On April 28, 2026, the Ontario Physicians and Surgeons Discipline Tribunal released its reasons in College of Physicians and Surgeons of Ontario v Iracleous, 2026 ONPSDT 15. Dr. Panayiotis Iracleous, an emergency physician at the Scarborough Health Network Centenary Hospital, had his certificate of registration revoked after the tribunal found that he submitted false claims to OHIP for services he did not provide, and then refused to cooperate when the College investigated. There was no patient injury at the heart of this case. It is about honesty and accountability: the integrity of the billing system, and the duty every physician owes to answer to the regulator.
The false claims
Physician billing to OHIP runs largely on an honour system. Most claims are processed automatically, and the physician is responsible for their accuracy and for following the Schedule of Benefits. The problem here surfaced in two ways: a Ministry of Health review of Dr. Iracleous’s billings, and the College’s own investigation.
The Ministry analyzed 408 records from the hospital for certain fee codes, covering claims between May and July 2021. It found no records to support any of them. In 406 of the 408 records there was no record that Dr. Iracleous had provided any service to the patient at all, and in the remaining two there was only a brief note that handover had been given to him. He had been paid $125,353.05 for claims he was not eligible to make, including fee codes for critical care resuscitations, cardioversions, and assessments of patients who had already been admitted and were under the care of other physicians on the ward, an involvement the Ministry noted would be unusual for an emergency department physician. When the Ministry asked for repayment in November 2022, he promptly repaid it.
The College then retained Dr. Andrew Bishop, a family physician practising emergency medicine, to review a sample of charts. His analysis made the pattern plain. In most of the 24 charts reviewed, Dr. Iracleous did not appear to have been involved in the patients’ care; in many, he billed for dates when the patient was not in the emergency department, or for dates he was not even scheduled to work. He repeatedly billed codes that apply only when a physician is called in from home, without evidence he had been on call. He billed thirteen times for cardioversion with no evidence in twelve of them that the procedure happened or was needed, and fourteen times for life-threatening critical care with no record of his involvement. As the analysis put it, had he actually provided that critical care, there would be a record of it.
The tribunal found this conduct disgraceful, dishonourable and unprofessional under the Professional Misconduct Regulation made under the Medicine Act, 1991. In its words, he took scarce health care dollars for his own benefit and betrayed the public’s trust in physicians to bill honestly.
The refusal to cooperate
The second branch of the misconduct was the failure to cooperate. The duty to cooperate with a College investigation is not optional. Section 76(3.1) of the Health Professions Procedural Code requires a registrant to cooperate fully with an investigator, and the Professional Misconduct Regulation makes it misconduct to fail to respond appropriately and within a reasonable time to a written inquiry, which includes attending an interview on request.
Over more than eighteen months, the College asked repeatedly. Dr. Iracleous, through counsel, gave an early answer that he had dealt with the Ministry and would contest any misconduct allegation, then declined to attend an interview and kept refusing despite reminders, did not respond to the assessor’s report when invited to make submissions, and did not answer the 23 detailed questions the investigator later required. The tribunal found this was itself professional misconduct, on two footings: failing to respond to the College’s inquiries, and conduct that was disgraceful, dishonourable and unprofessional.
Revocation
The penalty was a joint submission for revocation, a reprimand, and $6,000 in costs. A tribunal’s role on a joint submission is narrow: it must implement the agreement unless doing so would bring the discipline system into disrepute (R v Anthony-Cook, 2016 SCC 43). The tribunal had no difficulty accepting revocation here. It noted that a line of recent decisions involving intentional OHIP overbilling has led to revocation, and that earlier caselaw treats revocation as “the norm” for substantial premeditated fraud. The honour-based billing system depends on public trust in physicians’ integrity, and the refusal to cooperate had impaired the College’s ability to protect the public. The only factors in mitigation were the no-contest plea, which spared the College from calling evidence, and the prompt repayment.
One practical note from the reasons: the parties agreed that if Dr. Iracleous ever applies for reinstatement, the College is free to introduce additional evidence beyond the facts relied on here.
Why it matters
This is not a malpractice case, and it is worth being clear about that. No patient was injured by negligent treatment, and a discipline decision does not award compensation in any event. What the case illustrates is the accountability side of the profession, and two themes that run through this Tribunal’s work.
The first is the integrity of medical records. The fraud was detectable precisely because the records did not exist: if critical care had been delivered, there would have been a record of it. Contemporaneous, accurate records are the backbone of accountability in medicine, whether the question is a billing claim or, in a malpractice case, what was actually done for a patient and when. Their absence is rarely neutral.
The second is the duty to cooperate with the regulator. As in other recent decisions, the tribunal treated a refusal to engage with a College investigation as serious misconduct in its own right, because the College can only protect the public if physicians answer its questions. For patients, that is the reassurance the discipline system is meant to provide: a physician who bills dishonestly, and then stonewalls the body charged with investigating, can expect to lose the licence.
The full decision is available on CanLII: College of Physicians and Surgeons of Ontario v Iracleous, 2026 ONPSDT 15.
