Administrative Law - RCDSO

The Registrant admitted to professional misconduct for failing to maintain infection prevention and control (IPAC) standards at her dental clinic and for failing to cooperate with practice monitoring and public health inspections.

The Discipline Committee accepted a joint submission on penalty, ordering a reprimand, a five-month suspension, terms and conditions on her certificate of registration including clinical supervision, and $12,000 in costs.

The Royal College of Dental Surgeons of Ontario brought allegations of professional misconduct against the respondent dentist for sexually abusing a patient, abusing a patient, and engaging in disgraceful, dishonourable, unprofessional, and unethical conduct.

The evidence established that the respondent engaged in a concurrent treating and sexual relationship with the patient, provided financial assistance for vehicles, and paid for personal trips.

The Discipline Committee found the allegations proven.

On penalty, the parties presented a joint submission despite the respondent having denied the allegations at the merits stage.

The Committee accepted the joint submission, ordering the revocation of the respondent's certificate of registration, an oral reprimand, security for therapy funding, and $50,000 in costs.

The Royal College of Dental Surgeons of Ontario brought professional misconduct allegations against the Registrant for abruptly closing his practice without notifying patients, failing to retain or transfer patient records, and completely ignoring the College's investigation.

The Registrant did not attend the hearing.

The Discipline Committee found that the Registrant committed professional misconduct by failing to maintain standards of practice, failing to keep records, failing to reply to College inquiries, and engaging in disgraceful, dishonourable, unprofessional, or unethical conduct.

The Committee revoked the Registrant's certificate of registration, ordered a reprimand, and awarded costs of $13,511.29 to the College, citing his complete abandonment of his practice and pattern of ungovernability.

The Royal College of Dental Surgeons of Ontario held a discipline hearing regarding a dentist who abruptly closed his orthodontic practice without notifying patients, making provisions for their continuing care, or transferring their records.

The dentist also failed to respond to numerous communications from the College and relocated to Florida.

The Discipline Committee found the dentist guilty of professional misconduct, concluding that his actions demonstrated a complete disregard for his professional obligations and a pattern of ungovernability.

The Committee ordered the immediate revocation of his certificate of registration, a reprimand, and costs of $9,951.79.

The Royal College of Dental Surgeons of Ontario brought professional misconduct allegations against the Registrant for abruptly closing his practice without notifying patients, failing to retain or transfer patient records, and completely ignoring the College's investigation.

The Discipline Committee found that the Registrant abandoned his practice and relocated to Florida, actively evading the College's attempts to contact him.

Finding the Registrant ungovernable and noting the complete absence of mitigating factors, the Committee revoked his certificate of registration, ordered a reprimand, and awarded costs to the College.

The Registrant, a dentist, faced allegations of professional misconduct relating to clear aligner therapy provided to seven patients through an online platform.

The Registrant admitted to failing to maintain standards of practice, treating beyond his competence, failing to obtain informed consent, and failing to keep required records.

The Discipline Committee accepted the Agreed Statement of Facts and found the Registrant committed professional misconduct.

The Committee accepted a joint submission on penalty, ordering a reprimand, a 12-month suspension, a permanent restriction from providing orthodontic treatment, coursework, 12 months of clinical supervision, 36 months of practice monitoring, and $10,000 in costs.

The Registrant, a dentist, admitted to multiple allegations of professional misconduct, including submitting false or misleading insurance claims, charging excessive fees, failing to maintain standards of practice by providing aggressive periodontal surgery without adequate investigation, failing to keep proper records, and failing to respond appropriately to College inquiries.

The Discipline Committee accepted an agreed statement of facts and a joint submission on penalty.

The Registrant's certificate of registration was suspended for six months, and he was ordered to complete remedial courses, undergo clinical supervision and practice monitoring, receive a reprimand, and pay $10,000 in costs.

The Registrant, a dentist, admitted to professional misconduct including practising dentistry while his certificate of registration was suspended, sexually abusing a patient by engaging in a concurrent treating and sexual relationship, and providing inaccurate information to the College regarding the timeline of that relationship.

The Discipline Committee accepted the admissions and found the Registrant committed professional misconduct.

The Committee accepted a joint submission on penalty, ordering the mandatory revocation of the Registrant's certificate of registration, an oral reprimand, $10,000 in costs, and the posting of $5,000 in security for patient therapy funding.

The College alleged that the registrant committed professional misconduct by contravening a federal law relevant to the provision of dental care and by failing to report criminal charges in a timely manner.

The registrant had been convicted of aggravated assault and assault with a weapon, and had also been charged with impaired driving, which he failed to report to the College for over seven months.

The registrant admitted to the allegations via an Agreed Statement of Facts.

The Discipline Committee found that the registrant committed professional misconduct, noting that his criminal convictions demonstrated a disregard for public safety and his failure to report charges was unprofessional.

The College brought a motion to adjourn two discipline hearings against the Registrant sine die.

The Registrant had resigned his membership and signed an undertaking agreeing never to apply or re-apply for registration as a dentist in Canada.

The allegations included sexual abuse of a patient and criminal convictions for sexual assault and sexual exploitation.

The Discipline Committee granted the motion, finding that the resignation and undertaking permanently removed the Registrant from practice, thereby protecting the public interest and avoiding the costs and potential harm of a full hearing.

In a professional discipline hearing, the panel accepted the registrant’s admissions to multiple years of false or misleading dental billing, excessive periodontal charges, inflated laboratory fees, and deficient record-keeping affecting ten patient files.

The panel found all five allegations proven under s. 51(1)(c) of the Health Professions Procedural Code and paragraphs 25, 28, 31, 33, and 35 of s. 2 of Ontario Regulation 853/93.

