medicine appointments where the patient is located outside of Manitoba, regardless of whether the patient is insured by Manitoba Health. Tariff codes for virtual medicine cannot be used for any Manitoba patient located in any other province or territory in Canada,unless the care has been approved in advance (for example, for the continuity of care of a patient with complex needs).

Accordingly, physicians wishing to provide medicine to patients located in other Canadian jurisdictions (other than the exceptions for Nunavut, Saskatchewan, and NW Ontario) should first obtain approval from Manitoba Health, ensure they have appropriate medical liability insurance coverage, and ensure the provision of virtual medicine does not violate the licensing rules where the patient is located. 

Manitoba Health continues to maintain that, unless specifically approved, physicians must be physically present in Manitoba for all services billed to Manitoba Health.

Doctors Manitoba understands the combination of licensing, insurance and billing issues may seem restrictive to some patients and some members. We are here to help with your virtual care questions.

Last updated
November 4, 2022