Manitoba · College of Physicians and Surgeons of Manitoba

How to respond to a CPSM complaint

Your written response is the single most important document in a CPSM complaint. It is usually due within 30 days, it is the only account the committee will have from you, and in most cases the matter is decided on the paper record without you ever appearing.

Who CPSM regulates, and under what law

The College of Physicians and Surgeons of Manitoba regulates physicians, residents, physician assistants, clinical assistants and medical students — anyone holding a certificate of practice in the province. The governing statute is The Regulated Health Professions Act (RHPA), CCSM c. R117, supported by CPSM by-laws, the Standards of Practice of Medicine and the CMA Code of Ethics and Professionalism.

Note the vocabulary, because it matters when you write: in Manitoba you hold a certificate of practice and you are a registrant. CPSM has no jurisdiction over other health professionals, or over doctors registered in other provinces.

Triage: the four routes a complaint can take

Complaints must be in writing. The Registrar reviews and triages each one into one of four routes, and which route you are on shapes everything that follows:

• Facilitated communication — resolution between you and the complainant, for lower-level concerns.
• The Complaints Committee — review of the matter, with power to resolve it informally.
• The Investigation Committee — the serious route: complex care, a death, or a possible breach of fundamental ethical obligations.
• Dismissal — where the complaint is trivial, vexatious or cannot be sustained under the RHPA.

You do not get to choose. A dissatisfied complainant can push a Complaints Committee matter up to the Investigation Committee, but a physician cannot request that referral — the RHPA does not provide for it.

The 30-day written response

The complaint is sent to you and you are required to respond in writing, normally within 30 days. This is not optional and it is not a formality. In the ordinary case the committee decides on the documents: the complaint, your response, the clinical record and any expert opinion. There is no hearing at this stage and no chance to explain yourself in person.

So the response has to do all the work. Answer every allegation specifically, anchor each answer in the contemporaneous record, and explain your clinical reasoning at the time — not your reasoning with hindsight.

What a strong response looks like

• Answer each point in turn. An unanswered allegation reads as a conceded one.
• Ground it in the record. Quote your notes; attach the relevant chart entries, results and correspondence.
• Explain the reasoning, not just the outcome. The committee is assessing whether your care and conduct met the expected standard, not whether the result was unhappy.
• Show insight where something did fall short. Acknowledge it plainly, say what has changed, and evidence it. Defensiveness about an obvious failing costs you more than the failing.
• Keep the tone measured. Never disparage the patient. Incivility toward a complainant or a colleague is itself a professionalism concern.
• Do not rewrite history. Retrospective additions to a record are discovered, and they turn a care complaint into a probity case.

Access to the clinical record

Do not withhold the chart. CPSM has statutory authority to obtain the medical information it needs for an investigation, and its ability to do so does not depend on the patient consenting. Your obligation is to co-operate with the regulator; obstruction or an incomplete disclosure is a separate and far more serious matter than the complaint that started it.

Can CPSM restrict my practice while this is going on?

Yes, but it is rare. Under subsection 110(1) of the RHPA, the Investigation Committee (or its Chair) can impose an interim suspension or conditions on your certificate of practice during the investigation, where that is necessary to protect the public from exposure to serious risk. Where interim action is taken you are entitled to notice of it. If you receive any indication that interim action is being considered, treat it as an emergency and get the CMPA and counsel involved that day.

Is the complaint public?

Not at this stage. Decisions of the Complaints Committee and the Investigation Committee are not published. Only formal discipline is made public: a censure, or an Inquiry Panel decision. Those are posted on the CPSM website and remain there for ten years.

There is one thing to be aware of, however. Decisions from the past ten years are referenced on any Certificate of Professional Conduct you later request — the document you will need if you apply to practise in another province or to a prospective employer. A matter that is not published is not therefore a matter without consequences.

How long it takes

CPSM does not publish a statutory disposal deadline for complaints. Realistically, completing the process takes several months, and longer where an external expert opinion is required. Use the time: this is the period in which you can build the remediation record that changes what the committee decides.

This guide is general information about the College of Physicians and Surgeons of Manitoba (CPSM) and is not legal advice. Regulatory processes turn on their facts, and the RHPA and CPSM by-laws change. Contact the CMPA before you write to CPSM, and take advice from a lawyer experienced in Manitoba regulatory matters. Healthcare Ethics Courses is an independent CPD provider and is not affiliated with CPSM. Last updated July 14, 2026.