Billing day (Journée de facturation)
A billing day is counted only if the compensation (pay) associated with that day is equal to or greater than $500. A half day can be counted if the compensation associated with that half day is equal to or greater than $250 and less than $500.
Compliance notice (Avis de conformité)
All family physicians practising under the Quebec insurance plan are subject to the Special agreement on compliance with regional physician resource plans (PREMs). Under that agreement, the physician has to obtain a notice of compliance with the PREM from the Regional department of general medicine (DRMG) of the practice region in question. Obtaining this compliance notice implies the physician’s commitment to maintain the majority of his practice, i.e., 55% or more of his billing days, in a sub-area of that region (RLS).
The frequently used expression “to have a PREM” actually means holding a notice of compliance with a given region’s PREM.
A facility is a physical site where healthcare services are delivered, i.e., hospitals, local community services centres [CLSCs], long-term care facilities [CHSLDs], rehabilitation centres, etc., which are grouped together under a healthcare establishment within the meaning of the legislation.
Healthcare establishment (Établissement de santé)
A healthcare establishment is a group of healthcare facilities (hospital, local community services centre [CLSC], long-term care facility [CHSLD], etc.) which covers services for a given region. Following the adoption of Bill 10 (2015), the Minister grouped the 182 existing healthcare establishments into 34 establishments. Rounding out the network are the university health centres, and institutes.
Initial application period (Période initiale d’application)
The initial application period runs from October 15 to October 31.
Interregional mobility(Mobilité inter-régionale, or MIR)
Status of a physician who has worked a minimum of 200 days (synonymous with “doctor already practising”).
Local services network (Réseau local de service, or RLS)
Sub-area of a region (subregion).
Each region is divided into sub-areas. So you have a notice of compliance with a region’s PREM, with priority hiring in a subregion (RLS).
- Part-time locum (Dépannage à temps partiel)
A physician who holds a compliance notice but wants to perform locums part-time. Note that this practice is included in the 55%-45% ratio.
- PREM exclusively for locums (PREM dépannage exclusif)
A doctor wishing to practise exclusively under the locum mechanism can obtain a waiver in lieu of a compliance notice if positions are available. He has to apply for it on registering for locums with the provincial Centre national médecins-Québec. To register for locums, the physician has to hold a permit to practise from the Collège des médecins du Québec and malpractice insurance corresponding to the areas of activity covered by his locum practice. A practice is considered exclusive when it includes 95% or more of the physician’s total billing days.
New biller (Nouveau facturant)
New billers are physicians who have not yet completed at least 200 days of practice under Quebec’s public health insurance plan. During those 200 days of practice, the physician must have held a valid notice of compliance with the region’s regional physician resource plan (PREM) or a waiver in lieu of a notice of compliance with the PREM.
Non-compliance with the conditions of the compliance notice (Non-respect des conditions de l’avis de conformité)
A physician who does not meet his commitment to perform 55% of more of his billing days in the geographical area covered by his PREM compliance notice is subject to a 30% cutback of his total compensation for the year in question, i.e., from March 1 to February 28. The physician is notified by the Quebec Health Insurance Board (RAMQ) around September 1 of the following year. He may, however, request an exemption; his file will then be reviewed by the MSSS-FMOQ Parity Committee responsible for the Special Agreement concerning compliance with PREMs.
Opting out of a PREM (Désistement à un PREM)
You may opt out of a regional physician resource plan (PREM) at any time if you have not started your practice.
Physician resource plan (Plan d’effectifs médicaux, or PEM)
Physician resource plan of a facility, a healthcare establishment
In family medicine, the term “PEM” is used to designate positions in hospitals. You need a PEM to be able to work in a hospital setting.
Practice without a compliance notice (Pratique sans avis de conformité)
A physician practising under the Quebec Health Insurance Plan (RAMQ) without having obtained a notice of compliance with the regional physician resource plan (PREM) from the Head of the Regional department of general medicine (DRMG) of a region will have his total compensation cut back by 30%. A five-year waiting period will also be imposed on him before he can apply for a compliance notice in that region. If, however, the physician obtains a compliance notice from another region and meets his commitment there, this period will be only three years.
