Dr Toni Metelerkamp, a registered psychologist, was consulted multiple times by a patient for treatment of PTSD. After consultations with the patient ceased, Dr Metelerkamp entered into a personal friendship and financial relationship with the patient. The Health Care Complaints Commission (the Commission) brought disciplinary proceedings against the practitioner in the Civil and Administrative Tribunal of New South Wales.

Background Facts

Dr Metelerkamp is a registered psychologist. In January 2012, Patient A was diagnosed with Post Traumatic Stress Disorder after having worked for the New South Wales Ambulance Service for about eight years. She consulted Dr Metelerkamp and approximately 46 sessions occurred between July 2013 and around 10 April 2014.

From July 2014, Patient A made a telephone call to Dr Metelerkamp's rooms and requested to meet the practitioner for a coffee to talk about Patient A's interest in pursuing a degree in psychology. Patient A and Dr Metelerkamp subsequently met on a number of occasions over coffee and meals. Dr Metelerkamp and Patient A claimed that they formed a friendship and did not continue their doctor-patient relationship.

In October 2014, after Patient A received a lump sum payout in relation to her psychiatric injury, she decided to invest in property. However, she was not in a financial position to service a loan. She approached Dr Metelerkamp and they jointly took out a loan and purchased a house in December 2014. The understanding was that when the property was sold, each person would be given credit for their contribution and any net profits shared equally.

In the course of managing Patient A's workers compensation claim, the relevant insurer retained a private investigator to observe her activities. In the investigator's report, a claim emerged that Patient A was in a relationship with Dr Metelerkamp. The insurer forwarded this information to a consultant psychiatrist who notified the Psychology Council of his belief that Dr Metelerkamp had engaged in sexual misconduct in connection with her practice.

The Commission subsequently commenced disciplinary action against Dr Metelerkamp in relation to the above. It also alleged that the practitioner took advantage of Patient A in entering the purchase. Owing to the lack of evidence that Dr Metelerkamp and Patient A had been in a sexual relationship, the Commission did not press this issue in its submission at the hearing.


The Tribunal found that Dr Metelerkamp did not give sufficient consideration to ethical and professional guidelines of the Australian Psychological Society before entering a personal relationship with Patient A. These professional guidelines provide among other things, that psychologists should keep appropriate boundaries with patients and avoid relationships with them, which have the potential of causing a conflict of interest and interfering with good practice.

The Tribunal found no evidence that Dr Metelerkamp sought to take advantage of Patient A in the property transaction. Dr Metelerkamp put in her own capital in the transaction because it was her income that was relied upon to service the loan.

Dr Metelerkamp was held to be guilty of unsatisfactory professional conduct because, in entering a personal relationship with a Patient A soon after Dr Metelerkamp had been her therapist, the practitioner engaged in conduct that was significantly below the standard reasonably expected of a practitioner of an equivalent level of training or experience.

The Tribunal held that Dr Metelerkamp demonstrated insight in her expression of contrition and remorse. The Tribunal decided that the appropriate order to be made was that she be reprimanded. It ordered that she undertake professional mentoring to enable her gain further knowledge regarding professional boundaries and enhance her experience as a psychologist.