Krieger, Howard Marvin (CPSO#: 25085)

Current Status: Active Member as of 22 Aug 1972

CPSO Registration Class: Restricted as of 09 Aug 2017

Indicates a concern or additional information

Summary

Former Name: No Former Name

Gender: Male

Languages Spoken: English

Education:University of Toronto, 1971

Practice Information

Primary Location of Practice
Suite 200
11 Ferris Lane
Barrie ON  L4M 5N6
Phone: (705) 739-8667
Fax: (705) 739-9341
Electoral District: 05

Hospital Privileges

Hospital Location
Royal Victoria Regional Health Centre Barrie

Registration History

Action Issue Date
First certificate of registration issued: Postgraduate Education Certificate Effective: 14 Jun 1971
Transfer of class of registration to: Independent Practice Certificate Effective: 22 Aug 1972
Transfer of class of certificate to: Restricted certificate Effective: 09 Aug 2017
Terms and conditions imposed on certificate by member Effective: 09 Aug 2017
Terms and conditions amended by member Effective: 11 Sep 2017
Terms and conditions amended by member Effective: 12 Sep 2017

Practice Restrictions

Imposed By Effective Date Expiry Date Status  
member Effective: 12 Sep 2017 Active View Details [+]
            As  from  August  9,  2017,  the  following is imposed as a term, condition and
            limitation  on  the  certificate of registration  held  by  Dr.  Howard  Marvin
            Krieger, in accordance  with an undertaking and consent given by Dr. Krieger to
            the College of Physicians and Surgeons of Ontario:


                        UNDERTAKING, ACKNOWLEDGEMENT AND CONSENT 
                                          ("Undertaking")
                  
                                                of
                  
                              DR. HOWARD MARVIN KRIEGER
                                          ("Dr. Krieger")
                  
                                                to 
                  
                        COLLEGE OF PHYSICIANS AND SURGEONS OF ONTARIO
                                          (the "College")
                  
                  
                  
            A.    PREAMBLE

            (1)   In this Undertaking:

                  "Code" means the Health  Professions Procedural Code, which is Schedule 2
                  to the Regulated Health Professions  Act,  1991,  S.O.  1991,  c.  18, as
                  amended; 
                  
                  "ICR Committee" means the Inquiries, Complaints and Reports Committee  of
                  the College.
                  
                  "Narcotic  Drugs"  means from the Narcotic Control Regulations made under
                  the Controlled Drugs and Substances Act, S.C., 1996, c. 19, as amended.
                  
                  "Narcotic Preparations"  means from the Narcotic Control Regulations made
                  under the Controlled Drugs  and  Substances  Act,  S.C.,  1996, c. 19, as
                  amended.
                  
                  "Controlled  Drugs"  means  from  Part G of the Food and Drug Regulations
                  under the Food and Drugs Act, S.C., 1985, c. F-27, as amended.
                  
                  "Benzodiazepines  and  Other  Targeted   Substances"   means   from   the
                  Benzodiazepines  and Other Targeted Substances Regulations made under the
                  Controlled Drugs and Substances Act., S.C., 1996, c. 19, as amended 
                        (A summary of  the  above-named  drugs  [from  Appendix  I  to  the
                        Compendium  of  Pharmaceuticals and Specialties] is attached hereto
                        as Schedule "A";  and  the  current  regulatory  lists are attached
                        hereto as Schedule "B")
                  
                  "All  other Monitored Drugs" means as defined under the Narcotics  Safety
                  and Awareness  Act,  2010,  S.O.  2010,  c.  22,  as amended, as noted in
                  Schedule "C".                                          
                  
                  "NMS"  means  the Drug Program Services Branch, the Narcotics  Monitoring
                  System implemented  under  the  Narcotics Safety and Awareness Act, 2010,
                  S.O. 2010, c. 22, as amended;
                  
                  "OHIP" means the Ontario Health Insurance Plan;
                  
                  "Public Register" means the College's  register  that is available to the
                  public.
                  
            (2)   I, Dr. Krieger, certificate of registration number  25085, am a member of
                  the College.  

            (3)   I,  Dr.  Krieger,  acknowledge  that,  further  to  an assessment  of  my
                  practice, detailed in assessment reports dated October 10, 2016 and April
                  27, 2017, concerns have been identified with respect  to  my  standard of
                  practice, including my narcotics prescribing and medical record keeping. 

