DISCIPLINE COMMITTEE OF THE ROYAL COLLEGE OF DENTAL SURGEONS OF ONTARIO
IN THE MATTER OF: A Hearing held pursuant to the provisions of the Health Professions Procedural Code which is Schedule 2 to the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 (“Code”)
AND IN THE MATTER OF: the Dentistry Act and Ontario Regulation 853, Regulations of Ontario, 1993, as amended (“Dentistry Act Regulation”)
AND IN THE MATTER OF: the Statutory Powers Procedure Act, Revised Statutes of Ontario, 1990, Chapter S.22, as amended; 1993, Chapter 27; 1994, Chapter 27
BETWEEN:
Royal College of Dental Surgeons of Ontario
-and-
Dr. Catherine McGregor
FINDING AND PENALTY REASONS
RESTRICTION ON PUBLICATION
In the matter of the Royal College of Dental Surgeons of Ontario and Dr. Catherine McGregor the Discipline Panel ordered, under ss 45(3) of the Health Professions Procedural Code, that no person shall publish or broadcast the identity of any patients of the Registrant, or any information that could disclose the identity of any patients who are named in the Notice of Hearing and/or the Agreed Statement of Facts in this matter.
PANEL MEMBERS:
Susan Davis, Public Member (Chair)
David Mock, Professional Member
Harpaul Anand, Professional Member
APPEARANCES:
Ms. Megan Shortreed, for the College
Dr. Catherine B. McGregor, self-represented
Ms. Luisa Ritacca, Independent Legal Counsel
Heard: January 29, 2018, in person
Decision Date: January 29, 2018
Release of Written Reasons: February 15, 2018
REASONS FOR DECISION
This matter came on for hearing before a panel of the Discipline Committee (the “Panel”) at the Royal College of Dental Surgeons of Ontario (the “College”) in Toronto on January 29, 2018.
THE ALLEGATIONS
The allegations against Dr. Catherine McGregor (the “Member”) were contained in the Notice of Hearing, dated May 26, 2016. The allegations against the Member were as follows:
- You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Acts, 1991 Statutes of Ontario, 1991, Chapter 18 in that, during the years 2015, 2016, and 2017, you failed to reply appropriately or within a reasonable time to a written enquiry made by the College, contrary to paragraph 58 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.
Particulars:
In or about the years 2015 and 1016, you failed to respond to repeated enquiries made a College investigator to obtain M.B.’s original patient record from you on October 28, 2015, March 16, 2015, June 14, 2016, and October 11, 2016.
To date, you have not provided M.B.’s original patient record to the College, more than a year and half after the College originally requested it.
- You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the year 2016, you failed to keep records as required by the Regulations relative to one of your patients, namely M.B., contrary to paragraph 25 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.
Particulars:
You were unable to provide M.B.’s patient record when the College investigator attended at your practise on October 11, 2016, pursuant to s.75(1)(c) of the Health Professions Procedural Code, Schedule 2 of the Regulated Health Professions Act, 1991.
You indicated to the College investigator at the time that the patient record was not located at the office and accordingly, you could not produce it. You would not tell the investigator where the patient record was stored and you never produced it for the College.
- You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the year 2016, you contravened a provision of the Dentistry Act, 1991, the Regulated Health Professions Act, 1991 or the Regulations under either of those Acts, contrary to paragraph 48 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.
Particulars:
- You failed to co-operate with the College investigation of this matter as required by s. 76(3.1) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991.
o You did not produce M.B.’s original patient record when the College investigator attended at your practice pursuant to s. 75(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991.
o When the investigator attended at your practice you indicated that the record was not on the premises and you would not inform the investigator of its location.
o The investigator gave you until October 25, 2016, to produce the patient record, a year after the original request for it, but you did not produce the record by this date.
o To date, you have not provided M.B.’s original patient record to the College.
o You hindered the College’s investigation into clinical treatment issues by failing to produce the patient record.
- You committed an act or acts of professional misconduct as provided by s.51(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Heath Professions Act, 1991, Statutes of Ontario, 1991, Chapter 18 in that, during the years 2015, 2016, and 2017, you engaged in conduct or performed an act or acts that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable, unprofessional or unethical relative to one of your patients, namely M.B., contrary to paragraph 59 of Section 2 of Ontario Regulation 853, Regulations of Ontario, 1993, as amended.
