Therapy clinic regulations Manitoba: what a private clinic should check

Manitoba at a glance

This table summarizes what we found for a private pediatric or multidisciplinary therapy clinic in Manitoba. Each cell links to the official page behind it. Rules for records, fees, advertising and supervision often differ by profession, so check each clinician’s own regulator as well.

Health privacy: PHIA, trustees and breach notice

PHIA defines a trustee as a health professional, health care facility, public body or health services agency that collects or maintains personal health information. A health professional is a person licensed or registered to provide health care under an Act of the Legislature. A health services agency is an organization providing health care under an agreement with another trustee, and the facility list includes a medical clinic. The text we read does not say plainly where a private therapy clinic run by a non-clinician owner fits, or an ABA-only clinic with no regulated clinician, so ask the Ombudsman or counsel which category applies instead of assuming one. The federal Privacy Commissioner’s list of provincial laws that may apply instead of PIPEDA does not name PHIA, and we found no official answer on whether PIPEDA also applies to a fee-for-service clinic.

Breach notice is mandatory in Manitoba. A trustee that maintains personal health information must notify the individual about a privacy breach if, after weighing the factors in the Regulation, the breach could reasonably be expected to create a real risk of significant harm. Notice goes to the individual as soon as practicable after the breach becomes known, in writing and directly unless the Regulation allows indirect notice. A trustee that notifies an individual must also notify the Ombudsman at the time and in the form and manner the Ombudsman requires. PHIA gives no deadline in days. The amendment came into force on 1 January 2022.

Other duties we read:

• Safeguards: the Regulation requires a written security policy and procedures (s.2), a decision on what information each employee or agent may access (s.5), orientation and ongoing training (s.6), and an audit of security safeguards at least every two years (s.8).
• User activity: a trustee must keep a record of user activity for any electronic information system it uses for personal health information, audit those records to detect security breaches, and keep them at least three years (Regulation s.4).
• Privacy officer: a health care facility and a health services agency must designate one or more employees as privacy officer (PHIA s.57). Individual health professionals are not named in that section.
• Vendors: a written agreement with an information manager that protects the information (PHIA s.25(3)).
• Consent: consent must relate to the purpose, be knowledgeable and voluntary, and not be obtained through misrepresentation; it may be express or implied, except that it must be express for disclosure to someone who is not a trustee (s.19.1).
• Access: a trustee responds as promptly as the circumstances require and no later than 72 hours for care currently being provided to a person who is not a hospital in-patient, or 30 days in other cases. A reasonable fee is capped by the regulations; we did not find a fee schedule in the Regulation text we read (ss.6 and 10).
• Retention: a written retention and destruction policy that the trustee follows (s.17). Neither PHIA nor the Regulation sets a minimum period; see the regulators table.

Professional regulators and what each one publishes

The map is mixed. Speech-language pathology is under the Regulated Health Professions Act (RHPA). Occupational therapy, physiotherapy and psychology are listed in Schedule 2 as still operating under their own profession-specific Acts, and the College of Physiotherapists says it has no timeline for moving to the RHPA. Check each clinician’s own regulator for records, fees, advertising and supervision rules.

Reviews and testimonials: the CASLPM rule

The CASLPM Advertising Standard of Practice, approved on 2 May 2026, says registrants will not solicit reviews or testimonials, including social media commentary and linked resources that carry testimonials. They should take reasonable steps to remove testimonial-style comments on platforms that allow unsolicited comments. The companion FAQ says reviews from clients, relatives, friends and others cannot be used in advertising. The standard also says it supersedes any provisions set by an employer, and registrants remain responsible for advertising created by another person.

That makes this an SLP-specific rule in the sources we read. The physiotherapy advertising direction names discounts, gift certificates, package deals and free consultations but does not name testimonials in the text we read, and we did not find readable review rules for occupational therapy or psychology. Check each clinician’s own regulator for the advertising rule that applies to that profession.

Working with children: reporting, consent and record checks

Reporting is a duty of any person with information that leads them reasonably to believe a child is or might be in need of protection. The Child and Family Services Act (CFSA) says to report forthwith to an agency or to a parent or guardian of the child, with agency-only reporting in the cases s.18(1.1) lists. The duty applies despite professional duties and confidentiality, except solicitor-client privilege. In the Act a child is a person under the age of majority. The provincial reporting page lists province-wide intake and after-hours service at 1-866-345-9241, and (204) 944-4200 in Winnipeg; for an emergency call 911. The page says a reporter does not have to give a name.

PHIA section 60(1)(e) says a parent or guardian exercises the PHIA rights of a minor who does not have the capacity to make health care decisions. For consent to treatment, CASLPM’s informed consent FAQ states that the Health Care Directives Act presumes people 16 and older competent and that anyone under 16 needs a parent’s or guardian’s consent. CPM’s mature-minor document says a practitioner can find a child under 16 sufficiently mature to consent in the absence of a parent, within the child’s best interests. We read these through the regulators’ guidance and did not open the Directives Act text, so check it directly.

On separated parents, CASLPM’s FAQ says only one parent or guardian need consent, that registrants should have the parent confirm in writing that they hold the decision-making responsibility, and that if another parent or guardian asks for information about the services, the registrant must provide it. A registrant who has reason to think the consent is not sufficient may take extra steps. The comparison page shows the same questions for every province.