            (4)   I,  Dr.  Krieger,  acknowledge  that  this undertaking does not apply  to
                  prescriptions of testosterone in my transgender  medicine  practice  (the
                  "Testosterone Prescriptions"). 

            B.    UNDERTAKING

            (5)   I, Dr. Krieger, undertake to abide by the provisions of this Undertaking,
                  effective immediately.

            (6)   I, Dr. Krieger, shall keep a log of all prescriptions for Narcotic Drugs,
                  Narcotic   Preparations,  Controlled  Drugs,  Benzodiazepines  and  Other
                  Targeted Substances  and  All other Monitored Drugs, in the form attached
                  as set out in Schedule "D",  excluding  the  Testosterone  Prescriptions,
                  which  will  include at least the following information (the "Prescribing
                  Log"):  

                  (i)   the date of the appointment;
                  (ii)  the name of the patient and chart/file number;
                  (iii) the name  of  the medication prescribed, dose, direction, number of
                        tablets to be dispensed and frequency;
                  (iv)  the clinical indication;
                  (v)   whether the prescription  is  for a new medication and/or different
                        dose or frequency than currently prescribed to the patient (Y/N); 
                  (vi)  Dr. Krieger's signature;
                  (vii) the date of the Clinical Supervisor's review (if applicable, as set
                        out below); and
                  (viii)the Clinical Supervisor's signature  (if  applicable,  as  set  out
                        below).
                  
            (7)   I, Dr. Krieger, undertake to keep a copy of all prescriptions I write for
                  Narcotic  Drugs, Narcotic Preparations, Controlled Drugs, Benzodiazepines
                  and Other Targeted  Substances  and  All other Monitored Drugs, excluding
                  the Testosterone Prescriptions, in the corresponding patient chart.

            (8)   Clinical Supervision

                  (a)   I,  Dr. Krieger, undertake to practise  under  the  guidance  of  a
                        clinical  supervisor(s)  acceptable  to  the College (the "Clinical
                        Supervisor(s)"), for six (6) months on the terms set out below (the
                        "Clinical Supervision").
                  
                  (b)   I, Dr. Krieger, acknowledge and undertake  that Phase 1 of Clinical
                        Supervision set out below will only be reduced  upon recommendation
                        of the Clinical Supervisor(s) and approval by the College.
                  
            Phase 1 of Clinical Supervision ("Phase 1")

                  (c)   I,  Dr.  Krieger,  undertake  to  engage  in  Phase  1 of  Clinical
                        Supervision  for a minimum of four (4) weeks on the terms  set  out
                        below.
                  
                  (d)   During Phase 1,  I,  Dr.  Krieger,  undertake  to  review  with  my
                        Clinical  Supervisor(s)  every patient to whom I am prescribing any
                        narcotic   drugs,   narcotic   preparations,    controlled   drugs,
                        benzodiazepines  and  other targeted substances, and/or  all  other
                        monitored  drugs,  excluding  the  Testosterone  Prescriptions,  to
                        ensure that assessment,  clinical  examination, risk assessment for
                        addiction and on-going management and follow up is appropriate.
                  
                  (e)   During  Phase  1,  I,  Dr. Krieger, undertake  to  ensure  that  my
                        Clinical Supervisor(s) confirms  his  or  her  review of my patient
                        care with me as described in section (8)(d) above  by  signing  the
                        Prescribing Log and the patient chart in question.
                  
                  (f)   I,  Dr.  Krieger,  acknowledge  that  during  Phase 1, the Clinical
                        Supervisor(s) will provide a report to the College  at  least  once
                        every month.
                  
                  (g)   I,  Dr. Krieger, acknowledge that after a minimum of four (4) weeks
                        of Phase  1, if the Clinical Supervisor(s) is satisfied that I have
                        the necessary  knowledge, skills and judgment to practice in a less
                        highly  supervised  environment,  the  Clinical  Supervisor(s)  may
                        recommend to the College that supervision be reduced. 
                  
            Phase 2 of Clinical Supervision ("Phase 2")

                  (h)   Upon the  recommendation of the Clinical Supervisor(s) and approval
                        by the College,  I,  Dr. Krieger, undertake to engage in Phase 2 of
                        Clinical  Supervision  for   the   remaining   period  of  Clinical
                        Supervision on the terms set out below.
                  
