ONTARIO REGISTERED PSYCHOTHERAPISTS DISCIPLINE TRIBUNAL
Tribunal File No.: 25-011-RP
BETWEEN:
College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario
College
- and -
Adetoun (Ade) Ahmed
Registrant
FINDING AND PENALTY REASONS
Heard: March 2, 2026
Panel:
Sherry Liang (panel chair)
Andrew Benedetto (registered psychotherapist)
Janet Cullen (registered psychotherapist)
Henry Pateman (public)
Kevin Sack (public)
Appearances:
Justine Wong, for the College
Mario Delgado and Sahar Ali, for the registrant
RESTRICTION ON PUBLICATION
Pursuant to Rule 2.2.2 of the HPDT Rules of Procedure and ss. 45-47 of the Health Professions Procedural Code, no one shall publish or broadcast the names of clients or any information that could identify clients or disclose clients’ personal health information or health records referred to at a hearing or in any documents filed with the Tribunal. There may be significant fines for breaching this restriction.
Introduction
1The registrant, Adetoun Ahmed, provided psychotherapy services under the Interim Federal Health Program (IFHP), a program funded by Immigration, Refugees and Citizenship Canada to provide temporary health-care benefits to resettled refugees, refugee claimants and other groups. She entered into an agreement governing the provision of those services and breached the agreement by engaging in improper billing and record-keeping practices.
2At the hearing, the College and the registrant provided us with an agreed statement of facts (ASF) in which the registrant admits that her actions constitute professional misconduct. They made a joint submission on penalty and costs, seeking a reprimand, four-month suspension of the registrant’s certificate of registration (with the possibility of a two-month remission), and specified terms, conditions and limitations on her certificate.
3The panel found that the registrant engaged in professional misconduct and accepted the joint submission on penalty. Our role when there is a joint submission is limited. We must make the requested order unless it would bring the administration of the professional discipline system into disrepute. This proposal does not do so, and so we made the requested penalty order, as well as the proposed costs order. These are our reasons.
Professional misconduct
Failure to maintain the standards of practice of the profession
4The IFHP agreement (which comprises an agreement, a handbook and a benefit guide) contains terms governing how services are provided to beneficiaries and how service-providers are reimbursed. Among other things, the agreement requires that services be provided by persons with unrestricted licences. Service-providers agree that they may only submit claims using their IFHP provider ID for services they personally provide. Under the agreement, it is considered fraud to change the provider information from an ineligible provider to one approved by the claims administrator.
5The registrant was a registered provider under the IFHP program. She admits that she breached the agreement by submitting claims under her IFHP provider ID when psychotherapy services were actually being provided by psychotherapy interns. She also admits that she breached the agreement when she double-booked patients and submitted a separate claim for each patient.
6The College’s Professional Practice Standard 1.5: General Conduct, in force at the time of the events, requires registrants to act with integrity and professionalism. The parties agree that this requirement includes abiding by legally binding agreements, and that the registrant did not maintain this standard when she breached the IFHP agreement. We find this constitutes misconduct under para. 1 of s. 1 of Ontario Regulation 317/12 made under the Psychotherapy Act, 2007, SO 2007, c. 10, Sched. R (Misconduct Regulation), under which it is an act of misconduct to fail to maintain the standard of practice of the profession.
7The registrant also did not maintain clinical records that clearly state treatment dates and dates she amended records, and did not document discussions with an individual child patient during individual child therapy in any detail or at all. The parties agree that Professional Practice Standard 1.5: General Conduct requires registrants to ensure a clear and accurate record of what occurred and on what dates, and we find that her failure to do so is a breach of this standard. It is also a breach of Professional Practice Standard 5.1: Clinical Records and Standard 5.6: Record Storage, Security & Retrieval, which require registrants to keep accurate records, including ensuring that amendments show changes and original entries.
8These record-keeping deficiencies also amount to misconduct under para. 1 of the Misconduct Regulation, as well as under para. 25 (failing to keep written records in accordance with the standards of the profession).
9The registrant admits and we find that her actions constitute misconduct under para. 52 (engaging in conduct or performing an act relevant to the practice of the profession that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable or unprofessional) and para. 53 (engaging in conduct that would reasonably be regarded by members as conduct unbecoming a member of the profession) of the Misconduct Regulation. The registrant should be aware of the importance of acting with integrity when providing publicly funded services to a vulnerable population, and the potential for her actions to undermine the program.
Penalty and costs
10The parties’ agreement on penalty must be implemented unless it is so “unhinged from the circumstances” that implementing it would bring the administration of the College’s professional discipline system into disrepute: see R. v. Anthony-Cook, 2016 SCC 43 and Bradley v. Ontario College of Teachers, 2021 ONSC 2303 (Div. Ct.). We are satisfied that the proposed penalty is not contrary to the public interest in this manner.
