What Can a Health Profession Corporation Actually Bill For in BC?
I am not a lawyer or an accountant. This post is not legal or accounting advice. It is a deliberately conservative, compliance-focused translation of publicly available legislation, bylaws, and college guidance intended to help clinic owners understand how health profession corporations are regulated in British Columbia.
This topic comes up frequently, especially for clinic owners operating multidisciplinary clinics or considering new revenue streams. Many common clinic models rely on assumptions, historical tolerance, or informal advice. This post focuses instead on what is clearly authorized in legislation, where the grey zones exist, and why reasonable professionals often land in different places on this issue.
Health profession corporations are statutory entities
Health profession corporations in British Columbia do not exist under general business law alone. They exist because health legislation allows them to exist. Under the current framework, that legislation is the Health Professions Act (HPA). As of April 1, 2026, it will be replaced by the Health Professions and Occupations Act (HPOA).
A key point that often gets missed is this: a health profession corporation can only do what these sets of legislation, regulations, bylaws, and its permit authorize, not general corporate business law.
You can review the HPA here:
https://www.bclaws.gov.bc.ca/civix/document/id/lc/statreg/96183_01
You can review the HPOA here:
https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/22043
Who can bill for protected health services
The HPA is explicit about who may carry on the business of providing health profession services.
Health Professions Act, section 42(1):
“No corporation, other than a health profession corporation holding a valid permit under section 43(1), may carry on the business of providing to the public health profession services that may be provided by the registrants of the college whose board issued or renewed the permit.”
Full section:
https://www.bclaws.gov.bc.ca/civix/document/id/lc/statreg/96183_01#section42
Plain language translation:
If a service is a protected health profession service, only a corporation holding the appropriate health profession corporation permit may bill for it. A general or non-permitted corporation may not bill protected health services.
This principle continues under the HPOA.
What a permitted health profession corporation can earn income from
The HPOA provides the clearest language on what a health profession corporation is allowed to earn income from.
Health Professions and Occupations Act, section 66(2)(c):
“A health profession corporation must not carry on any activities that would, for the purposes of the Income Tax Act (Canada), give rise to income from business, except to provide health services governed by the issuer and services directly associated with the provision of those health services.”
Full section:
https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/22043#section66
Plain language translation:
A health profession corporation may earn business income only from
the health services governed by its permit, and
services directly associated with providing those health services.
The legislation does not provide a broader list of permitted income sources.
What the legislation does not say
The legislation does not say that a health profession corporation may bill for other professions as long as they are labelled clearly. It does not say that common industry practice expands what is authorized. It does not say that silence in the Act equals permission.
Health profession legislation is permission-based. It tells regulated entities what they are authorized to do. It does not list every possible activity and then prohibit them one by one.
One permit, one profession
Health profession corporation permits are issued by a specific regulatory college for a specific profession.
Neither the HPA nor the HPOA contains a provision that expressly authorizes one health profession corporation permit to bill and collect revenue for multiple regulated health professions under a single entity. This is why multidisciplinary clinics in British Columbia typically rely on separation rather than pooling.
Common compliant structures include rent models where other professionals operate independently, and parallel entities such as a permitted corporation for one profession alongside a general corporation for non-regulated activities.
These structures are not simply business preferences. They are responses to how the legislation is written.
Collaboration agreements are future focused
The HPOA introduces the concept of collaboration agreements.
Health Professions and Occupations Act, section 60:
https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/22043#section60
Plain language translation:
The legislation anticipates future cross-college arrangements, but does not currently authorize multidisciplinary billing under a single permit. Collaboration agreements are optional, profession-specific, and not automatic.
As of today, no collaboration agreements are in force that change corporate billing rules.
Enforcement and why this is not a CRA issue
Compliance with health profession corporation rules is enforced through regulators and health legislation, not through the Canada Revenue Agency.
CRA compliance and regulatory compliance are different systems with different mandates. CRA focuses on tax reporting. Colleges focus on public protection and compliance with professional legislation.
Historically, enforcement under the HPA has often been reactive and complaint-driven. That does not change what the legislation authorizes. It explains why many clinic models have existed without scrutiny.
The HPOA signals stronger oversight of health profession corporations, including permit conditions and centralized adjudication. The operational details are still being developed through bylaws and policy.
Why accountants and lawyers often do not flag this issue
A common question is why accountants or lawyers are not raising concerns about corporate billing structures more often.
For accountants, the reason is straightforward. Health profession corporation compliance is not a CRA issue. As long as income is reported correctly and taxes are paid, CRA generally does not assess whether that income was earned in compliance with provincial health profession legislation. This falls outside an accountant’s mandate.
For lawyers, the issue is more nuanced. Many lawyers advising clinics are corporate or commercial lawyers focused on incorporations, shareholder agreements, leases, and contracts under the Business Corporations Act. Unless a lawyer regularly works in regulated health professions, they may not approach a health profession corporation as a restricted statutory entity. Instead, it may be treated like a normal corporation with additional ownership rules.
Health profession corporation legislation sits at the intersection of administrative law, professional regulation, and health law. It is permission-based, intentionally vague in places, and written to govern regulators rather than guide business planning. Unless it is being read specifically through a regulatory compliance lens, important constraints can be missed.
When advisors say a structure is “allowed,” they often mean it is not explicitly prohibited, has not historically been enforced against, and does not violate corporate or tax law. This post asks a different question: what does the legislation clearly authorize a health profession corporation to do? Those are different questions, and they can lead to different conclusions.
Why interpretations differ
Reasonable people and advisors often read the same legislation and land differently, particularly in grey areas. This interpretation is intentionally conservative, it focuses on what the legislation clearly authorizes, rather than what has been historically tolerated or informally discussed.
Understanding where the grey zones exist allows clinic owners to make informed decisions and assess their own risk tolerance rather than assuming all advice is being given through the same regulatory lens.
Final note
This post is not about what clinics can get away with. It is about understanding the regulatory framework that governs health profession corporations in British Columbia. If you operate a permitted health profession corporation, it is worth understanding not just how your clinic functions in practice, but how it aligns with the legislation that authorizes it to exist.
Want help reviewing your structure?
If this raised questions about your clinic’s billing, contracts, or corporate setup, this is exactly the work I do. I help clinic owners understand how their real-world operations intersect with regulatory requirements and where risk may exist, before it becomes a problem.
This does not replace legal or accounting advice. It complements it by making sure the right questions are being asked.
You can learn more about working with me here.
References
Health Professions Act (RSBC 1996), Part 4
https://www.bclaws.gov.bc.ca/civix/document/id/lc/statreg/96183_01
Health Professions and Occupations Act (SBC 2022), Division 4
https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/22043
College bylaws and published guidance on health profession corporations
https://chcpbc.org/legislation/