Ontario Psychotherapist Hamouche: Registration Revoked for Boundary Violations

• The Ontario Registered Psychotherapists Discipline Tribunal revoked the registration certificate of psychotherapist Hamouche.
• The revocation stemmed from findings of professional misconduct, including boundary violations with a client and their spouse.
• Ms. Hamouche failed to engage with the disciplinary process, not responding to inquiries, appearing at hearings, or paying annual fees.
• The tribunal deemed her 'ungovernable' and ordered revocation to protect the public and maintain confidence in the College's regulatory role.
• She was also ordered to pay the College costs of $4,700.

The tribunal emphasized that revocation was necessary to safeguard the public and uphold confidence in the College's regulatory capacity.

The registration certificate of Ontario psychotherapist Hamouche has been revoked by the Ontario Registered Psychotherapists Discipline Tribunal, following findings of professional misconduct related to boundary violations with a client and their spouse. The decision, stemming from cases referenced as College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v Hamouche, 2026 ONRPDT 10 and 2026 ONRPDT 11, marks a significant disciplinary action by the regulatory body.

Ms. Hamouche, who received her certificate in the qualifying class on May 26, 2021, and had not yet met the requirements for full independent practice, faced an investigation by the Inquiries, Complaints and Reports Committee (ICRC) on June 26, 2025. This investigation concerned allegations of boundary breaches with her client and the client's spouse, alongside claims that she had falsified a college document. The boundary violation aspect of the complaint was subsequently referred to the Discipline Tribunal for adjudication.

Crucially, the tribunal proceeded with its hearing in Ms. Hamouche's absence due to her consistent failure to engage with the disciplinary process. She did not respond to the College's inquiries, failed to answer a request to admit facts, did not appear at the hearing, and neglected to attend an oral caution previously ordered by the ICRC. Furthermore, Ms. Hamouche failed to complete her annual renewal form or pay her registration fees for the 2025-26 period, contributing to the College's assertion that she was an ungovernable psychotherapist whose registration should be revoked.

The Ontario Registered Psychotherapists Discipline Tribunal ultimately directed the registrar to revoke Ms. Hamouche's registration certificate and ordered her to pay the College's costs amounting to $4,700. In reaching its decision, the tribunal relied on deemed admissions resulting from Ms. Hamouche's failure to respond to the request to admit, concluding that she engaged in professional misconduct under section 51(1)(c) of the Health Professions Procedural Code, which is Schedule 2 to Ontario’s Regulated Health Professions Act, 1991. The tribunal also found a violation of section 1 of Ontario Regulation 317/12, enacted under Ontario’s Psychotherapy Act, 2007.

The tribunal emphasized that revocation was necessary to safeguard the public and uphold confidence in the College's regulatory capacity. It considered the gravity of the registrant's misconduct, the absence of any indication that she would be a suitable candidate for remediation, and her complete lack of participation in both the investigation and the subsequent disciplinary proceedings. The panel explicitly stated that "The misconduct and the registrant’s non-participation in the disciplinary process show a pattern of conduct that demonstrates that she is not prepared to recognize her professional obligations and the regulator’s role."

This case highlights the stringent professional standards expected of regulated health professionals in Ontario, particularly concerning client boundaries and engagement with regulatory oversight. The finding of professional misconduct under the Regulated Health Professions Act, 1991, and the Psychotherapy Act, 2007, underscores the legal framework governing psychotherapists and the severe consequences for breaches of these standards.

The College's request for revocation, based on the registrant being deemed 'ungovernable,' reflects a critical aspect of professional regulation: a practitioner's willingness to acknowledge and adhere to their professional obligations and cooperate with their governing body. The tribunal's decision to proceed without Ms. Hamouche's participation, given her repeated failures to engage, demonstrates the regulatory body's authority to ensure public protection even in the face of a registrant's non-cooperation.

The revocation of Ontario psychotherapist Hamouche's registration serves as a stark reminder of the serious repercussions for professional boundary violations and a lack of engagement with disciplinary processes. This outcome reinforces the Ontario Registered Psychotherapists Discipline Tribunal's firm stance on maintaining public trust and ensuring the integrity of the profession. For regulated health professionals, this decision underscores the critical importance of adhering to ethical guidelines and actively participating in any regulatory inquiries.

This case also provides a precedent for understanding the tribunal's approach to severe misconduct and non-compliance, particularly when a registrant is deemed ungovernable. It aligns with other recent disciplinary actions by the tribunal, such as a five-month suspension issued on November 19, 2025, for a registrant involved in a dual relationship with clients, and a finding of professional misconduct on August 25, 2025, against a registrant who failed to report alleged sexual abuse by another professional. These cases collectively demonstrate the tribunal's commitment to upholding professional standards and protecting the public interest.

This decision underscores the Ontario Registered Psychotherapists Discipline Tribunal's firm stance on professional boundary violations and non-cooperation with disciplinary processes, serving as a critical precedent for lawyers advising regulated health professionals on the severe consequences of such misconduct and non-engagement with regulatory inquiries.

Source: Original reporting via Canadian Lawyer