Ontario · Royal College of Dental Surgeons of Ontario

How to respond to an RCDSO complaint

The College must investigate every complaint, however trivial it looks to you. And because the ICRC decides on the paper record, your written response is in most cases the only submission you will ever make.

The College has no discretion to ignore it

Dentists in Ontario are regulated by the Royal College of Dental Surgeons of Ontario (RCDSO) under the Regulated Health Professions Act, 1991 (RHPA), the Health Professions Procedural Code in Schedule 2, and the Dentistry Act, 1991. The first thing to absorb is that under section 25(1) of the Code the College must investigate and act on all complaints, subject to very limited exceptions. It does not matter how trivial the complaint appears to you, or how strongly you disagree with it. Once it is filed, a process starts and you are in it.

The complaint can come from anyone. Most come from patients, but they also come from other dentists, from insurers, and from the College itself. The mandate driving all of this is public protection — not fairness to you, and not compensation for the patient.

The 14 days, and the 35 days

The College is required to give you a copy of the complaint within 14 days, and it normally allows 35 days for your written response. If you need longer, ask the assigned investigator for an extension — before the deadline, not after it.

That letter is easy to misjudge because it arrives looking like administration. It is not. It is the opening of the only real opportunity you get to put your side of the case.

Why the written response carries the whole weight

The entire process before the Inquiries, Complaints and Reports Committee is conducted on paper. Dentists have no right to call witnesses and no right to make oral representations to the ICRC. You will almost certainly never explain your clinical reasoning to the panel in person. Whatever you write is what they read.

There is a trap inside that. If the ICRC reviews your response and finds that it failed to address a particular concern raised in the complaint, there may be no further opportunity to deal with it before the decision is made. So the response has to answer every complaint made — not just the ones you consider serious, and not just the ones you find easy to answer.

Everything you send is shown to the complainant

This surprises dentists, and it should change how you write. All correspondence you submit during the investigation is disclosed to the complainant, who is given an opportunity to comment on it. A response written in irritation, or one that characterises the patient unkindly, does not stay between you and the College. Write it as though the patient will read it — because they will.

What to enclose

Identify and copy the complete record as soon as the letter arrives, and enclose it with your response. That normally means:

• The patient chart and clinical notes, treatment plans and radiographs.
• Consent documentation and any correspondence with the patient.
• The financial ledger, receipts and insurance statements — money is frequently part of the story.
• The relevant policy or protocol you were working to, where the complaint concerns process rather than clinical care.

If your records are electronic, supply them in full rather than in excerpt. A partial record invites the investigator to ask what is missing.

What the ICRC can do — and what it cannot

A panel of the ICRC — typically two dentists and a public member — reviews the file and applies a published risk assessment framework, weighing the degree of risk to patient safety and explaining that analysis in its written reasons. It may take no action; give advice or recommendations; require you to attend for a caution; order a Specified Continuing Education or Remediation Programme (SCERP); accept an undertaking; refer specified allegations of professional misconduct or incompetence to the Discipline Committee; or refer the matter for incapacity proceedings.

What it cannot do is order money. The ICRC has no jurisdiction to order financial compensation. A patient who wants a refund is in the wrong forum — which is worth knowing, because it tells you what the case is actually about.

The Public Register

Three outcomes follow you into public view. Where the ICRC issues a caution, orders a SCERP, or refers a matter to Discipline, that is posted on your profile on the Public Register — searchable by any patient or employer through “Find a Dentist”. Criminal charges are posted too. This is precisely why the difference between advice and a SCERP is worth fighting for at the response stage rather than afterwards.

Alternative Dispute Resolution

Some relatively minor complaints can be diverted early into the College’s Alternative Dispute Resolution process. Both you and the complainant must consent; the College appoints a facilitator to attempt a mediated resolution; and any resolution reached must still be ratified by the ICRC. Where it is offered and the matter is suitable, ADR is often the cleanest available exit.

If the decision goes against you

Both you and the complainant can ask the Health Professions Appeal and Review Board (HPARB) to review an ICRC complaint decision. HPARB asks two questions only: was the investigation adequate, and was the decision reasonable. It does not rehear the case. Referrals to the Discipline Committee and to incapacity proceedings cannot be reviewed. Dentists increasingly seek review precisely because cautions and SCERPs now appear on the register.

For the investigation stage itself, read what happens during an RCDSO investigation. For the corrective record that changes an outcome, read remediation and reflection for Ontario dentists.

This guide describes the process of the Royal College of Dental Surgeons of Ontario. It is general information about how the regulator works and is not legal advice. Every case turns on its own facts. Before you respond to the College, contact your liability protection through the RCDSO Professional Liability Program (PLP) and consider a lawyer experienced in RHPA regulatory matters and RCDSO defence. Completing a course does not resolve a College matter and does not guarantee any outcome. Last updated July 14, 2026.