I am writing to request guidance in relation to a file review request from Blue Cross that we have been dealing with in recent months at my practice. More specifically, we received a letter dated June 11, 2021, requesting all clinical notes for 11 Canadian Armed Forces clients (5 of mine and 6 of hers) for the time frame of January 1, 2020 through December 31, 2020, totalling approximately 600 notes. The request qualified that “Clinical notes can be redacted provided that the member name, date, therapy attended, and therapist is visible.” It was also requested that all notes be submitted by July 14, 2021, three weeks after we were in receipt of the request. When we did not meet this deadline, another letter followed with a narrower window and outlined potential consequences for noncompliance. We responded on August 17, 2021 with a detailed accounting of client visits as printed from our practice management software Owl Practice, but indicated that our military clients had not consented to the release of the requested clinical notes, redacted or otherwise. We each received another letter dated September 14, 2021, indicating that because we had not provided the requested clinical notes that they are now seeking payment for all billing for these clients for 2020, totalling over $100,000 between the Doctor and myself. As this request was received on National Defense letterhead, I have since been in contact with the relevant health services administrator at CFB Halifax, who has agreed that our clients have not consented to providing these notes and is concerned that Blue Cross would have requested same. He has not been able to find any indication of this request originating within the Canadian Armed Forces. He is also now trying to get an answer from Blue Cross about the matter.

Blue Cross has indicated that we have 15 working days from the date of the last letter to submit an appeal to their decision, otherwise we must pay them by October 4, 2021. We are still inclined to not provide the requested documentation without client consent, but worry about ramifications for our practice from Blue Cross. Moreover, the administrative burden of printing, reviewing, redacting, copying, and submitting in excess of 600 clinical notes would require that we shut our practice down for a week in order to comply with the request.

We have reached out to other psychologists and could not find anyone who has ever heard of file review request of this scope.

I am writing to request guidance in relation to a file review request from Blue Cross that we have been dealing with in recent months at my practice. More specifically, we received a letter dated June 11, 2021, requesting all clinical notes for 11 Canadian Armed Forces clients (5 of mine and 6 of hers) for the time frame of January 1, 2020 through December 31, 2020, totalling approximately 600 notes. The request qualified that “Clinical notes can be redacted provided that the member name, date, therapy attended, and therapist is visible.” It was also requested that all notes be submitted by July 14, 2021, three weeks after we were in receipt of the request. When we did not meet this deadline, another letter followed with a narrower window and outlined potential consequences for noncompliance. We responded on August 17, 2021 with a detailed accounting of client visits as printed from our practice management software Owl Practice, but indicated that our military clients had not consented to the release of the requested clinical notes, redacted or otherwise. We each received another letter dated September 14, 2021, indicating that because we had not provided the requested clinical notes that they are now seeking payment for all billing for these clients for 2020, totalling over $100,000 between the Doctor and myself. As this request was received on National Defense letterhead, I have since been in contact with the relevant health services administrator at CFB Halifax, who has agreed that our clients have not consented to providing these notes and is concerned that Blue Cross would have requested same. He has not been able to find any indication of this request originating within the Canadian Armed Forces. He is also now trying to get an answer from Blue Cross about the matter.

Blue Cross has indicated that we have 15 working days from the date of the last letter to submit an appeal to their decision, otherwise we must pay them by October 4, 2021. We are still inclined to not provide the requested documentation without client consent, but worry about ramifications for our practice from Blue Cross. Moreover, the administrative burden of printing, reviewing, redacting, copying, and submitting in excess of 600 clinical notes would require that we shut our practice down for a week in order to comply with the request.

We have reached out to other psychologists and could not find anyone who has ever heard of file review request of this scope.