College of Nurses of Ontario v. Amandeep Kaur, 2025 ONCNO 149899

DISCIPLINE COMMITTEE OF THE COLLEGE OF NURSES OF ONTARIO

PANEL: Carly Gilchrist, RPN Chairperson Sylvia Douglas Public Member Aleksandra Grzeszczuk, RN Member Samuel Jennings, RPN Member Sandra Larmour Public Member

BETWEEN:

COLLEGE OF NURSES OF ONTARIO ) ALYSHA SHORE for ) College of Nurses of Ontario

• and - )

AMANDEEP KAUR ) CARINA LENTSCH for Registration No. 21416905 ) Amandeep Kaur ) ELYSE SUNSHINE ) Independent Legal Counsel

) Heard: October 17, 2025 ) via videoconference

DECISION AND REASONS

This matter was heard by a panel of the Discipline Committee (the “Panel”) of the College of Nurses of Ontario (the “College”) on October 17, 2025.

The Allegations

The allegations against Amandeep Kaur (the “Member”) as stated in the Notice of Hearing dated September 17, 2025, are as follows:

IT IS ALLEGED THAT:

1. You have committed an act of professional misconduct as provided by subsection 51(1)(c) of the Health Professions Procedural Code of the Nursing Act, 1991, S.O. 1991, c. 32, as amended, and defined in subsection 1(15) of Ontario Regulation 799/93, in that on or about July 15, 2023 while working with Greenstaff Medical as a Registered Practical Nurse and placed at Carleton Place & District Memorial Hospital in Carleton Place, Ontario, you signed or issued, in your professional capacity, a document that you knew or ought to have known contained a false or misleading statement when you provided false information on your resume indicating that you had previous experience working in an emergency department at Arnprior Regional Health; and/or

2. You have committed an act of professional misconduct as provided by subsection 51(1)(c) of the Health Professions Procedural Code of the Nursing Act, 1991, S.O.1991, c. 32, as amended, and defined in subsection 1(37) of Ontario Regulation 799/93, in that on or around July 15, 2023, while working with Greenstaff Medical as a Registered Practical Nurse and placed at Carleton Place & District Memorial Hospital in Carleton Place, Ontario, you engaged in conduct or performed an act, relevant to the practice of nursing, that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional when you provided false information on your resume indicating that you had previous experience working in the emergency department at Arnprior Regional Health.

Member’s Plea

The Member admitted the allegations set out in paragraphs 1 and 2 in the Notice of Hearing. The Panel received a written plea inquiry which was signed by the Member. The Panel also conducted an oral plea inquiry and was satisfied that the Member’s admissions were voluntary, informed and unequivocal.

Agreed Statement of Facts

College Counsel and the Member’s Counsel advised the Panel that agreement had been reached on the facts and introduced an Agreed Statement of Facts, which reads, unedited and without exhibits/appendices mentioned therein, as follows:

1. Amandeep Kaur (the “Member”) registered with the College of Nurses of Ontario (“CNO”) as a Registered Nurse (“RN”) on July 1, 2021.

2. Relevant to the incidents, the Member obtained a temporary contract position in the Emergency Department (“ED”) at Carleton Place & District Memorial Hospital (the “Facility”) through a nursing agency, Greenstaff Medical (the “Agency”), and worked in the Facility’s ED from on or about July 15 to July 20, 2023.

PRIOR HISTORY

3. The Member has no prior disciplinary findings with CNO.

THE FACILITY

4. The Facility is a small remote hospital in Carleton Place, Ontario.

5. The Facility’s ED is staffed by two nurses per shift. When one nurse is on a break, the other is responsible for the entire ED. Approximately 45 to 60 patients attend the ED on a daily basis, with upwards of 10 emergent cases. Nurses working in the ED are expected to have the knowledge, skills and judgment to operate in this environment.

6. The Facility had a contract with the Agency to assist with staffing of the ED. The Facility was short staffed in the ED to the point that it was at risk of closing. As a result, the Facility sought an experienced ED-trained nurse who had worked in an ED for at least one year and would therefore be able to be trained quickly.

