Ontario · College of Chiropractors of Ontario

What Happens During a CCO Investigation?

11 min readLast updated July 14, 2026

A CCO investigation can begin without a patient ever complaining — from an insurer, from the WSIB, or from a Quality Assurance review of your records. Its powers are broad, your procedural protections at this stage are limited, and it can restrict your certificate before any hearing. Understanding how the investigation works, and where its decisions can be challenged, is how you protect a practice through it.

Cooperation is a duty, but not an unadvised one. Failing to cooperate with a CCO investigation is itself professional misconduct — so take legal advice on how to respond, then respond properly. And if an interim order is proposed for your certificate, seek advice the same day: it can suspend you for the whole process.

How a CCO investigation begins

Most investigations follow a complaint, but the CCO’s reach is wider than that. An investigation can arise from a patient complaint, a report from a third-party insurer or the WSIB, a report from another regulated professional, the Registrar’s own action where there are reasonable grounds, or from a Quality Assurance process. The Registrar can appoint a special investigator to investigate serious matters, with the approval of the ICRC.

Quality Assurance is a live route, not just a formality. The CCO’s Quality Assurance Committee can review a chiropractor’s records at any time, independent of any complaint. Because inadequate record-keeping is an independent act of professional misconduct, a QA review can itself surface a conduct concern. Records kept to CCO Standard S-002 are not bureaucracy — they are your first line of defence.

What investigators can do — and the limits of your protections

The investigatory powers under the RHPA are broad, and chiropractors are frequently surprised by them. An appointed investigator may enter and inspect a practice, examine and copy records, and interview the complainant, witnesses and you. During an investigation the ICRC may also obtain a peer or expert opinion comparing your care against the standards of practice.

You have fewer procedural protections at the investigation stage than at a hearing — and failing to cooperate with an investigation can itself be professional misconduct. That does not mean answering without preparation. It means taking legal advice on how to respond, and then responding properly. The two are not in tension.

Interim orders: being stopped before any hearing

Where a chiropractor’s alleged conduct exposes or is likely to expose patients to harm or injury, the ICRC may impose an interim order before making any final disposition — and it can last for the entire complaint process. The ICRC uses an Interim Order Assessment Tool to decide.

An interim order can place terms, limitations or conditions on your certificate of registration, including suspension. For a practice owner, that is an immediate and serious commercial event, and interim orders appear on the public register. If one is proposed, you need advice at once.

How the ICRC concludes

After the investigator reports, a panel of the ICRC reviews the file and makes a disposition — from no further action, advice or a caution, through a SCERP or undertaking, to a referral of specified allegations to the Discipline Committee. The ICRC usually gives written reasons, except where it refers to discipline or to an incapacity panel.

Remember the screening threshold: because the ICRC does not weigh credibility, as long as there is some admissible evidence, a serious allegation will often be referred. A referral reflects the seriousness of the allegation, not a conclusion that you are guilty.

HPARB review

Where a matter is not referred to the Discipline Committee or Fitness to Practise Committee, both you and the complainant may ask the Health Professions Appeal and Review Board (HPARB) to review the decision. The request must be made within 30 days; the review considers whether the investigation was adequate and the decision reasonable, and is based on the material that was before the ICRC. It typically takes 12 to 18 months.

The Discipline Committee, if it comes to that

On referral, the CCO issues a Notice of Hearing setting out the specific allegations, which is posted on the CCO website. You receive full disclosure of the material the ICRC reviewed. In most cases you will also receive an offer to resolve on consent — a guilty plea to agreed facts with an agreed penalty, recorded in an Agreed Statement of Facts and a Joint Submission on Penalty.

Do not accept a resolution offer without advice. A finding of professional misconduct is published on the CCO public register on an indefinite basis, and — as insurers increasingly review that register — can lead to de-listing from billing networks. A guilty plea is sometimes the right strategic choice, but it is a consequential one, and the penalty range runs from a reprimand and suspension up to revocation of your certificate, with no reinstatement possible for five years in the most serious cases. The Committee may also order you to pay part or all of the CCO’s costs.

The sexual-abuse provisions

One matter demands separate mention. Under the RHPA’s zero-tolerance sexual abuse provisions, certain findings of sexual abuse of a patient carry mandatory revocation of the certificate of registration. These allegations may also be referred to the police for criminal investigation. If you face any allegation touching this area, specialist legal advice is essential and immediate.

