Ontario · College of Physiotherapists of Ontario
What happens during a CPO investigation?
A CPO investigation feeds one decision-maker, the ICRC, and that committee decides on documents rather than testimony. So the investigation is really about what goes into the file — and the most useful thing you can do is make sure your records, your response, and your account are accurate, complete, and consistent.
How an investigation starts
An investigation can follow a formal complaint, a Registrar’s report, or a mandatory report — for example, from an employer or an insurer. After you respond to a complaint, the ICRC may decide that further investigation is needed before it can dispose of the matter.
Who investigates, and what they can do
An investigator may be appointed, with the ICRC’s approval, under section 75 of the Health Professions Procedural Code. An appointed investigator can compel you to produce records and documents, take statements from witnesses, and interview you. In more serious matters, the Registrar can appoint a special investigator whose powers are broader still.
These powers are real, and clients are often surprised by their breadth. Resisting them is not a workable strategy; meeting them fully, with advice, is.
Your duty to cooperate
Cooperating with the investigation is a professional obligation, and it can include attending an interview with the College’s investigator. Failing to cooperate is itself a concern and can be treated as seriously as the matter under investigation.
Honesty is central. Do not reconstruct or embellish an account, and if something went wrong, say so plainly. You are entitled to counsel through your insurer, and it is sensible to involve them before an interview.
Records and disclosure
You can be compelled to provide records, and the ICRC can assess the quality of those records regardless of how it disposes of the complaint. Keep your records to the standards set under the Physiotherapy Act, keep your own copies, and never alter them after the fact.
Contemporaneous notes — made at the time of care — carry far more weight than anything written once a complaint has arrived. Good day-to-day documentation is the strongest protection you have long before any investigation begins.
What the ICRC does with the file
Once the investigator’s report is in, the ICRC reviews the whole file: the complaint, your response, and the investigation findings. It works on the paper record, makes no credibility assessments, and makes no findings of misconduct. If new information emerges, you may be invited to provide a supplemental response before the committee decides.
Interim measures during the investigation
Where a matter is serious enough that patients may be exposed to harm, the ICRC can impose interim terms, conditions, or limitations on your certificate of registration, or suspend it, while the investigation continues. Interim orders are recorded on the public register.
How investigations end
Most investigations end without a discipline hearing: the ICRC may take no action, give advice, caution you, require a remediation program, or accept an undertaking. Serious matters are referred to the Discipline Committee, which issues a Notice of Hearing that is posted publicly. The College’s own guidance is that the process commonly takes eight to 12 months; the Procedural Code sets a 150-day disposal target that is frequently extended. Either party can ask HPARB to review the ICRC’s disposition of a complaint.
Key takeaways
- A CPO investigation builds a file for the ICRC, which decides on documents, not live testimony.
- An appointed investigator can compel your records, take statements, and interview you.
- You have a professional obligation to cooperate; do it with legal counsel through your insurer.
- Keep records to Physiotherapy Act standards and never alter them — the ICRC can assess record quality whatever the outcome.
- Investigations commonly take eight to 12 months; the statutory 150-day target is often extended.
- Outcomes range from no action to a remediation program or a referral to the Discipline Committee.
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Frequently asked questions
What is the difference between the ICRC and the Discipline Committee?
The ICRC screens complaints on the paper record and decides how to dispose of them. The Discipline Committee holds a formal, public hearing and makes findings of professional misconduct or incompetence.
Can the College compel my records?
Yes. An appointed investigator can compel you to produce records and documents, take witness statements, and interview you.
Do I have to attend an investigator interview?
Cooperation is a professional obligation, so declining to engage is itself a concern. Take advice on how to prepare, and attend with counsel if the matter is serious.
How long does a CPO investigation take?
The College’s guidance is that it commonly takes eight to 12 months. Complex matters, or those heading to a hearing, can take longer.
Can I keep working during the investigation?
Usually yes, unless the ICRC imposes interim terms, conditions, or limitations on your certificate of registration, or suspends it.
Who pays for my lawyer?
Your mandatory professional liability insurance typically provides access to legal counsel. Contact your insurer early so counsel can be involved from the start.
This guide explains how the College of Physiotherapists of Ontario (CPO) handles investigation about physiotherapists under the Regulated Health Professions Act, 1991 and the Physiotherapy Act, 1991. It is general information, not legal advice. For advice on your own situation, contact your professional liability insurer, which provides access to legal counsel, or a lawyer experienced in health-profession regulation in Ontario. Last updated July 15, 2026.