Quebec is divided into 18 administrative regions. When you apply for a compliance notice, you do so to one of these regions:
Region 1 – Bas-Saint-Laurent
Region 2 – Saguenay–Lac-St-Jean
Region 3 – Quebec City (Capitale-Nationale)
Region 4 – Mauricie–Centre-du-Québec
Region 5 – Estrie
Region 6 – Montreal
Region 7 – Outaouais
Region 8 – Abitibi-Témiscamingue
Region 9 – Côte-Nord
Region 10 – Nord du Québec
Region 11 – Gaspésie–Iles-de-la-Madeleine
Region 12 – Chaudières-Appalaches
Region 13 – Laval
Region 14 – Lanaudière
Region 15 – Laurentides
Region 16 – Montérégie
Region 17 – Nunavik
Region 18 – James Bay Cree Territory
Regional department of general medicine (Département régional de médecine générale, or DRMG)
Each region has a regional department of general medicine (DRMG) consisting of all the general practitioners in the region who receive compensation from the Quebec Health Insurance Board (RAMQ). The DRMG’s responsibilities are carried out by a Steering Committee consisting of physicians who belong to the department. In particular, the DRMG’s mandate is to make recommendations concerning PREMs, general medical services, and specific medical activities (AMPs). It defines and proposes a regional organization plan for general medical services and a network of access to general medical services.
Head of DRMG (Chef du DRMG)
Head of Regional department of general medicine (Chef du département regional de médecine générale)
The Head of the Regional department of general medicine is in charge of authorizing and signing compliance notices.
Regional physician resource plan (Plan régional d’effectifs médicaux, or PREM)
Regional physician resource plans (PREMs) in family medicine authorize, for each of Quebec’s administrative regions, a quantitative target for recruitment of family physicians designed to distribute additional physician resources equitably. These plans are updated yearly on the basis of the differences observed between the resources in place and the needs to be met in each region. They take into account the mobility of physicians already practising and the expected number of new doctors. Since Quebec’s regions do not all enjoy the same level of access to healthcare services, PREMs aim to provide Quebecers with more equitable access to medical services.
In family medicine, the term “PREM” is used to designate positions allocated in one of the 18 administrative regions, with priority hiring in a local services network (RLS). Obtaining a compliance notice implies that the doctor undertakes to maintain the majority of his practice, i.e., 55% of more of his billing days, in a sub-area (RLS) of the region where he holds a PREM.
PREMs are associated not with a type of practice but with a practice location.
Selection criteria (Critères de sélection)
When the number of candidates exceeds the number of positions available in the regional physician resource plan (PREM), a selection is made. This selection is made on the basis not of the physician’s competence, but of his interest in practising in the priority needs identified by the regional department of general medicine (DRMG).
Special medical activity (Activité médicale particulière, or AMP)
Services delivered in an Emergency department; care provided to patients admitted for short-term care; services involving on-call duty provided in a long-term care centre or rehabilitation centre, or in connection with a local community service centre (CLSC) home care support program; medical services in obstetrics; primary care services provided to vulnerable patients in their homes, in a private health facility, or in any centre operated by an establishment; and, finally, services delivered in the context of any priority activity determined by a regional department of general medicine (DRMG) and approved by the Minister of Health. AMPs are listed in the Act respecting health services and social services as having a priority dimension. Conditions for physicians’ participation in AMPs have been determined through a special agreement between the Minister and the FMOQ.
Upon obtaining a notice of compliance with the regional physician resource plan (PREM), a physician with 15 years of practice or less must choose an AMP offered by the region to meet local needs. This AMP will be performed in one of the services named, for the equivalent of 12 hours per week.
University needs (university physician resource plans, or PEMUs (Besoins universitaires, PEMU)
Compliance notice reserved for doctors wishing to teach. This involves teaching positions set aside to meet priority academic needs.
***Caution: For this type of PREM, it is the director of the family medicine program of the faculty concerned who selects the candidate and confirms his choice with his region’s Regional department of general medicine (DRMG) and the Ministry of Health and Social Services (MSSS) by October 31.
(Please note that it is also possible to teach in a university family medicine group (UFMG) if a position is available in that UFMG, when you hold a regular PREM. You then have to go through the process of applying for a regular compliance notice.)