Particulars:
You failed to reply appropriately to the College in its investigation of M.B.’s complaint after repeated attempts to reach you by mail, telephone, and email.
You failed to provide M.B.’s original patient record to the College after repeated attempts to obtain it from you by mail, telephone, and email on October 28, 2015, March 16, 2016, May 24, 2016, June 14, 2016, and on October 11, 2016, pursuant to an investigation under s.75(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991. M.B.’s record has still not been provided to the College, more than a year and a half after the original request for it.
You are ungovernable in that you failed to cooperate with the College, your governing body, in its investigation of the complaint in that you have not provided M.B.’s patient record to the College, even after an investigator attended at your clinic in person to obtain it pursuant to s.75(1)(c) of the Health Professions Procedural Code, being Schedule 2 of the Regulated Health Professions Act, 1991.
You hindered the College’s investigation into clinical treatment issues by failing to produce the patient record.
THE MEMBER’S PLEA
The Member admitted the allegations of professional misconduct. She also made admissions in writing in the Agreed Statement of Facts, which was signed by the Member. The Member did not admit that she was “ungovernable” as set out as a particular in allegation #4. The College confirmed that it was not seeking a finding in that regard.
The Panel conducted a plea inquiry at the hearing, and was satisfied that the Member’s admissions were voluntary, informed and unequivocal.
THE EVIDENCE
On consent of the parties, College Counsel introduced into evidence an Agreed Statement of Facts which substantiated the allegations. The Agreed Statement of Facts provides as follows.
Background
1. Dr. Catherine McGregor has been registered with the College as a General Dentist since September 5, 1974. She practices at Lyndhurst Dental Centre in Lyndhurst, Ontario.
2. Dr. McGregor has no history of findings by the Discipline Committee of the College. She was issued an oral caution by the ICRC in 2012 in relation to her documentation and prescribing practices.
The Notice of Hearing
3. Dr. McGregor was served with a Notice of Hearing dated May 26, 2016. These allegations of professional misconduct against Dr. McGregor arose from her failure to cooperate with College investigators regarding a complaint made against Dr. McGregor by a patient, M.B.
4. The College and the Member have agreed to resolve the allegations on the basis of the facts and admissions agreed to and set out below.
Facts and Admissions
i. Failure to reply appropriately or within a reasonable time to written enquiries made by the College to obtain a patient’s original patient record
5. Dr. McGregor admits that she repeatedly failed to respond to requests and directions from the College’s investigators to produce her patient M.B.’s file.
6. M.B. received treatment from Dr. McGregor between December 5, 2013 and May 12, 2014, as well as on unspecified dates following this time period. M.B. submitted a complaint to the College on October 1, 2015, in respect of this treatment, after making numerous unsuccessful attempts to speak with Dr. McGregor.
7. Prior to submitting her complaint to the College, M.B. tried to pursue mediation through the Ontario Dental Association in relation to the same issues. Dr. McGregor did not respond to the ODA mediation process.
8. The ICRC began an investigation when Dr. McGregor did not respond to the College’s letter, dated October 28, 2015, enclosing M.B.’s complaint and inquiring about ADR.
9. The College investigator wrote to Dr. McGregor on March 16, 2016, referencing the College’s previous letter, and requesting a response to the complaint by April 20, 2016. The College investigator also requested that Dr. McGregor provided the original patient record with respect to M.B. Dr. McGregor did not respond.
10. The College investigator followed up by telephone multiple times and through email, and eventually reached Dr. McGregor on June 14, 2016. Dr. McGregor confirmed receiving the previous letter and complaint, and she indicated that she would be submitting a response with the patient record shortly. The College investigator and Dr. McGregor agreed on a new deadline of June 24, 2016 for Dr. McGregor to provide this information.
