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  MIG Update – August 31, 2026

GP vs. Specialist: Who Can Confirm a Concussion for MIG Removal?  

In this week’s edition the Tribunal considers whether a general practitioner’s concussion diagnosis requires corroboration from a specialist to remove an Applicant from the MIG. The Respondent argued that a family doctor’s diagnosis based on self-reported symptoms isn’t enough without a neurologist or concussion expert confirming it. We break down how the Tribunal resolved this evidentiary conflict.

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Factor – Concussion

In [SN] v. Unifund Assurance Company (25-001636) SN, a minor, was involved in an accident on February 26, 2022, the parties dispute whether SN suffered a concussion, vision impairments and psychological injuries, as a result of the accident, warranting removal from the MIG, and whether the treatment plans and expense are reasonable and necessary.

The Applicant’s Position

The Applicant argued she sustained a concussion and resulting post-concussive symptoms including strabismus (eye misalignment) post-concussion esotropia (eyes turning inward) nausea, headaches, and dizziness which are brain injuries that fall outside of the MIG.

She relied on the March 2, 2022 clinical note by her pediatrician, Dr. Pooja Prabhu who diagnosed a concussion and initiated a school concussion protocol and subsequently documented ongoing nausea, headaches, double vision and potential persistent concussion symptoms. Both her physiotherapist and chiropractor’s CNRs from March and April 2022 noted concussive symptoms and a differential diagnosis of concussion.

The October 2024 notes from optometrist Dr. Yvonne Au (noting inward turning of the eyes post-accident) and September 2025 diagnosis from Opthamologist Dr. Dexter Furlonge for post-concussion esotropia.

The Respondent’s Position

Unifund cited Wadood v. Economical (21-000233) to argue that general practitioner diagnoses of post-concussive injuries require expert corroboration.

Dr. Prabhu’s diagnosis was based solely on self-reported symptoms without objective testing or diagnostic imaging. Dr. Furlonge’s (ophthalmologist) records merely noted that SN reported a past concussion diagnosis, rather than providing an independent diagnostic confirmation.

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The Tribunal found:

• • In Wadood v. Economical, the applicant only had concussive symptoms noted by a chiropractor and physiotherapist, and no actual physician/medical doctor had provided a formal concussion diagnosis. Here, a treating pediatrician Dr. Prabhu explicitly made the diagnosis.
    
  • “I find that corroboration from a specialist or neurologist is not required to confirm a concussion diagnosis. In Ontario, a physician, nurse practitioner or neuropsychologist can diagnose a concussion. (See, for example: Singh v. Aviva General Insurance, 2025 CanLII 3764 (ON LAT) (“Singh”).”
  • While not bound by LAT precedents, the balance of the case law at the LAT indicates that a diagnosis from a physician is sufficient to demonstrate a concussion.
  • Although emergency records lacked notes of head trauma, they did record contemporaneous headaches, which aligned with Dr. Prabhu’s subsequent March 2, 2022 diagnosis and multi-year records of post-concussive symptoms.

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