How to Write Your Response to Fitness to Practise Allegations

Our guide to the fitness to practise investigation explains where this response sits in the process, the deadlines at each regulator and the test decision-makers apply. The principles here apply across the UK regulators. The names and details differ, for example the GDC calls them comments or observations, so always follow the instructions in your own regulator's letter. This guide is about the document itself: how to plan it, build it and write it.

Who will read your response

Before you write a word, it helps to picture the people who will read it. They are not all the same, and the rules about who sees it differ between regulators.

The practical lesson: write as if the patient or colleague who complained will read every word, because at some regulators they may. That rules out sarcasm, personal criticism and anything you would not want quoted back to you.

The blueprint: six parts of a strong response

There is no compulsory format. But responses that decision-makers find easy to use tend to share the same architecture. The HCPC's guidance for registrants supports the core of it: address each numbered allegation separately, refer to page numbers in the bundle, and support what you say with evidence.

1. Part 1

   Covering letter

   One page. Your name, registration number and case reference, a list of what is enclosed, and a single sentence summarising your position. If someone is representing you, say so.

2. Part 2

   Your background and the setting

   Your role, experience and the working environment at the time: staffing, systems, what was normal practice. Facts only, with evidence where possible. This is context for the reader, not a defence.

3. Part 3

   Allegation by allegation

   The heart of the document. One heading per allegation, numbered exactly as in the regulator's letter, each stating your position first and then the detail, with page references.

4. Part 4

   Your practice now

   Insight, reflection and what you have changed. This speaks to current impairment, which is the question decision-makers must ultimately consider. Link each claim to an enclosed document.

5. Part 5

   Closing

   A short, respectful conclusion. Where appropriate, an apology. Do not tell the decision-makers what outcome they must reach.

6. Part 6

   Evidence index and appendices

   A numbered list of everything enclosed: reflective piece, certificates, audits, supervision records, references, health evidence. Number the pages so the reader can find them.

Admit, dispute or partly accept: deciding your position

For each allegation, you need a clear position. This is the most consequential decision in the document, and it should be made with your adviser before you start writing. Allegations are often made up of several parts, so your position may differ between them.

If an allegation includes dishonesty, take particular care. Read exactly what you are said to have known, because that is usually where these allegations are decided. Our guide to dishonesty allegations explains how panels assess state of mind.

Remember what the decision-makers can and cannot do. They work from documents, and GMC guidance says case examiners should not normally try to resolve substantial conflicts of evidence. If your account conflicts with a witness, the strength of your response often lies in pointing to independent documents, not in arguing that the witness is wrong.

How to write each allegation: the four-move paragraph

Every allegation section can follow the same four moves, in this order. It keeps you focused and makes the document easy to read.

1. Position

   One sentence: admit, partly accept or dispute.

2. Facts

   What happened, in time order, with page references to the bundle and your own records.

3. Context

   Relevant circumstances, stated neutrally and evidenced. Not a reason to escape responsibility.

4. Learning

   What this allegation has taught you, and where the evidence of that change sits in your appendices.

Here is how that looks in practice. The example is fictional.

Notice what the context paragraph does. It gives the reader useful information, then explicitly says the circumstances do not excuse the failing. That sentence is what separates context from excuse.

Tone: what real panels said about written submissions

Two High Court judgments show how written words are read as evidence of insight, or of its absence. In both, the doctor's own submissions were part of the reasoning behind the most serious outcome.

A tone test before you send

• Who is the subject of most sentences? If it is other people, rebalance towards what you did and learned.
• Is there any sentence about what you have suffered? Its place, if anywhere, is a short line in the context, not the conclusion.
• Is every claim of change linked to an appendix? If not, add the evidence or remove the claim.
• Would you be comfortable if the patient read it? At some regulators, they may.

What to leave out

Saying sorry without fear

Many professionals hold back from apologising because they worry it will be treated as an admission. Two points are worth knowing.

A good apology in a response is specific about what you are sorry for, focused on the person affected, and free of qualifications such as "if any offence was caused". If you dispute the facts, you can still say you are sorry for the distress the patient or family experienced, without accepting something you do not believe happened.

If your health is part of the picture

Health can be relevant in two ways: as context for what happened, or as part of the concern itself. GMC guidance says health becomes relevant where it may have contributed to conduct or clinical concerns. The HCPC suggests providing documentation from your GP or specialist, covering both your health at the time of the events and your health now.

• Use medical evidence, not your own description. A letter from your GP or treating specialist carries far more weight.
• Address the present. Decision-makers need to know whether there is a current risk, so explain your treatment, support and any adjustments.
• Ask how it will be handled. Health information is sensitive. Ask your case worker how it will be used and whether it will be shared.
• Health is not an excuse. Present it as context and as part of your plan to practise safely, not as a reason the allegation should be dismissed.

After you send it: decisions you may be asked to make

Sending your response is not always the end of your involvement. Depending on what the decision-makers conclude, you may need to make another decision quickly. Our investigation guide sets out the outcomes and how often each occurs. This section is about what you will be asked to do.

Do not agree to undertakings or decline a warning without advice. The choice can change what happens to your case and what is published about you.

A sample response, start to finish

The fictional skeleton below brings the six parts together for an NMC case. Every case is different, so treat it as a model of structure, not wording to copy.

For the reflective account that sits in appendix 1, see our guide to writing a fitness to practise reflective account. For what to enclose in the other appendices, see evidence of remediation.

Before you press send

1. Deadline checked. If you need more time, you asked in writing before it expired.
2. Every allegation answered. Same numbering as the regulator's letter, nothing missed.
3. Positions consistent. What you admit in one place is not contradicted in another, or in anything you said earlier to your employer.
4. References accurate. Every page reference points to the right page.
5. Anonymisation followed. The HCPC asks registrants to use the same anonymised references as the allegations, such as Service User A.
6. Evidence attached. Every claim of change has an appendix behind it.
7. Reviewed by an adviser. Your defence organisation, union or professional body has read it.
8. Read aloud once. Tone problems that are invisible on screen are often obvious when spoken.

Frequently asked questions