11. Dr. McGregor failed to provide the material by the June 24, 2016 deadline.
12. The Registrar formally appointed an investigator under s. 75(1)(c) on September 28, 2016.
13. The College investigator attended at Dr. McGregor’s practice on October 11, 2016 and asked for M.B.’s patient record. Dr. McGregor responded that the patient record was not at the office and she would not be able to obtain it that day. Dr. McGregor refused to tell the College investigator where the patient record was located, stating only that it was “in her possession”. She agreed to forward the patient record to the College investigator by October 25, 2016. However, she failed to do so.
14. Further, after the referral of these allegations to the Discipline Committee, Dr. McGregor still did not provide the file for M.B. A pre-hearing conference was held on December 13, 2017, at which time, Dr. McGregor had not provided the file. The parties agreed to enter into this Agreed Statement on that date, and Dr. McGregor agreed to provide the file, but has not yet done so as at the date this Agreement is executed.
15. By failing to respond to repeated enquiries made by a College investigator to obtain M.B.’s patient record, and by continuing not to provide the record to date, Dr. McGregor admits that she failed to reply appropriately or within a reasonable time to a written enquiry made by the College, contrary to paragraph 58 of Section 2 of the Dentistry Act Regulation, as set out in Allegation 1 in the Notice of Hearing.
ii. Failure to keep records as required
16. Dr. McGregor admits that she failed to keep records as required in relation to M.B. In particular, Dr. McGregor was unable to provide M.B.’s patient record when the College investigator attended at her practice on October 11, 2016. She told the College investigator that the patient record was not located at her office, and could not produce it. She would not tell the investigator where the patient record was stored, and did not subsequently produce the patient record.
17. Dr. McGregor acknowledges that, with respect to patient M.B., her recordkeeping was not in accordance with the regulations, or the standards of practice of the profession. Dr. McGregor acknowledges that she breached her professional, ethical and legal responsibilities that required her to maintain a complete record which is readily accessible documenting all aspects of each patient’s dental care, per the College’s Dental Recordkeeping Guideline, and s.38 of Regulation 547.
18. Therefore, Dr. McGregor admits that she failed to keep records as required by the Regulations, contrary to paragraph 25 of section 2 of the Dentistry Act Regulation, as set out in Allegation 2 in the Notice of Hearing.
iii. Contravening the Regulated Health Professions Act
19. Dr. McGregor admits that she contravened the Regulated Health Professions Act, and, in particular, section 76(3.1) of the Health Professions Procedural Code which requires all members to cooperate with an investigator. By failing to produce M.B.’s patient record when the College investigator attended at her practice, Dr. McGregor hindered the College’s investigation into clinical treatment issues and breached the Code.
20. Therefore, Dr. McGregor admits that she contravened a provision of the Dentistry Act, 1991, the Regulated Health Professions Act, 1991 or the Regulations under either of those Acts, contrary to paragraph 48 of section 2 of the Dentistry Act Regulation, as set out in Allegation 3 in the Notice of Hearing.
iv. Disgraceful, dishonourable, unprofessional or unethical behaviour
21. Dr. McGregor admits that her response to the College’s investigation of M.B.’s complaint would reasonably be regarded by members as disgraceful, dishonourable, unprofessional or unethical. In particular, Dr. McGregor failed to reply appropriately to the College in its investigation of M.B.’s complaint, and she repeatedly failed to provide M.B.’s patient record to the College. By failing to produce the patient record, Dr. McGregor hindered the College’s investigation into clinical issues raised by the complaint.
22. Therefore, Dr. McGregor admits that she engaged in conduct or performed an act or acts that, having regard to all the circumstances, would reasonably be regarded by members as disgraceful, dishonourable, unprofessional, or unethical, contrary to paragraph 59 of section 2 of the Dentistry Act Regulation, as set out in Allegation 4 in the Notice of Hearing.
23. Dr. McGregor does not admit that she is ungovernable, and indicates that she will cooperate with the College by producing the patient record for M.B., although she has not done so to date.
24. Dr. McGregor was sued by M.B., and pursuant to a court order made on May 1, 2017, reimbursed M.B. for the full amount of treatment, with interest, and court costs.
Summary
25. Dr. McGregor admits that the acts described above constitute professional misconduct and she now accepts responsibility for her actions and the resulting consequences.
