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The following case summary is provided as an educational resource for registrants. This type of case has been selected because it reflects issues that arise in complaints and concerns reviewed by the College and highlights areas of practice where registrants may face increased risk. By sharing these examples, CRPO aims to support safe, ethical and effective practice through reflection on real-world regulatory issues.
Professional liability insurance audit
The College requires all registrants, other than those in the Inactive category of registration, to have professional liability insurance (PLI) coverage in the amount and form set out by the College’s By-laws. The College regularly conducts PLI audits in which randomly selected registrants are required to provide proof of their PLI coverage within 30 days. After this deadline, any registrant who has not successfully completed the audit is issued a notice of impending suspension and provided an additional 30 days to provide their proof of PLI.
Notice of audit
Registration staff notified the Registrant that they had been selected for a PLI coverage audit. To complete the audit, the Registrant had to provide proof of their insurance coverage within 30 days. The Registrant did not submit proof of their insurance coverage by the deadline. Registration staff informed the Registrant that they would be suspended if they did not provide proof of their insurance coverage within 30 days.
Registrant response
In response, the Registrant stated that they believed they had PLI coverage but during the audit process, discovered that they did not. The Registrant stated that at that time, they were in the process of applying for PLI coverage. However, they had been practising psychotherapy without PLI coverage for a period of time. As a result, a report was opened by Professional Conduct staff.
Report process and registrant submissions
As part of the reports process, Professional Conduct staff asked the Registrant to explain why they believed they had PLI. Staff also asked the Registrant to confirm whether they had since obtained appropriate insurance. The Registrant explained that they had previously been covered by the policy of an organization where they practised. The Registrant believed that the coverage was ongoing. As a result, the Registrant did not obtain separate PLI. During the audit process, the Registrant realized that this coverage had ended and that they did not have their own policy in place. The Registrant confirmed that once they became aware of the lapse, they obtained their own PLI and provided documentation confirming their coverage.
Outcome
In this matter, the Registrar determined that formal investigation was not necessary. The Registrar resolved the concerns by issuing written advice to the Registrant. The advice reminded them of their obligations under the College’s By-laws to maintain continuous PLI and their responsibilities toward the College, including responding accurately and in a timely manner to College inquiries.
Registrants are permitted to be covered by their employer’s PLI coverage. However, it is still the responsibility of registrants to independently verify coverage and proactively ensure continuous compliance with regulatory requirements. Practising without PLI coverage exposes clients and registrants to significant risk.
For further information regarding this topic, please see:
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