INCIDENTS RELEVANT TO ALLEGATIONS OF PROFESSIONAL MISCONDUCT

The Member provided false information on her resume

7. In July 2023, the Member submitted a resume to the Agency containing false information about her work history. On her resume, the Member falsely indicated that her prior nursing experience included working 14 months in the ED at Arnprior Regional Health (“Arnprior”).

8. On or around July 15, 2023, the Agency provided the Member’s resume to the Facility, for her to be considered as a candidate for the experienced ED nurse role at the Facility.

9. Arnprior’s ED is of a similar size as the Facility’s ED. In light of the Member’s listed experience in Arnprior’s ED, the Facility asked the Member to fill the temporary position in the ED. The Member agreed and worked four shifts between July 15 to 20, 2023 at the Facility.

10. The Facility received reports from staff regarding the Member’s practice, namely related to the length of time it took her to complete triage and other tasks. As a result, the Facility became concerned that the Member did not meet the demands of the role and lacked the expected experience and skills to become quickly oriented and practice independently in the ED at the Facility.

11. As a result of these concerns, the Facility contacted Arnprior to obtain information regarding the Member. Arnprior advised the Facility that the Member had not worked in the ED at Arnprior, contrary to what was indicated on the Member’s resume.

12. If the Member were to testify, she would state that she was placed at Arnprior for one month on an inpatient unit providing acute nursing care. She would further state that, on the advice of a friend, she changed the specifics of her experience at Arnprior on her resume to qualify for contract work as a travel nurse with the Agency. The Member would testify that at the time she believed she had sufficient training and experience to perform the role. Nevertheless, the Member acknowledges that her actions were wrong and sincerely regrets and apologizes for her lapse in judgment and conduct.

13. Before this incident was referred to the Discipline Committee, the Member voluntarily arranged and met with a regulatory expert. She paid for and completed three meetings with the regulatory expert, during which she reviewed CNO’s standards on ethics and completed related reflective exercises, including on the importance of trust in the health care system. The Member also reviewed and discussed with the expert a webinar regarding CNO’s Code of Conduct.

14. The Member obtained a report from the regulatory expert, which outlines the number of meetings attended, the Member’s successful completion of the meetings’ objectives, and the Member’s insights into her responsibilities and accountabilities as a nurse.

CNO STANDARDS

Code of Conduct

15. CNO’s Code of Conduct is a standard of practice describing the accountabilities all Ontario nurses have to the public. The Code of Conduct consists of six principles including:

• Nurses respect patients’ dignity;

• Nurses provide inclusive and culturally safe care by practicing cultural humility;

• Nurses provide safe and competent care;

• Nurses work respectfully with the health care team;

• Nurses act with integrity in patients’ best interest; and

• Nurses maintain public confidence in the nursing profession.

16. CNO’s Code of Conduct further provides, in relation to the principle requiring nurses to act with integrity in patients’ best interest, that nurses are truthful in their professional practice.

17. CNO’s Code of Conduct further provides, in relation to the principle requiring nurses to maintain public confidence in the nursing profession, that nurses are accountable for their own actions and decisions.

18. Attached as Exhibit “A” is a copy of CNO’s Code of Conduct that was in force at the time of the incidents.

ADMISSIONS OF PROFESSIONAL MISCONDUCT

19. The Member admits that she committed the acts of professional misconduct as alleged in paragraph 1 of the Notice of Hearing, by issuing, in her professional capacity, a document that she knew contained a false or misleading statement when she provided false information on her resume regarding her nursing experience, as described in paragraphs 7-18 above.

20. The Member admits that she committed the acts of professional misconduct as alleged in paragraph 2 of the Notice of Hearing, and in particular that her conduct was dishonourable and unprofessional when she provided false information on her resume regarding her nursing experience, as described in paragraphs 7-18 above.

Decision

The College bears the onus of proving the allegations in accordance with the standard of proof, that being the balance of probabilities based upon clear, cogent and convincing evidence.