26. Dr. McGregor has had the opportunity to take independent legal advice with respect to her admissions.
DECISION
Having considered the evidence and submissions of the parties, the Panel found that the Member committed professional misconduct as alleged in the Notice of Hearing and as admitted in the Agreed Statement of Facts.
REASONS FOR DECISION
The Member pled guilty to the allegations as set out in the Notice of Hearing as particularized in the Agreed Statement of Facts and did not dispute the facts presented in the Agreed Statement of Facts.
The Panel was of the view that the evidence contained in the Agreed Statement of Facts clearly substantiates the allegations of professional misconduct.
The Panel was satisfied that Dr. McGregor failed to keep and/or produce records and to reply appropriately within a reasonable time to a written enquiry made by the College with respect to one patient. Dr. McGregor failed to cooperate with the College as required by the Regulations and she admitted to the same in the Agreed Statement of Facts.
PENALTY SUBMISSIONS
The Royal College of Dental Surgeons of Ontario (“College”) and Dr. Catherine McGregor (“the Member”) jointly submit that this panel of the Discipline Committee impose the following penalty on the Member as a result of the panel’s finding that the Member is guilty of professional misconduct, namely, that it make an order:
Requiring the Member appear before the Panel of the Discipline Committee to be reprimanded, within ninety (90) days of this Order becoming final or on a date fixed by the Registrar;
Directing the Registrar to suspend the Member’s certificate of registration immediately upon the date this Order becomes final and to run until such date as the Member provides to the Registrar the complete patient record for patient M.B., and following that date, for a period of three (3) months, to run consecutively;
Directing the Registrar to impose the following terms, conditions and limitations on the Member’s certificate of registration (“the Conditions”), which Conditions shall continue until the suspension of the Member’s certificate of registration as referred to in paragraph 2 above has been fully served, namely:
a. while the Member’s certificate of registration is under suspension, the Member shall not be present in her dental office(s) when patients are present, save and except for unforeseen non-patient related emergencies. Where the Member is required to attend for a non-patient related emergency, the Member shall immediately advise the Registrar of that fact including details of the nature of the emergency;
b. upon commencement of the suspension, the Member shall advise her staff as well as any other dentist in the office of the fact that the Member’s certificate of registration is under suspension;
c. the Member shall not do anything that would suggest to another health professional, staff member or patients that the Member is entitled to engage in the practise of dentistry and will not communicate with any health professional, staff member or patient about the practise of dentistry during the suspension;
d. the Member shall permit and co-operate with any office monitoring which the Registrar feels is appropriate in order to ensure that the Member has complied with this Order, and in that connection, the Member shall provide access to any records associated with the practice in order that the College can verify that the Member has not engaged in the practice of dentistry during the suspension; and
e. the Conditions imposed in subparagraphs 3(a)-(d) above shall be removed at the end of the period the Member’s certificate of registration is suspended;
- Directing the Registrar to also impose the following terms, conditions and limitations on the Member's Certificate of Registration, namely:
a. the Member will successfully complete, at her expense, within six (6) months of this Order becoming final:
i. a comprehensive, hands-on course approved by the College, with an evaluative component, regarding record-keeping;
ii. an ethics course consisting of at least 3 meetings with a regulatory expert approved by the College (the “Expert”). To comply, the Member is required to ensure that:
The Expert has expertise in health regulation and has been approved by the Registrar in advance of the meetings;
At least seven days before the first meeting, the Member provides the Expert with a copy of:
a. the Panel’s Order,
b. the Notice of Hearing,
c. the Agreed Statement of Facts,
d. this Joint Submission on Penalty, and
e. if available, a copy of the Panel’s Decision and Reasons;
Before the first meeting, the Member reviews the College’s Code of Ethics;
the subject of the sessions with the Expert will include:
a. the acts or omissions for which the Member was found to have committed professional misconduct,
b. the potential consequences of the misconduct to the Member’s clients, colleagues, profession and self,
c. strategies for preventing the misconduct from recurring,
d. the Code of Ethics, and
e. the development of a learning plan in collaboration with the Expert;
- Within 30 days after the Member has completed the last session, the Member will ensure that the Expert forward his/her report to the Registrar, in which the Expert will confirm:
