Introduction

There is a $200 fee hiding in plain sight on every OCF-18 your clinic submits: the documentation support activity line for completing the form itself. The Professional Services Guideline caps that fee at $200.00 per procedure. You can charge it. And in a 2025 decision, 2025 CanLII 111707 (ON LAT), the Tribunal affirmed the fee across seven plans at once, ordering every one payable in full with interest after the insurer cut them all to one hour of provider time.

This post is about the fee itself: where it comes from, how to bill it, what the Tribunal said when the insurer tried to reduce it, and what to do when your clinic sees the same reduction.

The $200 Fee and Where It Comes From

The documentation support activity line compensates the practitioner for the time spent completing the OCF-18. The Professional Services Guideline sets a maximum of $200.00 per procedure for that activity, billed on a per procedure basis. Stay at or under $200, and you are within the guideline. There is nothing discretionary about the ceiling: it is the published maximum for the service.

The insurer's common counter is that form completion should be paid at one hour of the provider's hourly rate instead. That position has no basis in the Guideline, and the Tribunal said so in the 2025 decision. The $200 per procedure fee is not a target to negotiate down from. It is the fee the Guideline authorizes.

PR vs. HR: How to Bill It

Form completion can be billed two ways, and the difference decides how much you collect:

  • PR (per procedure): a flat fee per form, capped at $200.00 by the Guideline. This is the method the Tribunal affirmed.
  • HR (hourly rate): payment for the time spent completing the form at the provider's hourly rate.

The Guideline supports both methods. What it does not support is the insurer unilaterally converting a PR fee into an HR payment, which is exactly what happened across all seven files in the 2025 decision: each $200 PR line was reduced to one hour at the provider's hourly rate, a lower amount, with no explanation tied to any individual file.

What the LAT Affirmed

The dispute was not close. A clinic submitted seven OCF-18s, each with a $200 per procedure form completion fee. The insurer reduced every one, relying on the same blanket language in every Explanation of Benefits: a citation to section 25 of the Schedule and a statement that costs above the Professional Services Guideline are not payable.

The adjudicator found that language was not a reason. It was a statement. Section 38(8) of the SABS requires a refusal to include the medical and other reasons why the insurer considers a treatment not reasonable or necessary. The EOB never explained how section 25 applied to any specific file, how the Guideline was involved, or why the $200 fee was unreasonable. The denial failed section 38(8) across the board.

The findings line up in the provider's favour on every point:

  • The $200 per procedure fee did not exceed the PSG maximum. It sits exactly at the cap.
  • All seven plans were payable in full.
  • Interest was awarded on the outstanding amounts.
  • The only point the insurer won: the adjudicator declined a special award under section 10 of Reg. 664, finding the insurer made "consistent mistakes" but that the conduct did not rise to being "excessive, imprudent, stubborn, inflexible, unyielding, or immoderate."

When the Insurer Pushes Back

The decision gives your clinic a read on the pushback before it arrives. When an EOB reduces a form completion fee, ask the same questions the adjudicator asked: why does section 25 apply to this file, what part of the Guideline is relevant, and why is the $200 fee unreasonable here? A letter that cites a section number and stops is a legal conclusion, not an explanation.

The "consistent mistakes" finding is the second tool. The insurer applied one template across seven separate files. If your clinic holds near-identical EOB language across multiple patient files, keep them together. A pattern of form letters is evidence the insurer is not reviewing individual files, and the Tribunal has now called that out.

Practical Steps for Your Clinic

1. Bill form completion at $200 per procedure.

The Guideline authorizes it and the LAT has affirmed it. Do not accept a conversion to an hourly rate as routine.

2. Scrutinize every EOB that reduces the fee.

If it cites section 25 without connecting it to your file, flag it. That is the exact defect the 2025 decision struck down.

3. Keep a file of pattern denials.

Identical or near-identical reduction language across patient files strengthens the argument that the insurer is running a blanket policy rather than reviewing each plan.

4. When you challenge, cite the ruling.

The section 38(8) finding and the finding on the $200 per procedure cap are published and directly on point for the most common form completion dispute in Ontario. For the broader 2026 invoicing picture, see our roundup of 2026 LAT decisions affecting HCAI invoicing.

5. Do not expect a special award every time.

Special awards remain a high bar. Focus on getting the fees paid, not on punitive damages. And if the denial letter still misses the rules, our guide to insurer denials and your rights covers your response options.

Conclusion

The $200 form completion fee is real, it is inside the Guideline, and the Tribunal has affirmed it in a published decision that made seven plans payable in full with interest. The fee is not the risk in these files. The insurer's blanket reduction language is.

Charge the fee, read every EOB that pushes back, and keep the pattern documents when the same language shows up on the next file.