By Dr. Bob Uttl
In our last post, we looked at how School District No. 5 (SD5) HR Director Brent Reimer blindly accepted a psychological report declaring an average Canadian woman “unfit to teach,” admitting under oath that he “didn’t give it much thought, honestly.”
But if you think that administrative “head-in-the-sand” approach is unique to school districts, wait until you see how the regulators at the College of Alberta Psychologists (CAP) react when presented with an immediate, clear compliance breach regarding that very same psychologist.
When provided with formal notification that Dr. John Braxton Suffield’s professional liability insurance lapsed while the CAP’s public registered showed Dr. John Braxton Suffield in good standing, with no restrictions on his practice, Dr. Troy Janzen, CAP’s Complaints Director issued a response that can only be described as a masterclass in bureaucratic gymnastics.
Let’s break down the spell Dr. Troy Janzen attempted to cast—and why the law says his magic wand is broken.
Trick #1: The “Unsigned Complaint” Disappearing Act
Dr. Troy Janzen, Deputy Registrar and Chief of Practice/Complaints Director, leads with a classic procedural gatekeeping tactic: You didn’t use the magic form, so this doesn’t count.
Despite this manner of notification, no formal complaint was submitted. Typically for us to act, we must receive a signed written complaint. This is a requirement of the Health Professions Act (HPA)… ‘A person who makes a complaint… must do so in writing and must sign the written complaint.’
Dr. Troy Janzen, June 26, 2026 Letter to Dr. Bob Uttl
Dr. Janzen went on to slide in the word “anonymous” later in the letter, claiming they handled this matter purely as an “informal concern” and a “courtesy.” Moreover, Dr. Troy Janzen and I have been corresponding via email for years in my role as Ms. T’s agent, including about Dr. John Braxton Suffield.
The Reality: The notification was sent digitally, was fully identified, explicitly detailed the sender’s identity, and contained an electronic signature.
Under the Alberta Electronic Transactions Act, SA 2001, c E-5.5, an electronic signature carries the exact same legal weight as a physical “wet” ink signature. Statutes requiring a signature are legally satisfied by electronic ones unless strictly exempted—and the Health Professions Act is not exempted.
Why did CAP/Dr. Janzen try this trick? Because if they brand a fully identified, electronically signed formal complaint submission as “not a formal complaint,” they strip the complainant of their statutory right to appeal. Under the HPA, if a formal complaint is dismissed, the complainant has an absolute right to a review or an appeal to the Complaint Review Committee. CAP tried to use administrative semantics to close the escape hatch.
Trick #2: Schrödinger’s Insurance (“Intact but in Limbo”)
When forced to address the actual insurance lapse, Dr. Troy Janzen’s/CAP’s logic enters a parallel dimension. They manage to argue that Dr. Suffield’s mandatory $5 million professional liability insurance was simultaneously intact, expired, and non-existent.
The best way to characterize the situation is that Dr. Suffield’s liability insurance was intact but in limbo and future coverage had yet to be determined… It is probably more accurate to state that Suffield’s insurance was past its expiry date and is pending review and approval…”
Dr. Troy Janzen, June 26, 2026 Letter to Dr. Bob Uttl, para 5 & 8
Let’s look at the facts Dr. Troy Janzen/CAP actually admitted to in the letter:
- Dr. John Braxton Suffield’s insurance was past its expiry date.
- The insurer (BMS) was holding back renewal to review his file due to past complaints.
- At the tribunal, it was the School District No. 5’s own counsel—who recruited Dr. Suffield for litigation assistance and expert testimony—who announced on the record, in writing, that Dr. Suffield’s insurance had “lapsed.”
If your insurance has passed its expiration date, and your underwriter has locked your application away for a high-risk review and has not issued a certificate, you do not have insurance. Inventing the term “intact but in limbo” is an administrative fiction designed to excuse a blatant regulatory breach.
Trick #3: The “In Good Standing” Illusion
Perhaps the most alarming part of Dr. Troy Janzen/CAP’s response is how they define the integrity of their public register. They explicitly state that a psychologist can completely lack mandatory liability insurance, and CAP can be fully aware of it, but the public register will continue to lie to the public.
Thus, even should we have learned of a lapse of insurance, this evidence would have to be heard and determined by a Hearing Tribunal… before they would order a change on our register. Thus, our register is accurate and does not misrepresent any information to the public.
Dr. Troy Janzen, June 26, 2026 Letter to Dr. Bob Uttl, para 10
Read that again. Dr. Janzen/CAP is admitting that their public registry measures procedural bureaucracy, not factual day-to-day safety. If a member is in violation of the mandatory insurance bylaws, CAP will protect that member’s status as “in good standing” for the months or years it takes to hold a formal hearing, leaving the public in the dark, fully exposed to uninsured harms by psychologists whose pristine registry status is nothing more than an illusion.
The Duty of Accurate Representation
Dr. Troy Janzen/CAP asserts there is “no duty” for a registrant to notify them that their insurance has expired and is locked in underwriting limbo.
This flies directly in the face of the CAP Standards of Practice and the Canadian Code of Ethics for Psychologists. Registrants have a strict, positive, and continuous duty to ensure that the representation of their professional status, credentials, and regulatory compliance is completely accurate, honest, and transparent.
What Comes Next?
By invoking the Electronic Transactions Act, I am putting the choice squarely on Dr. Troy Janzen. In fact, in his very first response to my email notification, he asked me directly: “If your intention in your emailed notification was to submit a formal complaint, then please clarify that.” (Dr. Troy Janzen, Email dated June 8, 2026). At the time, I merely wanted to know if the SD5 lawyer’s submissions to the Tribunal were true or false. Instead of providing a straight answer, Dr. Troy Janzen repeatedly refused to say whether or not Dr. Suffield had notified the CAP of his insurance “lapse.”
Let’s be entirely clear: Dr. Troy Janzen, Deputy Registrar, received the signed electronic document. He read it. He explicitly invited me—via email—to clarify if it was a formal complaint. By doing so, he completely blew past any bureaucratic excuse that CAP doesn’t “accept” electronic filings.
So now Dr. Troy Janzen has a choice: pull his head out of the sand, honor the Electronic Transactions Act, and process the complaint he acknowledged receiving—or invent some new administrative sorcery to ignore it. If he insists on medieval methods, I am happy to oblige. I will pull out my old-fashioned feather ink pen, print the document, dip my feather pen into ink, sign the document by hand, and send it to him via Canada Post.
When regulatory colleges act more like medieval guilds focused on protecting their members rather than the public, they forfeit public trust. CAP’s “limbo exception” is a gaping hole in public protection—and it’s time to close it.