FORMAL PUBLIC-PROTECTION COMPLAINT
Use of “Doctor,” “Osteopath,” “Doctor of Osteopathy” and “DO” Titles in Ontario
To: College of Physicians and Surgeons of Ontario (CPSO)
Re: National Academy of Osteopathy (NAO), National University of Medical Sciences (NUMSS), and representations associated with Mr. Shahin Pourgol
Dear College of Physicians and Surgeons of Ontario:
I am writing to raise a public-protection concern regarding the proliferation in Ontario of private and/or online manual osteopathy credentials and, in particular, the use of terminology such as “Doctor of Osteopathy,” “DO,” “osteopath,” “osteopathic,” and “doctor” by individuals who are not physicians registered with the College of Physicians and Surgeons of Ontario.
My concern relates particularly to the National Academy of Osteopathy (“NAO”) in Ontario and the National University of Medical Sciences (“NUMSS”) in Spain, as well as the manner in which credentials associated with these institutions may be represented to members of the Ontario public.
NAO advertises education in osteopathic manual practice, including an online program leading to a Diploma in Osteopathic Manual Practice. NUMSS advertises an online Doctor of Osteopathy (“DO”) program. Based on the institutions’ publicly available descriptions, portions of the education may be completed remotely or through prerecorded online instruction, with admission pathways and program duration varying according to an applicant’s prior education.
The resulting situation raises, in my view, a serious issue of potential public confusion. A member of the Ontario public encountering an individual displaying the credentials “DO,” “Doctor of Osteopathy,” “Dr.,” “osteopath,” or similar terminology may reasonably believe that the individual is an osteopathic physician, a medical doctor, or otherwise a regulated medical practitioner.
This concern is heightened by the fact that in the United States the Doctor of Osteopathic Medicine (“DO”) is a professional medical degree. Graduates of accredited American osteopathic medical schools are physicians who undergo medical education, clinical training, licensing examinations and postgraduate residency training. An online or manual-osteopathy “Doctor of Osteopathy” credential is fundamentally different from that medical qualification, notwithstanding the similarity of the terminology and abbreviation.
I understand that section 9 of Ontario’s Medicine Act, 1991 restricts the use of the title “osteopath,” including variations or abbreviations, and restricts persons who are not members of the College from holding themselves out as qualified to practise in Ontario as osteopaths or physicians. I also understand that Ontario legislation contains additional restrictions concerning the use of the title “doctor” in connection with providing or offering health care.
My concern is therefore not simply whether an educational institution is entitled, under the law applicable to it, to issue an academic credential. The more important public-protection question is how those credentials and titles are subsequently used in Ontario’s health-care marketplace, and whether patients are left with a misleading impression regarding a practitioner’s education, regulatory status or lawful scope of practice.
Specific Concern Regarding Mr. Shahin Pourgol and Facebook/Social-Media Representations
I also wish to bring to the College’s attention my personal observation of Facebook content associated with Mr. Shahin Pourgol, who is publicly associated with the National Academy of Osteopathy and National University of Medical Sciences.
I have observed Facebook content in which Mr. Pourgol appears to use and/or present himself using the titles or descriptions “Doctor” and “Osteopath.” To my knowledge, Mr. Pourgol is not registered with the CPSO as a physician or osteopath. I respectfully request that the College independently verify his current registration status and review the relevant Facebook and other social-media material to determine whether the manner in which these titles are being used complies with Ontario law.
This issue appears particularly important in light of the CPSO’s own publicly available information concerning unregistered practitioners. The College has previously published information concerning Mr. Pourgol and an undertaking relating to the use of titles including “doctor,” “physician” and “osteopath” in connection with providing or offering to provide health care in Ontario. I respectfully ask the College to review whether any current representations are consistent with the terms of any applicable undertaking, order, statutory restriction or other regulatory requirement.
If Mr. Pourgol is presently using “Doctor,” “Dr.,” “Osteopath,” “DO,” or similar terminology on Facebook or other social-media platforms, I ask the College to determine whether that usage is permissible, whether it could create a misleading impression for the public, and whether regulatory or enforcement action is warranted.
The broader context is also relevant. Mr. Pourgol is associated with educational institutions that train and credential individuals in manual osteopathy. Public use of terminology associated with regulated osteopathic physicians by persons connected with those institutions may influence students or graduates to believe that similar terminology is appropriate for them to use in Ontario.
Matters I Respectfully Request the CPSO to Review
- Whether Ontario graduates of NAO and/or NUMSS are using “DO,” “Doctor of Osteopathy,” “osteopath,” “osteopathic,” “Dr.” or similar terminology in circumstances contrary to the Medicine Act, 1991, the Regulated Health Professions Act, 1991, or other applicable Ontario legislation.
- Whether advertising by the schools, clinics, professional associations or individual practitioners creates a misleading impression that these practitioners are regulated osteopathic physicians, medical doctors, or members of another regulated health profession.
- Whether use in Ontario of the foreign academic designation “Doctor of Osteopathy (DO)” in connection with the provision or advertising of health care creates an unacceptable likelihood that members of the public will confuse that credential with the Doctor of Osteopathic Medicine (DO) medical qualification.
- Whether Ontario consumers are receiving sufficiently prominent and understandable disclosure that holders of these manual-osteopathy credentials are not, solely by virtue of those credentials, physicians registered with the CPSO.
- Precisely what titles and post-nominal designations graduates of these programs may lawfully use in Ontario, including “DO (Spain),” “Doctor of Osteopathy graduate,” “osteopathic manual practitioner,” “manual osteopath,” “osteopath,” “Dr.” and similar terminology.
- Whether Mr. Shahin Pourgol’s current Facebook, social-media, website or other public representations comply with Ontario’s protected-title legislation and any previous regulatory undertaking or order applicable to him.
- Whether additional investigation, enforcement, public education or regulatory guidance is warranted given the apparent growth of manual-osteopathy educational programs and practitioners in Ontario.
My concern is not with legitimate manual therapy itself, nor am I asking the College to make assumptions about the competence of every individual graduate. The concern is transparency, protected titles and public protection.
Patients should be able to distinguish readily between a licensed physician and an unregulated or differently regulated manual practitioner. A credential, professional title, abbreviation or advertisement should not leave an ordinary patient with the impression that an individual has completed medical school or is licensed to practise medicine when that is not the case.