Having considered the evidence and the onus and standard of proof, the Panel finds that the Member committed acts of professional misconduct as alleged in paragraphs 1 and 2 of the Notice of Hearing. The Panel finds that the member engaged in misconduct that members of the profession would reasonably regard as dishonourable and unprofessional.

Reasons for Decision

The Panel considered the Agreed Statement of Facts and the Member’s plea and finds that this evidence supports findings of professional misconduct as alleged in the Notice of Hearing.

Allegation #1 in the Notice of Hearing, relating to signing or issuing a document with a false or misleading statement, is supported by paragraphs 7-14 and 19 in the Agreed Statement of Facts. The Member issued a false and misleading statement, in her professional capacity, on her resume when she indicated she had 14 months of emergency department nursing experience working at Arnprior when, in fact, she had not done so. This falsification led to her employment in the emergency department at the Facility where concerns developed about her knowledge and skills to perform in this area. The Member admitted that she intentionally altered her resume to qualify for the experienced emergency department nurse role at the Facility.

Allegation #2 in the Notice of Hearing, that the Member’s conduct would reasonably be regarded as disgraceful, dishonourable or unprofessional, is supported by paragraphs 7-18, and 20 in the Agreed Statement of Facts. The Member knowingly issued a false and misleading document to gain employment in an emergency department setting. This was unprofessional, as it demonstrated a serious and persistent disregard for her professional obligations. The College’s Code of Conduct is a series of standards which guide nurses in maintaining their accountabilities to the public. Under the Code of Conduct, nurses must: recognize and work within their knowledge, skill, and judgement; place their professional obligations before their personal gain; strive to protect clients from harm, including refraining from unsafe or unethical practice; be accountable for their own decisions and actions. In falsifying her resume to gain employment for which she was not qualified, the Member departed from these standards which was unprofessional.

The Panel also finds that the Member’s conduct was dishonourable. It demonstrated an element of dishonesty and deceit through the intentional issuance of a false and misleading resume which indicated she had experience working in an emergency department when she had no such experience. This was intentionally deceitful and done so in pursuit of employment and personal gain. The Code of Conduct sets out that nurses must be truthful in their professional practice. The Member ignored this standard. The Member knew or ought to have known that her conduct was unacceptable and fell well below the standards of a professional.

Penalty

College Counsel and the Member’s Counsel advised that a Joint Submission on Order had been agreed upon and requested that the Panel make the following order:

1. The Member is required to appear before the Panel to be reprimanded within 3 months of the date that this Order becomes final.

2. The Registrar is directed to suspend the Member’s certificate of registration for 1 month. This suspension shall take effect from the date that this Order becomes final and shall continue to run without interruption as long as the Member remains in a practicing class.

3. The Registrar is directed to impose the following terms, conditions and limitations on the Member’s certificate of registration:

a) The Member will attend 1 meeting with a Regulatory Expert (the “Expert”), at the Member’s own expense and within 6 months from the date that this Order becomes final. To comply, the Member is required to ensure that:

i. The Expert has expertise in nursing regulation and has been approved by CNO in advance of the meetings;

ii. At least 5 days before the first meeting, or within another timeframe approved by the Expert, the Member provides the Expert with a copy of:

1. the Panel’s Order,

2. the Notice of Hearing,

3. the Agreed Statement of Facts,

4. this Joint Submission on Order, and

5. if available, a copy of the Panel’s Decision and Reasons;

iii. Before the first meeting, the Member reviews the following CNO publications and completes the associated Practice Reflection Worksheets, online learning modules and decision tools (where applicable):

1. Code of Conduct;

iv. At least 5 days before the meeting, or within another timeframe approved by the Expert, the Member provides the Expert with a copy of the completed Practice Reflection Worksheets;

v. The subject of the sessions with the Expert will include:

1. the acts or omissions for which the Member was found to have committed professional misconduct,

2. the potential consequences of the misconduct to the Member’s patients, colleagues, profession and self,

3. strategies for preventing the misconduct from recurring,

4. the publications, questionnaires and modules set out above, and

5. the development of a learning plan in collaboration with the Expert;

vi. Within 30 days after the Member has completed the meeting, the Member will confirm that the Expert forwards their report to CNO, in which the Expert will confirm:

