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Consultation 2026: POLICY - Duty to Report Self, Colleagues or Patients

CONSULTATION SURVEY


Introduction

The Council of the College of Physicians and Surgeons of Saskatchewan (CPSS) recently approved the above-noted policy, Frequently Asked Questions (FAQ) document and Notification of Concern online form in principle for a second round of consultation. The Council directed that the documents be circulated to physicians and other CPSS registrants, health care organizations and the public to seek feedback.

Background

At its November 2024 meeting, the Council approved an earlier version of the policy and a supplemental guidance document in principle for consultation. System partners and all CPSS registrants were invited to participate in that consultation. The Council considered consultation responses at its meeting in September 2025, and broadly approved the committee’s approach to the proposed amendments. Subsequently, the committee met several times to further refine the policy and to provide direction on an FAQ document.

Below is a general overview of the themes of the feedback received in the initial round of consultation:
  • There were concerns that the language in the policy (as initially approved in principle) was too broad and vague and would lead either to over-reporting or under-reporting.
  • There were suggestions that the policy should focus on impairment (and possible patient safety issues) rather than the fact of illness, and that these concepts should be more clearly distinguished.
  • It was suggested that the Council should more carefully balance the tension between public protection and therapeutic confidentiality. This followed concerns that if a treating physician is expected to report their physician patient, physicians will be reluctant to seek appropriate care, particularly for mental health concerns.
  • Some respondents urged broader consultation with practising clinicians and educators, noting that the policy needs to balance public safety with professional compassion, while preserving the autonomy and dignity of physicians and patients.
Amended documents approved in principle for consultation

The amendments to the policy can be summarized as follows:
  • Updating formatting to align with currently utilized template and for ease of reference to specific provisions within the policy;
  • Adding definitions to improve clarity;
  • Emphasizing that the focus is on functional impairment and not the health condition/diagnosis itself;
  • While bylaw 3.1 and renewal question #8 include the language “mental and/or emotional condition,” based on feedback received, the committee suggested and the Council approved removing the term ‘emotional’ as it was not felt to be reflective of language utilized by physicians;
  • Adding details as to the mode of reporting, with the option of a proposed Notification of Concern online form (also available for consultation) and designated email address;
  • Adding detailed expectations if a patient discloses sexual misconduct by another registrant, including what should be recorded in the patient’s medical record, and changing “reasonable grounds” to “reasonably believe;”
  • Adding reference to HIPA and the data minimization principle, to emphasize that the registrant should report only the necessary information;
  • With respect to the broad “catch-all” provisions (2.6, 3.7), the Council has approved in principle changing this to a requirement to seek advice from the CMPA or CPSS rather than an automatic requirement to report.
The previously provided supplemental document has been completely redrafted as an FAQ, in an effort to provide granular advice on the interpretation of the policy. The document contains many of the FAQs included in supplemental documents adopted by other medical regulatory authorities, and also some of the questions raised in the initial consultation phase.

As was emphasized in the initial consultation, the reporting obligations are not new; they are just more explicitly restated in one document in addition to being based in The Code of Ethics (bylaw 7.1), the Code of Conduct (bylaw 7.2), bylaw 3.1 relating to questions posed at the time of licensure renewal, and the Sexual Boundaries policy.
Consultation Request

The Council would like to hear from you. We anticipate that the Council will consider feedback from interested parties, including members of the profession, at its meeting on Friday, November 27, 2026. If you have concerns with the proposed policy, FAQ or Notification of Concern online form, it would be helpful if you explain the reasons for those concerns.
How to Respond


In order for the College to consider feedback and correlate feedback for the Council in time for the next Council meeting, all feedback should be provided to the College no later than Monday, November 9, 2026.


1. Click on the links below to see the proposed Policy:
2. Complete the survey below. Alternatively, feedback can be provided to communications@cps.sk.ca.