                  (i)   During Phase 2, I, Dr. Krieger, undertake to meet  with my Clinical
                        Supervisor(s)  at  least  once every month to discuss the  Clinical
                        Supervisor(s)'s review of:
                        i.    15 charts for patients  to  whom  I  have prescribed narcotic
                              drugs,     narcotic    preparations,    controlled     drugs,
                              benzodiazepines  and other targeted substances, and all other
                              monitored  drugs since  the  Clinical  Supervisor(s)'s  prior
                              review, or if  there  are  not  15  patients  listed  in  the
                              Prescribing  Log  since  the  Clinical  Supervisor(s)'s prior
                              review,  then  the  charts  of  all  patients listed  in  the
                              Prescribing Log since the Clinical Supervisor's prior review,
                              excluding the Testosterone Prescriptions.
                  
                  (j)   I,  Dr.  Krieger,  acknowledge that during Phase  2,  the  Clinical
                        Supervisor(s) will provide  a  report  to the College at least once
                        every month.
                  
                  (k)   I,  Dr.  Krieger,  acknowledge that I have  reviewed  the  Clinical
                        Supervisor(s)'s undertaking,  attached  hereto as Schedule "E", and
                        understand  what  is  required of the Clinical  Supervisor(s).   In
                        addition to what is set out above, the Clinical Supervisor(s) will,
                        at a minimum:
                  
                        (i)   Discuss any concerns  with  me arising from chart reviews and
                              observations;
                  
                        (ii)  Make  recommendations  to me for  practice  improvements  and
                              ongoing  professional  development   and   inquire   into  my
                              compliance with the recommendations; and
                  
                        (iii) Perform  any  other duties, such as reviewing other documents
                              or conducting interviews  with  staff or colleagues, that the
                              Clinical  Supervisor(s)  deem  necessary   to   my   Clinical
                              Supervision.
                  
                  (l)   I,  Dr.  Krieger,  undertake  that  all  meetings  with my Clinical
                        Supervisor(s) will take place at my Practice Location,  or  another
                        location approved by the College;
                  
                  (m)   I,  Dr.  Krieger,  acknowledge  that  all  charts reviewed shall be
                        independently selected by the Clinical Supervisor(s)  based  on the
                        areas of concern identified in the assessment reports dated October
                        10, 2016 and April 27, 2017, and concerns that may arise during the
                        period of Clinical Supervision.
                  
                  (n)   I,  Dr.  Krieger,  undertake  to  cooperate fully with the Clinical
                        Supervision  of my practice, conducted  under  the  terms  of  this
                        Undertaking  and  Schedule  "E"  attached,  and  to  abide  by  the
                        recommendations  of  my  Clinical  Supervisor(s), including but not
                        limited  to,  any  recommended practice  improvements  and  ongoing
                        professional development.
                  
                  (o)   I, Dr. Krieger, undertake  to  ensure  that  Schedule  "E"  to this
                        Undertaking,  is  signed and delivered to the College within thirty
                        (30) days of the date I sign this Undertaking.
                  
                  (p)   I, Dr. Krieger, undertake  that  if  a  person  who  has  given  an
                        undertaking  in  Schedule  "E"  to  this  Undertaking  is unable or
                        unwilling  to  continue to fulfill its provisions, I shall,  within
                        fourteen (14) days  of receiving notice of same, obtain an executed
                        undertaking in the same  form from a similarly qualified person who
                        is acceptable to the College and ensure that it is delivered to the
                        College within that time.
                  
                  (q)   I, Dr. Krieger, agree that  if  I  am  unable  to obtain a Clinical
                        Supervisor  on  the  terms  set out in sections (8)(o)  and/or  (p)
                        above,   I  will  cease  prescribing   narcotic   drugs,   narcotic
                        preparations,  controlled drugs, benzodiazepines and other targeted
                        substances, and all other monitored drugs until such time as I have
                        obtained a Clinical Supervisor acceptable to the College.  
                  
                  (r)   I, Dr. Krieger,  agree  that  if I am required to cease prescribing
                        narcotic   drugs,   narcotic   preparations,    controlled   drugs,
                        benzodiazepines  and  other  targeted  substances,  and  all  other
                        monitored  drugs  as  a  result  of section (8)(q) above this  will
                        constitute a term, condition or limitation  on  my  certificate  of
                        registration  and  that  term,  condition  or  limitation  will  be
                        included on the Public Register.
                  
