Doing the right thing when no one is looking

For years, I told the teams I ran to do the right thing even when no one was looking. I meant it as a statement about character. In Ontario's retirement home sector, the regulator has quietly turned it into a statement about operations.

Every operator already knows the inspector can arrive unannounced. That has always been true. Complaint and harm-report inspections were never scheduled, and even routine inspections lost the twenty-four hours of notice they once carried. Today every inspection is a surprise. The surprise is not the news. What has changed is the volume feeding it, and what happens after.

In its 2024/25 annual report, the Retirement Homes Regulatory Authority recorded 2,375 reports of harm or risk of harm, up 46 per cent in a single year and 148 per cent over five. Those reports drove responsive inspections up 42 per cent, and half of every inspection returned findings of non-compliance. So the volume of unannounced scrutiny has never been higher. What matters is what happens to it. Follow a single year of reports from the top of the system to the bottom, and the shape tells you where your exposure actually sits.

Retirement Homes Regulatory Authority, Annual Report 2024/2025. Inspection practice per the RHRA FAQ: all inspections are currently unannounced.

At first glance the two ends look like they contradict each other. Reports of harm are surging while the regulator's most extreme tool sits nearly dormant. They are not in tension. They measure different things. A report of harm is the input. A management order is the rarest possible output, the regulator seizing operational control of a home over the licensee's objection. Between the two sits a ladder of lighter responses the RHRA reaches for far more often.

That middle is where the findings actually land. Of the 59 enforcement orders issued last year, the bulk were compliance orders and administrative penalties, correct-and-monitor tools rather than take-over tools. Conditions get attached to licences. Orders then get monitored for months. At year-end the RHRA still had 45 individual orders and conditions under active monitoring. The total number of orders was down about 16 per cent. So the story is not more enforcement. It is far more scrutiny, resolved lower on the ladder.

For an operator, that distinction is the whole game. The rare seizure is not your exposure. Your exposure is the everyday machinery above it: the unscheduled inspection that finds something half the time, the compliance order that follows, and the monitoring that then runs for months and expects you to keep proving you have held the fix. You cannot satisfy a monitoring obligation with a binder assembled after the fact. It runs continuously, which means your evidence has to as well.

This is what I was actually asking for, back when I told those teams to do the right thing when no one was looking. Not a good showing on inspection day. Not a binder assembled the week before a visit that might come. The ordinary, unglamorous discipline of a home run properly on a Tuesday, because that is the only readiness that survives an inspection you cannot see coming.

The committees either meet on their cadence or they do not. The corrective actions either close and get verified or they sit marked done and unchecked. The obligations either have an owner and a trail or they live in one manager's memory. None of it can be manufactured after a report is filed, because the inspector is now reading the record that already exists. A home governed this way is not preparing for anything. It is simply ready, because readiness has become a property of how it runs rather than an event it performs.

Why the record itself has become the test, and who else is now reading it, is the subject of a companion piece here.

The regulator has made every day an unannounced day. The operators who will be fine are not the ones with the best answer when an inspector arrives. They are the ones for whom the arrival changes nothing, because nothing was being held together for the visit. Doing the right thing when no one is looking was always the correct instruction. It is now also the only operating model that holds.

Solving the critical path.