Upadhye, Suneel

 As from January 15, 2021, by order of the Discipline Committee of the College of Physicians and Surgeons of Ontario, the following terms, conditions and limitations are imposed on the certificate of registration held by Dr. Suneel Upadhye: 

(i)	Dr. Upadhye shall comply with the College Policy "Closing a Medical Practice". 
(ii)	Dr. Upadhye will participate in the PROBE Ethics & Boundaries Program offered by the Centre for Personalized Education for Professionals, by receiving a passing evaluation or grade, without any condition or qualification.  Dr. Upadhye will complete the PROBE program within six (6) months of the date of this Order, and will provide proof to the College of his completion, including proof of registration and attendance and participant assessment reports, within one (1) month of completing it.
(iii)	Dr. Upadhye will provide proof of satisfactory completion of the University of Toronto Medical Record-Keeping Course upon the earlier of: (a) within six (6) months of the date of this Order; and (b) within 30 days of receipt of evidence of Dr. Upadhye's completion of the Course from the University of Toronto.  
Clinical Supervision
(iv)	Prior to resuming practice following the suspension of his certificate of registration described above in paragraph 3, Dr. Upadhye shall retain, at his own expense, a College-approved clinical supervisor, who will sign an undertaking in the form attached hereto as Schedule "A" (the "Clinical Supervisor");  
(v)	For a period of six (6) months commencing on the date Dr. Upadhye resumes practice following the suspension of his certificate of registration described above in paragraph 3, Dr. Upadhye may practice only under the supervision of the Clinical Supervisor, who shall facilitate the education program set out in the Individualized Education Plan ("IEP") attached hereto as Schedule "B" ("Clinical Supervision"), and as follows.   
(vi)	Clinical Supervision of Dr. Upadhye's practice shall contain the following elements:
a)	An initial meeting with Dr. Upadhye to discuss the objectives for the Clinical Supervision;
b)	The Clinical Supervision will be six (6) months in duration and consist of monthly meetings.  At each meeting, the Clinical Supervisor will:
1.	 Review a minimum of 15 patient charts, selected in the sole discretion of the Clinical Supervisor in accordance with the education needs in the IEP attached hereto as Schedule "B", to assess quality of documentation and care; and
2.	Directly observe a minimum of three (3) of Dr. Upadhye's patient encounters with patients receiving injections for chronic pain, subject to the following: after three (3) months of Clinical Supervision, if recommended by the Clinical Supervisor and approved by the College, direct observation of patient encounters will not be required for the remaining three (3) months of Clinical Supervision. 
c)	The Clinical Supervisor shall discuss with Dr. Upadhye any concerns the Clinical Supervisor may have arising from the chart reviews and/or direct observation;
d)	The Clinical Supervisor will make recommendations to Dr. Upadhye for practice improvements and ongoing professional development, and inquire into Dr. Upadhye's compliance with the recommendations;
e)	The Clinical Supervisor will keep a log of all patient charts reviewed along with patient identifiers; and
f)	The Clinical Supervisor will provide a report to the College at the end of every two (2) months of Clinical Supervision, or more frequently if the Clinical Supervisor has concerns about Dr. Upadhye's standard of practice or conduct or that Dr. Upadhye's patients may be exposed to harm or injury.
(vii)	Dr. Upadhye shall fully cooperate with the Clinical Supervision and shall abide by the recommendations of the Clinical Supervisor.
(viii)	If a Clinical Supervisor who has given an undertaking as set out in Schedule "A" to this Order is unable or unwilling to continue to fulfill its terms, Dr. Upadhye shall, within twenty (20) days of receiving notice of same, obtain an executed undertaking in the same form from a person who is acceptable to the College and ensure that it is delivered to the College within that time.
(ix)	If Dr. Upadhye is unable to obtain a Clinical Supervisor in accordance with this Order, he shall cease to practice medicine until such time as he has done so.
(x)	If Dr. Upadhye is required to cease to practice medicine as a result of section 4(ix) above, this will constitute a term, condition or limitation on his certificate of registration and that term, condition or limitation will be included on the public register.
(xi)	Dr. Upadhye shall consent to the disclosure by his Clinical Supervisor to the College, and by the College to his Clinical Supervisor, of all information the Clinical Supervisor or the College deems necessary or desirable in order to fulfill the Clinical Supervisor's undertaking and Dr. Upadhye's compliance with this Order.
Reassessment
(xii)	Approximately three (3) months after the completion of the PROBE program, Medical Record-Keeping Course, and the period of Clinical Supervision, each as set out above, Dr. Upadhye shall, at his own expense, undergo a re-assessment by a College-appointed assessor (the "Assessor(s)").  The Reassessment shall include a review of at least 15 patient charts and direct observation of Dr. Upadhye's practice, and may also include interviews with Dr. Upadhye, his colleagues and co-workers, feedback from patients, and any other tools deemed necessary by the College.  The Assessor(s) shall submit a written report on the results of the Reassessment to the College.
(xiii)	Dr. Upadhye shall cooperate fully with the Reassessment and with the Assessor(s).  Dr. Upadhye shall consent to the disclosure to the Assessor(s) of the reports of the Clinical Supervisor arising from the supervision, and shall consent to the sharing of all information between the Clinical Supervisor, the Assessor(s) and the College, as the College deems necessary or desirable.
Monitoring
(xiv)	Dr. Upadhye shall inform the College of each and every location where he practices including but not limited to hospitals, clinics and offices, in any jurisdiction (collectively his "Practice Location(s)"), within fifteen (15) days of the date he resumes practice following the suspension of his certificate of registration described in paragraph 3 above, and shall inform the College of any new Practice Locations within fifteen (15) days of commencing practice at that location, for the purposes of monitoring his compliance with this Order;
(xv)	Dr. Upadhye shall cooperate with unannounced inspections of his practice, patient charts and Ontario Health Insurance Plan ("OHIP") claims submissions by a College representative(s) for the purpose of monitoring and enforcing his compliance with the terms of this Order.
(xvi)	Dr. Upadhye shall consent to the College making appropriate enquiries of the OHIP and/or any person or institution that may have relevant information, in order for the College to monitor and enforce his compliance with the terms of this Order.  Dr. Upadhye shall promptly sign such consents as may be necessary for the College to obtain information from these persons or institutions.
Costs of Order
(xvii)	Dr. Upadhye shall be responsible for any and all costs associated with implementing this Order.