We found no Manitoba statute that requires a private therapy clinic to run criminal record or vulnerable sector checks. The requirements we found attach to a regulator or a funder:

• CASLPM registrants give a satisfactory criminal record check, child abuse registry check and adult abuse registry check at registration and every five years (General Regulation ss.2.5 and 2.32).
• Children’s disABILITY Services requires a criminal record check with a vulnerable sector search, plus child abuse registry and adult abuse registry checks, for agencies with a service purchase agreement (CDS Security Check Policy).
• Child Abuse Registry check: an employer or other person may apply, with the person’s written consent, when the work involves the care of a child or may permit unsupervised access to a child. The initial application carries a $20 fee that is waived for some purposes.

Running the clinic as a business and employer

These items sit outside health regulation but apply to most clinics. The thresholds come from the pages linked in the sources directory.

• Accessibility for Manitobans Act: standards apply to private organizations with one or more employees, including healthcare and professional services. Customer service has applied since 1 November 2018, employment since 1 May 2022, and information and communication since 1 May 2025. Web content must meet WCAG 2.1 Level AA when it is published after the standard applies or is needed to access goods and services, with listed exceptions. The customer service standard’s documentation duties apply only to organizations with 50 or more employees. Accessibility plans are best practice for private organizations but not required by the legislation.
• Workplace safety and health: a safety and health committee where at least 20 workers are regularly employed (Act s.40). Where no committee is required but five or more workers are regularly employed, the employer designates a worker safety and health representative (s.41). The Regulation requires a written harassment prevention policy developed in consultation with the committee or representative (s.10.1) and a risk-of-violence assessment (s.11.2).
• Workers’ compensation: businesses that employ workers in Manitoba register with the WCB. Service is among the mandatory industries, and in a mandatory industry everyone who works for the business, including contract workers, is considered a worker. We did not see a health care exclusion on the page. The registration deadline is not stated there.
• Employees and contractors: the Employment Standards Code does not apply to an independent contractor (s.2(3)). The fact sheet says employees who are mistakenly classified as independent contractors are still covered, and Employment Standards enforces payment of wages. Overtime is paid at not less than 150% of the regular wage (s.17(1)).
• Sick notes: Bill 11 limits when an employer can ask for a sick note, and it took effect on 1 October 2026.
• Health profession corporations: Part 5 of the RHPA lets regulated members of the same profession set up a corporation with a permit; it practises only through regulated members of that one profession (s.59(2)). We found no corporation provisions in the Acts for occupational therapy, physiotherapy or psychology.
• Sales tax: the Retail Sales Tax Act s.4(1) lists the taxable services, and health or therapy services are not on that list. That is a reading of a list, not an explicit exemption statement.
• Business name: all partnerships must be registered, and a sole proprietor generally registers a business name unless trading under their own surname.
• Premises: we found no health-facility or premises licence on the official pages we read.

Funding programs and insurers

Children’s disABILITY Services (CDS) serves Manitoba residents under 18 with a medical diagnosis that includes autism spectrum disorder. Its services include case management, respite, behavioural services and therapy through the Children’s Therapy Network of Manitoba, which is delivered through regional health authorities and other public partners. For preschool children, the named autism services are Autism Outreach from the Department of Families, based on DIR/Floortime, and the St.Amant Autism Early Learning Program, which uses applied behaviour analysis. The pages do not say private providers can be paid, and we found no individualized autism funding program with a provider registry like Saskatchewan’s.

Families receiving CDS funding may self-manage services such as respite and summer skills programming. The December 2025 invoicing guidelines require monthly claims no later than 10 working days after month-end and copies of invoices kept for six years. That guide describes respite and related supports, not clinic billing for therapy.

Other payers we read: the Manitoba Public Insurance Personal Injury Protection Plan covers care by physiotherapists and registered psychologists for collision injuries, and says most physiotherapists, athletic therapists and chiropractors bill MPI directly; a public provider-registration or fee page was not found. WCB Manitoba says all vendors and service providers need a WCB account to invoice, with a separate account for each location, and physiotherapists in fee-for-service clinics sign an individual services agreement. The WCB does not process invoices submitted more than 12 months after the service, and some services such as physiotherapy need pre-approval.

TherapyCRM's funding tracking is built around the Ontario Autism Program; it does not support Manitoba's Children's disABILITY Services.

Dated changes to check

We found no future-dated Manitoba change for this page, apart from the transportation standard that applies to vehicles-for-hire. The changes below are dated; check each source again before relying on it.

Official sources directory

Deep links we opened on 8 October 2026, one line each. Government PDFs may move; if a link fails, search the title on the same site.

How TherapyCRM fits

TherapyCRM is practice management software with a clinical record. It does not decide which rules apply to your clinic, and nothing on this page describes TherapyCRM as meeting any of them.

Manitoba clinicians can face different retention clocks inside one clinic: CASLPM and COTM count from the last entry and, for minors, from age 18, while CPM uses seven years and age 25. TherapyCRM stores each client’s date of birth and the dates of their appointments. Its Records and retention settings page shows a retention schedule by record class, in years after the last entry with a separate figure for minors counted from age 18, and lists records past retention. That review only reports; nothing is deleted from it, and a practice can place a legal hold on a client’s records. Check the figures against each clinician’s regulator.

PHIA section 60(1)(e) lets a parent or guardian exercise a minor’s rights when the minor lacks capacity. In the Family and consent tab of the client page, a Custody and consent card records a custody status for each guardian, shown as Custodial, Access only or No custody, and a consent ledger that notes who gave each consent and in what authority.

TherapyCRM's funding tracking is built around the Ontario Autism Program; it does not support Manitoba's Children's disABILITY Services.

Frequently asked questions