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GOsC

A Patient Has Complained to the GOsC — What Should You Do Right Now?

The immediate steps every osteopath should take when a patient makes a GOsC complaint, what to avoid, how to protect your osteopathic registration, and how to start building your response

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A patient complaint to the General Osteopathic Council is a serious professional matter that requires an immediate and structured response. The actions you take in the hours and days after you find out will shape how the case develops. This guide tells you exactly what to do.

What a GOsC Complaint Actually Means

A patient complaint to the GOsC is the beginning of a process — not a finding against you. The GOsC applies a threshold question to every concern received: would the concern, if proved, raise a real question about the osteopath's fitness to practise? Many complaints do not meet this threshold and are closed at initial

assessment without formal investigation.

But you cannot assume this will happen in your case, and the steps you take from the moment you find out about the complaint matter regardless of the GOsC's initial assessment decision.

The full scope of what GOsC fitness to practise proceedings involve — from referral through to committee hearing — is set out in the guide to GOsC fitness to practise proceedings.

Step 1: Contact the Institute of Osteopathy or Your Solicitor Immediately

Before anything else — before responding to the GOsC, before speaking to your employer or practice manager, before contacting anyone connected to the complaint — contact the Institute of Osteopathy (iO) or a specialist regulatory solicitor.

Today. iO membership includes regulatory support that covers GOsC proceedings. If you are not an iO member, contact a specialist regulatory solicitor directly. Do not attempt to navigate GOsC proceedings without professional support.

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Step 2: Do Not Contact the Patient

Do not contact the patient who has complained — even to apologise or explain. Direct contact with a complainant without specific legal advice can be treated as an attempt to influence them and can create additional conduct concerns.

In cases involving adverse events following manual therapy (including HVT), direct contact with the patient without legal guidance can significantly complicate your position.

Step 3: Preserve All Clinical Records

Gather all clinical records from the relevant treatment period immediately. Do not alter, annotate, or amend any record.

The clinical record is the primary evidence in most GOsC cases. Where records were contemporaneous and complete, they are your strongest asset. If records have gaps or weaknesses, your legal representative needs to know about this from the outset — it affects how the response is framed.

Good clinical record keeping is both a GOsC professional obligation under the Standard of Proficiency and a practical protection against complaints.

If this complaint reveals a record keeping gap, addressing it through CPD and practice change is part of the remediation response.

Step 4: Document the Consent Discussion for Your Legal Representative

GOsC complaints frequently involve consent — particularly for HVT and other higher-risk techniques. Write down, for your legal representative, exactly what you discussed with the patient before treatment: the technique proposed, the specific risks explained, any alternatives discussed, and

the patient's questions and responses. Be accurate and complete. The standard against which your consent process will be assessed is set out in the guide to informed consent in healthcare.

Step 5: Start CPD Immediately

Start CPD that directly addresses the area of concern from day one. For HVT-related complaints: CPD in manual therapy safety, adverse event recognition, and contraindication assessment.

For consent complaints: CPD in informed consent standards for manual therapy. For record keeping complaints: CPD in clinical record keeping under the GOsC Standard of Proficiency. Early, specifically targeted CPD is far more persuasive than pre-hearing CPD compiled at the last minute.

The guide to building GOsC remediation evidence explains exactly how CPD is assessed in GOsC proceedings and how to present it most effectively to the case examiners.

Step 6: Continue Practising — Absent a GOsC Interim Order

Unless a GOsC interim order is imposed, your registration remains current and you can continue practising. A GOsC complaint does not restrict your registration. Continue your clinical work, maintain the highest professional standards, and

document your practice with particular care during the investigation period. If the complaint involved an adverse event following a specific technique, consider whether voluntary modification of that aspect of practice while seeking specific training is the professionally appropriate response.

Step 7: Respond to the GOsC Allegation Letter With Advice

The GOsC formal allegation letter — if the investigation threshold is met — invites your written response within a defined period. This response is critical. Do not draft or submit it without professional advice and review. It should address each specific concern specifically, provide relevant clinical context, and

outline any remediation already completed. The GOsC case examiner stage guide shows exactly how your response will be assessed and what the case examiners are looking for.

Step 8: Look After Yourself Throughout the Process

A GOsC complaint creates significant personal and professional stress. The Institute of Osteopathy provides wellbeing support for members in difficulty. Your GP and employee assistance programmes are also available. Regulatory investigations can take months or years —

maintaining your own wellbeing throughout is a prerequisite for engaging with the process effectively, and is itself a sign of the professional self-awareness the GOsC values.

UK-registered healthcare professionals can access professional ethics training through Healthcare Ethics Courses.

Professionals with connections to Australia can consult ethics training in Australia.

Those with connections to Canada can review professional development in Canada.

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Frequently Asked Questions

What should I do first if a patient complains to the GOsC?

Contact the Institute of Osteopathy or a specialist regulatory solicitor immediately — before responding to the GOsC, before speaking to anyone connected to the complaint, and before taking any other action.

Should I contact the patient who complained to the GOsC?

No — without specific legal advice. Direct contact with a complainant without guidance can be treated as an attempt to influence them, particularly in adverse event cases involving manual therapy.

Can I alter clinical records after a GOsC complaint?

Absolutely not. Altering, deleting, or amending any records is a serious additional fitness to practise concern. Preserve all records exactly as they are.

Can I continue practising as an osteopath during a GOsC complaint?

Yes — absent a GOsC interim order. A complaint does not restrict your registration. You can continue working until and unless a formal interim order is imposed.

What if the complaint involves an HVT adverse event?

Contact the Institute of Osteopathy immediately. Preserve all records. Document everything you remember about the consent discussion and technique delivery. Consider whether voluntary temporary modification of the specific technique while seeking further training is the professionally appropriate response.

Should I start CPD after a GOsC complaint?

Yes — immediately. CPD in the specific area of concern started from day one carries far more weight than CPD compiled just before a hearing.

What professional body supports osteopaths in GOsC cases?

The Institute of Osteopathy (iO) provides regulatory support, professional indemnity coverage, and legal guidance as standard membership benefits.

What is the GOsC allegation letter?

The formal notification that a GOsC investigation has been opened, setting out the specific concern and inviting your written response. It is not a finding against you.

Does the GOsC investigate every patient complaint?

No. Many complaints are closed at initial assessment where the threshold question is not met. However, you cannot assume this will happen in your case and should take all recommended steps regardless.

How long does a GOsC investigation take?

Variable — from several months to over a year for complex matters. Actively building remediation evidence during this period is the most productive use of the investigation period.

Can a GOsC complaint be resolved without a formal hearing?

Yes — many GOsC cases are resolved at case examiner stage through a no case to answer decision or an agreed outcome.

What is the most important step I can take immediately after a GOsC complaint?

Contacting the Institute of Osteopathy or specialist regulatory solicitor before responding to the GOsC or taking any other action. Professional advice before any statement is the single most important protective step.

Is there wellbeing support available for osteopaths during GOsC proceedings?

Yes — the Institute of Osteopathy provides wellbeing support for members in difficulty. Your GP and employee assistance programmes are also available. Seeking support is a sign of professional self-awareness, not weakness.

Disclaimer

This guide is for educational purposes only and does not constitute legal advice. Seek independent legal advice from a solicitor experienced in GOsC regulatory proceedings.