Manitoba · College of Physiotherapists of Manitoba

What Happens During a CPM Investigation?

9 min readLast updated July 15, 2026

An investigation under The Physiotherapists Act follows a defined path — investigator, then Complaints Committee, then a possible referral to the Inquiry Committee. Knowing where you are on that path tells you what is at stake and how to prepare. And one duty runs through all of it: you must cooperate with the College.

Cooperate — but take advice first. The investigator has statutory powers, and failing to respond to the College on time is itself misconduct. Producing records when the College requires them is authorised, not a breach of confidentiality. Speak to your professional liability insurer or a regulatory lawyer before you answer in writing or hand over documents.

How an investigation begins

Most investigations begin with a written complaint to the College about a physiotherapist’s conduct or care — commonly concerning boundaries, physical harm, breach of confidentiality or unethical behaviour. The College can also act on information that reaches it in other ways, and it appoints practice auditors who can inspect a registrant’s practice. However it starts, the mechanism is set out in The Physiotherapists Act, and the first formal step is usually the appointment of an investigator.

The investigator’s powers and your duty to cooperate

An appointed investigator gathers the relevant evidence and, on concluding, reports their findings to the Complaints Committee. Registrants have a duty to cooperate. Manitoba is explicit that failing to respond to College correspondence within the required time is itself professional misconduct — a physiotherapist has been disciplined for exactly that. Cooperation and careful preparation are not in conflict: you can comply fully with every request and deadline while still taking advice on how to frame written answers and which documents actually respond to what has been asked.

Your records and Manitoba’s PHIA

Physiotherapists worry, understandably, about handing patient files to the College. The position is the same in principle as elsewhere in Canada: the investigator has statutory authority to require records, and producing them when the College requires them is an authorised disclosure, not a breach of confidentiality. Manitoba’s Personal Health Information Act governs how patient information is otherwise handled, and your ordinary record-keeping obligations continue to apply. Withholding records to “protect” a patient is not an option and will worsen your position.

What the investigator is looking for

Investigations tend to concentrate on a recognisable set of issues: whether your care met the College’s Standards of Practice and Code; the adequacy of your records; consent; boundary and dual-relationship questions; confidentiality; and your scope of practice. Manitoba adds two specific requirements worth remembering — you must hold and maintain liability insurance to the minimum the Act requires, and you must respond to the College. Both have been the subject of discipline in their own right. Anticipating which standard is engaged lets you address it directly rather than defensively.

Interim suspension or conditions during the investigation

If, while the matter is live, the Complaints Committee concludes that your conduct exposes or is likely to expose the public to serious risk, it can direct the registrar to suspend your certificate of registration or place conditions on your practice before any final decision. This is risk management, not a finding. Because it can affect your ability to work immediately, the Act lets you apply to the Court of King’s Bench to stay the interim decision — and this is when representation is most valuable.

How an investigation ends

When the investigator has reported, the Complaints Committee decides the matter on the written record, having given you and the complainant the chance to make written submissions. It can take no action, censure you with your agreement, refer the matter to mediation, enter into an agreement with you for assessment or remediation, or refer the matter to the Inquiry Committee. Record-keeping or insurance problems surfaced along the way can become issues in their own right, even where the original concern was something else.

If it goes to a hearing

A referral to the Inquiry Committee means a formal discipline hearing. Within 30 days of a referral, the chair selects a panel of at least three people, one of whom must be a public representative, and no one who took part in the investigation may sit on it. The hearing is a formal legal process: evidence is presented, witnesses can be examined, and the College is represented by counsel. If the panel makes a finding of professional misconduct it can impose orders — a reprimand, conditions, suspension, revocation, a fine, and a contribution to the College’s costs. A member can appeal a finding or order to the Court of Appeal, on the record of the hearing.

Key takeaways

  • A CPM investigation runs investigator → Complaints Committee → possible referral to the Inquiry Committee.
  • You have a duty to cooperate; failing to respond to the College on time is itself misconduct.
  • The investigator can require records — producing them when required is an authorised disclosure, not a breach.
  • Investigations test your care against the Standards of Practice and Code, plus Manitoba’s insurance and response duties.
  • The College can suspend or impose conditions during the investigation; you can seek a Court of King’s Bench stay.
  • A discipline hearing is before an Inquiry Committee panel; findings and orders can be appealed to the Court of Appeal.

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Frequently asked questions

Who investigates a complaint against me?

The College appoints an investigator, who gathers evidence and, on concluding, reports their findings to the Complaints Committee. The College can also use practice auditors to inspect a registrant’s practice.

Do I have to hand over my patient records?

Yes. The investigator has statutory authority to require records, and producing them when the College requires them is an authorised disclosure rather than a breach of confidentiality. Manitoba’s Personal Health Information Act governs how patient information is otherwise handled.

Can I be disciplined just for not cooperating?

Yes. Manitoba treats failing to respond to College correspondence within the required time as professional misconduct in its own right, and a physiotherapist has been disciplined on that basis. Cooperate fully — but take advice on how to frame your response.

Can I keep working during the investigation?

Usually, unless the Complaints Committee directs the registrar to suspend your certificate of registration or impose conditions because your conduct may expose the public to serious risk. You can apply to the Court of King’s Bench to stay such a decision.

What is the difference between the Complaints Committee and the Inquiry Committee?

The Complaints Committee reviews investigations and decides how to dispose of a complaint on the written record. The Inquiry Committee holds formal discipline hearings when a matter is referred to it, and its findings and orders can be appealed to the Court of Appeal.

How long does an investigation take?

It varies with the complexity of the matter and the volume of records involved. The College can give you a realistic sense of timing; your obligation throughout is to respond promptly to its requests.

This guide is general information about the College of Physiotherapists of Manitoba (CPM) 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.

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