Pharmacist and Pharmacy Complaints, Investigations and Discipline in Ontario

When the Ontario College of Pharmacists Contacts You

Pharmacy is regulated on two levels. Pharmacists and pharmacy technicians are individual registrants under the Pharmacy Act, 1991 and the Health Professions Procedural Code. Pharmacies themselves need a certificate of accreditation under the Drug and Pharmacies Regulation Act, and each must have a designated manager who is a pharmacist (DPRA, ss. 139, 146). A single incident, such as a dispensing error or a narcotic discrepancy, can lead to questions for the individual, the designated manager and the owner.

Illustrative example, not an actual OCP letter

“The College has received a complaint regarding a dispensing error involving a patient’s prescription filled at your pharmacy. Please provide the prescription, the patient profile, the dispensing and verification records, and any incident report, together with your response.”

Who Investigates and Who Decides

Regulator: The Ontario College of Pharmacists, continued, under the Pharmacy Act, 1991. Its complaint, investigation and discipline procedures come from the Health Professions Procedural Code, Schedule 2 to the Regulated Health Professions Act, 1991 (“the Code”), which applies to every regulated health profession in Ontario. The Drug and Pharmacies Regulation Act governs pharmacy accreditation and operation.
Who investigates: College investigators for complaints and Registrar’s investigations, and College inspectors for pharmacies. Inspectors may enter a pharmacy at reasonable times and can obtain a warrant to search (DPRA, ss. 148–148.1).
Who decides about individuals: A panel of the Inquiries, Complaints and Reports Committee (ICRC) (Code, s. 26).
Who decides about pharmacies: The Accreditation Committee can refer the accreditation holder, the designated manager or a corporation’s directors to the Discipline Committee for failing to meet the DPRA or for proprietary misconduct, and can make an interim order against the certificate of accreditation (DPRA, s. 140(1), (2.0.1)).
Who holds hearings: The OCP Discipline Committee hears allegations of professional misconduct and incompetence against registrants and of proprietary misconduct against pharmacies, under its Rules of Procedure.

Key timelines in the Code

The Registrar must notify you within 14 days of receiving a complaint or report (Code, s. 25(6)).
You may make written submissions to the Inquiries, Complaints and Reports Committee within 30 days of receiving that notice. The committee can shorten that time if it believes, on reasonable and probable grounds, that your conduct exposes or is likely to expose patients to harm or injury (Code, s. 25.2).
Complaints are expected to be disposed of within 150 days. If that is missed, the Registrar must give the complainant a new expected date no more than 60 days later (Code, s. 28).
With both your and the complainant’s consent, the Registrar can refer a complaint to alternative dispute resolution, but not if it involves an allegation of sexual abuse or has already been referred to discipline (Code, s. 25.1).

Common Issues in Pharmacy Investigations

Dispensing errors

Wrong drug, strength or directions, and how the error was handled once discovered. OCP’s supplemental standard requires a standardized medication safety program in Ontario pharmacies, so incident documentation is often reviewed.

Narcotics and controlled substances

Inventory discrepancies, losses, forged prescriptions and suspected diversion. These can involve the individual pharmacist, the designated manager and the pharmacy’s accreditation.

Billing and claims

Claims for services or drugs not provided, or billing that does not match records. Concerns may come from public or private payers as well as from patients.

Expanded scope

Prescribing for minor ailments, administering injections, and renewing or adapting prescriptions without meeting the documentation and assessment requirements that apply.

Operations and supervision

Pharmacy operating standards, supervision of technicians and assistants, and business pressure on professional judgment. OCP has adopted NAPRA’s model standards of practice for pharmacists and pharmacy technicians, along with its own Standards of Operation for pharmacies.

What Can Happen Next

Complaint or Registrar’s investigation

After considering the investigation and your submissions, a panel of the Inquiries, Complaints and Reports Committee (ICRC) may take no further action; give advice or recommendations; require a specified continuing education or remediation program (SCERP); require you to appear to be cautioned; refer specified allegations of professional misconduct or incompetence to the Discipline Committee; or refer you for incapacity proceedings (Code, s. 26). Matters are also sometimes resolved through an undertaking, such as an agreement to restrict or monitor your practice. If the panel considers a complaint frivolous, vexatious, made in bad faith, moot or an abuse of process, it must give notice and allow 30 days for written submissions before declining to act (s. 26(4)–(5)).
Interim order

If the committee believes your conduct exposes or is likely to expose patients to harm or injury, it can suspend your certificate or impose terms, conditions or limitations while the matter continues (Code, s. 25.4(1)). You must normally receive notice and at least 14 days to make written submissions first, unless the risk is urgent (s. 25.4(6)–(7)). The order lasts until it is varied or the matter is finally resolved (s. 25.4(4)).
Discipline hearing

