Virtual Care Rules Lag Behind a Rapidly Changing System

December 18, 2025 – Virtual care is now embedded in how Canadians access healthcare. But provincial rules have not kept pace with its rapid expansion, creating a fragmented system that risks worsening inequities and undermining continuity of care, according to a new report by the C.D. Howe Institute.

In “Disconnected: Inside Canada’s Patchwork of Virtual Care,” Katherine Fierlbeck and Rosalie Wyonch find that, while there is some consistency across jurisdictions in the provision and regulation of virtual care, in other instances, provinces have developed differing regulations, billing rules, and licensing approaches for virtual care. These inconsistencies have opened significant legal space for private, for-profit providers, blurred the lines between public and private healthcare, and added complexity to continuity of care and system integration.

“Because virtual care is not bound by time or space, individual provinces no longer have the ability to manage their healthcare systems as if each existed in isolation,” notes Fierlbeck. “Our healthcare system is rapidly transforming, and it is imperative Canadians think carefully about how virtual care fits into the kind of system we want.”

Provincial differences have significant system-wide effects: identical services may be insured or uninsured depending on the province, the platform, the mode of communication, or the type of provider offering care. Because provincial insurance plans typically cover only physician-delivered in-person or synchronous virtual services, fast-growing private platforms rely heavily on nurse practitioners or asynchronous communication models that fall outside the “insured services” definition – expanding private access while raising equity concerns.

Meanwhile, employers now provide virtual care to an estimated one-quarter of Canadians through benefit plans, giving millions rapid access to primary care and referrals outside the public healthcare system. While private virtual care raises equity concerns, it also has the potential to cover gaps in public insurance coverage and prevent unnecessary hospital visits.

“Canada faces a healthcare access crisis, and virtual care has become an essential tool for enabling rapid access to primary care,” says Wyonch. “The challenge for policymakers is not to resist the growth of virtual care or to choose definitively between public and private models, but rather to ensure that virtual care serves the goal of affordable and equitable access to quality healthcare for all Canadians.”

The authors recommend that provinces modernize regulatory frameworks, clarify what constitutes an insured virtual service, and set clearer requirements to support continuity of care. They also say that virtual care should be integrated in ways that enhance equity and ensure patients are not left navigating disconnected pathways.

Read the Full Report

For more information, contact: Katherine Fierlbeck, Fellow-in-Residence, C.D. Howe Institute; Rosalie Wyonch, Associate Director of Research, C.D. Howe Institute; Raquel Schneider, Communications Officer, C.D. Howe Institute, 647-805-3918, rschneider@cdhowe.org.

The C.D. Howe Institute is an independent not-for-profit research institute whose mission is to raise living standards by fostering economically sound public policies. Widely considered to be Canada’s most influential think tank, the Institute is a trusted source of essential policy intelligence, distinguished by research that is nonpartisan, evidence-based and subject to definitive expert review.

Want more insights like this? Subscribe to our newsletter for the latest research and expert commentary.