This article was first published in the October 2024 Communiqué
The Practice Advisory Service has received several questions from RPs and members of the public asking how to manage the changes to billing, now that psychotherapy services are GST/HST exempt. Specifically, some registrants are asking if they can stop remitting GST/HST to CRA but keep their overall fee for clients the same.
CRPO Professional Practice Standard 6.1: fees outlines the following:
6.1.1 Registrants establish a standardized fee schedule and make it available to current and prospective clients. Registrants inform clients of their fee schedule prior to providing services.
6.1.2 Registrants charge fees that are reasonable in relation to services provided; fulfill the terms of agreements established with clients; and provide itemized accounts upon request.
The Commentary to Standard 6.1 also outlines that if a registrant chooses to increase their fees, they shall provide reasonable notice to clients and should not discontinue therapy because a client cannot afford the higher fee.
Ideally, all registrants who were required to charge and remit sales tax before June 20, 2024 would have been issuing accurate documents, including invoices and receipts, that itemized their fees and any applicable taxes. (See Standard 5.3: Issuing Accurate Documents.)
After June 20, 2024, registrants are no longer required to collect GST/HST for providing psychotherapy services. This means, clients and members of the public no longer have to pay GST/HST for psychotherapy services after June 20, 2024.
If RPs stop charging HST/GST while keeping the total charge to the client the same, they are expected to give notice to clients.
Registrants are advised to consult with their accountant or tax professional to determine best practices for adjusting invoices and receipts and administering refunds, if applicable.