Cracking Down on Unlicensed Medical Practice

Summary#

This bill updates Saskatchewan’s Medical Profession Act to crack down on people who practice medicine without a licence. It gives the College of Physicians and Surgeons of Saskatchewan (CPSS) stronger tools to investigate and stop unlicensed practice, raises fines, and extends the time to prosecute. It also makes similar updates to the Regulated Health Professions Act for other health colleges.

• Lets CPSS get court orders to quickly stop someone from posing as a doctor, podiatric surgeon, or physician assistant.
• Allows courts to order people to provide records or answer questions needed for an investigation, including people who are not licensed.
• Increases fines for unlicensed practice and misuse of protected titles like “doctor,” “physician,” “surgeon,” “physician assistant,” and “podiatric surgeon.”
• Extends the prosecution window to two years from when CPSS discovers a possible offence.
• Allows the government to set regulations that define what counts as “practising medicine” and what activities are exempt.
• Permits CPSS (and other health colleges under the RHPA) to prosecute offences and seek interim court orders.

What it means for you#

• Patients and the public

  • Stronger measures to stop fake or unlicensed providers more quickly.
  • Better ability for CPSS to get records and evidence when investigating complaints.
  • Clearer rules on who can use titles like “doctor” in a health care setting.

• Unlicensed health and wellness providers

  • Higher risk of fines and court orders if activities are judged to be “practising medicine” or if protected titles are used in a way that implies being a medical professional.
  • The government may set exemptions by regulation for certain activities, but until set, the default rules are stricter.
  • A single act of unauthorized practice can be enough to be charged.

• Licensed physicians, physician assistants, and podiatric surgeons

  • No change to normal practice if properly licensed.
  • CPSS has stronger tools to act against unlicensed competitors misusing protected titles or performing restricted activities.

• Clinics and corporations

  • Higher fines if a corporation enables unlicensed practice or misuse of titles.
  • Corporate officers and directors can be personally liable if they direct or allow offences.

• People using the title “doctor” in other fields (e.g., PhD holders)

  • Using “doctor” as a job title connected to treating human ailments may trigger penalties unless clearly not implying medical practice.
  • Future regulations may clarify safe uses, but care is needed in health-related advertising and services.

• Other regulated health colleges (under the RHPA)

  • Similar powers to seek interim injunctions, compel information, prosecute offences, and apply increased fines.

Expenses#

Estimated near-term cost: small; government may shift existing funds to support investigations.

• The bill lets the government contribute money to CPSS for investigations and court actions.
• Explanatory notes state a proposal to repurpose about $100,000 from existing regulator funding to expand CPSS’s investigative and prosecution capacity.
• No new taxes or fees are set in the bill. Any government support can include conditions and may vary over time.

Proponents' View#

• Protects patients by stopping unlicensed or unsafe providers faster, before more harm occurs.
• Stronger fines and court orders deter people from pretending to be medical professionals.
• Aligns Saskatchewan rules with similar tools in the Regulated Health Professions Act.
• A two-year window from discovery gives investigators time to build solid cases.
• Clear authority for CPSS to prosecute helps ensure consistent enforcement without waiting on others.
• Flexibility to set exemptions by regulation helps avoid overreach into low‑risk activities.

Opponents' View#

• Power to search, seize records, or compel answers—even without advance notice—may raise privacy and due‑process concerns.
• Broad definitions and strong penalties could chill legitimate wellness services or non‑medical uses of the title “doctor.”
• Allowing colleges to prosecute may raise concerns about fairness or conflicts of interest.
• Uncertainty until regulations are issued on what exactly counts as “practising medicine” or what is exempt.
• Higher fines and daily “continuing offence” rules could be harsh for small businesses that make mistakes in advertising or titles.