🔁   HPARB Reviews

HPARB Explained:
Reviewing a College
Decision Short of a Hearing

An ICRC decision — a caution, a SCERP, or a finding of no further action — is not the end of the road. Here is how a review before the Health Professions Appeal and Review Board actually works, and how it differs from appealing a full discipline finding.

⚖️By Ryan Manilla, JD — Founder & Managing Lawyer
📅Updated November 2026
⏱️12 min read
📍Ontario Law
Ryan Manilla, Founder & Managing Lawyer
Ryan Manilla, BA, JD
Founder & Managing Lawyer · Barrister, Solicitor & Notary Public. Osgoode Hall & Harvard Law. Called to the Ontario Bar in 2008.
✓ Lawyer Reviewed
Quick Answer

The Health Professions Appeal and Review Board (HPARB) reviews decisions of a health college’s Inquiries, Complaints and Reports Committee (ICRC) — such as a caution, a SCERP, or a finding of no further action. It asks whether the ICRC’s investigation was adequate and its decision reasonable. This is a different, earlier-stage route than appealing a full Discipline Committee finding to the Divisional Court.

📋 Key Takeaways
  • HPARB reviews decisions of the Inquiries, Complaints and Reports Committee (ICRC) — not decisions of a Discipline Committee.
  • Either the member or the complainant can generally ask HPARB to review an ICRC decision.
  • A request for review must usually be made within a short deadline after receiving the ICRC’s decision letter.
  • HPARB asks whether the investigation was adequate and whether the decision was reasonable — not simply whether it would have decided differently.
  • HPARB can confirm the decision, make recommendations, or set it aside and substitute its own, including sending the matter back for reconsideration.
  • A full Discipline Committee finding is appealed to the Divisional Court instead — a separate, later-stage route covered in our companion article.

What Is HPARB?

The Health Professions Appeal and Review Board (HPARB) is an independent tribunal that sits apart from any individual college. Its role is narrow but important: it reviews certain decisions made at the complaint-screening stage — after a complaint is filed with your regulatory college and investigated, but before the matter ever reaches a formal discipline hearing.

What HPARB Can Review

HPARB reviews decisions of a health college’s Inquiries, Complaints and Reports Committee (ICRC) — the committee responsible for screening complaints after investigation. That includes a finding of no further action, a caution, or a SCERP. See our companion guide on what a caution, SCERP, or undertaking actually means for more on these outcomes.

ℹ️ HPARB Does Not Review Discipline Hearings

If a matter has already been referred to, and decided by, a Discipline Committee after a full hearing, that finding is challenged through an appeal to the Divisional Court, not through HPARB.

Deadlines to Request a Review

A request for an HPARB review must generally be made within a short window — commonly counted in days — after receiving the college’s letter setting out the ICRC’s decision and advising of the right to request a review. Both the professional and the complainant typically have this right, depending on the outcome.

⚠️ Act Immediately After Receiving a Decision

Missing the deadline to request a review can forfeit the right entirely. If you disagree with an ICRC decision, get legal advice the day you receive it, not after the deadline has already passed.

The Test HPARB Applies

HPARB does not simply ask whether it would have reached the same conclusion. It asks whether the ICRC’s investigation was adequate and whether the decision was reasonable — meaning it can be reasonably supported by the information before the committee and withstand a reasonably probing examination.

📌 Practical Example

A patient complains about a professional’s conduct, and the ICRC finds no further action is necessary. The patient asks HPARB to review the decision, arguing key records were never obtained during the investigation. HPARB agrees the investigation was inadequate, sets the decision aside, and sends the matter back to the ICRC to investigate further before deciding again.

Possible Outcomes

HPARB can confirm all or part of the ICRC’s decision, make recommendations to the committee, or — where it finds the investigation inadequate or the decision unreasonable — set the decision aside and substitute its own decision or send the matter back for reconsideration. There is generally no further appeal from an HPARB decision except by way of judicial review at the Divisional Court.

HPARB vs. a Divisional Court Appeal

It is easy to confuse these two review routes, but they apply at completely different stages. HPARB reviews ICRC-level outcomes before any discipline referral occurs. Once a matter has gone through a full discipline hearing and a finding has been made, the route for challenging that finding is an appeal to the Divisional Court, which our companion article covers in detail — a materially different process with its own deadlines and legal test.

📞 Free Consultation

Considering an HPARB review of a college decision? Call our Toronto regulatory defence lawyers at 416-274-2222 for a confidential consultation.


Frequently Asked Questions

What is HPARB?

The Health Professions Appeal and Review Board is an independent tribunal that reviews certain decisions made by Ontario health colleges at the complaint-investigation stage, before any matter reaches a formal discipline hearing.

What kinds of decisions can HPARB review?

HPARB reviews decisions of a college’s Inquiries, Complaints and Reports Committee (ICRC) — including a finding of no further action, a caution, or a SCERP. It does not review a Discipline Committee’s finding after a full hearing.

Who can ask for an HPARB review?

Generally either the professional who was the subject of the complaint or the person who made the complaint can request a review, depending on the outcome and the governing legislation.

How long do I have to request an HPARB review?

Deadlines are short and strictly enforced, typically counted from the date you receive the college’s decision letter. Confirm the exact deadline for your situation immediately, since missing it can forfeit the right to a review.

What standard does HPARB apply?

HPARB considers whether the ICRC’s investigation was adequate and whether its decision was reasonable, meaning it can be supported by the information before the committee and withstand a reasonably probing examination — not simply whether HPARB would have reached a different conclusion.

What can HPARB actually do?

HPARB can confirm all or part of the ICRC’s decision, make recommendations to the committee, or — where it finds the investigation inadequate or the decision unreasonable — set the decision aside and substitute its own or send the matter back for reconsideration.

Is an HPARB review the same as appealing a discipline hearing decision?

No. A discipline hearing finding is appealed to the Divisional Court under a different process entirely. HPARB reviews only ICRC-level outcomes that occur before a matter is referred to a formal discipline hearing.


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