1. the date the Member attended the session,

2. that the Expert received the required documents from the Member,

3. that the Expert reviewed the required documents and subjects with the Member, and

4. the Expert’s assessment of the Member’s insight into the Member’s behaviour;

vii. If the Member does not comply with any one or more of the requirements above, the Expert may cancel any session scheduled, even if that results in the Member breaching a term, condition or limitation on the Member’s certificate of registration;

b) For a period of 12 months from the date the Member returns to the practice of nursing, the Member will notify the Member’s employers of the decision. To comply, the Member is required to:

i. Inform any employer of the decision prior to commencing or prior to resuming employment in any nursing position;

ii. Ensure that CNO is notified of the name, address, and telephone number of all employer(s) within 14 days of commencing or resuming employment in any nursing position;

iii. Provide the Member’s employer(s) with a copy of:

1. the Panel’s Order,

2. the Notice of Hearing,

3. the Agreed Statement of Facts,

4. this Joint Submission on Order, and

5. a copy of the Panel’s Decision and Reasons, once available;

iv. Ensure that within 14 days of the commencement or resumption of the Member’s employment in any nursing position, the employer(s) forward(s) a report to CNO, in which it will confirm:

1. that they received a copy of the required documents, and

2. that they agree to notify CNO immediately upon receipt of any information that the Member has breached the standards of practice of the profession.

3. All documents delivered by the Member to CNO, the Expert or the employer(s) will be delivered by verifiable method, the proof of which the Member will retain.

College Submissions on Penalty

College Counsel submitted that the Joint Submission would protect the public as the proposed penalty would achieve specific and general deterrence and rehabilitation / remediation of the Member.

Based on the findings of professional misconduct and the nature of the Member’s misconduct, the proposed penalty is appropriate when considering the aggravating and mitigating factors.

The aggravating factors include:

• The potential harm caused to the public by the Member holding herself out as having experience that she did not have; and

• The Member’s conduct brought discredit to the nursing profession.

The mitigating factors include:

• The Member has no prior disciplinary history with the College;

• This was a single, isolated incident;

• The Member has taken accountability and accepted responsibility for her actions by admitting to the allegations and entering into an Agreed Statement of Facts and Joint Submission on Order with the College;

• The Member has proactively met with a regulatory expert to undertake activities to remediate and rehabilitate her professional practice.

College Counsel submitted that the Member’s proactive remedial work with a regulatory expert is an important mitigating factor. Accordingly, the Panel can rest assured that the proposed order on penalty is appropriate.

Counsel submitted the following case to the Panel to demonstrate that the proposed penalty falls within the range of similar cases from this Discipline Committee: CNO v Cousins, 2012 99770.

Member’s Submissions on Penalty

The Member’s Counsel indicated that they agreed with the College’s submissions and asked the Panel to make an order in accordance with the Joint Submission. Member’s Counsel highlighted that the Member has cooperated throughout the process and has taken accountability for her conduct by seeking out remedial work.

Further Penalty Submissions

The Panel requested further submissions regarding the proposed length of suspension of the Member’s certificate of registration and the proposed duration of employer notification. The Panel also requested Counsel to provide further cases to demonstrate that the proposed penalty falls within the range of previous decisions of this Discipline Committee, given that the sole case submitted was quite dated.

College Counsel submitted that the duration of employer notification is not more or less necessary when the misconduct relates to misrepresentation to employers. Generally, employer notification is based on a public protection principle. Based on the severity of the conduct at hand, the proposed 12-month period is the typical duration of employer notification for misconduct of this nature. On the other hand, 18-months would be reserved for instances where conduct is very concerning, and 24-months would be reserved for instances where there are no admissions of guilt nor any mitigating circumstances.

College Counsel reiterated that the Member has been cooperative throughout the disciplinary process and has proactively met with a regulatory expert before she was required to do so by a panel of this Discipline Committee. This demonstrates that the Member understands the serious nature of her conduct. College Counsel submitted that they are not concerned that the Member will repeat her misconduct as she has learned her lesson. This should be the overarching factor when considering whether to accept the proposed penalty.

