Physiotherapist Complaints, Investigations and Discipline in Ontario

When the College of Physiotherapists Contacts You

This page is for physiotherapists registered in Ontario, including clinic owners and those working in hospitals, home care and multidisciplinary clinics. The College hears from patients, employers, other physiotherapists and insurance companies. Insurer concerns about billing are a distinctive source of investigations in this profession.

Illustrative example, not an actual College letter

“The College has received information from an insurer about treatment invoiced under your name at a clinic where you work. The Registrar has appointed an investigator. You will receive the results of the investigation and an opportunity to respond.”

Who Investigates and Who Decides

Regulator: The College of Physiotherapists of Ontario, continued, under the Physiotherapy Act, 1991. Its complaint, investigation and discipline procedures come from the Health Professions Procedural Code, Schedule 2 to the Regulated Health Professions Act, 1991 (“the Code”), which applies to every regulated health profession in Ontario.
Who investigates: College investigators. A complainant can choose the formal complaint route, or leave the information with the Registrar to decide whether to investigate. In a Registrar’s investigation you must co-operate fully (Code, s. 76(3.1)).
Who decides at the investigation stage: A panel of the Inquiries, Complaints and Reports Committee (ICRC) (Code, s. 26). The College says the process typically takes eight to 12 months.
Who holds hearings: The Ontario Physiotherapists Discipline Tribunal. Since January 1, 2026 it has been part of the Health Professions Discipline Tribunal on a trial basis. Hearings are held virtually and are open to the public.

Key timelines in the Code

The Registrar must notify you within 14 days of receiving a complaint or report (Code, s. 25(6)).
You may make written submissions to the Inquiries, Complaints and Reports Committee within 30 days of receiving that notice. The committee can shorten that time if it believes, on reasonable and probable grounds, that your conduct exposes or is likely to expose patients to harm or injury (Code, s. 25.2).
Complaints are expected to be disposed of within 150 days. If that is missed, the Registrar must give the complainant a new expected date no more than 60 days later (Code, s. 28).
With both your and the complainant’s consent, the Registrar can refer a complaint to alternative dispute resolution, but not if it involves an allegation of sexual abuse or has already been referred to discipline (Code, s. 25.1).

Common Issues in Physiotherapist Investigations

Billing and fees

Invoices for treatment you did not provide or supervise, services billed under your registration by a clinic, and auto insurance or benefits claims. The College’s Funding, Fees and Billing standard applies, and responsibility can follow your name even if the clinic did the billing.

Documentation

Missing assessments, treatment plans or progress notes, and records that do not match invoices (Documentation standard).

Supervision

Assigning care to physiotherapist assistants or students without adequate supervision (Supervision standard).

Boundaries and sensitive areas

Treatment near sensitive areas without informed consent and appropriate draping, and personal relationships with patients. The Boundary Violations and Sexual Abuse standards apply, and sexual abuse findings carry mandatory penalties (Code, s. 51(5)).

Controlled acts and conflicts

Spinal manipulation, internal pelvic assessment or treatment, wound care below the dermis and tracheal suctioning must be performed in compliance with the regulations; failing to do so is professional misconduct under the Act itself (Physiotherapy Act, 1991, s. 4(2), (4)). Conflicts of interest in clinic arrangements raise related issues (Controlled Acts and Conflict of Interest standards).

What Can Happen Next

Complaint or Registrar’s investigation

After considering the investigation and your submissions, a panel of the Inquiries, Complaints and Reports Committee (ICRC) may take no further action; give advice or recommendations; require a specified continuing education or remediation program (SCERP); require you to appear to be cautioned; refer specified allegations of professional misconduct or incompetence to the Ontario Physiotherapists Discipline Tribunal; or refer you for incapacity proceedings (Code, s. 26). Matters are also sometimes resolved through an undertaking, such as an agreement to restrict or monitor your practice. If the panel considers a complaint frivolous, vexatious, made in bad faith, moot or an abuse of process, it must give notice and allow 30 days for written submissions before declining to act (s. 26(4)–(5)).
Interim order

