by Victoria Tremblett July 18, 2022 3 min read

Considerations for Virtual Care

As the COVID pandemic persists, virtual care/telehealth continues to be an important method of health care service delivery in Ontario and throughout Canada. The convenience of being able to consult a health care provider from home for routine health care services has been a welcomed change to our health care system for many people.

However, given the unique nature of telehealth services, there are several important considerations that health care providers should consider.

Registration Requirements

The integration of telehealth services into health care service delivery models means that health care providers can reach a wider population and provide care to people located in a different city or even province.

Any provider who intends to provide services to people located outside of their province must consider the applicable registration requirements. Different provinces and different regulatory bodies have different rules with respect to telehealth. One relatively consistent requirement is that the provider be registered in the province in which they are physically located. The guidelines and requirements vary with respect to whether a provider located outside the province must be registered in the province in which the patient/client is located.

The policy of the College of Nurses of Ontario (CNO), for instance, requires all nurses who wish to provide telehealth services to patients/clients located in Ontario to be registered with the CNO.

The policy of the College of Physicians and Surgeons of Ontario also requires a physician who is located outside of the province of Ontario to be registered with the CPSO in order to provide virtual health care services to patients located in Ontario. That said, there are exceptions for services not available within Ontario, emergency situations, and in the circumstances of an existing physician – patient relationship to bridge a gap in care. 

Many of the regulatory bodies have published policies and guidelines regarding registration requirements for virtual/telehealth care. If this information is not publicly available the provider should contact the regulatory body for clarification or seek legal advice.

Privacy and Confidentiality

Privacy and confidentiality are significant considerations in any health care setting. They are particularly important in electronic or virtual health care settings. It is important that the health care provider ensures a confidential setting for the patient. This requires the health care provider to take into account their own environment (whether that be at home or in a health care facility), as well as the patient’s environment, and the method of service delivery. It is important that secure methods of communication are used.

In addition to privacy and confidentiality in service delivery, the provider must also ensure that any electronic records and documentation is being stored securely and in accordance with the applicable legislation.

Quality of Care and Appropriateness of Services Provided

Perhaps one of the most important considerations is the appropriateness of virtual/telehealth care practices for the services being provided. While telehealth care may be an appropriate, efficient, and convenient method for conducting a routine primary care appointment to renew prescriptions for a long-standing client, this may not always be the case.

It is important to consider the limitations of virtual care methods and to determine whether virtual care is appropriate for each individual patient in their circumstances. This includes the patient’s familiarity with the relevant technology and their ability to participate adequately in the appointment/consultation.  A patient who is unwilling or unable to use video conferencing may be less appropriate for virtual care than a patient who is capable of the same. Any potential language or communication barriers are also important considerations in determining the appropriateness of virtual/telehealth care.

The provider must also consider the patient’s presenting complaint and whether a physical examination may be required. This should be considered both at the outset of the appointment at the scheduling/intake phase, as well as during the appointment as the provider gathers more information and completes their assessments. It is important that providers ensure appropriate follow-up for patients who may require a physical assessment or any further care.


The above sets out only a few of the numerous considerations relevant in providing telehealth care/virtual care. Health care providers should consider the most relevant considerations for their individual practice, review the policy or guidelines of their regulatory body, and contact practice consultants or seek legal advice for further guidance as necessary.


Note: Nothing in our blog post should be construed as legal advice. We encourage you to obtain legal advice tailored to the situation. At Wise Health Law, we have extensive experience assisting health care professionals with various regulatory and legal matters. Please contact us to see if we may be able to assist.

To learn more about Wise Health Law and our services, please contact us!

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