QCAT reinforces zero tolerance for dishonesty to regulators: key lessons from two recent judgments and the emerging risk of AI-enabled forgery

Two recent Queensland Civil and Administrative Tribunal (QCAT) decisions highlight the serious consequences for medical practitioners who provide false or misleading information to regulators or fail to comply with supervision conditions.

Importantly, these decisions land at a time when advances in artificial intelligence are making document manipulation and forgery easier, faster and harder to detect, elevating regulatory risk for practitioners, practices and insurers alike.

This article considers QCAT's recent decisions of Medical Board of Australia v Nkire¹ and Medical Board of Australia v JRT² and draws out key regulatory themes for insurers, healthcare organisations and practitioners.

Medical Board of Australia v Nkire [2025] QCAT 514

The conduct

Dr Nkire practised for approximately 440 days without the Level 1 supervision required by conditions on his limited registration. During this period, he also submitted a misleading performance report to the Medical Board which contained a forged supervisor signature, falsely representing that appropriate supervision had occurred.

The practitioner ultimately admitted both practising unsupervised and forging the report.

QCAT characterised the prolonged failure to comply with supervision conditions and the dishonest provision of a falsified document to the regulator as professional misconduct under multiple limbs of the National Law definition.³

Findings and orders

QCAT found professional misconduct on both grounds and ordered a formal reprimand and suspension of the practitioner's registration for six months. No order as to costs was made.

Key reasoning

The Tribunal emphasised that:

• compliance with supervision conditions is a fundamental obligation designed to protect patient safety;
• forging a supervisor's signature and misleading the Board is inherently dishonest and strikes at the heart of regulatory trust; and
• general and specific deterrence were paramount, particularly given the extended period of non-compliance.

While QCAT accepted mitigating factors (early admissions, cooperation, absence of prior disciplinary history, personal stressors, ethics training, and no evidence of patient harm), it concluded that a shorter suspension would not adequately reflect the seriousness of practising unsupervised for over a year combined with deliberate dishonesty.

Medical Board of Australia v JRT [2025] QCAT 512

The conduct

A psychiatrist subject to Level 3 supervision electronically copied and pasted his supervisor's signature onto a progression plan and arranged for it to be submitted to Ahpra. The document also contained misleading information about his work arrangements.

After being stood down by his hospital, the practitioner failed to formally notify Ahpra in writing, despite being advised to do so.

The practitioner admitted creating and submitting the forged document and accepted that he failed to comply with his notification obligations.

Findings and orders

QCAT considered the conduct globally and found professional misconduct. However, unlike Nkire, QCAT imposed only a reprimand, with no suspension, cancellation or disqualification period. A non-publication order was also made protecting the practitioner's identity.

Why no suspension?

Although QCAT reaffirmed that dishonesty toward the regulator is inherently serious and ordinarily attracts strong deterrent sanctions, it regarded this case as exceptional.

Critical factors included:

• the conduct was a single episode rather than prolonged behaviour;
• immediate admission and cooperation once discovered;
• no prior disciplinary or criminal history;
• significant mental health issues accepted as contextualising the conduct; and
• most importantly, the practitioner had already been unable to practise in Australia for approximately four years while proceedings were on foot.

QCAT treated this extended period out of practice as a substantial de facto sanction.

The AI factor: forgery is becoming easier - and riskier

These decisions arise in a period of rapidly changing technology.

Modern AI tools now allow users to:

• replicate handwritten or electronic signatures in seconds;
• alter PDFs without visible traces;
• generate realistic letters, reports and institutional branding; and
• fabricate "supporting documents" that appear authentic on first review.

What previously required time, skill or access to templates can now be done with minimal technical knowledge.

From a regulatory perspective, this creates a heightened risk environment:

• forged supervision reports, references and credentialing documents are easier to produce;
• misleading material can be generated at scale; and
• detection may be delayed until inconsistencies are identified by third parties.

For practitioners, the temptation to "fix" administrative problems through document manipulation, particularly during periods of stress or career pressure, may increase. However, as Nkire and JRT demonstrate, QCAT remains focused on the underlying dishonesty, not the sophistication of the forgery.

Whether a document is crudely altered or AI-generated is immaterial: providing false or misleading material to a regulator will almost invariably expose a practitioner to findings of professional misconduct.

Conclusion

Nkire and JRT confirm QCAT's zero-tolerance approach to dishonesty and non-compliance with registration conditions, while illustrating its nuanced assessment of sanction. Forgery or submission of misleading documents to Ahpra or a National Board will almost always be characterised as professional misconduct. Extended non-compliance, even without patient harm, is treated as a serious departure from professional standards.

Against the backdrop of AI-enabled document manipulation, these cases serve as a timely reminder: regulatory integrity depends on trust, and breaches of that trust, however easily achieved, carry serious professional consequences.

For insurers and healthcare organisations, proactive governance and early intervention remain critical to managing this evolving risk landscape. Robust verification processes, secure documentation systems, clear supervision frameworks and ongoing practitioner education will be critical in mitigating exposure.

Footnotes:

¹ Medical Board of Australia v Nkire [2025] QCAT 514.

² Medical Board of Australia v JRT [2025] QCAT 512

³ National Law s 5 'professional misconduct'.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.