If the committee believes your conduct exposes or is likely to expose patients to harm or injury, it can suspend your certificate or impose terms, conditions or limitations while the matter continues (Code, s. 25.4(1)). You must normally receive notice and at least 14 days to make written submissions first, unless the risk is urgent (s. 25.4(6)–(7)). The order lasts until it is varied or the matter is finally resolved (s. 25.4(4)).
Discipline hearing

A panel of the Ontario Physiotherapists Discipline Tribunal hears evidence and decides whether professional misconduct or incompetence is proven (Code, ss. 51, 52). If misconduct is found, it may revoke or suspend your certificate, impose terms, conditions and limitations, order a reprimand, or order a fine of up to $35,000 (s. 51(2)). Findings of sexual abuse carry mandatory orders, including revocation for the conduct listed in s. 51(5).
Review or appeal

HPARB review: you or the complainant may ask the Health Professions Appeal and Review Board to review an ICRC decision on a complaint, except a referral to discipline or for incapacity proceedings (Code, s. 29(2)). The request must be made within 30 days after receiving the notice of the right to request a review that comes with the decision (s. 29(3)), and HPARB cannot extend that time by more than 60 days (s. 29(4)).

Divisional Court: discipline and fitness to practise decisions can be appealed on questions of law, fact or both (Code, s. 70). Orders based on incompetence, incapacity or certain sexual abuse findings, and orders in matters where an interim order was in place, take effect immediately despite an appeal (ss. 25.4(5), 71, 71.1).

Checklist: Responding to a College of Physiotherapists Notice

Documents to gather

The College’s letter and the date you received it
Patient charts, including assessments, treatment plans, consent notes and discharge summaries
Invoices, insurer submissions and claim forms that list your name or registration number
Your schedule or timesheets for the dates in question
Your contract with the clinic, and any information about who controls billing
Supervision plans for assistants and students

Details to check in the notice

Is it a formal complaint, or a Registrar’s investigation started from information such as an insurer report?
Your deadline for written submissions
Which patients, dates and invoices are identified
Whether an interim order is being considered

Rules and resources to consult

Health Professions Procedural Code, ss. 25–29, 51–52, 70–71 and 75–76
Physiotherapy Act, 1991 and its regulations
College standards, including Funding, Fees and Billing, Documentation, Supervision, Boundary Violations and Sexual Abuse
Health Professions Discipline Tribunal rules and practice directions, if referred to a hearing
Your professional liability insurer: the College notes physiotherapists must carry liability insurance, which can give access to legal counsel

If a clinic billed under your name without your knowledge, preserve evidence of that now, such as schedules, messages and payroll, before you leave or are cut off from clinic systems.

Frequently Asked Questions

The clinic did the billing, not me. Can I still be found responsible?

Possibly. The College looks at whether invoices issued under your name were accurate and whether you took reasonable steps to oversee them. Showing what you knew, and what you did once you learned of a problem, is often important.

What is the difference between a complaint and a report?

A complaint is filed by someone, usually a patient or family member, who becomes a party and receives the decision. A report is information the Registrar acts on by appointing investigators (Code, s. 75), for example after a mandatory report from an employer or another professional. The same committee decides both, but HPARB review rights under s. 29 are tied to complaints.

Can I keep practising during the investigation?

Usually, yes. Your certificate is unaffected unless the committee makes an interim order (Code, s. 25.4) or you agree to an undertaking that limits your practice.

Will this appear on the public register?

The Code requires the public register to note cautions, SCERPs, acknowledgements and undertakings, and allegations referred to discipline (s. 23(2)). College by-laws can add more. Check what will be posted before agreeing to any resolution.

Sources

Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.

Regulated Health Professions Act, 1991, S.O. 1991, c. 18, Schedule 2 (Health Professions Procedural Code), ss. 23, 25–29, 51–52, 70–71, 75–76, 85.5 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
Physiotherapy Act, 1991, S.O. 1991, c. 37, ss. 4–5 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
College of Physiotherapists of Ontario, “The Complaints Process” — Checked November 10, 2026.
College of Physiotherapists of Ontario, “Discipline Hearings and Decisions” — Checked November 10, 2026.
College of Physiotherapists of Ontario, “Standards” — Titles checked November 10, 2026.
Health Professions Appeal and Review Board (role; Consolidated Rules of Practice and Procedure in effect May 4, 2026) — Checked November 10, 2026.