Responding to Third Party Requests

Consultation 31

About the standard

The Responding to Third Party Requests standard was last reviewed in January 2010 and is currently under review. A proposed title change improves awareness of the information provided within the standard. The added preamble and list of definitions provide necessary context while emphasizing the professional responsibility, accountability and objectivity that must be practised when handling these requests. Other amendments and additions support regulated member compliance with the Health Information Act and overall, emphasize fairness and protect the rights of vulnerable patients. Proposed title change to Completing Forms & Responding to Third Party Requests to ensure regulated members are aware of content within the standard.

What’s changed?

  • Addition of a preamble emphasizes the core professional responsibility, accountability and objectivity that is required when responding to requests of patients and third parties.
  • List of definitions created to provide regulated members with added context and clarity around clauses.
  • Revisions made to clarify requirements for requests, consent and timeframe to support compliance with the Health Information Act.
  • Changes overall were made to emphasize fairness and protect the rights of vulnerable patients.

View the draft standard

For your convenience, the draft standard has clean and marked copies available.

All Resources

Your opinion matters

Changes to CPSA’s Standards of Practice impact your day-to-day practice. Your feedback is important to us, as it helps us develop clear, reasonable expectations and helpful, applicable resources. We appreciate the time you took and the input you provided.

CPSA regulated members, partner organizations, other healthcare professionals and Albertans were invited to provide feedback from Oct. 7 to Nov. 6, 2025.

Anonymized feedback will be considered by Council. Once amendments are finalized and approved by Council, members will be notified by email and The Messenger newsletter.

We respect your privacy

All feedback is subject to CPSA’s Privacy Statement. CPSA reviews all comments before publication to ensure there is no offensive language, personal attacks or unsubstantiated allegations.

Other feedback on this standard

David G. Moores
CPSA-regulated member

Thank you for the opportunity to comment on 3rd Party Requests SOP. It is clear and an improvement on the previous document. I wonder about how best to ensure that undergraduate and postgraduate health professionals are made aware of these and other documents. While the "devil in the details" may be disarming, the CPSA's SOP approach is vital to quality, safety and quality improvement. Who within the CPSA and our respective medical schools are collaborating on this?

John Kramer
CPSA-regulated member

1. Quality of Care Risks

The CPSA document’s requirements for form completion and third-party responses can inadvertently increase liability by mandating medical opinions for non-clinical purposes, risking misinterpretation and punitive consequences if information is incomplete or misunderstood.

Physician independence is challenged when external parties pressure physicians to provide judgments that may exceed their direct clinical scope, risking error and undermining their impartiality.

2. Professional Stress and Burnout

Additional administrative burdens and the fear of repercussions for honest, nuanced responses (or for refusing inappropriate requests) increase stress, discourage practitioner engagement, and contribute to burnout.

3. Threats to Access

Complex and demanding third-party requirements may deter physicians from engaging with certain patient populations or occupational health cases, worsening shortage in key areas.

4. Erosion of Trust

If physicians feel compelled to comply with requests that threaten their independence or professional judgment—for instance, issuing opinions on matters outside their expertise—patients may perceive doctors as agents of insurers/employers rather than advocates, eroding trust.

5. Chilling Effect on Advocacy

The mention of legislative requirements (HIA, provincial standards) must be balanced with respect for physician autonomy; otherwise, advocacy for patient interests and ethical dissent is suppressed.

6. Financial and Systemic Burdens

Third-party forms and the liability attached can increase malpractice risks and administrative costs, crowding out resources for clinical care.

Conclusion
Policies and standards—such as those in the CPSA document—should:

Safeguard physician autonomy so that responses to third-party requests remain strictly within scope and evidence-based, not coerced.

Limit liability for honest, bounded opinions.

Promote clear boundaries: Physicians must not be pressured to act as de facto legal or insurance gatekeepers. The role of a physician is clinical advocacy, not bureaucratic risk-bearing.

Francois Grimbeek
CPSA-regulated member

The only private business where you are “told “ what you can ask for your time. I am overwhelmed with insurance forms, third party requests. Forms are on my family time, I will not do this for peanuts, sorry, lawyers charge $600 / hr, why should my time be less appreciated. If we get restricted on what we can charge patients, either AHS, should cover cost or o will refuse to do “ forms”. Family physicians remain the puppets for government and governing bodies.

Noel Corser
CPSA-regulated member

I would very much like to see the basis for the statement that “Regulated members are ethically and legally required to provide reports on patients they have attended” - perhaps this holds for requests by patients (although I can easily think of counter-examples), but I’m surprised that the CPSA holds that docs must complete any form that a third-party throws at them? Unless I'm missing something about what "reports" means? This isn’t about providing “health information” from a patient’s chart, as a custodian, this is spending significant time and energy on forms that in many cases ARE NOT “an essential part of good patient care”, as claimed. I understand the CPSA’s mandate to protect patients’ interests, but I’m unclear that mandate extends to protecting the interests of third-parties, particularly when “forms” are a top-3 cause of physician burnout (which clearly HARMS patients). The fog is beginning to clear around why we’ve gotten to this state! This is a critical issue that the CPSA needs to wrestle with - and not by tweaking the Standard to address fees. Perhaps reviewing what’s actually meant by the HIA, and/or pushing for changes to the legislation if this an error of government rather than regulator? I can’t emphasize it enough - the CPSA is mandated to protect Alberta patients (among other things), and if its actions lead to net unintended harm (e.g. the effect of physician burnout on primary care) relative to intended benefit (e.g. forms getting completed), then it’s failing in this mandate.