Manitoba · College of Pharmacists of Manitoba

How to respond to a CPhM complaint

A CPhM complaint is handled by the Complaints Committee, and your written response is the account it weighs — but two things make this regulator different: failing to respond is itself professional misconduct, and in a serious case you may be given as little as one day to reply or to meet.

First: the CPhM is not an RHPA college

Unlike Manitoba’s doctors and nurses, pharmacists are not yet regulated under The Regulated Health Professions Act. CPhM regulates under The Pharmaceutical Act (C.C.S.M. c. P60) and the Pharmaceutical Regulation, which have their own committees, language and deadlines. CPhM regulates pharmacists, pharmacy technicians, interns, students, pharmacies and pharmacy owners. (A move to bring pharmacy under the RHPA is in planning, but the Pharmaceutical Act governs today.) Everything below is CPhM’s process.

How a complaint reaches you

CPhM encourages patients to raise concerns with the pharmacy manager first. Where that does not resolve it, a formal complaint must be made in writing and signed — and note a feature that surprises many pharmacists: CPhM does not act on anonymous complaints. You have a right to know the nature of the allegations and who made them. Complaints come from patients, families, other health professionals, employers, and often from pharmacy inspections or reports from the College’s own programs.

The complaint goes to the Complaints Committee, which has statutory authority under section 30 of the Pharmaceutical Act to investigate and decide. It reviews the complaint, then decides whether it needs a formal investigation or has enough to decide right away.

The response — and the deadline you must not miss

CPhM will always set a deadline to respond, and this is not a formality: a failure to respond to the complaint can itself ground a charge of professional misconduct. In the ordinary case you will have a reasonable period. But where the Committee has information suggesting your conduct could present a serious risk to the public, it may demand a response, or a meeting, within one day — and in those cases you are at real risk of an immediate licence suspension or a request that you voluntarily surrender your licence.

So the moment a CPhM letter arrives, check the deadline first and call a lawyer second. A good response is honest, fact-driven, reasonable and unemotional — and it is far easier to build that with advice than alone at speed.

What a strong response contains

• Answer every allegation, in order, against the dispensing record and the patient profile.
• Anchor it in the documentation — the prescription, the software log, the counselling note, the incident report.
• Explain your process at the time — the checks done, the clinical judgment applied — not with hindsight.
• Address the Standards of Practice and Code of Ethics where they are engaged.
• Show accountability where something went wrong. For a medication error, the Committee expressly weighs your level of accountability and self-reflection — so demonstrate it.
• Keep it unemotional. Regret is understandable and human, but the Committee is assessing insight and change, not contrition.

The record is the case — do not touch it

The single fastest way to turn a survivable complaint into a career-threatening one is to alter a record after the fact — changing a dispensing log, adjusting a date, or amending a patient profile once you know a complaint is coming. Pharmacy systems keep audit trails, the change is discovered, and a dispensing error becomes a dishonesty case. Preserve everything exactly as it stands, and let your response explain the record rather than improve it.

What the Complaints Committee can do

After considering the complaint and any investigation, the Complaints Committee can:

• Dismiss the matter where there is not sufficient evidence of misconduct, incompetence or incapacity;
• Resolve it informally with you;
• Issue a censure (see below), sometimes after a censure-consideration meeting;
• Impose conditions on your practice, or suspend your licence;
• Accept a voluntary surrender of your licence or registration, which may include a formal agreement; or
• Refer the matter to the Discipline Committee for a hearing.

The censure — a Manitoba pharmacy particular

A CPhM censure is worth understanding precisely, because it is not what the word suggests. Under the Act it is remedial and educational, not a finding of professional misconduct and not punitive. It is a written warning that impresses on you the conduct that could put the public at risk, and it may carry specific practice-change and education requirements. Crucially, you must agree to accept a censure — it depends on your accepting accountability. The Committee can also order a censured pharmacist to pay costs of the investigation.

One recent shift matters: historically CPhM did not publish censures, but under section 36(2) it now may — on a case-by-case basis, including your name and the circumstances, potentially on your public profile. A censure is still the better outcome than a discipline referral, but it is no longer always private. Take advice before accepting one.

How long it takes, and what is public now

Resolving a complaint can take several months. While a matter is open there is nothing on your public profile indicating an active complaint or investigation — the process itself is not public. What becomes public is the outcome: a published censure (if the Committee so decides) or, if the matter is referred and proven, a discipline decision, which must be published. Use the time to prepare and, above all, to remediate: see the investigation and remediation.

This guide is general information about the College of Pharmacists of Manitoba (CPhM) and is not legal advice. Regulatory processes turn on their facts, and The Pharmaceutical Act, the Pharmaceutical Regulation and CPhM by-laws change. Take advice from a lawyer experienced in Manitoba pharmacy regulation before you respond to CPhM, and notify your professional liability insurer. Note that CPhM may contact you directly without going through your lawyer — keep your lawyer informed of every communication. Healthcare Ethics Courses is an independent CPD provider and is not affiliated with CPhM. Last updated July 14, 2026.