            (9)   Professional Education  

                  (a)   I,  Dr.  Krieger,  undertake  to  participate  in  and successfully
                        complete  all  of the following elements of professional  education
                        (the "Professional Education"):
                  
                        (i)   Review of  the  Canadian Guideline for the Safe and Effective
                              Use of Opioids for Chronic Non-Cancer Pain:
                              http://nationalpaincentre.mcmaster.ca/opioid;
                  
                        (ii)  University of Toronto  Faculty of Medicine program in Medical
                              Record Keeping: http://www.cpd.utoronto.ca/recordkeeping;
                  
                        (iii) any  additional  professional  education  recommended  by  my
                              Clinical Supervisor(s).
                  
                  (b)   I, Dr. Krieger, undertake  to  provide  proof  to the College of my
                        successful completion of each element of the Professional Education
                        specified  above, including proof of registration,  attendance  and
                        participant  assessment  reports  where  available,  within one (1)
                        month of completion of each element. I acknowledge that the College
                        will determine, in its sole discretion, whether I have successfully
                        completed each element of the Professional Education.
                  
                  (c)   I,  Dr.  Krieger,  acknowledge  that  a  report  or reports may  be
                        provided to the College regarding my progress and  compliance  with
                        the Professional Education.
                  
            (10)  Reassessment of Practice

                  (a)   I, Dr. Krieger, undertake that, approximately six (6) months  after
                        the   Clinical  Supervision  set  out  under  section  (8)  of  the
                        Undertaking  has  ceased,  I  will  submit  to a reassessment of my
                        practice by an assessor or assessors selected  by  the College (the
                        "Reassessment").

                  (b)   I,  Dr.  Krieger,  acknowledge and agree that the Reassessment  may
                        include a chart review,  direct  observation of my care, interviews
                        with  colleagues and co-workers, feedback  from  patients  and  any
                        other tools deemed necessary by the College.
                  
                  (c)   I,  Dr.   Krieger,   undertake   to   co-operate   fully  with  the
                        Reassessment, conducted under the terms of this Undertaking 
                  
                  (d)   I,   Dr.   Krieger,   acknowledge   and   agree  that  my  Clinical
                        Supervisor(s)   may  receive  and  review  the  findings   of   the
                        Assessor(s), and  may  discuss  with  the Assessor(s) any issues or
                        concerns arising from the Reassessment.
                  
                  (e)   I, Dr. Krieger, acknowledge that the results  of  the  Reassessment
                        will  be  provided  to me and reported to the College and that  the
                        Reassessment may form the basis of further action by the College.
                  
            (11)  Monitoring 

                  (a)   I, Dr. Krieger, undertake  to  inform the College of each and every
                        location that I practise or have  privileges,  including,  but  not
                        limited   to,   hospital(s),   clinic(s)   and  office(s),  in  any
                        jurisdiction (collectively my "Practice Location(s)"),  within  ten
                        (10) business days of executing this Undertaking.  Going forward, I
                        further undertake to inform the College of any and all new Practice
                        Locations  within  ten (10) business days of commencing practice at
                        that location.
                  
                  (b)   I, Dr. Krieger, undertake  and agree that I will submit to, and not
                        interfere with, unannounced  inspections of my Practice Location(s)
                        and patient records by a College representative for the purposes of
                        monitoring my compliance with the provisions of this Undertaking.
                  
                  (c)   I, Dr. Krieger, give my irrevocable  consent to the College to make
                        appropriate enquiries of OHIP, NMS and/or any person or institution
                        who may have relevant information, in  order  for  the  College  to
                        monitor my compliance with the provisions of this Undertaking. 
                  
                  (d)   I,  Dr.  Krieger, acknowledge that I have executed the OHIP and NMS
                        consent form(s),  attached hereto as Schedule "F" and Schedule "G",
                        respectively. 
                  
            C.    ACKNOWLEDGEMENT

            (12)  I, Dr. Krieger, acknowledge that all schedules attached to or referred to
                  in this Undertaking form part of this Undertaking.

            (13)  I, Dr. Krieger, acknowledge  that  I  shall  be  solely  responsible  for
                  payment  of  all  fees,  costs,  charges, expenses, etc. arising from the
                  implementation of any of the provisions of this Undertaking. 

            (14)  I, Dr. Krieger, acknowledge and confirm  that  I have read and understand
                  the provisions of this Undertaking and that I have  obtained  independent
                  legal counsel in reviewing and executing this Undertaking, or have waived
                  my right to do so.

            (15)  I,   Dr.   Krieger,  acknowledge  that  the  College  will  provide  this
                  Undertaking   to  any  Chief  of  Staff,  or  a  colleague  with  similar
                  responsibilities, at any Practice Location ("Chief(s) of Staff").

