Bill 11 record-keeping checklist: the records to keep for three years

Why organize your records now?

Bill 11 is not yet in force, but when it is proclaimed, your agency will have three years to keep copies of health care facility contracts and six months to report aggregate billing and pay rate data to Ontario's Ministry of Health. Starting now gives you time to set up a system that captures the right data without scrambling when the proclamation comes.

The checklist below covers what Bill 11 will require legally, plus what you should track operationally to produce those reports without re-creating data from invoices or memory.

Bill 11 record-keeping checklist

1. Contracts with health care facilities

• Save a signed copy of every contract entered into, amended, or modified after Bill 11 comes into force.
• Label each contract with the facility name, contract start date, and expected end date.
• Store contracts in a centralized folder (e.g., a shared drive, document management system, or filing cabinet labeled by facility and year).
• Set a calendar reminder for three years after each contract expires. When the date passes, you can delete the contract.
• Include in the contract file any amendments, extensions, or rate changes agreed with the facility.

2. Invoices and billing records

• Keep a copy of every invoice sent to a health care facility that shows the billing amount, the rate charged, and the period covered.
• Invoices must be kept for the same period as contracts (three years after contract expiry, or as prescribed by regulation when the Act comes into force).
• Organize invoices by facility and month so you can retrieve them if the ministry requests them during an audit.
• Ensure each invoice clearly shows: facility name, invoice date, period of service, number of workers or hours, rate per hour, and total billed amount.

3. Per-assignment records (worker, facility, hours, rates)

• Keep a record of every worker assignment to a health care facility. Include: worker name or ID, facility name, assignment date, hours worked, rate paid, and role.
• Use a spreadsheet, timesheet system, or staffing software that you can easily query. When you need to report to the ministry, you will aggregate these records by facility and reporting period.
• Do not discard individual assignment records; keep them for at least three years after the assignment ends (aligned with contract retention).
• Ensure your system captures: pay rate (what you paid the worker), billing rate (what you charged the facility), and whether any premiums or adjustments applied.

Bill 11 record-keeping setup guide

How to prepare your data structure now

You do not need to wait for Bill 11 regulations to start capturing the right data. Set up a simple process now:

• Create a file or spreadsheet for each health care facility client with columns: Date, Worker Name/ID, Hours Worked, Rate Paid, Billing Rate, Role, Notes.
• Each time you place a worker or record hours, enter the data immediately (do not rely on memory or invoices later).
• Store invoices digitally, organized by facility and month, or integrate your accounting software with your staffing software so invoices and assignments match.
• Set a recurring monthly or quarterly reminder to review records for accuracy and completeness. If data is missing or unclear, fix it while the assignment is fresh.
• Practice exporting or aggregating your assignment data by facility and month. If Bill 11 requires reporting for months July to December, can you pull that data in under an hour? If not, adjust your system.

What if you are using a spreadsheet?

A spreadsheet is better than no system, but has limits. Make sure it includes:

• A dedicated worksheet for each facility or a Master sheet with a Facility column for filtering.
• Columns for: Date, Worker ID, Hours, Rate Paid, Billing Rate, Role.
• Backup copies saved to a shared drive weekly.
• Read-only access for workers; only payroll and dispatch can edit.
• A summary sheet that totals hours and rates by facility for each reporting period.

When Bill 11 is proclaimed and reporting begins, you will copy data from your spreadsheet into the ministry's reporting form.

What if you are using a staffing software?

A platform with assignment history and export capability is ideal. Verify it can:

• Record worker assignment to a facility, hours worked, and rate paid.
• Track both the rate you paid the worker and the rate you billed the facility.
• Export assignment data filtered by facility, date range, and role.
• Generate a summary report of hours and rates by facility for a given period.
• Retain historical data for at least three years.
• Integrate with your invoicing or accounting system so that billing and assignment data align.