Introduction

The psychological pre-screen is one of the most common line items on an MVA file: a short screening interview, typically $190 to $282.50, attached to an OCF-18 for a full psychological assessment. Clinics use it as the first step toward psychological treatment. It feels low-risk. It is not.

Across roughly 50 Licence Appeal Tribunal decisions, pre-screens are losing on both fronts. As evidence, they are routinely given little or no weight. As billable services, they are denied far more often than they are paid. The pattern is consistent enough that clinics should stop treating the pre-screen as a revenue item or a proof of injury, and start treating it as what the Tribunal considers it to be: a triage step with two narrow paths to payment.

This post walks through what the Tribunal has actually ruled, where the wins are, where the traps are, and how to position the pre-screen so it helps your file instead of hurting it. If your clinic bills psychological assessments, this pairs directly with our guide to validity testing and the SIMS at the LAT, which covers the assessment quality bar that comes next.

Why the Pre-Screen Keeps Losing as Evidence

The core problem is structural. A pre-screen is a screening interview. It produces a provisional diagnosis from self-reported symptoms. The Tribunal has said, repeatedly, that this is not medical evidence of anything.

The canonical rule comes from a 2020 decision the Tribunal still cites: "a psychological pre-screen interview where the provisional diagnosis is determined solely based on the applicant's self-reporting is not sufficient evidence on its own" (2020 CanLII 87934 (ON LAT), at para. 37, adopting a Financial Services Commission of Ontario line). Screens based on self-report alone fail because there is nothing objective underneath them.

Three recurring defects sink specific reports:

1. Authorship problems. In 2025 CanLII 523 (ON LAT), the report was signed by a psychologist but the screening was conducted by a psychotherapist, with no details on supervision or who did which portion. The Tribunal preferred the insurer's report. The same defect appears in 2025 CanLII 75768 (ON LAT), where a psychotherapist's pre-screen was supervised by a psychologist who was not involved in preparing it. Psychotherapists and social workers are not "health practitioners" under s. 3(1) of the SABS, so a screen they conduct cannot carry a diagnosis. In 2020 CanLII 12749 (ON LAT), the adjudicator could not even tell who "we" was in the report. That uncertainty alone cost the report its weight.

2. No explanation of why the screen happened. In 2018 CanLII 130864 (ON LAT), the adjudicator gave no weight to the plan because "the pre-screening makes no reference as to why the pre-screening was done in the first place." No referral source, no contemporaneous complaints, no records reviewed. The same gap appears in 2025 CanLII 125978 (ON LAT), where the report had no accompanying clinical notes, no psychometric testing, and no information on what records were reviewed.

3. The report contradicts the chart. In 2020 CanLII 34466 (ON LAT), the family doctor's note two weeks after the screen said "no psychiatric issues." In 2025 CanLII 119946 (ON LAT), a social worker's screen did not concur with the family doctor's clinical notes. The Tribunal reads these conflicts against the screen, not against the doctor.

Timing matters too. In 2023 CanLII 119802 (ON LAT), the first mention of psychological complaints anywhere in the file was the pre-screen itself, four years after the accident. The Tribunal called it unpersuasive. A screen with no clinical footprint behind it reads as funding-driven, not medicine-driven.

How the Pre-Screen Also Loses as a Fee

The fee data is just as consistent. Every adjudicated pre-screen fee falls in the $190 to $282.50 band. Most of them were denied, and the denials fall into four mechanical traps:

2. The duplication trap. In 2025 CanLII 28492 (ON LAT), a $282.50 pre-screening plan submitted the same day as a $2,486 assessment plan was denied as a duplication of services.

3. The anti-stacking trap. In 2023 CanLII 72635 (ON LAT), a separate treatment plan for a pre-screen on top of an approved full assessment was characterized as "an attempt to contravene the $2,000.00 maximum payable for an assessment" under s. 25(5)(a). The Tribunal's rule: a pre-screen is unnecessary when the full assessment is approved.

4. The guideline cap. In 2020 CanLII 87977 (ON LAT), a $200 pre-screen was denied because the insurer had already paid the Professional Services Guideline (Superintendent's Guideline No. 03/14) maximum for the assessment. The guideline does not pay for the same professional service twice.

This is the same adjudicated-fee terrain as our posts on how much clinics can charge for form completions and billing above guideline rates: the Tribunal knows what the service costs, and it will not pay twice or above the schedule.

Where the Pre-Screen Can Still Win

The losses are consistently insurer procedural errors only.

The merits lane. In 2024 CanLII 2631 (ON LAT), a $250 pre-screen assessed inside the OCF-18 itself was found reasonable and necessary. The applicant was entitled to the amounts incurred "starting on the 11th business day after the respondent received the plans, with interest in accordance with s. 51 of the Schedule."

The process lane. In 2024 CanLII 102102 (ON LAT), a $282.50 pre-screen and a $2,486 assessment were both ordered payable, not because the reports were persuasive, but because the insurer's denial letter failed s. 38(8). Once the denial was non-compliant, the amounts became payable under s. 38(11) once properly invoiced. The pre-screen's content was irrelevant. The insurer's process was the reason it got paid.

The evidentiary lane. In 2022 CanLII 70253 (ON LAT), a pre-screen plus a psychological assessment supported removal from the Minor Injury Guideline, and the insurer had filed no examination of its own. The $2,200 assessment was payable. The pre-screen earned its keep because it led somewhere.

The lesson across all three: the pre-screen is not being approved in LAT.

The Approval Tally

The numbers put the pattern in one line. Across 11 adjudicated disputes over pre-screen and psychometric testing fees, two were approved and nine were denied.

Approved (2 of 11):

  • 2024 CanLII 2631: a $250 pre-screen, approved because time-limits weren't met by the insurer.
  • 2024 CanLII 102102: a $282.50 pre-screen, payable only because the insurer's denial letter failed s. 38(8)

Denied (9 of 11): 2025 CanLII 523, 2023 CanLII 98426 (timing), 2025 CanLII 28492 (duplication), 2023 CanLII 72635 (stacking), 2020 CanLII 87977 (guideline cap), 2020 CanLII 57416 (no submissions), 2017 CanLII 33680, 2023 CanLII 47507, and 2021 CanLII 314.

The follow-on assessments tell the same story. They were approved only where the file escaped the MIG (2022 CanLII 70253, 2026 CanLII 53737, and 2022 CanLII 120024) or the denial process failed (2024 CanLII 102102). In every file held inside the MIG, the pre-screen and the assessment died together.

Conclusion

Pre-screens are not winning at the LAT, and the reason is structural, not bad luck. As evidence, they are screens, not diagnoses, and the Tribunal treats them that way. As fees, they sit inside a thicket of timing, duplication, stacking, and guideline rules that deny them by default.

That does not mean dropping pre-screens. It means scoping them correctly: a health practitioner conducts them, the report documents its own purpose, the fee rides inside the assessment plan, and the real evidentiary work happens in the assessment that follows. A pre-screen positioned that way is a useful first step. Positioned any other way, it is a $190 to $282.50 lesson.

If your clinic submits OCF-18s for psychological services, track how your pre-screens are structured against these rulings before the next denial arrives. The decisions we covered, including the 2026 cases, are summarized alongside their billing consequences in our roundup of 2026 LAT decisions affecting HCAI invoicing.