11The parties provided us with decisions of this and other health profession discipline tribunals to establish that this penalty is proportionate to the misconduct. In one, College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v. La Rose, 2021 ONCRPO 1, the panel accepted the parties’ joint submission on penalty and imposed a reprimand and specified training. In other cases involving inadequate record-keeping, tribunals have combined suspensions with requirements such as ethics training and practice monitoring (see, for example, College of Physicians and Surgeons of Ontario v. Hui, 2016 ONCPSD 11 and College of Physicians and Surgeons of Ontario v. Goldstein, 2019 ONCPSD 35). The precedents also demonstrate that remission of a portion of a suspension contingent on the achievement of specified measures can be a reasonable penalty provision (see College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v. Saxton, 2024 ONCRPO 6). While each case was based on its own set of unique facts, we conclude that the four-month suspension proposed, with a possibility of a two-month remission, is reasonably within the range of penalties for similar misconduct.
12The suspension and reprimand serve the goals of specific and general deterrence. The registrant has acknowledged her wrongdoing, and the penalty reminds her of the importance of acting ethically and responsibly when practising her profession, including when participating in a publicly funded program such as the IFHP. General deterrence is achieved by demonstrating to other registrants that scrupulous billing practices and proper record-keeping are important obligations that come with the privilege of practicing as a member of the profession.
13The terms, conditions and limitations imposed on the registrant’s certificate of registration serve the purpose of remediation and ensure that the registrant has the tools to return to practice in keeping with the standards of practice of the profession. The penalty shows the public that the College takes seriously improper billing and record-keeping, and maintains public confidence in the College’s ability to protect the public.
14We considered the mitigating factors addressed in the ASF. Among other things, by admitting to the misconduct and participating in the proceedings, the registrant has shown insight and remorse and spared the parties and the Tribunal the time and expense of having a contested hearing. She has taken steps towards fulfilling some of the requirements of the penalty provisions and, in a letter to the College, signals her commitment to safe, ethical, competent, and accountable practice.
15Having regard to the relevant penalty principles as well as the caselaw, we are satisfied that the joint submission is not contrary to the public interest.
16We also accept the parties’ joint costs submission of $4,700, which is the amount set by the Tariff for a half-day hearing.
Order
17We ordered:
Penalty
The Tribunal requires the registrant to appear before the panel to receive a reprimand immediately following the conclusion of the hearing.
The Tribunal directs the Registrar to:
a. suspend the registrant’s certificate of registration for four months uninterrupted to commence one month after the date of the order, two months of which shall be remitted if the registrant complies with the provisions in subparagraphs 2(b)(i)–(iii) below, no later than three months from the date of the order; and
b. impose the following specified terms, conditions and limitations on the registrant’s certificate of registration, effective immediately, all to be completed at the registrant’s expense and to the satisfaction of the Registrar:
i. Requiring the registrant to successfully complete, within six months of the order, an individualized professional ethics and responsibility course, about the issues that arose in this case, including recordkeeping and billing practices related to insurance plans and/or agreements with insurance providers such as the IFHP, with a College-approved instructor, who will provide written confirmation of same to the Registrar;
ii. Requiring the registrant to review, and provide written confirmation of completion of same to the Registrar by the date one day prior to her return to practice following the suspension in subparagraph 2(a), of the following:
The College’s Professional Practice Standard 1.5 – General Conduct;
The College’s Professional Practice Standard 5.1 – Recordkeeping – Clinical Records;
The College’s Professional Practice Standard 5.6 – Recordkeeping – Storage, Security and Retrieval; and
The College’s Jurisprudence e-Learning Manual;
iii. Requiring the registrant to successfully complete the College’s Jurisprudence e-Learning Module by the date one day prior to her return to practice following the suspension in subparagraph 2(a);
iv. Requiring the registrant to successfully undergo practice monitoring for one year, with a College-approved practice monitor, upon the registrant’s return to practice regarding the issues raised by the facts and findings of professional misconduct in this case, and to review and discuss with the registrant any insurance billings, including in relation to any insurance plans and/or agreements, corresponding patient records, and recordkeeping in general. The registrant shall meet with the practice monitor every month who will specifically communicate any areas of concern and improvement in relation to the issues raised in this case, and submit a monthly written report to the Registrar to advise on whether the registrant is abiding by the College’s expectation in relation to same, and about the registrant’s progress with the practice monitor, with a final report to the Registrar upon the registrant’s completion of the practice monitoring that confirms the registrant co-operated and incorporated the practice monitor’s advice; and
v. Requiring the registrant to cooperate with any unannounced inspections, by College representatives, of her practice in relation to her recordkeeping, billing practices, and compliance with any insurance plans and/or agreements, for one year upon her return to practice following the suspension in subparagraph 2(a).
Costs
- The Tribunal requires the registrant to pay the College costs in the amount of $4,700 within 30 days of the date of the Tribunal’s order in this matter.