The Business Practice Policy is a guideline that sets out the minimum standard by which a Canadian Certified Pedorthic Practitioner’s behaviours and actions are measured. Failure to comply with the below mentioned guidelines may result in an ethical violation.

The Certified Pedorthic Professional will engage in ethical business practices.

Records are an important communication tool for the Registrant to demonstrate that they are accountable to clients, payers, the College of Pedorthics of Canada (CPC) and other healthcare providers. Proper record keeping enhances the safety of the public.

Registrants must maintain records in a manner that is accessible to clients, investigators, assessors and/or the CPC. It is unethical to refuse access to an authorized party.

1.2 Responsibility and Accountability

Registrant will maintain records and all documentation in the management of their practices in order to:

  1. Facilitate the care of the client.
  2. Provide accurate records that do not mislead or misrepresent treatment provided.
  3. Enhance outcomes and safety for the client.
  4. Provide information to enable continuity of care for the client.
  5. Ensure their accountability to clients, payers, the CPC, the profession and other health care providers.
  6. Demonstrate their adherence to the established CPC Code of Ethics, By-Laws, Standards of Professional Practice, Standards of Clinical Practice, Standards of Business Practice, Standards of Supervision, policies and the law.
  7. Meet any other requirements mandated by the organization they are associated with, or where required by law.

1.3 General Requirements for All Records

1.3.1 Organized and Understandable

  1. Entries must be legible.
  2. Records must be kept together and secure.
  3. Specialized terms, short forms and all diagrams must be understandable to anyone who may be involved in the care, including peers and insurance companies performing audits. This can be done by defining the terms, short forms and diagrams in the record or having a glossary of definitions available.
  4. Records may be prepared and retained in a language of the Registrant’s choice, provided that a copy of all records must also be maintained in English or French.
  5. Records must use appropriate, respectful, and non-judgmental language.

1.3.2 Accuracy

  1. Information must be complete, entered within a reasonable time frame (24-48 hours) and be chronological.
  2. Entries must be permanent, they must be written in permanent ink, typewritten or in an acceptable electronic format and dated on which the entry was completed.
  3. Author of each entry must be identified through signature or typed initials.
  4. When corrections are made, the original content must remain readable. The content must indicate who made the correction, when and for what reason.

Information in clinical records must support the Registrant’s rationale for the care they provide.

Registrants shall be personally responsible for all contents of a client’s clinical records including all assessments, treatments, orders, advice and referrals. If an entry is made by a Non-registrant, the author of the record and supervisory Registrant should both be identified.

Clinical records must contain relevant information about a client’s care in enough detail to allow another health care professional to assume care of the client.

Client records must use a clear and logical format at the discretion of the Registrant (SOAP, F-DAR or other method).

The clinical record for each client must include the following, but is not limited to:

  1. The client’s name, address and date of birth.
  2. A description of each encounter including the date and purpose of each contact, whether the contact was made in person, by telephone, video, text, or electronically.
  3. Date and time of all appointments, including missed and/or canceled appointments.
  4. Name of primary care physician and any referring health professional for referred clients.
  5. Notation of the patient’s refusal to provide any relevant information.
  6. Written expressed consent of each client.
  7. Reasonable information about every examination performed by the Registrant and reasonable information about every clinical finding, assessment, treatment goals, pedorthic treatment plans and treatments made/performed by the Registrant.
  8. Clinical impression leading to any treatment provided.
  9. Progress notes, outcomes, re-assessments and changes to pedorthic treatment plan.
  10. A new entry for each re-assessment.
  11. Every written report received by the Registrant with respect to imaging, examinations, tests, consultations or treatments regarding the client’s care.
  12. Correspondence with any other health care professional and details about any care that is being requested.
  13. Refusal of care by client.
  14. Dismissal of client by Registrant.

The daily appointment record must include:

  1. The name of each client.
  2. The time of each appointment.
  3. Name of each person involved in the client’s care during each visit.

Registrants must maintain a financial record for each client regardless of whether the service is paid for by the client or billed directly to a third-party.

The financial record must include, but is not limited to:

  1. The name of the client.
  2. The date of service (for products, the date of service is when the product is dispensed).
  3. Description of the service and/or product.
  4. Name and registration number of Registrant for each pedorthic service and/or product dispensed.
  5. Total cost of the service.
  6. Payment details including the payer’s information and method of payment.
  7. Any refunds and/or reimbursements.

The Registrant must maintain confidentiality of all information in accordance with PIPEDA (Personal Information Protection and Electronic Documents Act), and such successor laws as may be applicable, from time to time and with Provincial Privacy Acts.

