The Health Professions Appeal and Review Board has issued a decision confirming that a registered dietitian will receive a formal written reminder regarding her communication style following a series of complaints from a patient1. The case, involving Linda B. Tokarew and Geneviève Grégoire, a registered dietitian practicing in Ontario, centered on allegations of verbal abuse and bullying during medical consultations. The board, consisting of Vice-Chair Thomas Kelly and members Barbara Mellman and Helen-Claire Tingling, reviewed the matter after the patient expressed dissatisfaction with the initial outcome provided by the College of Dietitians of Ontario.
The history of the relationship between the two parties began through the Diabetes Education Program at the Bruyère Academic Family Health Team. Over several years, the applicant, Linda B. Tokarew, received diabetes care and education from various healthcare professionals at the facility, including nurses and dietitians. The specific interactions that sparked the formal complaint occurred during two distinct sessions. The first was a virtual appointment held on September 12, 2022, and the second was an in-person appointment that took place on October 19, 2023. These interactions led the patient to seek intervention from the regulatory college that oversees the conduct of dietitians in the province.
In her formal complaint to the College of Dietitians of Ontario, the applicant alleged that the respondent, Geneviève Grégoire, had been verbally abusive and had engaged in bullying behavior during their sessions. According to the records reviewed by the board, the applicant stated that the dietitian’s tone was inappropriate and that she had raised her voice during their interactions. The complaint further detailed that the respondent had made comments that the applicant perceived as belittling and disrespectful. These experiences reportedly caused the patient significant discomfort and led to the feeling that she was being bullied by a healthcare professional in a position of authority.
Upon receiving the complaint, the Inquiries, Complaints and Reports Committee of the College of Dietitians of Ontario launched an investigation into the matter. As part of this process, the respondent provided written responses to the allegations, defending her conduct and providing her patient charts as evidence. These clinical notes and her personal recollections outlined her version of the events and the nature of the communications that took place during the contested appointments. The committee also examined the respondent’s professional history, noting that she had no prior disciplinary record or previous decisions against her by the college.
After reviewing the available evidence, the committee reached a decision to issue a written reminder to the dietitian. This reminder focused specifically on the respondent’s communication style. However, the committee concluded that there were no significant concerns regarding the dietitian’s overall clinical practice or conduct that would necessitate more severe remedial action, such as a referral to a discipline committee. The committee noted that while there was room for improvement in how the dietitian communicated with patients, the evidence suggested a low risk of harm to the public.
The applicant was not satisfied with this outcome and filed a request for a review with the Health Professions Appeal and Review Board. In her request, the applicant argued that the dietitian should be required to undergo further training to protect other patients. She expressed the view that the dietitian had abused her position of authority and asked that the formal record include specific instructions for monitoring and training until the dietitian’s behavior showed measurable improvement. The applicant stated that she felt unfairly treated by the initial decision and the process that led to it.
The board’s mandate in such a review is governed by the Health Professions Procedural Code. Its role is limited to assessing two primary factors: the adequacy of the college’s investigation and the reasonableness of the committee’s decision. The board does not have the authority to make its own findings of professional misconduct or to order specific penalties that fall outside the jurisdiction of the regulatory committee. Instead, it must determine if the committee sought the essential information required to make an informed decision and if the resulting decision was transparent, intelligible, and justified based on the facts and the law.
During the review process, which was held via teleconference on July 9, 2025, the dietitian was represented by counsel, while the college was represented by its case manager and registrar. Although the applicant did not participate in the review session itself, the board proceeded with its analysis based on the written record, noting that legislation does not require all parties to be present and that no negative inference would be drawn from her absence. The board examined the complete record of investigation, which included the original complaint, the dietitian’s responses, nutrition notes, and the applicant’s replies.
In evaluating the adequacy of the investigation, the board found that the college had collected all relevant documents necessary to understand the conflict. This included not only the direct correspondence between the parties but also the clinical records and the respondent’s professional history. The board concluded that both the patient and the dietitian had been given ample opportunity to clarify their versions of the events. Because the investigation covered the essential elements of the dispute and there was no evidence of missing information that would have altered the outcome, the board deemed the investigation to be adequate under the legal standard.
The board then turned its attention to the reasonableness of the committee’s decision to issue only a written reminder. The board noted that in cases where the recollections of the parties differ significantly, a regulatory committee faces a difficult task. In this instance, there was a direct conflict between the patient’s description of verbal abuse and the dietitian’s account of the appointments. The board observed that there was no independent evidence or third party information in the record that would allow the committee to definitively prefer one person’s account over the other.
Given this lack of corroborating evidence for either side, the board found that the committee’s choice to take no further action beyond the written reminder was a rational and justified outcome. The board explained that the inability of the committee to decide between two competing versions of events does not mean the committee disbelieved the applicant. Rather, it reflects the legal reality that a committee must have a sufficient basis to take stronger regulatory action. The board found that the committee had properly applied its professional expertise to determine that the dietitian’s conduct posed a low risk and that a reminder was a sufficient tool for professional reflection.
The content of the written reminder, which was attached to the board’s final decision, provides specific guidance to the dietitian. It emphasizes that the college expects all members to communicate in a professional, respectful, and client centered manner. The reminder acknowledges that while the dietitian’s clinical care and the questions she asked to gain insight into the patient’s health were not a cause for concern, the manner in which those questions were delivered was the core issue. The committee advised the dietitian to consider how her questions might be perceived by patients and suggested that she reframe her inquiries and modify her tone and word choice when dealing with sensitive situations.
The formal reminder further encourages the dietitian to view the complaint as a learning opportunity to improve her future practice. It explicitly warns that should similar concerns regarding her communication style arise in the future, the college could consider taking more significant disciplinary action. This serves as a formal notice that while the current issue was resolved through a reminder, a pattern of such behavior would be viewed more seriously by the regulator.
In its final analysis, the Health Professions Appeal and Review Board confirmed the initial decision of the committee. The board stated that the committee’s reasoning was coherent and rational, demonstrating a clear connection between the facts of the case and the chosen regulatory response. By upholding the written reminder, the board concluded the review process, maintaining the balance between addressing the patient’s concerns and applying the proportional regulatory response deemed appropriate by the professional college. The decision reinforces the standards of communication expected of healthcare professionals in Ontario and the procedural requirements for investigating patient grievances within the regulated health professions.
Read more cases about proceedings in regulated professions here.
