Manitoba · Psychological Association of Manitoba

How to Respond to a PAM Complaint

A letter from the Psychological Association of Manitoba is unsettling, but the Manitoba complaints process is more predictable than it first looks — and one feature governs everything else: the Complaints Committee decides largely on the documents. What you write, and what your records show, is your case.

What a PAM complaint actually is

A complaint to the Psychological Association of Manitoba is a formal request that the regulator look into your conduct or competence. PAM is the body legally constituted to register psychologists in Manitoba and to protect the public under The Psychologists Registration Act (C.C.S.M. c. P190). It is not a lawsuit and not a court. PAM cannot award your client money, and it has no power to force you to change a professional report or opinion — its jurisdiction is your registration and your fitness to practise, nothing else.

Two features of the Manitoba process shape how you should respond. First, the complaint is handled largely on the documents: your written response and your clinical records are, in practice, your case. Second, PAM will share your complaint with you and ask for your account — and your response is then released to the complainant. Write every word knowing both the committee and the complainant will read it.

Who can complain, and what PAM can and cannot handle

Anyone — a client, a family member, another professional, or PAM itself — can raise a concern. But PAM’s reach has limits worth knowing early. It does not handle complaints about people working under the title “psychologist” in certain exempt settings such as schools, government, universities and hospitals while acting in the course of that employment, because the Act exempts them from the title restriction. Concerns about a physician go to the College of Physicians and Surgeons of Manitoba; concerns about a counsellor or therapist may belong to a different body altogether. If the complaint has been sent to the wrong regulator, say so early — but still respond to anything that does fall to PAM.

What happens first

The matter goes to PAM’s Complaints Committee, chaired by a psychologist and including other members and public representatives. Where a complaint looks capable of being resolved informally between you and the complainant, the committee may attempt that first. If informal resolution is not reached to the complainant’s satisfaction, the committee can direct a formal investigation and appoint an investigator.

You will be given a copy of the complaint and asked to respond in writing, usually within a set period stated in PAM’s letter. Note that deadline the day it arrives. If you need more time or clarification, ask — but ask early and in writing.

Before you draft a word

The instinct to explain everything immediately is the one to resist. Three things come first:

• Do not alter the record. Amending, back-dating or “tidying” notes after a complaint is far more serious than the original concern and is the fastest route from a minor matter to a referral. Late entries, if genuinely needed, must be dated and marked as such.
• Do not contact the complainant to discuss, persuade or apologise your way out of it. Communication runs through PAM.
• Tell your professional liability insurer and get advice before you respond. Most psychologists carry liability cover that includes assistance with regulatory complaints; that support is most useful at the start, not after a first draft has been sent.

What a strong written response contains

Because the committee decides on the paper, the quality of your response matters more than anything else you do. A strong response is measured, specific and anchored in the record. It answers the actual concern raised rather than the one you wish had been raised. It sets out what you did and why, referenced to your notes and to the relevant standards — the PAM Code of Conduct and the Canadian Code of Ethics for Psychologists. It acknowledges, without defensiveness, anything that with hindsight could have been done better, and shows what you have already changed. When you release records, do so in a way that is consistent with The Personal Health Information Act (PHIA) and PAM’s request.

Tone carries weight. A response that is dismissive, combative or that attacks the complainant reads badly to a committee whose job is to assess insight. One that engages seriously with the concern — even where you disagree with it — reads as the response of a safe practitioner.

What the Complaints Committee can do

After its review or investigation, the Complaints Committee has a range of options under the by-law. It can decide the matter needs no referral; it can accept the voluntary surrender of your registration; it can, with your agreement, issue a censure where it has met with you and decided no further action is needed; it can refer the matter to mediation where the dispute is strictly between you and the complainant and both agree; it can enter into an agreement with you providing for steps such as assessing your fitness to practise or completing targeted remediation; or it can refer the matter, in whole or in part, to the Inquiry Committee for a hearing. Understanding this menu is why a considered response matters: it is often what keeps a matter at the Complaints Committee stage rather than sending it to a hearing.

How long it takes

PAM itself indicates that a straightforward complaint may be dealt with in around five months, while a complex matter that needs an investigator can take eighteen months or longer. That is a long time to carry a complaint. Keep your own contemporaneous file, respond to every PAM request promptly, and use the interval to complete any learning that is plainly relevant — not as an admission, but as evidence you take the concern seriously.

This guide concerns the Psychological Association of Manitoba (PAM) and is general information about regulatory process in Manitoba, not legal advice. Every complaint turns on its own facts. For advice on your situation, contact your professional liability insurer and a lawyer experienced with PAM and health-profession regulation before you respond. Last updated July 15, 2026.