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Investigating Complaints: Inquiries, Complaints and Reports Committee

Inquiries, Complaints and Reports Committee 

The Inquiries, Complaints and Reports Committee (ICRC) reviews all investigations and makes decisions. The committee is made up of both occupational therapists and members of the public appointed by the government. 

The College aims to ensure appropriate diversity and inclusion on this committee to ensure the various perspectives of Ontario are at the table. This includes diversity of:

  • geography,
  • race,
  • sex,
  • practice area,
  • practice setting,
  • age, etc. 

Role of the ICRC

The ICRC reviews all the information obtained during an investigation, including interview summaries, client records, relevant policies and procedures as common examples.

The main role of the Committee is to determine which matters are serious enough to require a disciplinary hearing. Matters that do not, may be dealt with by other remedial measures. Only the most serious cases move on to discipline.

Learn more about discipline hearings.

It is in the public interest that, where appropriate, the College and the ICRC take measures to improve an occupational therapist's practice so that they can continue to offer occupational therapy services at the expected level of service.

An investigation can be stressful for all parties involved. However, it can also be into an opportunity for growth and learning, even in matters that are considered lower risk.

Decisions of the Inquiries, Complaints and Reports Committee 

In making decisions, the panel’s goal is to protect and promote the public interest, while enhancing the standards of the profession.

By law, the ICRC is permitted to make only the following decisions:

  1. Close the matter with no further action – referred to as a “take no action”.
  2. Issue advice or make recommendations, if the ICRC believes that will help the occupational therapist to understand how to conduct himself or herself in the future and avoid difficulties.
  3. Offer the occupational therapist an Undertaking (or agreement) to complete certain remedial activities.
  4. Direct the occupational therapist to complete education or remediation, to improve their practice in the identified areas of concern; this is known as a SCERP.
  5. Require the occupational therapist to appear before the Committee to be cautioned. The panel will share its concerns about the occupational therapist’s behaviour, and describe what the occupational therapist must do to avoid future difficulties.
  6. Refer specific concerns about the occupational therapist’s conduct or competence to the Discipline Committee, which will hold a public hearing about those concerns.
  7. If there is information that the occupational therapist may have a health condition that is affecting their ability to practise safely:

  8. Refer the occupational therapist for a s.58 health inquiry to ensure that there is no physical or mental impairment that is affecting their ability to practise safely.
  9. After a s.58 health inquiry, refer the occupational therapist to the Fitness to Practise Committee if there are concerns about the occupational therapist’s capacity, meaning if the occupational therapist’s physical or mental health affects his or her ability to practise.

Learn more about how the College makes decisions.

Making decisions public

  • Decisions 3, 4 and 5 (see above) are made public by providing a summary on the registrant’s public register profile.
  • Undertakings are only public for the time period that they are in effect.
  • Verbal Cautions and SCERPS are public indefinitely.

Making these decisions public is a matter of transparency to the public and to assist the public with informed choices about a practitioner they may wish to seek services from. It is not a punitive measure by the College.

COTO and all health regulatory colleges are required by law to post these decisions. If the registrant is compliant with the terms of these decisions, we note this on the summary. 

Appealing ICRC decisions

All decisions by the ICRC, except decisions to refer to Discipline, Fitness to Practice or a s.58 health inquiry, are appealable by registrants.

When an occupational therapist receives a copy of the written Decision and Reasons from the ICRC, they will receive information about the applicable appeals process.