5.1 Requirements include:

  1. Client confidentiality must be maintained in the course of collecting, storing, using, transmitting and disposing of personal information.
  2. Hard copy records must be protected by physical locks and electronic controls such as passwords and/or encryption must be used for electronic records.
  3. Custody of client records must be established and communicated to each client in consent forms.
  4. Ensure that clients are informed of their right to view their personal records and the process to do so in accordance with PIPEDA and Provincial Privacy Acts.
  5. Expressed consent must be received and recorded prior to disclosing contents of the clients’ records to a third party.
  6. Access to records when requested by the client or a third-party must be made in a timely manner.

If a breach of confidentiality occurs, it is the responsibility of the Registrant to notify all potentially affected parties within a timely manner.

Registrants who are served with a formal notice or subpoena to produce client records before a court and who are of the opinion that disclosure would be detrimental to the client, should themselves, or through legal counsel, advocate for restricted or non-disclosure to the court.

Registrants shall take reasonable steps to ensure that confidential information concerning clients is gathered, managed, and stored in a secure manner and in accordance with relevant federal and provincial statutes, regulations, and organizational policies.

In the case of electronic records, Registrants should carefully consider the ability of their own or outsourced systems to safeguard client information. In the case of outsourced electronic record systems, Registrants should ensure that their agreement with the service provider contains appropriate contractual protection of and provisions for access to client information.

Clinical records must be stored in a secure location for ten (10) years following the client’s last visit. If the client was less than 18 years old at the time of the last visit, the records must be kept for ten (10) years after the day the client became or would have become 18 years old.

Financial records, as per CRA requirements, must be kept for at least six (6) years from the end of the tax year to which they apply.

Records must be destroyed in a manner that maintains confidentiality. If a record is electronic, it must be destroyed in a way that is not recoverable. Any electronic storing records must have their data removed to prevent records from being recovered.

Upon leaving the profession, the Registrant will take reasonable steps for all records that are in their custody to ensure continuity of care. This includes but is not limited to;

  1. The client is notified that the Registrant intends to resign, and the client can obtain copies of the client’s health record.
  2. Reasonable efforts are made to obtain the client’s consent and records are transferred to another healthcare professional.
  3. If the record transferred is not the original client health record, the original record is stored, at the Registrant’s expense, in compliance with PIPEDA.

The amount which a client is invoiced for non-insured products must not be based on whether the patient purchases insured products.

8.1  Accountability

Registrants are accountable for any invoices and/or billing that uses their name and registration number. All Registrants must be aware of how their name and number are being used and are expected to be knowledgeable of the billing practices for each facility they provide services. If invoices/receipts are provided by someone other than the Registrant, the invoices/receipts should be reviewed regularly to ensure appropriate invoicing/billing.

In the event that the Registrant discovers errors with respect to invoices and/or billing or improper billing practices where they practice, the Registrant must:

  1. Document the finding and make a reasonable attempt to rectify the error.
  2. Inform the CPC of billing practices that are against the CPC’s Standards and what actions they have taken to correct such situation.

In accordance with PCI (Payment and Card Industry) Security Standards Council (PCI SSC) PCI Data Security Standards (PCI DSS), the Registrant will take reasonable steps to ensure customer payment data is safe.

8.2  Accuracy

It is unethical for Registrants to conceal or to confuse the ultimate cost of the service that they undertake to provide;

All billing must reflect and not misrepresent the pedorthic service or product provided;

All records, invoices, receipts, statements, etc. must contain accurate information with respect to names, dates, products, and pedorthic service provided;

8.3 Fee Schedule

Registrants are required to establish their own fee schedule for services and products they provide. This may or may not be published publicly. This includes but is not limited to:

  1. Fees for assessment, reassessment, check-ups and other services.*
  2. Fees for custom foot orthotics.
  3. Fees for custom foot orthotics for special populations (seniors, students etc)
  4. Fees for footwear modifications.
  5. Fees for custom footwear.
  6. Fees for administrative tasks.
  7. Late payment fees or penalties.
  8. Fees for late cancellations or missed appointments.

*Registrants may not publish services or items that do not incur a cost.

Fees must be competitive within their geographical region, they must not be excessive, false or misleading. Any departure of the fee schedule can only be to reduce fees. Under no circumstances may higher fees be charged based on clients’ coverage.

The fee schedule and/or eligible discounts must apply to all clients, regardless of available insurance coverage.

8.4 Communicating Fees to Clients

Registrants must advise the client in advance as to the provision of services and any relevant billings, specifically:

  1. The total cost of the service.
  2. That a service may be uninsured.
  3. The specific terms and conditions relevant to payment.
  4. Any penalties for non-attendance or non-payment.
  5. If payment will be required in advance of a requested service.
  6. Acceptable methods of payment.

