# How to Set Up a CQC-Compliant Complaints Procedure for Your Orthodontic Practice

Publisher: Virtual Consultant Online
Author: Virtual Consultant Online
Published: 2026-10-07
Updated: 0001-01-01
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Every orthodontic practice receives complaints, and the Care Quality Commission (CQC) does not expect you to avoid them. It expects you to have a complaints procedure that is easy for patients to find and use, that is followed in practice, and that leads to learning . This guide explains what a CQC-compliant complaints procedure for an orthodontic practice in England needs to contain, how NHS and private complaints differ, and how to build a log that stands up when an inspector asks to see it. It focuses on the CQC and General Dental Council (GDC) expectations that apply to dental providers; it is not legal advice, and you should check current guidance for your own circumstances.

Key takeaway
CQC Regulation 16 requires a registered provider to have an accessible system for identifying, receiving, recording, handling and responding to complaints, and to investigate them and take action where problems are found. A written policy on its own is not enough. Inspectors look for evidence that the process is used: a complaints log, response letters, and examples of changes made as a result.

## What does the CQC require for dental complaints?

Regulation 16 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 requires registered providers to operate an effective system for receiving and acting on complaints. In practice, the CQC assesses complaints handling mainly under the Responsive key question, and a weak process can also affect the Well-led rating because it points to a governance gap. The regulation expects that complaints are investigated thoroughly and in a timely way, that the complainant is told the outcome, that action is taken where a problem is identified, and that nobody is treated worse for complaining.

Separately, the GDC's Standards for the Dental Team require every registered dental professional to make sure there is an effective complaints procedure readily available for patients, to respond to complaints politely and constructively, and to cooperate with any investigation. A practice with a CQC-compliant process will normally be meeting the GDC expectation too.

Requirement What an inspector wants to see Accessible procedure A written policy patients can find without asking, such as on the website, in the waiting area and in the patient information pack Named responsible person A named complaints lead and a deputy for when they are away Acknowledgement and timescales Written timescales, and evidence that acknowledgements and responses met them Recording A log of every complaint, including verbal ones, with dates and outcomes Learning Examples of changes made after a complaint, and a record that the team discussed them Signposting Clear information about where the complainant can go if they remain dissatisfied

## How do NHS and private complaints differ?

NHS patients and private patients are signposted to different external bodies, so your procedure must explain both routes. Many orthodontic practices treat both groups, so a single policy needs two clear escalation paths.

NHS patients
Complain to the practice, or to the commissioner (the integrated care board or NHS England team acting for it)

Under the NHS complaints regulations, the complaint is acknowledged within three working days and the complainant receives a written response

Normally within 12 months of the event, or of becoming aware of it

If still unhappy, the Parliamentary and Health Service Ombudsman reviews the case

Private patients
Complain to the practice using the practice procedure

The practice should acknowledge promptly and respond within its published timescale

If unresolved, the patient can seek help from the Dental Complaints Service, run by the GDC, if it remains available, or a private dental complaints scheme your practice subscribes to

Serious concerns about an individual's fitness to practise can be raised with the GDC

Because the external routes and their processes can change, always check the current details on the GDC, CQC and NHS websites before printing patient information.

Fewer complaints start with clearer expectations
Many orthodontic complaints trace back to misunderstood cost, duration or what was agreed at consent. Showing patients a transparent assessment and quote before their first visit helps set expectations early. See how it works →

## What should be in the written procedure?

A complaints policy should be short enough that a patient can read it and detailed enough that a new team member can follow it. Aim for a single clear document, plus a one-page patient leaflet.

How to complain: by phone, in person, in writing or by email, and to whom. Accept verbal complaints and record them.

Who is responsible: the named complaints lead, with their role and contact route.

Timescales: how quickly you will acknowledge, how long you expect an investigation to take, and what you will do if it will take longer.

What happens next: who investigates, whether the clinician involved is consulted, and how the response is written.

Support for the complainant: an offer to meet, and acceptance that they may bring someone with them.

Escalation: where to go if the complaint is not resolved, with separate routes for NHS and private patients.

No detriment: a statement that making a complaint will not affect the patient's care.

Keep the policy under version control with a review date, and note the date it was last reviewed. Out-of-date contact details for external bodies are one of the more common small findings in dental governance reviews.

## How should you run an investigation?

### Acknowledge quickly

A short written acknowledgement within three working days, naming the person dealing with the complaint, is good practice for private complaints and a requirement under NHS rules for NHS complaints. It tells the complainant they have been heard before the facts are known.

### Gather the facts

Pull the clinical record, consent form, treatment plan, appointment history and any messages exchanged. In orthodontics, the written treatment plan and the signed consent are often the key documents, so make sure they are complete before a complaint arises. Our guides on the orthodontic consent process and explaining a treatment plan cover what good records look like.

### Respond in plain English

A good response apologises where something went wrong, explains what happened, says what the practice has changed, and tells the complainant where to go next if they are still unhappy. Avoid defensiveness and jargon. If an offer such as a refund, a free review appointment or a remedial treatment is appropriate, set it out clearly. Consider telling your indemnity provider early if a complaint suggests a possible claim.

### Remember the duty of candour

Where a notifiable safety incident has occurred, Regulation 20 (duty of candour) applies in addition to the complaints regulation. Be open with the patient about what happened and offer an apology.

## Which orthodontic complaints come up most often?

Most orthodontic complaints concern communication, cost, duration and outcome expectations rather than clinical negligence. Recognising the patterns helps you prevent them.

Treatment taking longer than first estimated, which usually points to expectations set at consent or missed appointments.

Disagreement about what was included in the fee, including retainers, refinements and replacement appliances.

