GST/HST Applicability on Physician Services

The Excise Tax Act predominantly classifies the services rendered by medical doctors as exempt. Nonetheless, for physicians offering non-medical services, understanding the nuances of GST/HST registration, collection, and reporting is crucial. Broadly, physician services can be categorized into:
- GST/HST Exempt Supplies (Medical Services):
- These are the services that are exempt from GST/HST. The primary objective behind this exemption is to keep basic health services free from GST/HST. Services that fall under this category are those that pertain to consultation, diagnosis, treatment, or other healthcare-related services. Historically, the CRA has recognized the following services as exempt:
- Executive medical assessments for patient healthcare.
- Renewing prescriptions without an in-person visit.
- Preparing and transferring medical records.
- Medical reports on patients or on individuals who have been examined by the physician, provided the examination also aims at promoting, protecting, or maintaining health. This includes:
- Employment and pre-employment examinations/reports.
- Immigration examination/reports.
- Employer-related forms such as “Back to Work”, “Timely Return to Work”, and “Modified Employment”.
- Treatment Plan (Form OCF-18).
- GST/HST Taxable Supplies (Non-Medical Services):
- If the primary intent of a service doesn’t revolve around protecting, maintaining, or restoring health, it’s deemed a GST/HST taxable supply, and hence, HST becomes payable. Services that are typically taxable under GST/HST include:
- Cosmetic surgical procedures.
- Medical reports based solely on chart reviews.
- Block & Annual Fees.
- Fees for court appearances as witnesses.
- Expert opinion reports.
- Medical-legal reports.
- CPP disability reports.
- Preparing certificates or letters for employers, camps, or educational institutions.
- Reviewing medical documentation for third parties.
- Teaching stipends.
- Consulting/research services.
- Administrative roles such as department head positions in hospitals.
It’s essential to note that a physician must register if their GST/HST taxable supplies (pertaining to non-medical services) surpass $30,000 over four consecutive calendar quarters.

Determining the applicability of GST/HST can sometimes be intricate, especially when discerning certain supplies. For instance, the classification of a supply as “single or multiple supplies” in the context of HOCC fees can be challenging. In 2017, the CRA undertook several audits at Ontario hospitals, examining payments made under the HOCC Program to physicians. Despite this, the OMA remains optimistic about the appeal’s merits and advises members not to levy HST on the continued receipt of HOCC payments.