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The $80/Hour Opportunity Most Clinics Aren't Ready For
On April 1, 2026, Ontario's FHO+ model officially launches. For the first time, family physicians can bill $80 per hour, in 15-minute increments, up to 14 hours per day, for indirect care and clinical administration they've been doing unpaid for years.
That includes reviewing lab results, coordinating referrals, managing your EMR inbox, care planning, and patient messaging. The work you've always done between appointments now has a dollar value attached to it.
But here's the problem: you can't bill what you can't document.
Most Ontario clinics have no system in place to track how they spend their indirect care time. When April 1 arrives, the physicians who've prepared a tracking workflow will capture revenue from day one. Everyone else will leave money on the table, or worse, submit claims they can't defend in an audit.
What Qualifies as Billable Time Under FHO+
FHO+ recognizes four categories of billable time:
Direct Patient Care, face-to-face encounters, virtual visits, and in-clinic assessments. This was already billable under the traditional FHO model.
Indirect Patient Care, the work that happens around the patient encounter. Reviewing incoming lab results. Following up on referral status. Drafting patient instructions. Coordinating care with specialists. This category is where most of the new revenue opportunity sits.
Telephone Care, phone consultations with patients, compensated at 85% of the standard rate ($68/hour). These need to be logged separately.
Clinical Administration, EMR management, documentation, roster management, and quality improvement activities. Capped at 25% of total monthly hours, but still a significant revenue stream for work that was previously invisible.
Every billable increment is 15 minutes. If you spend 10 minutes reviewing labs and 5 minutes drafting a follow-up message, that's one billable unit. The discipline is in tracking it, consistently, accurately, and defensibly.
The Three Approaches to Time Tracking
1. Manual Tracking (Spreadsheet or Timer)
The simplest approach: a spreadsheet or time-tracking app where staff log each task as it happens. Columns for date, start time, duration, task category (direct/indirect/telephone/admin), and patient association.
Pros: No cost, no setup, works immediately.
Cons: Relies entirely on human discipline. Staff forget. Entries get rounded. At audit time, a spreadsheet with round numbers and gaps doesn't inspire confidence. It also adds to the administrative burden FHO+ was supposed to reduce.
Verdict: Acceptable as a stopgap for April 1, but not sustainable beyond the first quarter.
2. EMR-Based Tracking
Some Ontario EMRs (OSCAR, PS Suite, Accuro) are adding or have added time-tracking features in anticipation of FHO+. These integrate directly with your charting workflow, you start a timer when you open a patient's chart and it logs the duration automatically.
Pros: Integrated with your existing workflow. Time entries are associated with specific patients and encounters. Audit trail is built into the system you already use.
Cons: Not all EMRs have this yet. Features vary widely. You're dependent on your EMR vendor's implementation timeline. And EMR time tracking typically captures only the time you spend inside the EMR, it misses phone calls, fax handling, and offline coordination. For a complete analysis of what vendors are recommending and where the gaps remain, see our FHO+ Time-Tracking Landscape report.
Verdict: The right long-term approach for direct care tracking, but check with your EMR vendor now to understand what's available by April 1.
3. Automated Workflow Tracking
The third approach uses clinic automation tools to log time spent on administrative workflows, fax triage, referral tracking, results routing, patient instruction drafting, as these tasks move through the system. Every action is timestamped and associated with a patient record automatically.
Pros: No manual logging required. Every workflow step is documented with timestamps. The audit trail is generated as a byproduct of the work itself, not as an extra step. Captures the indirect care tasks that EMR timers miss.
Cons: Requires automation infrastructure in place. Not all workflows are automated yet in most clinics.
Verdict: The most defensible approach for indirect care and clinical administration billing. If your clinic already uses workflow automation for fax triage or referral tracking, you're closer than you think.
What Auditable Documentation Looks Like
When the Ministry reviews your FHO+ time claims, they're looking for five things:
- Date and time, when was the work performed?
- Duration, how long did it take (in 15-minute increments)?
