Alberta · College of Dental Surgeons of Alberta

What Happens During a CDSA Investigation?

10 min readLast updated July 14, 2026

A CDSA investigation can restrict your practice permit before any hearing, can begin from a routine practice visit rather than a complaint, and — on a finding — puts your name on the public record. It can also end in a costs award large enough to threaten a practice. But a 2025 Alberta Court of Appeal decision has just reshaped how far those costs and sanctions can go, in a way dentists should understand.

Cooperation is a statutory duty, not a courtesy. Failing or refusing to cooperate with a CDSA investigator is itself unprofessional conduct. Get legal advice on what to say — then say it, on time. And if interim conditions are proposed for your permit, act quickly: they have immediate consequences for a practice.

Where an investigation comes from

Most CDSA investigations begin with a patient complaint, but not all. The Complaints Director can also act on information from another regulator, an insurer, Alberta Health Services, a hospital where you hold privileges, a mandatory report, or the College’s own monitoring — including through practice visits, which are a routine feature of dental regulation and can themselves surface concerns.

What investigators can do, and what you must do

Once a matter is assigned for investigation, an investigator appointed under the Health Professions Act can compel records, attend and inspect the practice, and interview you, your staff and other witnesses. The purpose is to determine whether you have complied with the HPA, the CDSA Standards of Practice and Code of Ethics — in short, whether there is sufficient evidence of unprofessional conduct.

The report goes back to the Complaints Director, who decides what happens next. Your duty to cooperate is statutory, and its breach is a free-standing form of unprofessional conduct. Take legal advice on what to say, and then engage properly and on time. Those are not competing options.

Conditions on your permit while the matter is live

The College can impose interim conditions on a practice permit, or suspend it, before any hearing, where that is necessary to protect the public. For a dentist that can mean a restriction on certain procedures, a limit on sedation, a chaperone requirement, or a full suspension — each of which has immediate consequences for a practice owner with staff, overheads and booked patients. This is a point at which the speed of your response, and representation, matter a great deal.

How an investigation ends

Following the investigation, the Complaints Director may dismiss the matter for insufficient evidence, pursue a form of resolution, or refer it to the Hearings Director for a disciplinary hearing. A dismissal can still be reviewed by a Complaint Review Committee, which may confirm it, order further investigation, or refer the matter to a hearing.

The Hearing Tribunal

If the matter is referred, it is heard by a Hearing Tribunal convened by the Hearings Director, made up of dentists and public members. Counsel for the Professional Conduct Department presents the allegations, much as a prosecutor would; you may be represented, call witnesses and lead evidence. Complainants may be required to give evidence under oath and be cross-examined. The standard of proof is the balance of probabilities.

Where a dentist is found to have engaged in unprofessional conduct, a written decision is prepared and a summary, including the dentist’s name, is published — this is required by CDSA Bylaw 24.5. Complainants and patients are reduced to initials.

Sanctions, and the cost consequences you should understand

On a finding of unprofessional conduct, section 82 of the HPA gives the Tribunal a wide range: a reprimand; conditions on the practice permit; suspension or cancellation; mandatory training, a practice review or a fitness assessment; fines of up to $10,000 per finding, to a maximum of $50,000 at one hearing; and an order for costs.

Costs are where dental discipline can become financially ruinous, and where the law has just moved.

A 2025 case worth knowing. In a matter arising from the College of Dental Surgeons, a Hearing Tribunal ordered a dentist to pay 75% of investigation and hearing costs — which, with the appeal, approached $429,000. On appeal, the Alberta Court of Appeal called that award a “crushing burden”, reduced it to $60,000, and held that a professional should not generally have to fund the infrastructure of the hearing. It also held that suspension, rather than cancellation, should be the primary sanction where the dentist is not shown to be a continuing threat to the public. This is significant, recent, and favourable to dentists — but it is guidance on proportionality, not a shield against serious findings.

The appeal route Alberta keeps

Unlike British Columbia, which abolished the statutory right of appeal to the courts in April 2026, Alberta retains a full appeal route. A dentist or the Complaints Director may appeal a Hearing Tribunal decision to an Appeal Panel of CDSA Council, and from there an appeal lies to the Alberta Court of Appeal — the court that decided the costs case above.