The Registrant may not offer free or deeply discounted products in exchange for the purchase of multiple pedorthic products or services or otherwise engage in any practice which has the effect of stimulating a demand for unnecessary or excessive use of pedorthic services.

Advertising refers to promotional material and/or activity in any medium for the purpose of promoting the Registrant’s services and/or products. Advertising of retail operations, sales, promotions or other marketing campaigns must be separated from advertising for professional services.

9.1  Accountability

Registrants will take all reasonable steps to ensure that advertisements placed by others (e.g. employers, facility operators etc.) about their services meet these standards.

Registrants’ advertisements will be comprehensible, professionally appropriate and compliant with the CPC Code of Ethics, By-Laws, Standards of Professional Practice, Standards of Clinical Practice, Standards of Business Practice, Standards of Supervision, policies and the law.

9.2  Content

Professional Service advertising must:

  1. Be confined to the presentation of information reasonably needed by clients or colleagues in making informed decisions about the availability and appropriateness of a Registrant’s services.
  2. Make certain that any announcement or advertisement directed towards clients or colleagues is true in all respects.
  3. Refrain from making fraudulent or misleading statements concerning their, or the profession’s skills, knowledge or capabilities.
  4. Not provide any guarantee of the success of the service provided.
  5. Avoid bringing the profession into disrepute.
  6. Not stimulate a demand for unnecessary health care services.

9.3 Claims of Superiority

The use of comparative terms suggesting superiority to other Registrants or other healthcare professionals is not permitted.

9.4 Advertising Prices

Advertising for pedorthic services and custom products is acceptable as long as it meets the following requirements:

  1. Does not incentivize through the advertising of coupons, discounts or free assessments for pedorthic services for any reason. This includes custom made orthotics and modified devices. For example custom orthotics and a free or discounted pair of footwear.
  2. Registrants must not advertise in a way that promotes the excessive or unnecessary use of pedorthic services. This shall include, but not be limited to, advertising which expressly or implicitly states that the purchase of multiple pedorthic products or services shall include one such product or service free of charge or at a discounted rate or otherwise represent a discount based on having purchased multiple pedorthic products or services.
  3. If listed, fees must be clearly stated so that anyone consuming the advertisement knows what you are offering.
  4. The advertised fee must be applicable to all clients, whether or not they were aware of the advertisement and whether or not they had insurance coverage.

Ensure compliance with Canada’s Anti-Spam Legislation (CASL) by obtaining and recording consent for all electronic messages.

9.5 Reviews, Testimonials and Social Media Influencers

A client review is a true statement of their experience with a particular business and/or Registrant published/posted to their own or a third-party platform.

A testimonial is the provision by a Registrant of a subjective statement from a client or other individual expressing an opinion about the nature or quality of the Registrant’s services and/or the pedorthic profession generally.

A Social Media Influencer is a content creator who has access to a large audience and can share information to persuade others and drive social media engagement through their authenticity and reach. Social media influencers often partner with brands to promote products or services to their followers in exchange for monetary compensation, free products, or discounts.

The CPC allows all three forms of advertising, provided that they are done ethically and responsibly and in a manner that conforms to all laws and CPC rules, procedures and policies (including the Advertising Standards of these Standards of Business Practice).

Registrants must recognize the privacy settings on their business and personal social media accounts and ensure compliance with these standards. Registrants should separate their personal social media activity from their professional social media activity, being mindful to avoid in their personal activity things that could bring the profession into disrepute.

Registrants are responsible for representing themselves and the Pedorthic profession in the highest standard when engaging on social media.

Registrants are expected to adhere to the CPC Standards of Business Practices, Standards of Professional Practice, Code of Ethics, By-laws and Laws when engaging online.

Registrants must only share pedorthic and/or business related information that is true, not misleading and/or obtained from a credible source.

Registrants should avoid posting information that may induce unnecessary fear, panic and/or misinformation.

Registrants must always give credit to the original source when using images and/or information that is not their own and refrain from using any work protected by intellectual property laws in a manner that infringes the rights of others.

Registrants must respect the privacy of their clients and never share nor post their health information or image online without the client’s expressed consent.

Registrants are prohibited from seeking personal or sensitive information about clients, clients’ family members and/or friends online.

The Registrant shall not be employed by or otherwise associated with a clinic or business providing pedorthic services that engage in conduct deemed to be contrary to the established CPC Code of Ethics, By-Laws, Standards of Professional Practice, Standards of Clinical Practice, Standards of Business Practice, Standards of Supervision, policies and the law.

The Registrant employed or associated with a clinic or business acting in a manner that is contrary to the established CPC Code of Ethics, By-Laws, Standards of Professional Practice, Standards of Clinical Practice, Standards of Business Practice, Standards of Supervision, policies and the law will be considered to be in violation by association.