Complaints Process

One of the functions of the College in fulfilling its mandate of protecting the public interest is to receive, investigate and act upon complaints made against its members.  The formal process for investigation of a complaint is outlined in the legislation and each step of the process is designed to ensure fairness to both the person filing the complaint, and the Naturopathic Doctor named in the complaint. Although the College investigates most of the complaints received, the law permits the Inquiries, Complaint and Reports Committee (ICRC) to decline to investigate complaints it considers to be frivolous, vexatious, made in bad faith, moot or otherwise an abuse of process.

The College does not have authority to order monetary compensation for you from the naturopath.  This can only be achieved through civil proceedings.

Submitting a Complaint

The College must receive your complaint about a Naturopathic Doctor in a recorded format.

The more information that you can provide, the easier it will be to look into the complaint. If you are having trouble writing your letter of complaint or have questions about the College’s Complaints process, you can contact the College for assistance.

A fillable complaint form that may be printed out and mailed to the College or saved in pdf format and sent by email is available in the resource library for your convenience.


The Complaints Process

When a complaint is received the College will:

  1. Acknowledge receipt of the complaint and send out letter of confirmation.
  2. If applicable, request the member to submit the original patient file to the College.
  3. Send a written notice of the complaint to the member, together with a copy of all or part of the letter of complaint, so that the member can provide a response.
  4. Provide the member’s response to the complainant for additional comments.


Once all of the initial documentation has been collected from all parties involved in the complaint, the matter is referred to a Panel of Inquiries, Complaint and Reports Committee (ICRC), which consists of naturopathic doctors and appointed public members, who will initiate and investigation into the matter.  The investigation may include interviewing parties or witnesses, appointing an investigator to obtain records, collecting any relevant documentation.

As part of the investigation process the patient's personal health information may be obtained by the College.  According to Section 43 (1)(b) of Personal Health Information Protection Act, 2004 (PHIPA) NDs are permitted to disclose personal health information about an individual to the College for the purpose of the administration or enforcement of the Regulated Health Professions Act, 1991.

College staff are not members of the ICRC, so are not part of this body’s decisions.


Decisions and Reasons

After a thorough review of the complaint, submissions, and results of the investigation the ICRC may do one or more of the following:

    • Take no further action.

       

    • Refer specified allegations of professional misconduct or incompetence to the Discipline Committee.

      The discipline process is entirely separate from the complaints process.  The Discipline Committee deals with allegations of professional misconduct or incompetence through a formal hearing.

       

    • Refer the matter to another Panel of the ICRC for incapacity proceedings if there are concerns suggesting that the member is suffering from a physical or mental incapacity.

       

    • Require the member to appear before a panel of the ICRC to be cautioned.

      As per section 20.06 (xxx) of the College bylaws, where a panel of the ICRC requires a member to appear before the panel to be cautioned, the following information will be published on the naturopathic doctors register with respect to the member:

      • a notation of the fact, including a summary of the caution;
      • the date of the decision; and
      • where the decision of the panel is appealed, a notation of that fact until the appeal is finally disposed of.

      This information is removed from the register 24 months after the member has appeared before a panel of the ICRC and received the caution.

       

    • Require the member to complete a specified continuing education or remediation program (SCERP).

      As per section 20.06 (xxxi) of the College bylaws, where a panel of the ICRC requires a member to complete a SCERP, the following information will be published on the naturopathic doctors register with respect to the member :

      • a notation of the fact, including a summary of the SCERP;
      • the date of the decision; and
      • where the decision of the panel is appealed, a notation of that fact until the appeal is finally disposed of.

      This information is removed from the register once the Registrar is satisfied that the member has successfully completed the SCERP.

       

    • Take other action it considers appropriate that is not inconsistent with the RHPA, the Health Professions Procedural Code, the regulations governing the practice of Naturopathy in Ontario or by-laws of the College.

 

A written decision and the reasons for the decision will be provided to both the complainant and the member except where the matter has been referred to the Discipline Committee or Fitness to Practise Committee.

Click the link below to see the ICRC Decision-Making Flow Chart.

Timeframes

The investigation of a complaint should be completed within 150 days of it being filed with the college.  Should an extension be necessary a notification will be sent to the complainant explaining the reason for the delay and a proposed new date of completion that is no more than 60 days from the date of the notice.


Request for Review

Unless the decision is a referral to the Discipline or Fitness to Practise Committee both the complainant and the member have the right to request a review of the decision by the Health Professions Appeal and Review Board(HPARB) within 30 days of receipt of the ICRC’s decision.  The Board is an independent body established by the provincial government and is made up of non-health care professionals.