When the RCDSO Contacts You
This page is for dentists registered in Ontario, including owners and associates of dental practices, who have learned that the College is looking into their treatment, billing or conduct. Most matters start with a patient complaint. Others start as a Registrar’s investigation, prompted for example by a mandatory report from another health professional, a public health unit investigation, or information about criminal charges.
Illustrative example, not an actual RCDSO letter
“The College has received a complaint from your patient concerning crown and bridge treatment and the fees charged. A copy is enclosed. Please provide the patient’s complete dental record, including radiographs, treatment plans and financial records, together with any response you wish the Inquiries, Complaints and Reports Committee to consider.”
Who Investigates and Who Decides
- Regulator
- The Royal College of Dental Surgeons of Ontario, continued, under the Dentistry Act, 1991. Its complaint, investigation and discipline procedures come from the Health Professions Procedural Code, Schedule 2 to the Regulated Health Professions Act, 1991 (“the Code”), which applies to every regulated health profession in Ontario.
- Who investigates
- College investigators, who usually obtain the dental record and may interview staff, hygienists, other dentists and the patient’s family. In a Registrar’s investigation, you must co-operate fully (Code, s. 76(3.1)).
- Who decides at the investigation stage
- A panel of the Inquiries, Complaints and Reports Committee (ICRC). The College also offers a resolution program for some complaints.
- Who holds hearings
- The RCDSO Discipline Committee, with panels of dentists and public members. The College asks for a publication ban on complainants’ names, and results of all hearings are published.
- Facility permits
- Offices that use dental CT scanners or provide sedation or general anaesthesia need a College facility permit and are inspected, and inspection deficiencies can appear on the register. Inspection findings can lead to separate concerns about the dentist.
Key timelines in the Code
- The Registrar must notify you within 14 days of receiving a complaint or report (Code, s. 25(6)).
- You may make written submissions to the Inquiries, Complaints and Reports Committee within 30 days of receiving that notice. The committee can shorten that time if it believes, on reasonable and probable grounds, that your conduct exposes or is likely to expose patients to harm or injury (Code, s. 25.2).
- Complaints are expected to be disposed of within 150 days. If that is missed, the Registrar must give the complainant a new expected date no more than 60 days later (Code, s. 28).
- With both your and the complainant’s consent, the Registrar can refer a complaint to alternative dispute resolution, but not if it involves an allegation of sexual abuse or has already been referred to discipline (Code, s. 25.1).
Common Issues in Dentist Investigations
Treatment planning and standard of care
Failed restorations, endodontic or implant complications, and treatment that was not supported by the diagnosis or radiographs. The College compares your care to the accepted standard of practice and its own standards and guidelines.
Consent and fees
Disputes about whether alternatives, risks and costs were explained before treatment, and about estimates, billing and insurance claims. RCDSO’s Consent to Treatment standard and Conflict of Interest guideline are often relevant.
Records
Missing clinical notes, radiographs or medical histories, or records that do not match billing. RCDSO’s Dental Recordkeeping and Electronic Records Management guidelines apply.
Sedation, anaesthesia and prescribing
Adverse events under sedation, monitoring and staffing problems, or opioid prescribing. See the Use of Sedation and General Anesthesia in Dental Practice standard and the opioid prescribing guideline.
Infection control, boundaries and professionalism
Public health findings on infection prevention and control, ending the dentist–patient relationship, advertising and social media, and boundary or sexual abuse allegations, which carry mandatory penalties (Code, s. 51(5)).
What Can Happen Next
-
Complaint or Registrar’s investigation
After considering the investigation and your submissions, a panel of the Inquiries, Complaints and Reports Committee (ICRC) may take no further action; give advice or recommendations; require a specified continuing education or remediation program (SCERP); require you to appear to be cautioned; refer specified allegations of professional misconduct or incompetence to the Discipline Committee; or refer you for incapacity proceedings (Code, s. 26). Matters are also sometimes resolved through an undertaking, such as an agreement to restrict or monitor your practice. If the panel considers a complaint frivolous, vexatious, made in bad faith, moot or an abuse of process, it must give notice and allow 30 days for written submissions before declining to act (s. 26(4)–(5)).
-
Interim order
If the committee believes your conduct exposes or is likely to expose patients to harm or injury, it can suspend your certificate or impose terms, conditions or limitations while the matter continues (Code, s. 25.4(1)). You must normally receive notice and at least 14 days to make written submissions first, unless the risk is urgent (s. 25.4(6)–(7)). The order lasts until it is varied or the matter is finally resolved (s. 25.4(4)).
