Manitoba · Psychological Association of Manitoba

What Happens During a PAM Investigation?

A PAM investigation is not the same as a hearing, and confusing the two is what makes the process feel worse than it is. The investigation stage belongs to the Complaints Committee, which gathers the facts and then decides whether anything further is needed. Knowing which committee you are dealing with tells you exactly where you stand.

When an investigation actually starts

Not every complaint to the Psychological Association of Manitoba becomes an investigation. Under PAM’s by-law, the Complaints Committee may first attempt to resolve a matter informally. It is when informal resolution is not reached to the complainant’s satisfaction — or where the committee considers it appropriate on any referred matter — that the committee directs an investigation and appoints an investigator. So the appointment of an investigator is a decision, not an automatic step, and it signals that the committee wants the facts tested rather than dismissed on the papers.

Two committees, two different jobs

The single most useful thing to understand about the Manitoba process is that two separate committees are involved, and knowing which one you are dealing with tells you where you stand.

The Complaints Committee

This committee owns the investigation stage. It directs the investigation, receives the investigator’s report, and then decides what to do — from taking no further action, through a censure or an agreement with you, to referring the matter on. An investigation does not mean a hearing is coming; it means the committee is gathering what it needs to decide.

The Inquiry Committee

This is the separate, adjudicative body that holds a formal hearing if the matter is referred to it. A majority of its members must be psychologists, and at least one must be a psychological associate certified for independent practice where one is available. Once a matter is referred, the chair must select a hearing panel within thirty days. You only reach this stage if the Complaints Committee refers you — and much of how you conduct yourself during the investigation is aimed at making that referral unnecessary.

What an investigator does — and what you must provide

The investigator gathers evidence: your clinical records, correspondence, and often a written account from you, and may interview people involved. Your obligation is to cooperate and to produce the records requested. Release them in a way that is consistent with The Personal Health Information Act (PHIA) and PAM’s direction. This is where the quality of your day-to-day record-keeping is exposed. Contemporaneous, legible, complete notes make an investigation shorter and support your account; thin or reconstructed notes do the opposite. Do not create or amend records now to fill gaps — that is a separate and more serious matter.

How to conduct yourself during an investigation

Cooperate fully, meet every deadline, and keep your responses factual and referenced to the record. Answer the concern that was actually raised. Take advice from your professional liability insurer and, where the matter is serious, a regulatory lawyer, before you submit anything. Resist the urge to argue the complainant’s motives; the committee is assessing your conduct and your insight, not theirs. If, on reflection, part of the concern is fair, say so and set out what you have changed — measured candour is read as a mark of a safe practitioner, not an admission that decides the case against you.

What the committee decides after the investigation

With the investigator’s report in hand, the Complaints Committee chooses from the same range of options open to it throughout: no further action; accepting a voluntary surrender of registration; a censure by agreement where it has met with you; referral to mediation; an agreement with you providing for steps such as assessing your fitness to practise or completing targeted remediation; or referral of the matter, in whole or in part, to the Inquiry Committee. Except where it has issued a censure, the committee can also refer the conduct to the Inquiry Committee later. Where the investigation uncovers possible criminal activity, PAM may disclose that information to law enforcement.

If the matter is referred to a hearing

A referral to the Inquiry Committee moves the matter from investigation to adjudication. A panel is selected within thirty days, and a hearing follows at which the case is put and you can respond, usually with legal representation. This is the point at which the most serious outcomes — conditions on your registration, suspension or cancellation — become possible. A member whose registration is cancelled or suspended may appeal to a judge of the Court of King’s Bench within one month, with notice served on PAM’s council within seven days of filing. Most matters never reach this stage; the way to keep yours from doing so is to engage seriously with the investigation while it is still with the Complaints Committee.

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.