Ontario · College of Psychologists and Behaviour Analysts of Ontario

How to Respond to a CPBAO Complaint

A letter from the College of Psychologists and Behaviour Analysts of Ontario is an unsettling thing to open. But the Ontario complaints process is more predictable than it first appears, and one feature shapes everything else: in most cases the committee that decides your file will never meet you. It reads what you write. Once you understand that, you respond differently.

A complaint is not a finding

The College received thousands of registrants’ worth of contact each year and opens dozens of new complaint files every quarter. Anyone may complain — a client, a family member, another professional, or a member of the public — and the College must investigate every complaint, with only narrow exceptions. That a file has been opened tells you nothing about the outcome. In a typical year the great majority of complaints close with no action, advice, or a caution; only a small fraction are referred to discipline.

So the letter is the start of a process, not a verdict. What it does require is a considered, timely, written response. Treat it seriously, but do not panic, and do not let the shock of it push you into the two mistakes that make matters worse: editing the record, or contacting the person who complained.

The committee that decides never meets you

Your file is decided by a panel of the Inquiries, Complaints and Reports Committee — the ICRC — a screening committee established under the Health Professions Procedural Code, which is Schedule 2 to the Regulated Health Professions Act, 1991. A CPBAO panel is made up of two professional members and one public member. The ICRC does not hold a hearing. It does not meet the complainant or the member. It reads the paper record: the complaint, your written response, and whatever the investigation gathers.

This is the single most important fact about the process. It means your written response is not a preliminary — it is your case. There is no later day in court at this stage to explain what you meant. The panel weighs what is on the page, assessed through the College’s Risk Assessment Framework, which asks how much risk the conduct suggests and what response is proportionate.

The 30-day clock, and what to send

The College will send a formal acknowledgement within about 14 days of receiving the complaint, and you will generally have 30 days to respond in writing. The complaint itself will be enclosed, along with your prior complaint history where there is one. If you need more time, ask the case manager early rather than letting the deadline pass.

A strong response is measured, specific and grounded in the record. It addresses each concern raised, explains your clinical reasoning at the time rather than with hindsight, and references the relevant standards — the Standards of Professional Conduct and the Professional Misconduct Regulation made under the Psychology and Applied Behaviour Analysis Act, 2021. Enclose the client chart and any other relevant records. Avoid defensiveness, avoid blaming the client, and do not overstate; a response that reads as evasive does more damage than the original concern.

What the College can already see

The ICRC may review your records regardless of what the complaint is about. Inadequate record-keeping is, by itself, an act of professional misconduct — so a complaint about one issue can surface a records problem the complainant never mentioned. This is why your documentation practices matter as much as the substance of the concern. Where your notes are contemporaneous, legible and complete, they are your best evidence. Where they are thin, no amount of later explanation fully repairs them.

What the ICRC can decide

After considering the file, an ICRC panel can: take no further action; provide advice or recommendations; issue a written or oral caution; require you to complete a Specified Continuing Education or Remediation Program (a SCERP); accept an undertaking from you; refer allegations of professional misconduct or incompetence to the Discipline Committee; or, where capacity is in question, take the matter toward the fitness-to-practise stream. It can also order further investigation before deciding.

Some of these outcomes are public. Cautions, SCERPs, undertakings and referrals to discipline are posted on your profile on the College’s Public Register. Advice and no-action decisions are not. Knowing which outcomes are published helps you understand what is genuinely at stake in how you respond.

Interim orders — during, not after

Where the alleged conduct is serious enough that it may expose clients to harm, the ICRC can impose an interim order while the investigation is still running — terms, conditions or limitations on your certificate of registration, or in the most serious cases a suspension. An interim order is not a finding of misconduct; it is a precaution pending the outcome. If one is proposed, this is the point at which legal representation matters most.

If you disagree with the decision

A complainant or member can ask the Health Professions Appeal and Review Board (HPARB) to review an ICRC decision on a complaint, within 30 days. HPARB looks at two things only: whether the investigation was adequate, and whether the decision was reasonable. It is not a fresh hearing, and it has no jurisdiction over a decision to refer a matter to the Discipline Committee. Decisions arising from a Registrar’s investigation are outside HPARB entirely and can only be challenged by judicial review.

This guide is general information about the College of Psychologists and Behaviour Analysts of Ontario (CPBAO) complaints, investigation and remediation process. It is not legal advice and does not create a professional relationship. For advice on your own situation, contact your professional liability insurer or a lawyer who practises regulatory or health law. Last updated July 15, 2026.