a. the dates the Member attended the sessions,
b. that the Expert received the required documents from the Member,
c. that the Expert reviewed the required documents and subjects with the Member, and
d. the Expert’s assessment of the Member’s insight into her behaviour;
- if the Member does not comply with any one or more of the requirements above, the Expert may cancel any session scheduled, ever if that results in the Member breaching a term, condition or limitation on her certificate of registration;
b. the Member’s practise shall be monitored by the College, including monitoring her recordkeeping practices, by means of inspection(s) by a representative or representatives of the College at such time or times as the College may determine with advance notice to the Member, during the period commencing with the end of the period the Member’s certificate of registration is suspended, and ending twelve (12) months thereafter, or such earlier time as a panel of the ICRC is satisfied that monitoring is no longer necessary and has advised the Member of this in writing;
c. the Member shall cooperate with the College during the inspection(s) and further, shall pay to the College in respect of the costs of monitoring, the amount of $600.00 per monitoring inspection, such amount to be paid immediately after completion of each of the inspections;
d. the representative or representatives of the College shall report the results of those inspections to the ICRC and the ICRC may, if deemed warranted, take such action as it considers appropriate; and
- Requiring the Member to pay costs to the College in the amount of $3,500 in respect of this discipline hearing, such costs to be paid within thirty (30) days of this Order becoming final or on a date to be fixed by the Registrar.
The College and the Member further submit that pursuant to the Regulated Health Professions Act, 1991, the results of these proceedings must be recorded on the Register of the College and publication of the Decision of the panel will therefore occur with the name and address of the Member included.
PENALTY DECISION
The Panel agreed and accepted the Joint Submission on Penalty and ordered that:
The Member is required to appear before the Panel of the Discipline Committee to be reprimanded, within ninety (90) days of this Order becoming final or on a date fixed by the Registrar;
The Registrar is directed to suspend the Member’s certificate of registration immediately upon the date this Order becomes final and to run until such date as the Member provides to the Registrar the complete patient record for patient M.B., and following that date, for a period of three (3) months, to run consecutively;
The Registrar is directed to impose the following terms, conditions and limitations on the Member’s certificate of registration (“the Conditions”), which Conditions shall continue until the suspension of the Member’s certificate of registration as referred to in paragraph 2 above has been fully served, namely:
a. while the Member’s certificate of registration is under suspension, the Member shall not be presented in her dental office(s) when patients are present, save and except for unforeseen non-patient related emergencies. Where the Member is required to attend for a non-patient related emergency, the Member shall immediately advise the Registrar of that fact including details of the nature of the emergency;
b. upon commencement of the suspension, the Member shall advise her staff as well as any other dentist in the office of the fact that the Member’s certificate of registration is under suspension;
c. the Member shall not do anything that would suggest to another health professional, staff member or patients that the Member is entitled to engage in the practice of dentistry and will not communicate with any health professional, staff member or patient about the practice of dentistry during the suspension;
d. the Member shall permit and co-operate with any office monitoring which the Registrar feels is appropriate in order to ensure that the Member has complied with this Order, and in that connection, the Member shall provide access to any records associated with the practice in order that the College can verify that the Member has not engaged in the practice of dentistry during the suspension; and
e. the Conditions imposed in subparagraphs 3(a)-(d) above shall be removed at the end of the period the Member’s certificate of registration is suspended;
- The Registrar is directed to also impose the following terms, conditions and limitations on the Member’s Certificate of Registration, namely:
a. the Member will successfully complete, at her expense, within six (6) months of this Order becoming final:
i. a comprehensive, hands-on course approved by the College, with an evaluative component, regarding record-keeping;
ii. an ethics course consisting of at least 3 meetings with a regulatory expert approved by the College (the “Expert”). To comply, the Member is required to ensure that:
The Expert has expertise in health regulation and has been approved by the Registrar in advance of the meetings;
At least seven days before the first meeting, the Member provides the Expert with a copy of:
a. the Panel’s Order,
b. the Notice of Hearing,
c. the Agreed Statement of Facts,
