An Ontario audiologist has had her certificate of registration permanently revoked after a disciplinary tribunal declared her “ungovernable” following a lengthy history of professional misconduct and a persistent refusal to cooperate with her regulatory body. In a case cited as College of Audiologists and Speech-Language Pathologists of Ontario v Berge, 2025 ONASLPDT 6 (CanLII), Brenda Berge, who practiced in Guelph, lost her license effective immediately in a decision released on July 10, 2025, by the Ontario Audiologists and Speech-Language Pathologists Discipline Tribunal. The ruling is the culmination of years of disputes, multiple suspensions, and what the tribunal described as a pattern of disregard for the College’s authority.
The most recent case, which triggered the revocation, stemmed from Ms. Berge’s failure to comply with a previous disciplinary order. In September 2023, the College’s Inquiries, Complaints and Reports Committee, or ICRC, ordered Ms. Berge to attend an in-person caution. This measure was imposed due to concerns over her infection control procedures, her public statements about COVID-19, and her continued use of the title “doctor” in her professional capacity as an audiologist. The ICRC directed that the caution must be completed by December 13, 2023.
Following the order, the College of Audiologists and Speech-Language Pathologists of Ontario emailed Ms. Berge on two separate occasions to ask for her availability to schedule the mandatory caution. According to the tribunal’s findings, she never responded to these communications, and the caution never took place. This failure prompted the College to launch a new investigation in January 2024, specifically into her non-compliance with the ICRC’s order. An investigator was appointed and made multiple attempts to contact Ms. Berge by phone and email in February and March 2024, leaving messages and requesting an interview. Again, she failed to respond. In April 2024, the College sent a formal letter requesting a written response to the investigation within 30 days. The mailed copy was returned as unclaimed, and the email received no reply.
This persistent non-cooperation led the ICRC to refer the matter to the Discipline Tribunal in November 2024 for a formal hearing on allegations of professional misconduct. When the hearing convened by videoconference on May 29, 2025, Ms. Berge was neither present nor represented by counsel. The tribunal panel found that she had been properly notified of the proceedings through her official email address on file with the College and decided to proceed in her absence. The panel noted that it is a registrant’s professional responsibility to keep their contact information up to date and that the College is not obligated to undertake “herculean efforts” to locate them.
The tribunal heard evidence about the College’s extensive efforts to serve her with documents, which included hiring a process server who attended her clinic and multiple residential addresses. One of these was a weekend residence where a neighbour confirmed she lived. Despite this, the tribunal denied a last-minute request from the College’s own counsel for an adjournment, stating that last-minute delays impair public confidence and that Ms. Berge’s history suggested she had no intention of participating. The tribunal concluded that her failure to attend the caution and her subsequent refusal to respond to the investigation constituted “disgraceful, dishonourable or unprofessional conduct.”
In determining the penalty, the tribunal considered Ms. Berge’s extensive and troubling disciplinary history. The panel stated that while most of her prior misconduct findings occurred after the events in the current case, they were relevant in assessing the risk of future misconduct and her willingness to be governed. Her record dates back to March 2015, when she was first found guilty of professional misconduct for improperly using the “doctor” title despite prior warnings. That resulted in a reprimand and a three-month suspension. Ms. Berge fought that decision through the courts, but her appeals were ultimately dismissed, with the Divisional Court in 2021 prohibiting her from launching further proceedings against the College without prior permission.
More recently, Ms. Berge was the subject of three separate disciplinary findings in 2024 alone. In one case, she was found to have failed a client, engaged in unprofessional conduct, and kept poor records, resulting in a nine-month suspension that would continue until she completed remedial courses. In another, she was found to have posted misleading information about COVID-19, earning a two-month suspension. A third finding involved another failure to cooperate with an investigation and making inappropriate statements on social media, which resulted in a six-month suspension. Ms. Berge did not attend the hearings for any of these 2024 matters, and her certificate was already under suspension because she had not completed the required remediation from those orders.
The tribunal concluded that this long pattern of non-compliance, a failure to participate in hearings, and a refusal to be regulated demonstrated that Ms. Berge is ungovernable. “The registrant’s repeated failure to respond to her regulator demonstrates that she is not willing to be governed by the College’s rules, which are put in place to protect the public,” the panel wrote in its decision. Finding no evidence of remorse or any mitigating factors, the tribunal ordered the immediate revocation of her certificate of registration to protect the public. In addition to the revocation, Ms. Berge was issued a formal written reprimand and ordered to pay the College $26,917.70 in costs by May 29, 2026.
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