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Ontario · College of Chiropractors of Ontario

How to Respond to a CCO Complaint

10 min readLast updated July 14, 2026

The committee that handles your CCO complaint does not decide whether you are guilty — it decides, on paper alone, whether the allegations are serious enough to send to a hearing. That distinction changes how you should respond. And for chiropractors, a profession under unusually heavy insurance scrutiny, the stakes reach past the College: insurers read the public register, and a finding can cost you your billing networks.

Before you do anything: get legal advice and notify your liability insurer. Your written response is often the single most important document in the case. Do not alter the clinical record — inadequate records are misconduct in themselves — and do not contact the complainant, who is often your own patient.

Who regulates you, and under what law

Chiropractors in Ontario are regulated by the College of Chiropractors of Ontario (CCO) under the Regulated Health Professions Act, 1991 (RHPA) and the Chiropractic Act, 1991, together with CCO’s standards of practice, policies and guidelines.

The complaints process is the same statutory process that governs every Ontario health College — the one Ontario doctors, dentists and nurses go through. What is at stake is your certificate of registration. And the concept you may be found to have committed is professional misconduct, as defined in the professional misconduct regulation under the Chiropractic Act, or incompetence.

The ICRC: a screening committee, not a judge

Every complaint is handled by the Inquiries, Complaints and Reports Committee (ICRC) — a statutory committee of chiropractors and public members. Understanding what the ICRC actually does is the single most important thing for a chiropractor who has just received a complaint, because it is widely misunderstood.

The ICRC screens; it does not decide guilt. It reviews the complaint, your written response and any investigator’s report on paper. It does not hear live witnesses and it is not permitted to make credibility assessments — it cannot decide who is more believable. Its question is narrow: if the allegations were true, are they serious enough to refer to the Discipline Committee? This means a chiropractor can be referred to discipline even where they did nothing wrong — a referral is not a finding, and it does not mean the College believes the complainant.

How a complaint proceeds

A complaint must be made in a signed letter to the CCO. Then:

  1. CCO acknowledges the complaint within 14 days and, at the same time, notifies you — sending you a copy of the complaint and the supporting documents.
  2. You are asked to respond in writing, and to provide a copy of the patient’s clinical record with your response. The process proceeds by documentary exchange: you will generally not get to give an in-person explanation.
  3. CCO provides the complainant with a copy of your response and may seek further information.
  4. A panel of the ICRC reviews the file and makes its decision.

You will normally also receive your prior complaint history as part of this — the ICRC sees patterns, and so should you when you prepare.

The dispositions open to the ICRC

The RHPA defines how the ICRC may resolve a complaint. It can:

  • Take no further action;
  • Provide advice or recommendations;
  • Issue a written caution, or require you to attend to be cautioned in person;
  • Require a Specified Continuing Education or Remediation Program (SCERP);
  • Require you to sign an undertaking;
  • Refer specified allegations to the Discipline Committee for a hearing;
  • Refer to the Registrar for further investigation, or take other appropriate action.
Which of these becomes public matters enormously. Cautions delivered in person, SCERPs, undertakings and referrals to discipline are posted on the CCO public register under your name. Advice, recommendations and “no further action” are not. That line — between what publishes and what does not — is where most of a chiropractor’s energy should go.

The chiropractic-specific risk: insurance and billing

Chiropractic is one of the most actively investigated health professions in Ontario, and a large part of the reason is insurance. A complaint can come not only from a patient but from a third-party insurer, the WSIB, or another regulated professional — frequently about block billing, charging for services not rendered, or treatment allegedly driven by claim value.

The consequence reaches past the College. Insurers review the CCO public register, and in recent years have been known to de-list chiropractors found guilty of professional misconduct from their billing networks. For many practices, losing insurer billing status is a more serious commercial blow than the College penalty itself. This is why the publication question is not abstract.

Your first week

  1. Get legal advice and notify your liability insurer before you write anything. The written response is often the single most important document in the case — it is the version of events the ICRC reads.
  2. Diarise the deadline and request an extension early if you need one.
  3. Preserve the clinical record exactly as it stands. Inadequate record-keeping is an independent act of professional misconduct, and late edits turn a treatment question into an honesty question.
  4. Do not contact the complainant — often your own patient — to resolve it.