            (16)  I, Dr. Krieger,  acknowledge that a breach by me of any provision of this
                  Undertaking may constitute  an  act  of  professional  misconduct  and/or
                  incompetence,  and  may result in a referral of specified allegations  to
                  the Discipline Committee of the College.

            (17)  I, Dr. Krieger, acknowledge  that  this  entire  Undertaking  constitutes
                  terms, conditions, and limitations on my certificate of registration  for
                  the purposes of section 23 of the Code. 

            (18)  Public Register

                  (a)   I,  Dr. Krieger, acknowledge that, during the time period that this
                        Undertaking  remains in effect, this Undertaking shall be posted on
                        the Public Register.
                  
                  (b)   I, Dr. Krieger,  acknowledge  that, in addition to this Undertaking
                        being posted in accordance with  the  section  above, the following
                        summary  shall  be  posted on the Public Register during  the  time
                        period that this Undertaking remains in effect:
                  
                              Further to an assessment  of Dr. Krieger's practice, concerns
                              have  been  identified  with  respect   to  his  standard  of
                              practice,  including  his narcotics prescribing  and  medical
                              record keeping. As a result:
                  
                                    *     Dr.  Krieger's  prescribing  of  narcotic  drugs,
                                          narcotic    preparations,    controlled    drugs,
                                          benzodiazepines  and  other  targeted substances,
                                          and other monitored drugs, but  not  testosterone
                                          prescriptions,  will be supervised by a  Clinical
                                          Supervisor acceptable  to the College for six (6)
                                          months. 
                  
                                    *     Dr. Krieger will engage in professional education
                                          in  the  prescribing  of  controlled  substances,
                                          including narcotics, and medical record keeping.
                  
                                    *     Following the professional  education  and period
                                          of  supervision,  Dr.  Krieger's  prescribing  of
                                          controlled substances, including narcotics,  will
                                          be  re-assessed  by  an  assessor selected by the
                                          College.
                  
            D.    CONSENT

            (19)  I, Dr. Krieger, give my irrevocable consent to the College to provide the
                  following information to any person who requires this information for the
                  purposes of facilitating my completion of the Professional  Education and
                  to all Clinical Supervisors, and/or Assessors:

                  (a)   any information the College has that led to the circumstances of my
                        entering into this Undertaking;
                  
                  (b)   any information arising from any investigation into, or  assessment
                        of, my practice; and 
                  
                  (c)   any  information arising from the monitoring of my compliance  with
                        this Undertaking.
                  
            (20)  I, Dr. Krieger, give my irrevocable consent to the College to provide all
                  Chief(s) of  Staff  with  any information the College has that led to the
                  circumstances of my entering into this Undertaking and/or any information
                  arising from the monitoring of my compliance with this Undertaking.

            (21)  I, Dr. Krieger, give my irrevocable consent to any person who facilitates
                  my  completion  of  the  Professional  Education,  and  to  all  Clinical
                  Supervisors, Chiefs of Staff  and  Assessors, to disclose to the College,
                  and to one another, any information:

                  (a)   relevant to this Undertaking;
                  
                  (b)   relevant to the provisions of the Clinical Supervisor's undertaking
                        set out at Schedule "E";
                  
                  (c)   relevant to the Reassessment;
                  
                  (d)   relevant for the purposes of monitoring  my  compliance  with  this
                        Undertaking; and/or  
                  
                  (e)   which  comes to his or her attention in the course of providing the
                        Professional  Education  and  which  he  or she reasonably believes
                        indicates a potential risk of harm to my patients.

Concerns

Source: Member
Active Date: August 9, 2017
Expiry Date:
Summary:
Summary of the Undertaking given by Dr. Howard Marvin Krieger to the College of Physicians and Surgeons of Ontario, effective August 9, 2017:

Further to an assessment of Dr. Krieger’s practice, concerns have been identified with respect to his standard of practice, including his narcotics prescribing and medical record keeping. As a result:

- Dr. Krieger’s prescribing of narcotic drugs, narcotic preparations, controlled drugs, benzodiazepines and other targeted substances, and other monitored drugs, but not testosterone prescriptions, will be supervised by a Clinical Supervisor acceptable to the College for six (6) months.

- Dr. Krieger will engage in professional education in the prescribing of controlled substances, including narcotics, and medical record keeping.

- Following the professional education and period of supervision, Dr. Krieger’s prescribing of controlled substances, including narcotics, will be re-assessed by an assessor selected by the College.