Key takeaways

Investigations arise from patient complaints, insurer/WSIB reports, other regulated professionals, the Registrar, or a Quality Assurance review \u2014 which can examine your records at any time.
RHPA investigatory powers are broad: entry and inspection, copying records, interviews, and a peer/expert opinion on your care. Failing to cooperate is itself professional misconduct.
An interim order (decided with the Interim Order Assessment Tool) can restrict or suspend your certificate before any hearing, for the whole process, and appears on the public register.
Because the ICRC does not assess credibility, a serious allegation with some admissible evidence will often be referred \u2014 a referral reflects seriousness, not guilt.
If a matter is not referred, you or the complainant can seek HPARB review within 30 days; the review asks whether the investigation was adequate and the decision reasonable.
A discipline finding is published indefinitely and can lead insurers to de-list you. Sexual-abuse findings under the RHPA can carry mandatory revocation and a police referral.

Related courses

Practical, self-paced CPD courses that map onto the issues in this guide. These are educational courses. They are not accredited by the CCO and are not a substitute for legal advice.

Dealing With a Complaint or Investigation Professionally

How to conduct yourself through an investigation, on the record and under scrutiny.

View course →

Probity and Honesty for Healthcare Professionals

Honesty and candour under investigation. Concealment turns a care issue into a probity issue.

View course →

Documentation for Healthcare Professionals

What investigators and QA reviews look for in your records, and what Standard S-002 requires.

View course →

Professionalism and Professional Standards for Chiropractors

The professional standards and misconduct regulation applied to your care.

View course →

Continue reading: Ontario chiropractors

How to respond to a CCO complaint Remediation and reflection for Ontario chiropractors

Frequently asked questions

Can the CCO investigate me without a patient complaint?

Yes. An investigation can arise from a report by a third-party insurer or the WSIB, from another regulated professional, from the Registrar acting on reasonable grounds, or from the Quality Assurance Committee, which can review a chiropractor’s records at any time. Because inadequate record-keeping is itself professional misconduct, a QA review can independently surface a conduct concern.

Can I be stopped from practising before a hearing?

Yes. Where alleged conduct exposes or is likely to expose patients to harm or injury, the ICRC may impose an interim order, using its Interim Order Assessment Tool, before making any final disposition. It can place terms, limitations or conditions on your certificate of registration, including suspension, can last for the entire complaint process, and appears on the public register.

Why would I be referred to discipline if I did nothing wrong?

Because the ICRC screens rather than adjudicates. It does not hear live witnesses or assess credibility; it asks only whether the allegations, if true, are serious enough for a hearing. As long as there is some admissible evidence, a serious allegation will often be referred. A referral reflects the seriousness of the allegation, not a conclusion that you committed misconduct.

Should I just accept the offer to resolve on consent?

Not without legal advice. Many discipline matters come with an offer to plead guilty to agreed facts for an agreed penalty. It is sometimes the right strategic choice, but a finding of professional misconduct is published on the CCO public register indefinitely and can lead insurers to de-list you from billing networks. The consequences are serious enough that the decision should never be made alone.

What happens with a sexual abuse allegation?

It is treated with the utmost seriousness. Under the RHPA’s zero-tolerance sexual abuse provisions, certain findings of sexual abuse of a patient carry mandatory revocation of the certificate of registration, and such allegations may also be referred to the police for criminal investigation. Immediate, specialist legal advice is essential if you face any allegation in this area.

How long does an HPARB review take?

Typically 12 to 18 months. Where a matter has not been referred to the Discipline Committee or Fitness to Practise Committee, either party may request a review by the Health Professions Appeal and Review Board within 30 days of the ICRC decision. The review is based on the material that was before the ICRC and considers whether the investigation was adequate and the decision reasonable.

This article is general information for chiropractors registered with the College of Chiropractors of Ontario and does not constitute legal advice. Regulatory processes and the law change, and every case turns on its own facts. If you are the subject of a complaint or investigation, obtain advice from a lawyer experienced in professional regulation, and notify your professional liability insurer, before you respond. Last updated July 14, 2026.