THE FOLLOWING INFORMATION WAS OBTAINED FROM THE FIND A DOCTOR SECTION OF THE WEBSITE OF THE COLLEGE OF PHYSICIANS AND SURGEONS OF ONTARIO WWW.CPSO.ON.CA

Date: 23/02/2018 11:19:25 PM

Proulx, Christian Andrew (CPSO#: 79807)

Current Status: Revoked: Discipline Committee as of 06 Feb 2018

CPSO Registration Class: None as of 06 Feb 2018

Indicates a concern or additional information

Summary

Former Name: No Former Name

Gender: Male

Languages Spoken: English

Education:Queen's University, 2001

Practice Information

Primary Location of Practice
Practice Address Not Available

Registration History

Action Issue Date
First certificate of registration issued: Independent Practice Certificate Effective: 27 Jun 2003
Transfer of class of certificate to: Restricted certificate Effective: 04 Jul 2016
Expired: Resigned from membership. Expiry: 29 Jul 2016
Revoked: Discipline Committee. Effective: 06 Feb 2018

Previous Hearings

Committee: Discipline
Decision Date: 06 Feb 2018
Summary:

On February 6, 2018, the Discipline Committee found that Dr. Christian Andrew Proulx 
committed an act of professional misconduct, in that he has failed to maintain the standard of 
practice of the profession, and in that he has engaged in conduct or an act or omission relevant to 
the practice of medicine that, having regard to all of the circumstances, would reasonably be 
regarded by members as unprofessional. The Committee also found that Dr. Proulx is 
incompetent. 
 
Dr. Christian Proulx received his certificate of independent practice from the College of 
Physicians and Surgeons of Ontario in 2003, and his specialist qualification in family medicine 
in 2006. Before July 2016, Dr. Proulx practised medicine in St. Catharines, Ontario. 
 
Ms A 
 
Between August 2013 and January 2016, Dr. Proulx prescribed controlled drugs to Ms A, who 
was his neighbour. Despite beginning to prescribe to her in 2013, Dr. Proulx saw Ms A in a 
clinical setting only on two occasions, once at the beginning of 2015 and again at the beginning 
of 2016, and billed OHIP for his care and treatment of Ms A only on those two occasions. 
 
In the beginning of 2016, the College received two reports raising concerns about Dr. Proulx’s 
prescribing to Ms A. The first report was from a physician who had treated Ms A in the hospital 
emergency department after she took an impulsive overdose of medication with the intent to end 
her life. The physician reported that although Ms A’s Ontario Drug Benefit profile indicated that 
Dr. Proulx had been repeatedly prescribing 200 tabs of medication to Ms A every 16 days, she 
denied taking the medication. The second report was made by Ms A’s relative, who advised the 
College that she was concerned that Dr. Proulx was prescribing 200 tabs of medication to Ms A 
every two weeks and taking half the medication back from her. 
 
In his initial response to the College, Dr. Proulx stated that: 
 
-  he knew Ms A as his neighbour and that one day, when Ms A asked him to be her family 
   doctor, he advised her to come and see him in his family clinic. Ms A explained that she had 
   difficulty with transportation, experienced pain with her ambulation, and that she needed 
   medication as she felt that her pain was largely responsible for her depression;  
-  when he reiterated that Ms A that she should come to his medical office so he could record 
   her history and symptoms, initiate a proper patient chart and set out her treatment plan, she 
   insisted that she was unable to come to his office and begged him to provide her with a 
   prescription; 
-  against his better judgment, Dr. Proulx wrote her a prescription for medication accompanied 
   by a discussion about how to take medication and potential effects;  
-  Ms A returned to his door two weeks later reporting that she felt a lot better and asked to 
   renew her prescription which he did, but insisted that she come to his office for future care; 
-  Ms A attended at his office in February 2015, at which time she indicated that her problem 
   was depression/anxiety and Dr. Proulx tried her on a short course of the mood stabilizer as 
   he felt she had difficult-to-treat depression, query bipolar disorder;  
-  in November 2015 Dr. Proulx referred her for a psychiatric support;  
-  in January 2016, when the reports came to him as her family physician from a couple of 
   hospital attendances, he spoke with Ms A and she agreed to taper off the medication, which 
   he understood she did successfully. He hasn’t seen her since and understood that her 
   psychiatrists have been filling her medications for her; and 
-  Dr. Proulx admitted that he failed to follow a number of College policies regarding medical 
   record-keeping, boundaries and prescription, and in particular, not seeing Ms A in his office. 
   He expressed regret for prescribing medications to Ms A outside of his office and indicated 
   that he takes ownership of his conduct as inappropriate and unprofessional.  
    
