Home Practice Standards Business Practices 6.4 Closing, Selling, or Relocating a Practice
Closing, Selling, or Relocating a Practice

Standard 6.4: Closing, Selling, or Relocating a Practice

The Professional Practice Standards regarding closing, selling, or relocating a practice. This includes the four standards, examples in demonstrating the standard, definitions and related resources.


Business Practices
Closing, Selling, or Relocating a Practice

Standard 6.4: Closing, Selling, or Relocating a Practice

The Professional Practice Standards regarding closing, selling, or relocating a practice. This includes the four standards, examples in demonstrating the standard, definitions and related resources.

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The Standard

 

6.4.1 Registrants intending to close or relocate their practice take reasonable steps to give appropriate notice of the intended closure or relocation to each client for whom the registrant has primary responsibility.

 

6.4.2. Registrants have a contingency plan in place to promote continuity of care in the event of an unexpected interruption to their practice

 

6.4.3 Registrants who are health information custodians provide the College with up-to-date information about who would take custody of the records in their care in event of the registrant’s death or long-term inability to fulfill their obligations related to this position.

 

6.4.4 Registrants acting as health information custodians maintain records in a secure manner for the period set out in Standard 5.1, even after the closure of their practice, unless the records are transferred to another health information custodian.

Standard 6.4

Demonstrating the Standard

  • Standard 6.4

    • providing as much notice to clients as reasonably possible when closing or relocating a practice, with an expected minimum notice of 30 days for foreseeable closures.
    • providing information to clients about alternative services;
    • ensuring that each client record is either,
      • i. retained securely by the registrant in compliance with the Personal Health Information Protection Act, 2004 and the College’s record-keeping and documentation standards.,
      • ii. transferred to the registrant’s successor, or
      • iii. transferred to another practitioner if the client so requests

  • Standard 6.4

    • if the retention period has passed, ensuring records are disposed of in a secure manner;
    • informing their health information custodian successor of their obligations under the law including that they may be contacted by clients for copies of their clinical record

Key Definitions

  • Key Definitions

    Adequate notice

    In the case of a pre-planned move, retirement, or practice closure for other reasons, adequate notice generally constitutes a minimum of 30 days. In cases of emergency or sudden and unexpected incapacitation, registrants or their representatives shall provide as much notice as reasonably possible.

  • Key Definitions

    Health information custodian

    The person or organization that has custody of personal health information, as defined by section 3 of the Personal Health Information Protection Act (2004).

  • Key Definitions

    Health information custodian successor

    The person who would take over responsibility for a registrant’s original client records following the planned or unplanned sale or closure of the registrant’s practice or following the registrant’s death.

Standard 6.4

Commentary

Registrants are obliged to advise their clients and those whose records they possess if they intend to close, sell, or relocate their practice. Notice should be given well in advance, or as soon as is reasonably possible. The purpose is to provide time for clients to seek alternate services. Where possible, the registrant shall assist the client in identifying alternative services. If a registrant is leaving an organization rather than closing, selling, or relocating their practice, they shall still make reasonable efforts to notify active clients about their upcoming departure.

 

When closing or relocating a practice, registrants first attempt to provide direct notice (in person during a scheduled appointment, telephone conversation, direct letters, personal emails, etc.) of the change to clients. If not all clients can be reached, registrants use at least two forms of indirect notice (posting a message on one’s website, using an automatic reply on emails, updating a voicemail to note closure or sale, publishing closure in a newspaper, etc.).

 

Regardless of method of communication, registrants document their attempts to alert clients.

 

Registrants must ensure that client records are transferred to the registrant’s successor (if there is one) or to another registrant if the client requests this. Client records that are not transferred must be retained or, if the retention period has lapsed, disposed of in a secure manner in accordance with the Personal Health Information Protection Act, 2004 and the College’s record-keeping and documentation standards.

Registrants are required to have in place a plan to address unforeseen interruptions to their practice, such as unplanned leave, illness or death and even natural disaster. These plans should promote continuity of client care and allow others to manage, transfer, or close a practice in the event that a registrant is unable to do so. The plan should include back-up and storage of contact lists and where possible, client records, directions for contacting clients or their authorized representatives, and contact information for alternative service providers.

 

The registrant’s next of kin or executer of the will should be made aware of this contingency plan and have appropriate contact information for the health information custodian successor.

 

CRPO strongly encourages registrants to select qualified successors with knowledge of healthcare privacy law. In order to best ensure compliance with CRPO standards, the College suggests selecting another registrant when possible.

 

If individuals (such as clients or colleagues) become aware of an abandoned or interrupted practice, they should contact the College.

 

Additional information on contingency planning and expectations of the College can be found on the Practice Matters page linked in related resources.

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