-
Discipline hearing
A panel of the Discipline Committee hears evidence and decides whether professional misconduct or incompetence is proven (Code, ss. 51, 52). If misconduct is found, it may revoke or suspend your certificate, impose terms, conditions and limitations, order a reprimand, or order a fine of up to $35,000 (s. 51(2)). Findings of sexual abuse carry mandatory orders, including revocation for the conduct listed in s. 51(5).
-
Review or appeal
HPARB review: you or the complainant may ask the Health Professions Appeal and Review Board to review an ICRC decision on a complaint, except a referral to discipline or for incapacity proceedings (Code, s. 29(2)). The request must be made within 30 days after receiving the notice of the right to request a review that comes with the decision (s. 29(3)), and HPARB cannot extend that time by more than 60 days (s. 29(4)).
Divisional Court: discipline and fitness to practise decisions can be appealed on questions of law, fact or both (Code, s. 70). Orders based on incompetence, incapacity or certain sexual abuse findings, and orders in matters where an interim order was in place, take effect immediately despite an appeal (ss. 25.4(5), 71, 71.1).
Remediation is the most common outcome. RCDSO says the ICRC may ask a dentist to enter a voluntary remedial agreement, order courses, or agree to an undertaking. Referral to discipline is reserved for more serious concerns.
Checklist: Responding to an RCDSO Complaint
Documents to gather
- The College’s letter and the date you received it
- The complete patient chart: clinical notes, medical history updates, radiographs and scans, photographs and lab prescriptions
- Treatment plans, estimates, signed consent forms and financial ledgers, including insurance submissions
- Electronic record audit trails
- Sedation records and monitoring logs, if sedation was used
- Correspondence with the patient, and referral letters to or from specialists
- Names of associates, hygienists and assistants involved in the care
Details to check in the notice
- Is it a complaint or a Registrar’s investigation?
- Your deadline for written submissions, and whether it has been shortened
- Whether the resolution program or an interim order is mentioned
- Which patients, procedures and dates are identified
Rules and resources to consult
- Health Professions Procedural Code, ss. 25–29, 51–52, 70–71 and 75–76
- The Dentistry Act, 1991 and its regulations, including the professional misconduct regulation
- RCDSO standards, guidelines and practice advisories that match the allegations
- RCDSO Discipline Committee practice directions and the guide for self-represented registrants
- Your professional liability insurer, to ask what assistance is available
Do not alter records. If you need to clarify an entry, add a dated note that leaves the original visible.
Frequently Asked Questions
Is a fee dispute something the College investigates?
The College does not set or collect fees, but complaints about fees often raise regulated issues: whether costs were disclosed before treatment, whether billing matched the treatment provided, and whether insurance claims were accurate. Those can be investigated as possible professional misconduct.
Can I keep practising during the investigation?
Usually, yes. Your certificate is unaffected unless the committee makes an interim order (Code, s. 25.4) or you agree to an undertaking that limits your practice.
Will this appear on the public register?
The Code requires the public register to note cautions, SCERPs, acknowledgements and undertakings, and allegations referred to discipline (s. 23(2)). College by-laws can add more. Check what will be posted before agreeing to any resolution.
Can the patient or I challenge the ICRC’s decision?
For a complaint, either of you may ask HPARB to review the decision within 30 days after receiving the notice of the right to request a review (Code, s. 29(3)). A referral to the Discipline Committee cannot be reviewed by HPARB (s. 29(2)).
Sources
Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.
- Regulated Health Professions Act, 1991, S.O. 1991, c. 18, Schedule 2 (Health Professions Procedural Code), ss. 23, 25–29, 51–52, 70–71, 75–76, 85.5 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
- Dentistry Act, 1991, S.O. 1991, c. 24, s. 5 — e-Laws consolidation period beginning January 1, 2026; checked November 10, 2026.
- RCDSO, “Our Complaints and Investigation Process” and “Registrar’s Investigations and Reports” — Checked November 10, 2026.
- RCDSO, “Discipline Process” — Checked November 10, 2026.
- RCDSO, “Standards, Guidelines and Resources” — Titles checked November 10, 2026.
- RCDSO, “Dental Facility Inspections” — Checked November 10, 2026.
- Health Professions Appeal and Review Board (role; Consolidated Rules of Practice and Procedure in effect May 4, 2026) — Checked November 10, 2026.