When the College requested additional information from Dr. Proulx, including the circumstances 
which led him to prescribing to Ms A prior to having seen her in his clinic in 2015, he refused to 
respond to the request.  
    
Dr. Proulx’s account of events was untruthful and incomplete. In fact, the following occurred:  
 
 - Ms A initially approached Dr. Proulx about obtaining narcotics as a joke, including because 
   she didn’t have any money, and/or by asking Dr. Proulx if he could prescribe her 
   “something fun”; 
 - Dr. Proulx agreed to prescribe narcotics to Ms A and devised the specifics of their 
   arrangement; 
 - Dr. Proulx prescribed narcotics to Ms A about 200 pills at a time, approximately every 16 
   days, and sometimes more frequently than that. Of the 200 pills Ms A obtained each time, 
   Dr. Proulx would take the first 100 pills, and purchase most or all of the remaining 100 pills 
   from Ms A for between $2.50 and $3.50 per pill. He would typically pay her $3.00 per pill.  
   Sometimes Ms A would keep approximately 20 pills for her own use. All payments by Dr. 
   Proulx to Ms A for the pills were made in cash; 
 - The transactions were arranged through text messaging. Often, Dr. Proulx would pick Ms A 
   up in his car, drive her to the pharmacy, and write her a prescription in the pharmacy parking 
   lot. Ms A would go into the pharmacy and fill the prescription, paying for it either through 
   her Ontario Drug Benefit coverage, or with cash provided to her by Dr. Proulx; 
 - Dr. Proulx falsely told Ms A he needed the pills to treat his lymphoma, and that his own 
   doctor wouldn’t prescribe them to him. Dr. Proulx does not have lymphoma; 
 - There were occasions on which Ms A went to the pharmacy without Dr. Proulx after having 
   collected the prescription from Dr. Proulx’s mailbox, and then met Dr. Proulx for the 
   exchange; 
 - Dr. Proulx had a similar arrangement with respect to prescribing and buying narcotics with 
   Ms A’s then-boyfriend, Mr. X, whom Ms A introduced to Dr. Proulx. Sometimes the three 
   of them would drive to the pharmacy together. Ms A continued to receive prescriptions from 
   Dr. Proulx after she terminated her relationship with Mr. X; 
 - Dr. Proulx advised Ms A that their arrangement was a secret, that it was illegal, and that if 
   the College ever discovered it, he would be in a lot of trouble and that Ms A would probably 
   face criminal charges; and 
 - After the College notified Dr. Proulx of its investigation into his prescribing to Ms A, Dr. 
   Proulx contacted her and told her that he was being investigated, that they would both be in 
   trouble and/or go to jail, and that she specifically would be in trouble.  He told her not to 
   speak to the College investigators. 
 
 
 
 
Expert evidence 
     
An expert retained by the College during its investigation had significant concerns with Dr. 
Proulx’s prescriptions for opioids and benzodiazepines. She opined that Dr. Proulx fell below the 
standard of practice of the profession, that his care displayed a lack of knowledge, skill, or 
judgment, and that clinical practice, behaviour or conduct was likely to expose his patients to 
harm or injury: 
 
 - Most patients were prescribed opioids without a full assessment of their pain and often when 
   they were quite new to Dr. Proulx’s practice. In many cases, Dr. Proulx initiated opioids 
   after only a few visits when he had not performed a full history or physical examination 
   regarding the pain or tried other non-opioid medications; 
 - In most cases, Dr. Proulx made no determination regarding patients’ potential for addiction 
   or documented discussion regarding functional status, adverse effects, and risks of opioids 
   before prescribing opioids to them; 
 - In many cases, the opioids were prescribed when Dr. Proulx did not have any results of 
   investigations regarding patients’ pain. The actual indication for the opioids was not clear 
   for several of the patients. In some cases, opioid prescriptions were initiated for one 
   diagnosis, then apparently continued for another diagnosis; 
 - Dr. Proulx typically prescribed very large quantities of opioids, writing prescriptions for 
   200-300 tablets of short-acting opioids or benzodiazepines or 3-month supplies of chronic 
   opioids, with no documented use of “part-fill” prescriptions which can reduce opioid 
   misuse; 
 - Many of the patients were prescribed relatively high doses of opioids. In the majority of 
   charts reviewed in which Dr. Proulx prescribed chronic opioids, most patients were 
   prescribed a Morphine Equivalent Dose (“MEQ”) greater than 200 mg/day. There was no 
   evidence that Dr. Proulx monitored these patients any more carefully. There was minimal 
   documentation regarding the nature, location or severity of their pain, or their functional 
   status and minimal screening for potential opioid misuse; 
 - There were further concerns regarding documentation surrounding the opioid prescriptions. 
   Most charts did not include any documentation that patients were advised of the potential 
   adverse effects. There was no documented assessment of the patients’ individual risk for 
   addiction, and no documentation as to whether the patient had any past history of addiction 
   prior to prescribing the opioids. There was no use of a formalized addiction risk screening 
   tool or narcotic treatment agreement, and urine drug screens were performed extremely 
   rarely. Only three patients had documented urine drug screens.  One urine drug screen 
   yielded an abnormal result, but was not repeated. Several of the patients demonstrated 
   features of inappropriate opioid such as lost medications, early prescription renewals, and 
   requests to escalate the dosage. In the majority of the aspects of care where opioids were 
   prescribed, Dr. Proulx did not demonstrate enough diligence in his documentation and 
   monitoring to determine that they were being used safely; and 
 - For several patients, the records appeared to indicate that the patients were obtaining 
   excessively large quantities of opioids from Dr. Proulx that were not documented anywhere 
   in their chart notes. There were prescriptions for several thousands of tablets of opioids 
   without any documentation or patient encounters associated with these prescriptions. For 
   two patients to whom he had prescribed opioids, including Ms A’s ex-boyfriend, Dr. Proulx 
   had no patient chart whatsoever. 
     
