Ontario has no Medicaid, no transportation broker and no licence for patient transfer. What it does have is a statutory accident benefits system that funds transportation as a named benefit, and a mechanism that lets a transportation company bill insurers directly.
This is one of the few genuinely structured payer relationships available to an Ontario operator. It also has a restriction that will determine whether it fits your business at all, so we are going to lead with that.
The 50 kilometre rule, first, because it decides everything
The Statutory Accident Benefits Schedule defines an authorized transportation expense as one that relates to transportation expenses "incurred only after the first 50 kilometres of a trip", unless the insured person is catastrophically impaired.
Read that carefully. On a 60 kilometre trip you are paid for 10 kilometres. On a 30 kilometre trip you are paid for nothing. Ontario auto is structurally a long-distance payer, not a local-trips payer.
If your operation is urban short-haul, dialysis runs across a city, or discharge transport within a region, this channel will disappoint you. If you carry people long distances to specialist appointments, rehabilitation facilities or assessments, it is worth setting up. Catastrophic impairment claims are the exception where local trips are payable, and those are a small but valuable segment.
The rate
The governing document is Superintendent's Guideline No. 04/16, the Transportation Expense Guideline, in effect since October 1, 2016 and still listed as active by FSRA. It has not been replaced.
- Automobile use: $0.40 per kilometre for trips on or after October 1, 2016. The previous rate was $0.38.
- Taxi: reasonable fares where the insured person has no vehicle access, cannot operate a vehicle, or where a taxi is practical.
- Air, rail and bus: covered where circumstances warrant, following prior discussion with the insurer.
Travel must use the most direct route and the most economical practical option. The 50 kilometre deductible applies once per round trip and covers all modes, including attendant expenses.
SABS section 3(2) keeps the last FSCO guideline in force until FSRA publishes a replacement, so $0.40 stands until that happens. Re-check before building a rate card, since a new guideline would supersede it without notice to you.
What is covered
Transportation appears in its own enumerated clauses rather than being buried inside medical benefits:
- Section 15(1)(g) covers transportation for the insured person to and from treatment sessions, including transportation for an aide or attendant.
- Section 16(3)(k) is the rehabilitation-benefit equivalent, covering counselling and training sessions.
- Section 19(1)(b) covers attendant care as a residual.
- Section 25(4) covers insurer examinations.
Caps are combined medical and rehabilitation: $3,500 for minor injury, $65,000 standard, and $1,000,000 for catastrophic impairment. Transportation draws down the same pot as treatment, so it competes with it.
Note the scope limit: the trip must be to a treatment session, counselling or training session, or an assessment. A ride to a routine appointment outside an approved plan is not covered.
The billing chain
Under section 38(2), the insurer is not liable for a medical or rehabilitation expense incurred before a conforming treatment and assessment plan, the OCF-18, is submitted. The insurer must respond within 10 business days. If it does not, it must pay everything in the plan from the eleventh business day until it responds, and cannot assert the minor injury guideline.
Invoices go on the OCF-21 through HCAI, the central processing agency designated under section 49. Transportation to and from treatment is explicitly listed in Appendix 2 of the Health Claims for Auto Insurance Guideline, which makes it a listed expense. Mileage is conveyed using the KM measure; disbursements such as parking use the "Other" code AXXOT.
The insurer must pay within 30 days of receiving an invoice. Overdue amounts carry interest at 1 percent per month, compounded monthly.
Getting paid directly, and the honest caveat
Patient transportation is a listed expense, and FSRA is explicit that an insurer cannot pay an unlicensed service provider directly for listed expenses. That gives you three routes:
- FSRA-licensed and HCAI-enrolled. Invoice the insurer directly on an OCF-21. Note the order of operations: HCAI enrolment comes first, because FSRA requires facilities to be registered, enrolled and in good standing in HCAI to be eligible for a licence. The licence is held by a business entity, and the Principal Representative does not have to be a regulated health professional.
- HCAI-enrolled but unlicensed. Under section 49.1 you deliver the OCF-21 to the insured person, who delivers it to the insurer. In HCAI you answer "No" to the payee question, and the insurer may only pay the claimant.
- The client pays and claims reimbursement themselves.
The caveat, and we would rather flag it than let you build on it. FSRA's licensing material does not address transportation-only businesses, and we found no FSRA statement listing which business types are eligible for a service provider licence. The Principal Representative rule means it is not restricted to regulated health professions on its face, but that is an inference, not a published FSRA position. Confirm your own eligibility with FSRA before designing a billing process around route 1.
There is no fourth route. Section 62(1) states that "the assignment of a benefit under this Regulation is void." Assignment-of-benefits arrangements that work elsewhere are not available in Ontario, and where an assignment is void the assignee also loses the right to bring a Licence Appeal Tribunal proceeding.
If you do get licensed
Ongoing obligations under O. Reg. 90/14: invoice only under the licensed name and number, no duplicate submissions, no invoicing for anything that required prior approval and did not get it, records retained six years in Ontario, and billing reconciliation reviews that run quarterly if you were paid $50,000 or more for listed expenses in the prior calendar year.
What changed July 1, 2026
Benefit optionality (O. Reg. 383/24). Income replacement, non-earner and caregiver benefits, housekeeping, home maintenance and death and funeral benefits became optional on policies entered into or renewed on or after July 1, 2026.
Medical, rehabilitation and attendant care did not. Part III of SABS remains mandatory, which means transportation coverage remains mandatory. Some commentary has blurred this. It should not affect your volume.
Auto becomes first payer (O. Reg. 58/25). For accidents on or after July 1, 2026, the auto insurer must pay medical and rehabilitation benefits, other than medication, for the portion reasonably available under a supplementary health insurance plan. Previously the private plan went first. This should shorten the path to payment.
Unchanged: the benefit limits, the $0.40 per kilometre rate, the 50 kilometre deductible, the HCAI architecture, and the assignment prohibition.
How this compares to Quebec, which is instructive
Quebec's public auto insurer runs the same idea better. The SAAQ allows expenses to be paid directly to suppliers at the victim's request, enrols vendors through the SAAQclic Intervenants externes portal, issues an eight-digit supplier number, and applies no distance deductible at all.
If you operate near the Ontario-Quebec border, that difference is worth understanding. The same trip that pays nothing in Ontario under 50 kilometres may be fully payable on the Quebec side.
The other provinces, briefly
- Manitoba Public Insurance and SGI in Saskatchewan both cover transportation statutorily and can direct-pay per claim, but neither publishes a self-serve credentialing path. You negotiate claim by claim.
- ICBC in British Columbia covers transportation under the Insurance (Vehicle) Act and pre-approves taxi through a Recovery Specialist, but its direct-billing system's eligible-discipline list contains no transportation category. That door is closed.
Everything above is Ontario law. British Columbia, Saskatchewan, Manitoba and Quebec run public insurers under entirely separate rules.
Get started with Bambi
Our aiNEMT software records trip distance, timestamps and signatures automatically, which is what an OCF-21 and any subsequent reconciliation review both depend on. Get in touch for a demo.