A panel of the Discipline Committee hears evidence and decides whether professional misconduct or incompetence is proven (Code, ss. 51, 52). If misconduct is found, it may revoke or suspend your certificate, impose terms, conditions and limitations, order a reprimand, or order a fine of up to $35,000 (s. 51(2)). Findings of sexual abuse carry mandatory orders, including revocation for the conduct listed in s. 51(5).
Proceedings against a pharmacy

If the Discipline Committee finds that an accreditation holder or a corporation’s directors operated a pharmacy contrary to the Drug and Pharmacies Regulation Act or committed proprietary misconduct, it may revoke or suspend the certificate of accreditation, impose terms, conditions and limitations, or order a fine of up to $100,000 (DPRA, s. 140(3.1)). A designated manager found to have contravened the Act faces the same range of orders as an individual registrant (s. 140(3.2)). The Code’s hearing, review and appeal provisions apply to these proceedings (s. 140(2)).
Review or appeal

HPARB review: you or the complainant may ask the Health Professions Appeal and Review Board to review an ICRC decision on a complaint, except a referral to discipline or for incapacity proceedings (Code, s. 29(2)). The request must be made within 30 days after receiving the notice of the right to request a review that comes with the decision (s. 29(3)), and HPARB cannot extend that time by more than 60 days (s. 29(4)).

Divisional Court: discipline and fitness to practise decisions can be appealed on questions of law, fact or both (Code, s. 70). Orders based on incompetence, incapacity or certain sexual abuse findings, and orders in matters where an interim order was in place, take effect immediately despite an appeal (ss. 25.4(5), 71, 71.1).

Checklist: Responding to an OCP Complaint or Inspection

Documents to gather

The College’s letter or inspection report and the date you received it
The prescription, patient profile, and dispensing, verification and counselling records
Medication incident reports and any follow-up or root-cause analysis
Narcotic and controlled substance registers, counts, reconciliations and loss reports
Billing and claims records for the relevant period
Staff schedules showing who was working, and their roles
Policies and procedures in effect at the time

Details to check in the notice

Is it addressed to you as a registrant, as designated manager, or to the pharmacy?
Complaint, Registrar’s investigation, or Accreditation Committee matter?
Your submission deadline, and whether it has been shortened
Whether an interim order against your certificate or the accreditation is proposed

Rules and resources to consult

Health Professions Procedural Code, ss. 25–29, 51–52, 70–71 and 75–76
Pharmacy Act, 1991 and its regulations
Drug and Pharmacies Regulation Act, ss. 139–148.4, and its regulations
OCP Code of Ethics, NAPRA model standards of practice adopted by OCP, OCP supplemental standards and Standards of Operation
OCP Discipline Committee Rules of Procedure and practice directions

Frequently Asked Questions

I am the designated manager. Am I responsible for errors by other staff?

The designated manager is the pharmacist responsible for managing the pharmacy (DPRA, s. 1) and can face proprietary misconduct allegations of their own (s. 140(3.2)). The pharmacist or technician who made the error may also be investigated individually.

Can the College suspend a pharmacy’s accreditation before a hearing?

Yes. The Accreditation Committee can make an interim order if it believes the conduct or operation of a pharmacy is likely to expose a patient or the public to harm or injury. The Code’s notice and submission rules for interim orders apply (DPRA, s. 140(2.0.1)–(2.1)).

What is the difference between a complaint and a report?

A complaint is filed by someone, usually a patient or family member, who becomes a party and receives the decision. A report is information the Registrar acts on by appointing investigators (Code, s. 75), for example after a mandatory report from an employer or another professional. The same committee decides both, but HPARB review rights under s. 29 are tied to complaints.

Will this appear on the public register?

The Code requires the public register to note cautions, SCERPs, acknowledgements and undertakings, and allegations referred to discipline (s. 23(2)). College by-laws can add more. Check what will be posted before agreeing to any resolution.

Sources

Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.

Regulated Health Professions Act, 1991, S.O. 1991, c. 18, Schedule 2 (Health Professions Procedural Code), ss. 23, 25–29, 51–52, 70–71, 75–76, 85.5 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
Pharmacy Act, 1991, S.O. 1991, c. 36, ss. 5, 10 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
Drug and Pharmacies Regulation Act, R.S.O. 1990, c. H.4, ss. 1, 139–140, 146, 148–148.1 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
OCP, “Discipline Process” — Checked November 10, 2026.
OCP, “Standards of Practice” — Checked November 10, 2026.
OCP, “Report Concerns” — Checked November 10, 2026.
Health Professions Appeal and Review Board (role; Consolidated Rules of Practice and Procedure in effect May 4, 2026) — Checked November 10, 2026.