What Happens If a Patient Complains About Me to the HCPC?

Roughly two thirds of the fitness to practise cases the HCPC closed in 2024-25 were closed at triage or threshold, before an Investigating Committee Panel ever looked at them: 949 of the 1,408 cases closed that year. Add the 244 the panel closed with no case to answer, and about 85% ended without a final hearing.

If a letter has arrived, that is the number nobody leads with. Most pages ranking for this question are written by regulatory defence solicitors: accurate on process, but paid to prepare you for the worst outcome, so the worst outcome is what you read first. The regulator's own Fitness to Practise annual report 2024-25 describes a funnel that removes most cases long before anyone sits in a hearing room.

None of that makes a concern trivial. It is a serious process with real consequences at the far end and it deserves a serious response from day one. It is simply not the process most registrants imagine when the envelope arrives.

This article is general information, not legal advice. If a concern has been raised about you, contact your indemnity provider or professional body today, before you reply to anyone.

What is a concern, and what happens to it first?

A concern is what the HCPC calls a complaint about a registrant. Anyone can raise one: a patient, a relative, an employer, another practitioner, or the police. A concern is an allegation that has been received, not a finding, and not a charge.

The first stage is triage. This is an administrative filter, not a judgement about your practice. It checks that the person named is on the Register, that the issue is one the HCPC can deal with, and that there is enough information to take it further. The HCPC received 2,409 concerns in 2024-25, up from 2,226 the previous year, and 2,044 of them met the triage criteria.

Next comes the threshold policy: the test of whether the concern, even if every word of it were proven, could amount to impaired fitness to practise. Fitness to practise is about your ability to do your job safely and effectively, not about whether a patient was satisfied. Fee disputes, rudeness at reception, disagreement with a discharge decision, and dissatisfaction with an outcome are the kinds of concern that most often close at this stage. The HCPC sets out the categories it does and does not pursue in what we investigate.

The funnel: what happened to 2,409 concerns

Every figure in this table is from the HCPC Fitness to Practise annual report 2024-25.

The three closure routes add up exactly: 949 + 244 + 215 = 1,408. The 949 "includes cases closed at triage and at threshold", and in the report's own words, "we closed 591 cases as they did not meet our threshold policy and 244 cases were closed by an ICP as there was no case to answer", and "215 cases were concluded at final hearings where 146 sanctions were imposed".

Read the bottom of that table against the top. From 2,409 concerns received across all of the professions the HCPC regulates, 59 registrants were struck off in the year. A sanction is the order a panel makes when it finds fitness to practise impaired, and strike-off is the most severe of them. The others range from a caution order, through conditions of practice, to suspension.

What actually happens to you at each stage, and how long does it take?

Triage and threshold. You are told a concern has been raised and given the substance of it, and you are usually invited to comment. The process diagram in the HCPC's annual report puts the threshold stage at around eight months. That is a long time to sit with, and it is the single most common criticism registrants make of the process. Nothing about your registration changes while a case is open unless the HCPC separately applies for an interim order, which happens only in the most serious cases. Your adviser will tell you quickly whether yours is one of them.

The Investigating Committee. If a case passes the threshold, it goes to the Investigating Committee, a panel that reviews the evidence on paper and decides one thing only: whether there is a case to answer. You are given the allegation and the evidence, and you have 28 days to respond in writing. That written response matters more than almost anything else you will do in the process. Write it with your indemnity provider or union representative, never alone and never in the first flush of anger. In 2024-25 the Investigating Committee closed 244 cases outright, finding no case to answer.

The final hearing. If there is a case to answer, it goes to a hearing before a panel that includes a registrant from your profession and a lay member. The same diagram puts the hearing stage at around nine months. Of the 215 cases concluded at final hearings in 2024-25, 67 ended with no adverse finding: not well founded, discontinued, or no further action.

Those are indicative timescales, not guarantees. Cases can and do run longer.

How does physiotherapy compare with other professions?

Physiotherapists accounted for 360 concerns in 2024-25, which is 14.9% of all concerns received, and 324 physiotherapists had one or more concern raised, 16.5% of all registrants subject to a concern. Those shares sound alarming until you set them against the size of the physiotherapy register.

