Proposed Exemption of Multidisciplinary Health Care Services

A corporation makes a single supply of a rehabilitation program rendered to an individual by a multidisciplinary health care team. The rehabilitation program consists of psychological services rendered by a psychologist, physiotherapy services rendered by a physiotherapist and chiropractic services rendered by a chiropractor (the particular services). The consideration for the supply can reasonably be attributed to the particular services in the following manner:

• 40% for the psychological services;
• 30% for the physiotherapy services; and
• 30% for the chiropractic services.

Each of the particular services is rendered in the course of the corporation making its supply of a rehabilitation program and would be included in sections 5 to 7.3 if the particular services were supplied separately. Therefore, as all of the consideration for the supply can be reasonably attributed to the particular services, the single supply made by the corporation would be exempt pursuant to proposed section 7.4 of Part II of Schedule V to the Act.

A corporation operates a clinic to make supplies of rehabilitation programs that are rendered to individuals who have sustained minor injuries in an accident. The 12 week rehabilitation program consists of a variety of health care services depending on the individual’s needs. The rehabilitation program’s services are provided for a fixed fee and typically include a combination of several sessions of chiropractic services, physiotherapy services, acupuncture and/or massage therapy. The 12 week rehabilitation programs are billed to the individual or the individual’s insurance company at a fixed price regardless of the combination of services provided. The invoice issued by the corporation for the rehabilitation program only lists a fixed fee for a package of services. The corporation also makes supplies of chiropractic services, physiotherapy services, acupuncture services and massage therapy services on a fee for service basis.

Where a flat fee is charged for a package of services, it would be reasonable to attribute the consideration for the supply to each of the particular services by looking at the relative value for each of the particular services compared to the total supply. The attribution of the consideration of a fixed fee for a package of services can reasonably be done using the rates that would be charged for each of the services if those services were supplied separately multiplied by the number of hours for each of the services.

In this case, the individual’s insurance company is billed a fixed fee of $3,500 for the rehabilitation program. The rehabilitation program for an individual consists of the following treatment plan:

If the particular services were supplied separately, based on the number of hours of treatment and the fee for service rates for each of the particular services it would reasonable to attribute the consideration for the supply in the following proportions:

The chiropractic services, physiotherapy services and acupuncture services are all rendered to the individual by a practitioner of the service and would be exempt pursuant to section 7 of Part II of Schedule V to the Act if the services were supplied separately. However, a supply of massage therapy services rendered to the individual by a Registered Massage Therapist would not be included in sections 5 to 7.3 of Part II of Schedule V to the Act if the massage therapy services were supplied separately. Therefore, only 82% of the consideration can be reasonably attributed to particular services (chiropractic, physiotherapy and acupuncture services) that would be included in section 7 if the services were supplied separately. Proposed section 7.4 would not apply to this supply of a rehabilitation program as the supply has not met the condition that all or substantially all of the consideration for the supply is reasonably attributable to particular services that would be included in sections 5 to 7.3 of Part II of Schedule V to the Act if supplied separately. Where the corporation is a registrant, the supply of the rehabilitation program would be subject to the GST/HST at the applicable rate depending on the province in which the supply is made.

A corporation makes a single supply of an assessment and rehabilitation program which includes a variety of health care services. The services are rendered by a multidisciplinary health care team to an individual who was injured in an accident. The corporation charges a flat fee of $1,580 for the supply. The particular services rendered in the course of making the supply consist of massage therapy services, occupational therapy services, physiotherapy services, and nursing services. The individual’s insurance company receives an invoice for the total amount based on the following treatment plan:

In this case, the particular services of occupational therapy, physiotherapy and nursing services all would be included in sections 5 to 7.3 of Part II of Schedule V to the Act if they were supplied separately. Massage therapy services are not included in any of those sections. The corporation determines that, based on its fee for service rates, 8% of the consideration for the supply can be reasonably attributed to the massage therapy services. In this case, 92% of the consideration for the supply can reasonably be attributed to the occupational therapy, physiotherapy and nursing services. Where all or substantially all of the consideration for the supply is reasonably attributable to particular services, rendered in the course of making the supply, that would be included in sections 5 to 7.3 of Part II of Schedule V to the Act if the particular services were supplied separately, the supply would be exempt pursuant to proposed section 7.4 of Part II of Schedule V to the Act.

A corporation makes a supply of a rehabilitation program that consists of a variety of health care services that are rendered to an individual by a multidisciplinary health care team consisting of a social worker, kinesiologist, massage therapist and occupational therapist. Based on the relative value and amount of time spent for each particular service, the consideration for the supply of the rehabilitation program can reasonably be attributed to the particular services at the follow percentages:

Social work services 30%
Kinesiology services 20%
Massage therapy services 15%
Occupational therapy services 35%

The social work services rendered by a social worker and the occupational therapy services rendered by an occupational therapist would be included in sections 7.2 and 7, respectively, of Part II of Schedule V to the Act if they were supplied separately. Massage therapy services rendered by a massage therapist and kinesiology services rendered by a kinesiologist are not included in sections 5 to 7.3 of Part II of Schedule V to the Act. Therefore, only 65% of the consideration for the supply by the corporation is reasonably attributable to particular services (social work services and occupational therapy services) that would be included in sections 5 to 7.3 of Part II of Schedule V to the Act if supplied separately. The supply of the rehabilitation program made by the corporation would not be exempt pursuant to proposed section 7.4 of Part II of Schedule V to the Act as not all or substantially all of the consideration for the supply is reasonably attributable to services that would be included in sections 5 to 7.3 of Part II of Schedule V to the Act if the particular services were supplied separately. Where the corporation is a registrant, the supply of the rehabilitation program would be subject to the GST/HST at the applicable rate depending on the province in which the supply is made.