One caution about admissions. Admitting unprofessional conduct can support a joint submission on sanction and a materially lighter outcome. But an admission will largely prevent you from later appealing on the basis that the facts were wrongly found. It is a strategic and consequential decision — do not make it without counsel.

Key takeaways

Investigations can begin without a patient complaint — from insurers, AHS, another regulator, a mandatory report, or a routine CDSA practice visit.
Investigators can compel records, inspect the practice and interview staff. Failing to cooperate is itself unprofessional conduct.
Interim conditions or suspension can be imposed on a practice permit before any hearing — a serious matter for a practice owner with staff and overheads.
Hearing Tribunals (dentists and public members) apply the balance of probabilities. On a finding, a named summary is published under CDSA Bylaw 24.5.
Section 82 sanctions include fines to $50,000 and costs. A 2025 Alberta Court of Appeal decision cut a ~$429,000 costs award to $60,000, called it a “crushing burden”, and said suspension — not cancellation — should be the primary sanction where the dentist is not a continuing threat.
Alberta retains an appeal to CDSA Council and then to the Alberta Court of Appeal — the route BC abolished in April 2026.

Related courses

Practical, self-paced CPD courses that map onto the issues in this guide. These are educational courses. They are not accredited by the CDSA and are not a substitute for legal advice.

Dealing With a Complaint or Investigation Professionally

How to conduct yourself through an investigation, on the record and under scrutiny.

View course →

Probity and Honesty for Healthcare Professionals

Honesty and candour under investigation. Concealment turns a care issue into a probity issue.

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Documentation for Healthcare Professionals

What investigators look for in dental records, and what strong documentation protects.

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Professionalism and Professional Standards for Dentists and Dental Professionals

The professional conduct and standards expected of Alberta dentists.

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Continue reading: Alberta dentists

How to respond to a CDSA complaint Remediation and reflection for Alberta dentists

Frequently asked questions

Can CDSA restrict my practice before a hearing?

Yes. The College can impose interim conditions on your practice permit, or suspend it, before any hearing where that is necessary to protect the public. For a dentist that might mean restricting certain procedures, limiting sedation, requiring a chaperone, or a full suspension — each with immediate consequences for a practice owner.

Will my name be published if there is a finding?

Yes. Where a Hearing Tribunal finds a dentist engaged in unprofessional conduct, a written decision is prepared and a summary including the dentist’s name is published, as required by CDSA Bylaw 24.5. Patients and complainants are reduced to initials. During a suspension, CDSA also notifies insurers, Alberta Health Services and hospitals where the dentist holds privileges.

How large can a costs award be?

Historically, very large. In a 2025 case from the College of Dental Surgeons, a Tribunal ordered a dentist to pay around $429,000 in costs. On appeal the Alberta Court of Appeal called that a “crushing burden”, reduced it to $60,000, and held that a professional should not generally fund the infrastructure of the hearing. That decision meaningfully limits costs awards — but the underlying findings still stood.

Did that case change how sanctions work?

It clarified proportionality. The Court held that suspension, rather than cancellation of a permit, should be the primary sanction where the dentist is not shown to be a continuing threat to the public — even where the conduct was serious. It is favourable guidance for dentists, but it is guidance on how sanctions are calibrated, not protection against a finding of unprofessional conduct.

Can I appeal a CDSA Hearing Tribunal decision?

Yes. Alberta, unlike British Columbia, retains a full appeal route. A dentist or the Complaints Director may appeal to an Appeal Panel of CDSA Council, and from there to the Alberta Court of Appeal. British Columbia abolished the equivalent statutory court appeal in April 2026; Alberta did not.

Should I admit unprofessional conduct?

It can be strategically sound — an admission often supports a joint submission on sanction and a lighter outcome. But it will largely prevent you from later appealing on the basis that the facts were wrongly found. It is a consequential decision that should only be made with legal advice.

This article is general information for dentists regulated by the College of Dental Surgeons of Alberta and does not constitute legal advice. Regulatory processes and the law change, and every case turns on its own facts. If you are the subject of a complaint or investigation, obtain advice from a lawyer experienced in professional regulation, and notify your professional liability insurer, before you respond. Last updated July 14, 2026.