Difficulty getting through by phone or getting an emergency appointment.

Dissatisfaction with the final result, including relapse after debond, which links to the importance of retainer compliance.

Feeling pressured or not fully informed about options.

Our articles on managing difficult consultations and handling negative reviews look at how to defuse these situations before they become formal complaints.

## How do you turn complaints into evidence of learning?

Inspectors want to see that complaints change what you do. Keep a simple complaints log with date received, nature of complaint, whether NHS or private, response date, outcome, and action taken. Review it at a regular team meeting, record the discussion and note any changes.

Important
Do not treat the log as a place to hide problems. A practice with a log showing no complaints for years may be asked how it captures verbal complaints and informal feedback. A thin log can look worse than an honest one with clear actions.

Give patients clearer information from day one
Virtual Consultant Online helps patients understand their options, costs and likely timelines before they book, so fewer misunderstandings turn into complaints.
Explore the online assessment →

## FAQs

### Does an orthodontic practice need a written complaints procedure?

Yes. CQC Regulation 16 requires registered providers to have an effective system for receiving and acting on complaints, and the GDC Standards for the Dental Team require a complaints procedure that patients can readily access. Inspectors will usually ask to see the written policy.

### How quickly must a complaint be acknowledged?

For NHS complaints in England, the regulations require acknowledgement within three working days. For private complaints, the same timescale is widely used as good practice, and your policy should state the timescales you commit to.

### Who can a patient complain to if the practice does not resolve the issue?

NHS patients can take an unresolved complaint to the Parliamentary and Health Service Ombudsman. Private patients can seek help from the Dental Complaints Service run by the GDC, where available, or a private complaints scheme, and can raise fitness to practise concerns with the GDC.

### Do verbal complaints need to be recorded?

Yes. The system required by Regulation 16 covers identifying and recording complaints, so a verbal complaint should be written into the log with the date, the issue and the action taken, even if it is resolved on the spot.

### What should a complaints log contain?

At a minimum: the date received, who complained, whether the patient was NHS or private, the nature of the complaint, the dates of acknowledgement and response, the outcome and any learning or action. Review it at team meetings and record the discussion.

### What are the most common orthodontic complaints?

They tend to concern communication, cost, treatment duration and result expectations, rather than clinical negligence. Clear consent, a written treatment plan and transparent fees reduce the likelihood of most of them.

### How long do I have to make an NHS dental complaint?

NHS complaints should normally be made within 12 months of the event or of becoming aware of it. Complaining to the practice first is usually the quickest route, and the practice must tell you how to escalate if you remain unhappy.

### Does an orthodontic practice need a written complaints procedure?

Yes. CQC Regulation 16 requires registered providers to have an effective system for receiving and acting on complaints, and the GDC Standards for the Dental Team require a complaints procedure that patients can readily access. Inspectors will usually ask to see the written policy.

### How quickly must a complaint be acknowledged?

For NHS complaints in England, the regulations require acknowledgement within three working days. For private complaints, the same timescale is widely used as good practice, and your policy should state the timescales you commit to.

### Who can a patient complain to if the practice does not resolve the issue?

NHS patients can take an unresolved complaint to the Parliamentary and Health Service Ombudsman. Private patients can seek help from the Dental Complaints Service run by the GDC, where available, or a private complaints scheme, and can raise fitness to practise concerns with the GDC.

### Do verbal complaints need to be recorded?

Yes. The system required by Regulation 16 covers identifying and recording complaints, so a verbal complaint should be written into the log with the date, the issue and the action taken, even if it is resolved on the spot.

### What should a complaints log contain?

At a minimum: the date received, who complained, whether the patient was NHS or private, the nature of the complaint, the dates of acknowledgement and response, the outcome and any learning or action. Review it at team meetings and record the discussion.

### What are the most common orthodontic complaints?

They tend to concern communication, cost, treatment duration and result expectations, rather than clinical negligence. Clear consent, a written treatment plan and transparent fees reduce the likelihood of most of them.

### How long do I have to make an NHS dental complaint?

NHS complaints should normally be made within 12 months of the event or of becoming aware of it. Complaining to the practice first is usually the quickest route, and the practice must tell you how to escalate if you remain unhappy.

## References

- Care Quality Commission - Regulation 16: Receiving and acting on complaints (https://www.cqc.org.uk/guidance-providers/regulations-enforcement/regulation-16-receiving-acting-complaints) - CQC guidance on what registered providers must do to receive, record, investigate and respond to complaints.
- General Dental Council - Standards for the Dental Team (https://www.gdc-uk.org/standards-guidance/standards-and-guidance/standards-for-the-dental-team) - The GDC standards, including the expectation that patients have access to an effective complaints procedure.
- Parliamentary and Health Service Ombudsman - Complaining about the NHS (https://www.ombudsman.org.uk/making-complaint) - Information on how NHS complainants can escalate unresolved complaints to the Ombudsman.
- Care Quality Commission - Regulation 16: Receiving and acting on complaints (https://www.cqc.org.uk/guidance-providers/regulations-enforcement/regulation-16-receiving-acting-complaints) - CQC guidance on what registered providers must do to receive, record, investigate and respond to complaints.
- General Dental Council - Standards for the Dental Team (https://www.gdc-uk.org/standards-guidance/standards-and-guidance/standards-for-the-dental-team) - The GDC standards, including the expectation that patients have access to an effective complaints procedure.
- Parliamentary and Health Service Ombudsman - Complaining about the NHS (https://www.ombudsman.org.uk/making-complaint) - Information on how NHS complainants can escalate unresolved complaints to the Ombudsman.
