Manitoba · College of Pharmacists of Manitoba

What happens during a CPhM investigation?

A CPhM investigation is directed by the Complaints Committee and carried out by an investigator who gathers records and a statement from you. If the matter is referred onward, the Discipline Committee holds a formal hearing — and Manitoba pharmacy discipline can carry penalties into the hundreds of thousands of dollars.

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 an investigation starts

Where the Complaints Committee decides a matter needs more than the paper record, it orders an investigation and a CPhM investigator is assigned. The investigator will contact you to gather a statement and any additional information, and will collect the dispensing records, the patient profile, pharmacy documentation and, where relevant, findings from a pharmacy inspection. You are notified and involved throughout, and invited to provide further information to the investigator to be shared with the Committee before it decides.

The statement: co-operate, but with advice

Two things must both be true. You should co-operate — obstructing or refusing to engage is itself a conduct problem. But what you tell the investigator becomes evidence, so you should give your statement with legal advice on its substance and tone. This is doubly important at CPhM because the College is entitled to contact you directly, sometimes without notifying your lawyer. Do not treat an informal call as harmless; keep your lawyer informed of every contact, and never guess at an answer to look co-operative.

Medication errors: what the Committee actually weighs

Most pharmacists’ matters arise from a dispensing or medication error, and CPhM is explicit about how it approaches them. The Complaints Committee is sensitive to the collateral effect an error has on the pharmacist — it knows registrants are often deeply affected — but it must balance that against protecting the public. It looks at the nature of the error, the contributing factors, the level of practice shown, and the pharmacist’s accountability and self-reflection. That last factor is within your control, and it is precisely what your engagement and remediation demonstrate.

What the Complaints Committee does with the findings

On the investigator’s findings the Committee applies its statutory options: dismiss, resolve informally, censure (remedial, must be accepted, and now potentially published under s.36(2)), impose conditions or suspend, accept a voluntary surrender, or refer to the Discipline Committee. Note two things. The Committee is not required to meet you before referring a matter to discipline. And even after taking another step, it may — with the sole exception of a censure — still refer the conduct to discipline later. Matters that are referred are typically serious or egregious.

The Discipline Committee hearing

The Discipline Committee is a separate committee under section 44 (its members cannot also sit on the Complaints Committee), with public representation. If your matter is referred you receive a Notice of Hearing setting out the charges, served at least 30 days before the hearing, which must begin within 120 days of referral. The hearing is a formal legal proceeding — evidence, witnesses, experts and cross-examination.

Many matters resolve without a contested fight: your lawyer may negotiate with the Committee’s lawyer to plead to some charges, drop others, and put a joint recommendation on penalty to the Committee. If it is contested, the Committee decides whether you committed professional misconduct, conduct unbecoming, or showed a lack of knowledge, skill or judgment or incapacity, on the balance of probabilities.

What discipline can cost

If a finding is made, after a sentencing hearing the Discipline Committee can reprimand you, suspend or cancel your licence, require a course of study, a preceptor, or counselling or treatment, impose conditions, and order a fine and costs. The costs exposure is the part pharmacists underestimate: in one recent published CPhM case a pharmacist faced $150,000 in total penalties — a $20,000 fine and $130,000 toward investigation and hearing costs — plus a one-year suspension. Discipline decisions must be published, on the CPhM website and in its newsletter, and recorded on the public profile.

Appeals — a two-step route

Manitoba pharmacy appeals are distinctive. A Discipline Committee decision is first appealed to the Council of the College, which must decide within 90 days and can make any decision the committee could have. From there, an investigated person may appeal to the court — in practice the Manitoba Court of Appeal — within 30 days of the Council’s decision. Note that an appeal does not automatically stay the decision; you must apply for a stay. Use the months well — our remediation guide shows how.

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.