d. this Joint Submission on Penalty, and
e. if available, a copy of the Panel’s Decision and Reasons;
Before the first meeting, the Member reviews the College’s Code of Ethics;
The subject of the sessions with the Expert will include:
a. the acts or omissions for which the Member was found to have committed professional misconduct,
b. the potential consequences of the misconduct to the Member’s clients, colleagues, profession and self,
c. strategies for preventing the misconduct from recurring,
d. the Code of Ethics, and
e. the development of a learning plan in collaboration with the Expert;
- Within 30 days after the Member has completed the last session, the Member will ensure that the Expert forwards his/her report to the Registrar, in which the Expert will confirm:
a. the dates the Member attended the sessions,
b. that the Expert received the required documents from the Member,
c. that the Expert reviewed the required documents and subjects with the Member, and
d. the Expert’s assessment of the Member’s insight into her behaviour;
- If the Member does not comply with any one or more of the requirements above, the Expert may cancel any sessions scheduled, even if that results in the Member breaching a term, condition or limitation on her certificate of registration;
b. the Member’s practice shall be monitored by the College, including monitoring her recordkeeping practices, by means of inspection(s) by a representative or representatives of the College at such time or times as the College may determine with advance notice to the Member, during the period commencing with the end of the period the Member’s certificate of registration is suspended, and ending twelve (12) months thereafter, or such earlier time as a panel of the ICRC is satisfied that monitoring is no longer necessary and has advised the Member of this in writing;
c. the Member shall cooperate with the College during the inspection(s) and further, shall pay to the College in respect of the costs of monitoring, the amount of $600.00 per monitoring inspection, such amount to be paid immediately after completion of each of the inspections;
d. the representative or representatives of the College shall report the results of those inspections to the ICRC and the ICRC may, if deemed warranted, take such action as it considers appropriate; and
- The Member is required to pay costs to the College in the amount of $3,500.00 in respect of this discipline hearing, such costs to be paid within thirty (30) days of this Order becoming final or on a date to be fixed by the Registrar.
The College and the Member further submit that pursuant to the Regulated Health Professions Act, 1991, the results of these proceedings must be recorded on the Register of the College and publication of the Decision of the panel will therefore occur with the name and address of the Member included.
REASONS FOR PENALTY DECISION
The Panel concluded that the proposed penalty was appropriate in all circumstances of this case. It therefore accepted the Joint Submission and ordered its terms be implemented.
The Panel was satisfied that a reprimand and the recording of the results of these proceedings on the College register will act to deter the Member from behaving in this manner again and would also send a clear message to the members of the profession that prompt communication with the regulator is required.
The Panel was satisfied that all goals of Penalty Orders have been met and that the public will be adequately protected.
At the conclusion of the hearing, the Member waived her right to an appeal from the decision on liability and penalty. The panel delivered its reprimand, a copy of which is attached as Schedule “A”.
I, Susan Davis, sign these Reasons for Decision as Chairperson of this Discipline Panel.
Schedule “A”
RCDSO v. Dr. Catherine McGregor
Dr. Catherine McGregor, as you know, this Discipline panel has ordered you be given an oral reprimand as part of the sanction imposed upon you. The reprimand should impress upon you the seriousness of your misconduct.
The fact that you have received this reprimand will be part of the public portion of the Register and, as such, part of your record with the College.
You will be given an opportunity to make a statement at the end of the reprimand if you wish. This panel has found that you have engaged in acts of professional misconduct. The misconduct related to your failure to reply appropriately or within a reasonable time to enquiries made by the College to obtain a patient’s record and a failure to keep records as required. Your professional misconduct is a matter of concern. It is unacceptable to your fellow dentists and to the public. You have brought discredit to the profession and to yourself. Public confidence in the profession has been put in jeopardy.
Of special concern to us is the fact that the professional misconduct in which you engaged has involved a repeated failure to provide a patient chart despite many requests from your governing body. There were several phone calls, letters, promises made and broken as deadlines came and went.
As I advised earlier, you will now be given an opportunity to make a comment if you wish to do so. This is not an opportunity for you to debate the merits or the correctness of the decisions we have made.