Regarding Ms A’s care, the expert opined that: 
 
-  Dr. Proulx did not meet the standard of practice of the profession in his care of Ms A, in 
   that: 
   - Dr. Proulx provided medical care to Ms A outside of an office setting, without adequate 
     documentation, which falls well below the standard of care with respect to record-
     keeping. Any prescription requires documentation of an assessment, diagnosis, and the 
     name and quantity of the medication prescribed. Prescriptions for controlled substances, 
     such as opioids and benzodiazepines, require an even higher level of caution, including 
     knowledge of the patient’s clinical status, diagnosis, assessment of risk of misuse, and 
     documentation of informed consent. Dr. Proulx did not document any history regarding 
     the cause of Ms A’s pain, any previous investigations, other medications she had taken 
     for the pain, past history of substance abuse, functional status, and he did not document a 
     physical examination prior to prescribing opioids. He also did not document the 
     quantities or dosages of opioids and benzodiazepines that he was prescribing on an 
     ongoing basis for her; 
   - Dr. Proulx’s care also failed to meet the standard of practice of the profession in terms of 
     the requirements for prescribing. Before prescribing a drug, physicians must have current 
     knowledge of the patient’s clinical status. This can only be accomplished through an 
     appropriate clinical assessment of the patient. Dr. Proulx did not appear to have 
     performed a thorough clinical assessment of Ms A prior to prescribing the medications 
     she had requested. He also did not document that he was prescribing Oxycocet and 
     clonazepam regularly to this patient. 
-  Dr. Proulx’s care displayed a severe and ongoing lack of judgment evidenced by his 
   prescriptions of large quantities of a controlled substance to an acquaintance who he had not 
   adequately assessed regarding the indication or safety of the opioids and benzodiazepines.  
   This was not a single lapse in judgment; and 
-  Dr. Proulx’s conduct in this case was likely to expose Ms A to harm or injury, since she was 
   at high risk for opioid misuse or overdose, given her past history of overdose and her current 
   substance use. Ms A had in fact taken an overdose, and Dr. Proulx was not monitoring to 
   ensure that Ms A was using the opioids he prescribed to her safely. Furthermore, the lack of 
   oxycodone on her urine drug screen at the time of the overdose raised questions for the 
   expert as to whether it was being diverted. 
 
Dr. Proulx’s Undertaking and Resignation  
 
On July 4, 2016, during the College’s investigations, Dr. Proulx resigned his prescribing 
privileges with respect to narcotic drugs, narcotic preparations, controlled drugs, 
benzodiazepines and other targeted substances, and all other monitored drugs, and he undertook 
not issue new prescriptions or renew existing prescriptions for any of those substances.   
 
On July 11, 2016, Dr. Proulx resigned his membership in the College. 
 
On February 21, 2017, in a submission to the Inquiries, Complaints and Reports Committee in 
respect of its investigations, Dr. Proulx emphasized that he had permanently resigned his 
membership in the College, and that he has no intention of ever practicing medicine in Ontario, 
or any other jurisdiction. Dr. Proulx advised that after resigning his membership, he began 
 receiving intensive outpatient addiction treatment for active alcohol and substance abuse. He 
 advised that his program of recovery is ongoing. 
  
 Disposition 
  
 On February 6, 2018, the Committee ordered and directed that: 
  
-  The Registrar revoke Dr. Proulx’s certificate of registration, effective immediately. 
-  Dr. Proulx appear before the panel to be reprimanded. 
-  Dr. Proulx pay to the College its costs of this proceeding in the amount of $5,500.00 within 
   thirty (30) days from the date of this Order.

Hearing Date(s): February 6, 2018