FSRA Fee Rules and Travel Time Rules



Time is of the Essence

ORA Provider Travel Time Advocacy

Dear colleagues,

It’s all hands on deck if we are to turn this provider travel time denial ship around so we’re hoping you’ll get involved.

We’ve been invited to meet with the Ministry of Finance soon in response to the letter we sent and will report back once that’s taken place.

It’s vital that we reach out to MPPs so that we are approaching government from multiple angles. Politicians care about their constituents/voters. This is where you come in. Contact your MPP and ask for a meeting. We have developed some Travel Time Talking Points which you can revise as needed to best suit you/your practice and that you can use in an email, phone message or meeting.

Please help get political eyes on this issue by meeting with your MPP.

We have also had an initial response from our letter to FSRA which involves the now familiar usual side-step around what seems to be their responsibility. We will keep pushing.

And in further news on the death by a thousand cuts front we’ve learned that that scorched earth policy on Attendant Care levels and rates is expanding to other insurers. Bad faith like bad news continues to travel fast.

FSRA Fee Rule Consultation

FSRA is having a consultation on its regulatory fees proposal that will close the end of February. Hugely surprising (I saved the best news for last) is that they are not proposing an increase to HSP fees. Nevertheless, we will respond. We can’t wait to talk to FSRA about fees.  Share your thoughts with them online here

Follow Us on Social Media

In hopes of expanding our reach as an advocacy measure, we are working to increase our presence on social media. If you are not currently following us, please take some time to follow us on your chosen platforms.

Laurie Davis, Executive Director

[email protected]
GTA:       647-317-7244
Toll free: 866-475-2844

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Winter is Coming! News from the Front



Winter is Coming: News from the Front

Dear members/colleagues,

It has been an eventful advocacy and issues-arising time in our sector. Having promised to keep you posted on developments, I’ve prepared this one-stop-shop update on all the various fires we’re fighting and some smoke we see on the horizon.  I’ll start with the most recent….

Auditor General’s Report on FSRA’s Regulation of Auto Insurance  – Released November 30

The above link will take you to the full report. The general themes in the report line up with David Marshall’s report(s) and hint at auto insurance changes likely waiting in the wings. There’s a lot here of interest to us. On an initial read the following recommendations to FSRA jump out. Underline and italics are mine.

More MIG?

  • Implement up-to-date programs of care for injuries such as sprains, strains and whiplash to standardize treatment provided after an accident and the costs of such treatment, beyond just those of minor injuries; An expansion of the MIG approach to more serious injuries? Yikes.
DAC Comeback?
  • Assess the cost of a centralized medical assessment process requiring both insurers and consumers to use the process to reduce medical assessments and disputes related to those assessments; Are the Designated Assessment Centres (DECs) coming back from the dead?
Auto Bodies to Get the Regulatory Gaze?
  • Develop an accreditation regime for automobile repair shops; This is long overdue. At least there would be a better balance of regulatory oversight between the attention paid to those who fix car bodies and those that fix human bodies.
More Marshall
  •  Act on previous reform recommendations that can most reduce costs and premiums, strengthen industry oversight and increase consumer protection. This recommendation refers to Appendix 9 wherein we see Mr. Marshall frequently referenced
Those Pesky HSPs
  • Return to on-site inspections of HSPs as soon as operationally possible;
    • Require HSPs to provide evidence (such as through attestation) that they have corrected all issues identified during an inspection and conduct follow-up examinations or desk reviews to confirm this on a risk basis.
    • I note the convergence of this recommendation with FSRA’s recent HSP Supervision Plan which suggests a focus on those:
      • that conduct IEs examinations to assist an insurer’s determination of an insured person is or continues to be entitled to a benefit
      • that have never been examined by FSRA
      • that have a sanctioned practitioner listed on their HCAI roster
LAT Facts & Fairness
  • Expand information-sharing with the LAT to request information about automobile accident disputes, including which companies were involved and how long cases took to resolve
    • follow up the market conduct of insurance companies that have a disproportionately high number of LAT disputes relative to their market size, or a high volume of specific types of disputes, and identify necessary action items for the companies to take to reduce the occurrence of such cases going forward and study the reasons for the most frequent types of disputes. Be still my beating heart! Winter may be coming but spring could be around the corner.

Laurie Davis, Executive Director

[email protected]
GTA:       647-317-7244
Toll free: 866-475-2844


All accounts are linked here as well as other useful ORA links.

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‘Zombie’ Attendant Care Issue Raises it Ugly Head

Dear members,

Many of you will already be aware of the emergent Attendant Care benefit issue that has surfaced in recent weeks. I have been in close contact with attendant/PSW care provider members to collectively compare notes and strategize. A joint letter sent to FSRA yesterday in collaboration with OSOT is shown below. It should provide a decent summary of the issue.

I may have missed some AC providers in the somewhat flurried outreach. Please do let me know if I’ve missed you, and I’ll be sure to loop you in going forward. Thanks to Darcy Merkur for his legal insight and support and to all those members who’ve lent a hand to date.

Watch this space for updates and resources (template letters to insurers etc.).

ORA & OSOT letter to FSRA no name (pdf)

It’s (still) all about FSRA & Fairness

Read full submission here: ORA Comments on Proposed UDAP Rule


The Ontario Rehab Alliance (ORA) welcomes this opportunity to comment on the proposed changes to Rule 2020-002, Unfair or Deceptive Practices Act.

We were pleased to be able to provide initial input to the proposed rule change last fall as part of FSRA’s Health Service Providers Stakeholder Advisory Committee and have reviewed the comments and FSRA’s response to these in the subsequent public consultation ‘the Original notice’.

We have restricted our comments and questions in this document to those aspects which we believe may require further consideration or explanation.


Once again, the ORA would like to acknowledge our thanks for this opportunity to contribute to the consultation process. We would be pleased to provide any further clarification or information.

Respectfully submitted by,

Laurie Davis, Executive Director

Ontario Rehab Alliance



<a href=’https://www.freepik.com/photos/background’>Background photo created by suksao – www.freepik.com</a>

FSRA Priorities Submission

Submitted: October 26, 2020

The Ontario Rehab Alliance (ORA) is highly supportive of FSRA’s stated priorities for 2021-22. This submission will comment primarily on broad-strokes intentions and hoped-for outcomes.

At the Cross Sectoral level, we believe that all four priorities: Protect the Public Interest, Enable Innovation, Modernize Systems and Processes, and Transition to Principles Based Regulation may be harnessed to drive improvement to the auto insurance sector.

The ORA has made a number of previous submissions, along with other HSP associations, that reference our keen support for modernized systems and processes, and have offered multiple examples and specific suggestions of how and where we see the greatest need for these. As Principles-Based Regulation is a new form in Ontario’s regulatory environment we find it challenging to forecast how this transition might change our operations or the experience of our injured clients, so have focused our remarks elsewhere.

Read the rest in the attached PDF submission

ORA Commentary 2021-22 Priorities