College Counsel submitted the following additional cases to the Panel to demonstrate that the proposed penalty falls within the range of similar cases from this Discipline Committee: CNO v Olalere, 2022 113314, and CNO v Etienne, 2024 140478. College Counsel noted that while each of these cases have a longer suspension, the members’ conduct was more egregious than in the case before this Panel. This supports a one-month suspension, as submitted by the parties. College Counsel submitted that this penalty is in the Public’s interest and should be accepted.

The Member’s Counsel submitted that the Member is remorseful and has been cooperative. The Member has acknowledged her misconduct throughout the disciplinary process. The Member has undertaken significant effort to acknowledge this isolated lapse in judgement. The Panel should take comfort in the early and proactive remediation the Member has completed; this has been in the public’s benefit.

The Member’s Counsel directed the Panel to Bradley v. Ontario College of Teachers, 2021 ONSC 2303. In this case, the Divisional Court affirmed the principle set out by the Supreme Court in R. v. Anthony-Cook that Panels ought to accept a Joint Submission on Order unless it violates the public interest or would bring the administration of justice into disrepute. The Member’s Counsel submitted that the Joint Submission on Order in the case before this Panel does not meet this threshold, and the Panel must accept it.

Penalty Decision

The Panel accepted the Joint Submission on Order and made the order requested.

Reasons for Penalty Decision

There is a high threshold for departing from a Joint Submission on Order established by the Supreme Court of Canada in R. v. Anthony-Cook, 2016 SCC 43. Departing from a joint submission would require a finding that the proposed penalty would bring the administration of justice into disrepute or is otherwise contrary to the public interest.

The Panel was troubled by the Member’s conduct. It is wholly inappropriate to misrepresent one’s experience on a resume to gain employment in a specialty care area. The Member did not simply exaggerate her employment history in an emergency setting, but rather, she completely fabricated her resume in a tailored fashion to improve her employability.

The Panel was relieved that there was no evidence of patient harm as a result of the Member’s conduct. Effective triaging in emergent situations is not something you can “fake until you make it.” Inappropriately categorizing the severity of a patient’s condition can have fatal implications and place immense stress on health systems. The Panel is of the opinion that the Member repeated this deceit when she accepted her position at the Facility and on each of the occasions that she reported for work in the emergency department at the Facility.

The Panel relied on the principles set out by the Supreme Court in R. v. Anthony-Cook in accepting that the proposed penalty is not contrary to the public interest and does not bring the administration of justice into disrepute. If, however, this misconduct had been before the Discipline Committee in a contested hearing, this Panel likely would have imposed a lengthier suspension of the Member’s certificate of registration as well as a longer duration of employer notification.

The Panel finds that the proposed penalty satisfies the penalty goals of specific and general deterrence, rehabilitation and remediation, and public protection.

The proposed penalty provides for general deterrence through the suspension of the Member’s certificate of registration and the employer notification provision. These demonstrate to the profession that this conduct is taken seriously and has consequences.

The proposed penalty provides for specific deterrence through the suspension of the Member’s certificate of registration, the employer notification provision, and the oral reprimand. The suspension and employer notification also demonstrate a deterrent effect to prevent the Member from repeating this conduct again in the future. As well, the oral reprimand will help the Member gain insight to how members of the profession and the public view her conduct and how it impacts her peers and the public.

The proposed penalty provides for remediation and rehabilitation through the additional meeting with a regulatory expert. The Panel notes the Member’s previous meetings with a regulatory expert, and that she has sought to improve her understanding of her professional obligations and the standards expected of nursing professionals.

Overall, the public is protected through the specific and general deterrence, remediation and rehabilitation, and the employer notification provisions.

The Panel acknowledges that the Member has co-operated with the College and, by agreeing to the facts and a proposed penalty, has accepted responsibility, which is a mitigating factor.

The penalty is in line with the range of what has been ordered in previous similar cases.

I, Carly Gilchrist, RPN sign this decision and reasons for the decision as Chairperson of this Discipline Panel and on behalf of the members of the Discipline Panel.