- Task category, was it direct care, indirect care, telephone, or clinical administration?
- Patient association, which patient's care was this related to?
- Activity description, what specifically was done?
A defensible record looks like: "March 15, 2026, 10:15 AM to 10:30 AM, Indirect care, Patient J. Smith, Reviewed incoming lab results from LifeLabs, flagged abnormal creatinine, drafted follow-up instruction for physician review."
An indefensible record looks like: "March 15, 2 hours, Admin."
The difference between those two is the difference between getting paid and getting clawed back.
The Shadow Billing Opportunity You're Probably Missing
FHO+ also increases shadow billing rates from 19.4% to 30% for most in-basket services, and up to 50% for select procedures. This means every service you provide to a rostered patient has higher passive revenue potential. For all FHO+ billing code details, ratio caps, and documentation requirements, see our complete FHO+ Billing Guide.
The catch: shadow billing only works if the correct fee codes are submitted. Many clinics lose revenue because minor procedures discussed during a visit never get coded. An AI scribe captures the clinical encounter, but the billing codes still need to be cross-referenced against OHIP's in-basket service list.
Clinics that pair their AI scribe output with an automated code-matching workflow can ensure every shadow-billable procedure is captured, potentially increasing passive revenue without seeing a single additional patient.
The Continuity of Care Factor
FHO+ replaces the old Access Bonus with a 75% Continuity of Care target. If less than 75% of your rostered patients' in-basket primary care happens within your FHO group for two related quarters (the same quarter in consecutive years), a 15% capitation discount kicks in.
This means patient retention is now directly tied to your revenue. When a lab result comes back or a follow-up is due, how quickly your clinic reaches out to the patient matters. Automated follow-up workflows, triggered by incoming results or approaching appointment gaps, help maintain that continuity without requiring staff to manually track every patient's status.
How to Prepare Before April 1
You have less than two weeks. Here's what you can do right now:
This week: Audit your current workflows. Map every task your staff does between patient encounters, fax handling, lab review, referral follow-ups, phone calls, EMR documentation. These are your billable indirect care activities under FHO+.
Before April 1: Choose your tracking method. Even a spreadsheet is better than nothing on day one. Set up columns for date, time, duration, category, patient, and activity. Train your staff on what to log.
By end of Q1 2026: Evaluate whether your manual tracking is sustainable. If your staff are spending time logging time instead of doing the work, that's a sign you need a more automated approach.
Ongoing: Review your shadow billing codes monthly. Compare what your AI scribe captures against what's being billed. The gap between those two numbers is revenue you're leaving behind.
The Bottom Line
FHO+ finally puts a dollar value on the work Ontario family physicians have been doing for free. The physicians who capture that value are the ones who can document it, accurately, consistently, and defensibly.
The tracking system doesn't need to be complex. It needs to be consistent. Whether you start with a spreadsheet, use your EMR's built-in tools, or implement automated workflow tracking, the important thing is to start on April 1 with something in place.
Not sure how much indirect care time your clinic is leaving on the table? Book a free 20-minute Clinic Efficiency Check-Up. We'll map your admin workflows and show you exactly where the billable time is hiding, no commitment, no sales pitch.
Sources:
- Ontario Medical Association, 2024–2028 Physician Services Agreement
- OMA, FHO+ Agreements and Forms (March 2026)
- Bill Medics, Strategic Analysis of the FHO+ Model (March 2026)
- DoctorCare, Comparing Ontario's Primary Care Payment Models
- Ontario Ministry of Health, OHIP InfoBulletins 2025
Marc Lacroix is co-founder of OpsMed.ca, which provides administrative workflow automation for Ontario family practices. OpsMed operates as a PHIPA agent with all data hosted in Azure Canada Central. Learn more about our FHO+ service.
You can't bill what you can't document. The difference between a defensible record and a clawback is consistency.
Explore our clinic automation services or book a free check-up.
Is your clinic ready to capture every billable FHO+ minute?
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