Winding Down in Ontario? Use This 90-Day Plan to Stay PHIPA-Compliant —and Sane
(≈ 5-minute read)
Intro
Retirement, relocation, sabbatical—whatever’s pulling you away from practice, the check-list starts long before your last patient visit. CPSO policy says patients need at least 90 days’ notice, PHIPA sets the retention clock, and the CMPA reminds us about litigation buffers. Here’s the three-sprint, 90-day playbook I built for colleagues (myself included) so we can exit with fewer sleepless nights and zero regulatory surprises.
Why Start 90 Days Out?
- 90-day notice is mandatory; missing it can trigger a College investigation.
- Retention clocks: adults = 10 years from last entry; paediatrics = 10 years after the 18 th
birthday.
Example: a 7-year-old seen in 2025 turns 18 in 2036; keep the chart until 2046. ( cpso.on.ca - closing a medical practice ) - CMPA advises a 15-year buffer because some legal actions can surface that late. ( cmpa-acpm.ca - specific rules by age )
- Patient-access fees are capped at about $30 for the first 20 pages + $0.25/page after that, thanks to IPC Order HO-009. ( mondaq article )
- Breaking the job into monthly “sprints” protects both your clinic schedule and your sleep.
The 90-Day Countdown • Week-by-Week Tasks
Days −90 to −60 | Notify & File
- Draft the patient-closure notice (mail or secure e-mail). Include last-visit date, future chart location, and the capped fee schedule.
- Begin phoning hard-to-reach or complex patients.
- File your provisional storage address with CPSO Membership Services; you can update it later if the vendor changes.
Days −60 to −30 | Contract & Communicate
- Sign a written, PHIPA-compliant vendor agreement—must include breach-notification duty, 30-day fulfilment standard, and destruction rules.
- Refresh voicemail message, website banner, and office signage so walk-ins aren’t blindsided.
Final 30 Days | Verify & Box Up
- Log every patient acknowledgement—keep letters/e-mails in a “closure evidence” folder.
- Run that adult vs. paediatric retention check; see the 2046 example above.
- Export EMR data early and spot-check for scan errors; “one-click” rarely is.
- Optional but physician-friendly: maintain an after-hours voice message for up to three months so late-arriving patients know where to find their charts. (Recommended by OMA; not legally required, because CPSO will also list your storage location on its public register once you file it.)
Budget Snapshot • What It Really Costs
- Vendor quotes (2025): range from “no-up-front, we bill patients” to $2 000–$5 000 flat + annual storage.
- What you can legally pass on to patients: ~ $30 (first 20 pages) + $0.25/page thereafter. ( ipc.on.ca - access and correction )
- Hidden extras: per-page courier, “indexing,” or “encryption release” fees—insist on written disclosure.
Five Common Pitfalls (And How to Dodge Them)
- Leaving the fee schedule out of the patient letter.
- Assuming your EMR export is turnkey—bulk PDFs often arrive scrambled.
- Forgetting inactive or deceased patients; document best-effort notice.
- Skipping a breach-notification clause—under PHIPA, you’re still the custodian.
- Delaying website/voicemail updates until the final week.
Let’s Talk • Your Templates, On Us
Planning a closure within 24 months? I’m a fellow Ontario FP building a physician-led record-custody platform that trims PHIPA paperwork to minutes. Book a 20-minute Zoom and grab the full template pack—no strings attached.
