The applicant, an oral and maxillofacial surgeon, sought judicial review of a decision by the Health Professions Appeal and Review Board (HPARB) upholding a screening committee's order requiring him to complete a specified continuing education or remediation program (SCERP).
The applicant argued the remedy was overbroad as the committee's concerns were limited to record-keeping and communication.
The Divisional Court dismissed the application, finding that HPARB reasonably concluded the committee had wide-ranging concerns about the applicant's practice, including post-surgical management, which justified the broader remediation program.
