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A Profound Breach of Trust in End-of-Life Care In CNO v. Lindsey Coyle, the Discipline Committee of the College of Nurses of Ontario addressed one
On January 21, 2026, the Ontario Physicians and Surgeons Discipline Tribunal released an important decision addressing how professional misconduct findings from another province can ground discipline in Ontario — even where some underlying conduct occurred years earlier and outside the province.
In College of Physicians and Surgeons of Ontario v. Faruqi, 2026 ONPSDT 4, the Tribunal imposed a two-month suspension, reprimand, mandatory ethics training, and costs on an Ontario-licensed physician based largely on misconduct findings made by Quebec’s medical regulator.
Dr. Faruqi is an obstetrician-gynecologist specializing in fertility and reproductive medicine. Although licensed in Ontario, the underlying misconduct occurred while he was practising in Quebec.
Following a Quebec investigation, the physician admitted to 16 counts of professional misconduct before Quebec’s discipline tribunal. Those findings included:
Advertising and facilitating paid egg donation, contrary to the Assisted Human Reproduction Act (a federal statute);
Paying egg donors, also prohibited under federal law;
Improper referral of a patient for fertility services prohibited in Quebec due to age restrictions;
Unprofessional and disparaging comments about another healthcare professional;
Record-keeping and financial practice concerns under Quebec’s regulatory framework.
Quebec imposed a three-month suspension and $15,000 in fines. The physician later resigned from Quebec’s regulator but remained licensed in Ontario.
Ontario law expressly allows the CPSO to rely on disciplinary findings from another jurisdiction.
Under Ontario’s Professional Misconduct Regulation and the Health Professions Procedural Code, a physician may be found to have committed professional misconduct in Ontario if:
Another jurisdiction has made a misconduct finding; and
The underlying facts would constitute professional misconduct if they occurred in Ontario.
The Tribunal emphasized that contravening federal legislation designed to protect public health — such as the Assisted Human Reproduction Act — squarely meets Ontario’s misconduct definitions.
The Tribunal made Ontario findings for:
Contravention of federal reproductive legislation (advertising and payment for eggs);
Conduct considered disgraceful, dishonourable, or unprofessional;
Public disparagement of another healthcare professional.
Importantly, the Tribunal declined to make Ontario findings on some Quebec-specific issues, including:
Failure to provide detailed invoices (because Ontario only requires itemized accounts if requested);
Certain financial and regulatory breaches that have no Ontario equivalent.
This distinction highlights that out-of-province findings are not automatically imported wholesale — the facts must map onto Ontario’s regulatory framework.
Accepting a joint submission, the Tribunal ordered:
A two-month suspension of the physician’s Ontario licence;
A formal reprimand, published on the public register;
Mandatory completion of the PROBE Ethics & Boundaries Program;
$6,000 in costs payable to the CPSO.
While the misconduct was described as serious, the Tribunal noted mitigating factors, including admissions, expressions of regret, and prior discipline already imposed in Quebec.
This case is significant for several reasons:
Out-of-province conduct matters
Physicians licensed in Ontario remain accountable for misconduct findings made elsewhere in Canada.
Federal law breaches are taken extremely seriously
Violations of public-health legislation will almost always support Ontario discipline.
Professional conduct extends beyond patient care
Advertising practices, financial arrangements, and public commentary about colleagues all fall within regulatory oversight.
Not every foreign finding translates automatically
Ontario panels will carefully analyze whether the conduct aligns with Ontario’s specific misconduct definitions.
For patients, this decision reinforces that regulators can and do act to protect the public, even where misconduct occurred outside Ontario.
For physicians, it is a clear reminder that ethical obligations travel with your licence, and regulatory consequences may follow you across provincial borders.
If you are concerned about whether professional misconduct or regulatory failures contributed to patient harm — or if you are navigating CPSO proceedings — obtaining legal advice early is critical.
Decision Date: January 21, 2026
Jurisdiction: Ontario Physicians and Surgeons Discipline Tribunal
Citation: College of Physicians and Surgeons of Ontario v. Faruqi, 2026 ONPSDT 4 (CanLII)

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