Ontario · Ontario College of Pharmacists

What happens during an OCP investigation?

9 min readLast updated July 14, 2026

An OCP investigation can run on two tracks at once: the College looking at your conduct, and the Ministry or a private insurer auditing your pharmacy’s billing. They are separate processes with separate consequences, and both need managing.

Do this first: Preserve everything — the OCP bars you from destroying or removing pharmacy documents while the matter is open — and never amend a record after a complaint arrives. Cooperate through counsel, and remember that everything you say to the investigator goes into the report the ICRC reads.

The investigator’s work

Once a complaint or report is opened, the College assigns an investigator who gathers the evidence. The scope varies with the matter: a single dispensing concern may need the profile and your response, while a broader allegation can draw in the complainant, pharmacy staff and other witnesses. The investigator may also want a verbal conversation with both sides. Pharmacists have a duty to cooperate, and everything provided to the investigator is submitted to the ICRC in the investigator’s report — there is no informal, off-the-record conversation.

Preserve the record — and never amend it

Two rules protect you here, and both are easy to breach without thinking. First, the OCP requires you not to destroy or remove any pharmacy documents for the duration of the matter. Second, do not amend, complete or “tidy” a record after you learn of a concern. A dispensing record altered after the fact turns a defensible clinical case into an integrity case, and integrity cases are the ones that get referred. If a record is imperfect, explain that in your response; do not fix it.

The billing track: ODB, HNS and third-party audits

This is the part pharmacists most often underestimate. Where the concern touches billing, a second, separate process can run alongside the College’s. Every pharmacy’s Health Network System agreement lets the Ministry of Health — through the Executive Officer — suspend or revoke the ability to bill the Ontario Drug Benefit programme where claims are unsubstantiated or ineligible, such as early refills or amounts billed but not dispensed. Private insurers, including through Telus Health, run their own audits. These matters range from administrative to quasi-criminal, they do not wait for the College, and they call for advice in their own right.

How much protection you have

Pharmacists are frequently surprised by how broad the College’s investigatory powers are and how few procedural protections apply at this stage compared with a hearing. There is no cross-examination and no live testing of the evidence; the material simply accumulates into the report. And because the ICRC screens rather than adjudicates — asking whether the allegations, if true, are serious, and making no findings on credibility — a matter can be referred to Discipline even where you dispute it, as long as there is some admissible evidence.

Section 75: the Registrar’s investigation

Beyond the ordinary route, section 75 of the Code lets the Registrar appoint an investigator with wider powers where there are reasonable and probable grounds to believe there has been professional misconduct or incompetence, with ICRC approval. These investigations reach further — into records, premises and colleagues — and they carry a consequence that matters on appeal: an ICRC decision arising from a section 75 investigation is not reviewable by HPARB, leaving only judicial review. If you learn the Registrar has appointed an investigator, get counsel involved at once.

Interim orders

While the investigation runs, the ICRC can impose an interim order placing terms, conditions or limitations on your certificate of registration — up to suspension — where the concerns suggest patients may be exposed to harm. It is a protective measure, not a finding, but for a pharmacist it can mean an immediate loss of the ability to dispense, which is worth taking advice on the moment it is raised.

How it ends

The complaint or report, the records, your response and any reply go to a panel of the ICRC, which decides on the papers. The outcomes range from no action or advice, through an oral caution, a SCERP or an undertaking, to a referral to the Discipline Committee. Where a matter is referred, you receive full disclosure and a Notice of Hearing; discipline can then resolve on consent — through an Agreed Statement of Facts and a Joint Submission on Penalty — or proceed to a contested hearing.

For the response mechanics, read how to respond to an OCP complaint. For the corrective record, read remediation and reflection for Ontario pharmacists.

Key takeaways

An investigator gathers records and may interview the complainant, staff, and you; pharmacists have a duty to cooperate.
You are barred from destroying or removing pharmacy documents for the duration of the matter.
Billing concerns can trigger a separate ODB / Health Network System audit by the Ministry or an insurer, with its own powers.
A section 75 Registrar’s investigation is broader, and its ICRC outcome carries no HPARB review right.
The ICRC screens for risk; because it makes no credibility findings, a matter with some evidence can still be referred.
Interim orders can restrict or suspend your certificate of registration while the investigation runs.

Related courses

Courses that map to what an investigation examines — your records, your candour and your insight:

Dealing with a Complaint or Investigation ProfessionallyHow to handle a College letter and prepare a measured written response. Documentation for Healthcare ProfessionalsThe chart is the evidence the ICRC reads — how to keep records that hold up. Probity and Honesty for Healthcare ProfessionalsWhy candour with an investigator matters more than the original concern. Insight for Fitness to PractiseEvidencing that you understand what went wrong and why it mattered.

Continue reading

How to respond to an OCP complaint Remediation and reflection for Ontario pharmacists

Frequently asked questions

Do I have to cooperate with an OCP investigation?

Yes. Pharmacists have a duty to cooperate with the investigator, and everything provided is submitted to the ICRC in the investigator’s report. Cooperating fully is not the same as volunteering an unconsidered account — take advice first.

Can I update my records to make them clearer?

No. You are barred from destroying or removing pharmacy documents while the matter is open, and amending a record after learning of a concern turns a clinical case into an integrity case. Explain any imperfection in your response instead.

Is a billing concern handled by the College?

Not only. Billing concerns can trigger a separate Ontario Drug Benefit / Health Network System audit by the Ministry of Health, or an audit by a private insurer such as Telus Health, with its own power to suspend billing. That process runs alongside the College’s and needs its own advice.

What is a section 75 investigation?

A Registrar’s investigation with broader powers, appointed where there are reasonable and probable grounds to believe there has been professional misconduct or incompetence. An ICRC decision arising from it cannot be reviewed by HPARB — only by judicial review.

Can I be referred to discipline even if I did nothing wrong?

Potentially, yes. The ICRC screens rather than decides guilt and makes no credibility findings, so where the allegations are serious and there is some admissible evidence, a matter can be referred to the Discipline Committee even though you dispute it.

Can my registration be restricted before any finding?

Yes. The ICRC can make an interim order placing terms, conditions or limitations on your certificate of registration, including suspension, for the duration of the investigation, where the concerns warrant it.

This guide describes the process of the Ontario College of Pharmacists. It is general information about how the regulator works and is not legal advice. Every case turns on its own facts. Before you respond to the College, notify your professional liability insurer (professional liability insurance is a registration requirement for Ontario pharmacists) and consider a lawyer experienced in RHPA regulatory matters and OCP defence. Completing a course does not resolve a College matter and does not guarantee any outcome. Last updated July 14, 2026.