Applying the public-interest test for joint submissions on penalty, the panel accepted a joint penalty submission despite disagreement over some mitigating facts.

The panel imposed a reprimand, a four-month suspension, practice restrictions during suspension, required courses, two years of practice monitoring, and $10,000 in costs.

Professional discipline decision arising from admitted misconduct in three separate notices of hearing involving a prohibited business relationship with an unregistered clinic operator, substandard endodontic care and inducements to withdraw a complaint, and sexual abuse and boundary violations involving patients.

The panel held that the admissions and agreed statement of facts established conflict of interest, fee sharing, failure to maintain standards of practice, abuse of a patient, sexual abuse of a patient, and disgraceful, dishonourable, unprofessional or unethical conduct under the Health Professions Procedural Code and Ontario Regulation 853/93.

Applying the joint-submission public-interest standard, the panel accepted the proposed penalty and rejected a request to convert the mandatory oral reprimand into a written reprimand.

The registrant’s certificate was revoked immediately, with a reprimand, reimbursement and security orders, a $35,000 fine, and $10,000 in costs.

The College prosecuted a dentist for administering unauthorized and improper sedation to ten minor patients, including three under the age of three, while lacking the requisite authorization and specialty training and, on many occasions, after his minimal sedation authorization had been cancelled.

The panel accepted admissions that the registrant treated patients beyond his competence, contravened the sedation standard of practice and recordkeeping requirements, and engaged in conduct reasonably regarded by members of the profession as disgraceful, dishonourable, unprofessional or unethical.

Applying the joint-submission public-interest standard, the panel accepted an agreed penalty that included a reprimand, a three-month suspension, remedial recordkeeping education, practice monitoring, and costs.

The panel emphasized the vulnerability of the pediatric patients, the repeated nature of the misconduct, and the registrant’s undertaking never to administer or seek authorization for sedation in future.

In a professional discipline matter, the registrant moved to recuse two public members of the panel because they had participated in an earlier contested discipline hearing involving him that was under appeal, including on an alleged bias ground.

The panel applied the reasonable apprehension of bias test and held that prior participation in an earlier adverse decision, without compelling evidence of actual or apparent bias, was insufficient to displace the strong presumption of impartiality.

The panel rejected the submission that the registrant was entitled to “fresh eyes” and found that the pending appeal and unproven bias allegations in the earlier matter were immaterial to the present hearing.

The recusal motion was dismissed and the hearing was directed to be rescheduled before the same panel.

No costs were awarded on the motion.

Professional discipline decision concerning a dentist who admitted breaching a prior Discipline Committee order that permanently restricted him from performing implant dentistry.

The panel found professional misconduct proved on an agreed statement of facts, including pre-suspension and post-suspension breaches and the registrant's failure to seek clarification of the restriction despite prior discipline history.

Applying the stringent public-interest test for joint submissions, the panel accepted a jointly proposed penalty consisting of a reprimand, a consecutive 10-month suspension, suspension conditions, an ethics course, practice monitoring, and costs.

A publication restriction was ordered protecting the identity of patients.

In a dental discipline proceeding alleging professional misconduct in insurance billing practices involving multiple patients, the College moved with the registrant's consent to adjourn the hearing sine die after the registrant signed a binding undertaking and had already resigned his certificate of registration.

The panel held that it had jurisdiction to control its own process and to grant the requested adjournment, relying on its procedural authority and the terms of the undertaking.

It found the public interest was adequately protected because the registrant agreed never to practise or reapply for registration in Ontario, and the College retained the ability to reinstitute the hearing if the undertaking were breached.

The panel also emphasized transparency through publication on the register and deterrence to other registrants.

At a penalty and costs hearing following findings that the registrant sexually abused two patients and committed multiple additional acts of professional misconduct, the discipline panel held that revocation was mandatory under the Health Professions Procedural Code because the sexual abuse included sexual intercourse.

The panel rejected arguments alleging bias in the earlier merits reasons, held it was functus officio and could not revisit its findings, and found no merit in the contention that the patient relationships were merely incidental to employment or sexual relationships.

The panel also held that a victim impact statement was not a precondition to imposing penalty under s. 51(6).

It ordered a reprimand, immediate revocation, security for therapy and counselling funding for two patients, and substantial costs reflecting roughly two-thirds of the College's actual investigation and hearing expenses.

In a professional discipline hearing, the registrant admitted falsifying dental records and backdating insurance-related documents for multiple patients so they could maximize year-end benefits.

The panel found professional misconduct proven under s. 51(1)(c) of the Health Professions Procedural Code and paragraphs 26, 28, 33, and 59 of s. 2 of Ontario Regulation 853/93.

Applying the public-interest test governing joint submissions on penalty, the panel accepted a joint penalty and costs submission.

The order imposed a five-month suspension, remedial coursework, 24 months of practice monitoring, a prohibition on employing the registrant’s wife in the practice, and $10,000 in costs.

In a professional discipline hearing, the panel found that the registrant persistently failed to comply with mandatory continuing education and reporting obligations under the quality assurance regime, despite repeated directions, reminders, extensions, and investigative follow-up.

The panel also denied a last-minute adjournment request brought through the registrant's daughter, finding insufficient evidence of inability to participate and no indication the registrant would engage later.

Applying the balance of probabilities standard, the panel held that the registrant failed to cooperate with the Quality Assurance Committee, breached the continuing education reporting requirements, failed to respond appropriately to written College enquiries, and engaged in disgraceful, dishonourable, unprofessional or unethical conduct.

A further hearing was directed on penalty and costs.