Key takeaways

  • Ontario chiropractors are regulated by the CCO under the RHPA and the Chiropractic Act, 1991. What is at stake is your certificate of registration.
  • The Inquiries, Complaints and Reports Committee (ICRC) SCREENS complaints on paper — it cannot make credibility assessments and does not decide guilt. A referral to discipline is not a finding.
  • The process is documentary: you respond in writing and provide the clinical record; you generally do not give an in-person explanation.
  • ICRC dispositions range from no action, advice and cautions to SCERPs, undertakings and referral to the Discipline Committee.
  • In-person cautions, SCERPs, undertakings and discipline referrals are posted on the CCO public register; advice and no-further-action are not. That line is where your energy should go.
  • Chiropractic is heavily investigated over insurance and billing — and insurers review the public register and may de-list chiropractors found guilty. Get legal advice before responding; never alter the record.

Related courses

Practical, self-paced CPD courses that map onto the issues in this guide. These are educational courses. They are not accredited by the CCO and are not a substitute for legal advice.

Dealing With a Complaint or Investigation Professionally

How to respond to a College complaint calmly, constructively and on the record.

View course →
Documentation for Healthcare Professionals

Record-keeping to CCO Standard S-002 \u2014 inadequate records are misconduct in themselves.

View course →
Consent and Chaperone in Healthcare Practice

Consent and boundaries for hands-on treatment, a recurring source of complaints.

View course →
Ethics and Ethical Standards for Chiropractors

Core ethical standards and the professional misconduct regulation.

View course →

Continue reading: Ontario chiropractors

What happens during a CCO investigation? Remediation and reflection for Ontario chiropractors

Frequently asked questions

Does a complaint mean I have done something wrong?
No. The Inquiries, Complaints and Reports Committee (ICRC) screens complaints on paper and asks only whether the allegations, if true, are serious enough to refer to the Discipline Committee. It cannot make credibility assessments. A chiropractor can be referred to discipline even where they did nothing wrong, and a referral is not a finding of misconduct — it does not mean the College believes the complainant.
Will I get to explain in person?
Generally not at the complaint stage. The CCO complaints process proceeds by documentary exchange: you respond in writing and provide a copy of the patient’s clinical record, and the ICRC decides on the paper record. This is exactly why your written response, prepared with legal advice, is so important — it is the version of events the Committee reads.
What outcomes can the ICRC impose?
Under the RHPA the ICRC can take no further action, give advice or recommendations, issue a written caution or require an in-person caution, require a Specified Continuing Education or Remediation Program (SCERP), require an undertaking, or refer specified allegations to the Discipline Committee. In-person cautions, SCERPs, undertakings and referrals are posted on the public register; advice and no-further-action are not.
Can an insurer complain about me, and does it matter?
Yes, and it matters a great deal. Complaints can come from third-party insurers, the WSIB or other regulated professionals, often about billing. And insurers review the CCO public register: in recent years chiropractors found guilty of professional misconduct have been de-listed from insurer billing networks. For many practices that commercial consequence is more serious than the College penalty itself.
Do I have to give the College the patient’s record?
Yes. When a complaint concerns a patient’s own treatment, CCO asks the chiropractor for a copy of that patient’s health record, and you are expected to provide it with your response. What you must never do is alter or supplement the record after the complaint arrives. Inadequate record-keeping is itself an independent act of professional misconduct.
Can I challenge an ICRC decision I think is wrong?
In most cases, yes. Where a matter is not referred to the Discipline Committee or the Fitness to Practise Committee, both the chiropractor and the complainant can ask the Health Professions Appeal and Review Board (HPARB) to review the ICRC decision. The request must be made within 30 days of receiving the decision, and the review considers whether the investigation was adequate and the decision reasonable.

This article is general information for chiropractors registered with the College of Chiropractors of Ontario and does not constitute legal advice. Regulatory processes and the law change, and every case turns on its own facts. If you are the subject of a complaint or investigation, obtain advice from a lawyer experienced in professional regulation, and notify your professional liability insurer, before you respond. Last updated July 14, 2026.

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