Physiotherapy sits at one of the lower rates on the Register, well below practitioner psychologists and paramedics. The report also gives the figure for the Register as a whole: "the percentage of registrants subject to a concern is 0.6%".

What actually protects you?

Your records. Almost every fitness to practise case turns on what was written at the time, because a panel looking at events from two years ago has nothing else to work from. If your note says what the patient reported, what you examined, what you found, what you did, what you advised, and why, the case is about a documented clinical decision. If your note says "as before, exercises given", the case becomes your word against theirs.

The Chartered Society of Physiotherapy sets the standard as an independent-reader test in its record keeping guidance: a good record lets an independent reader understand what conversations took place, what was examined, what treatment was given, and what clinical reasoning was applied. Written that way, a note also answers the far more common allegation that consent was never discussed, because the discussion is on the page.

For the practical version of that standard, see how to write SOAP notes that hold up and how long you have to keep the records. A concern can arrive years after discharge, which is precisely why the retention periods exist.

Can fixing a record afterwards make things worse?

Yes, and this is the trap worth understanding before you are ever in it.

The HCPC lists "failure to maintain accurate records" under misconduct, and "poor record-keeping" under lack of competence. It also lists "dishonesty (for example, falsifying records)" under misconduct. Those are different categories with very different outcomes. A thin note raises a competence question, and competence questions are frequently answered with remediation and reflection. An undated, unattributed amendment made after you learned a complaint existed can be read as an attempt to improve the record, and that is a dishonesty question. Dishonesty is where the severe sanctions live.

The CSP guidance is specific about how to correct a record properly: amendments "should be dated, timed and signed and the original entry still clearly visible". The original entry stays. You add to the record, you never overwrite it.

This is one of the few points where your software genuinely changes your exposure. A system that locks a note when it is signed, versions every later edit, and keeps a full audit log produces that dated, timed, attributed trail automatically, so a legitimate late addition reads as exactly what it is. Atlacare works this way by default.

What should you do if a letter arrives?

1. Tell your indemnity provider or union the same day. This is the first call, before anything else. Representation is usually included in your cover, and the earliest advice is the most valuable.
2. Do not contact the patient. Not to explain, not to apologise, not to ask what happened. Contact can be read as pressure on a complainant, and it creates a second problem worse than the first.
3. Do not amend, tidy, add to, or back-date any record. Leave the file exactly as it stands. If something genuinely needs recording now, date and time it, sign it, and leave every original entry visible.
4. Take a copy of the record as it currently is and note the date you took it. Your adviser will want to see what existed at the point the concern was raised.
5. Diarise every deadline, particularly the 28 days to respond at Investigating Committee stage. Ask for an extension early rather than missing it.
6. Send nothing to the HCPC without your representative seeing it. A defensive first draft written at midnight has ended worse than the original concern would have.
7. Get support. These cases run for months. Your professional body and the HCPC both signpost support for registrants, and using it is not an admission of anything.

Frequently asked questions

Does every case end with a sanction? No. In 2024-25, 215 cases were concluded at final hearings, 146 sanctions were imposed, and 67 were recorded as not well founded, discontinued, or no further action.

How likely is being struck off? Across all professions, 59 registrants were struck off in a year in which 2,409 concerns were received.

Should I just reply myself and get it over with? No. Talk to your indemnity provider first, every time, even when the concern looks obviously baseless to you.

Does a concern mean I have done something wrong? No. A concern is an allegation that has been received. Roughly two thirds of the cases closed in 2024-25 closed before reaching the Investigating Committee, and about 85% without a final hearing.

Sources: HCPC Fitness to Practise Annual Report 2024-25 | HCPC: What we investigate | CSP: Record keeping guidance

Related: How to Write SOAP Notes for Physiotherapy | How Long to Keep Physiotherapy Patient Records | UK GDPR for Physiotherapists

This article is general information, not legal advice. A registrant who receives a concern should contact their indemnity provider or professional body immediately.