Screening: Your First Response

Regulation Resolution Solicitors
Fitness-to-practise defence · cross-regulator guidance

Stage 0a — Screening stage responses: getting the first reply right

The first written response a registrant gives to the regulator is read by the case examiner and shapes the entire downstream investigation. This guidance explains the screening / triage stage at each regulator, what to include and exclude, and how to use the firm’s screening templates safely. It sits as a curtain-raiser to Stage 0 (Interim Orders) and the eight substantive defence stages that follow.

What “screening” means at each regulator

• NMC — Screening team (initial assessment) followed by Case Examiners.
• GMC — Triage and Investigation Stage; Case Examiners take the decision to refer.
• GDC — Initial assessment; Investigating Committee takes the referral decision.
• HCPC — Initial scrutiny; Investigating Committee Panel.
• GPhC — Investigation Officer; Investigating Committee.
• Social Work England — Initial assessment; Case Examiners.

Each route has the same shape: a referral is received, a regulator-side assessor decides whether it crosses the threshold for full investigation, and then the case proceeds (or is closed). The registrant’s screening-stage response is the single most important opportunity to influence that decision before the regulator commits resources to a full investigation.

What the registrant’s screening response is for

• To narrow the scope of allegation — so that issues that should never have been on the list come off it.
• To put context around the allegation — clinical, employment, personal — so the case examiner reads the referral with appropriate framing.
• To raise red flags about the quality of the referral — anonymous sources, hearsay, time-barred matters, matters already dealt with.
• To establish a tone of professional engagement — co-operative, candid, organised.
• To begin the documentary record on insight and remediation — the regulator will return to this later.

What it is not for

• It is not a full defence statement. Do not commit on disputed facts before disclosure is in.
• It is not the place to attack individual complainants or colleagues.
• It is not the place to put a “no comment” position — silence at this stage is taken adversely.
• It is not a place to admit matters that may be wider than what is actually alleged.

Common types of screening referral

Whatever the subject matter, a screening response draws on the same three templates set out later on this page — an acknowledgement, a partial response or a full substantive response. What changes is the material each type of referral calls for. The most common referral scenarios, and the points each one turns on, are:

• General complaint: factual context, professional standing, response to specifics, insight, request for fair process.
• Health-related referral: disclosure of relevant health information; treatment in place; occupational health; reasonable adjustments.
• Conviction or caution disclosure: facts of the criminal matter; whether the registrant accepts the conviction; remediation; submissions on relevance to fitness to practise.
• Clinical practice concern: clinical context; standards relied on; reflection; any contemporaneous learning; expert input where available.
• Boundaries / probity concern: candour about the matter alleged; insight; remediation; reflection on professional standards.
• Employer referral with internal investigation outcome: position on the internal investigation; what was accepted and what was contested; remediation since.

Structure that works at every regulator

1. Cover page: registrant’s details, case reference, date of response.
2. Section 1 — Introduction: who the registrant is, current practice, length of registration, any current restrictions.
3. Section 2 — Response to the specific allegations: each item addressed in turn; brief, factual, anchored in documents where possible.
4. Section 3 — Wider context: clinical / employment / personal context relevant to how the regulator should read the referral.
5. Section 4 — Insight, reflection and remediation: what has been thought about, done, and is in train.
6. Section 5 — Public protection: a brief statement (in suitable cases) that the registrant has continued to practise safely / has been suspended internally / has complied with employer measures.
7. Section 6 — Submissions on disposal: invitation to close at screening / refer for no further action / accept undertakings, as appropriate.
8. Section 7 — Annexes: CV, certificates, reflective piece, references, occupational health letters, training records.

Tone and drafting

• Plain English. No legalese.
• Calm, professional, candid. Frustration is normal but should not appear on the page.
• Quote, do not paraphrase, the allegation when responding to it — so it is clear what is being addressed.
• Volunteer no more than the allegation requires — but do not be evasive on what the allegation does cover.
• Insight and reflection in the registrant’s own voice. Avoid template phrases.

Red flags to raise expressly

• Anonymous referral — invite the regulator to identify the source or to disregard.
• Time-barred matters — where regulator rules permit a screening-stage application to close on time grounds.
• Matters already dealt with by another regulator or by the employer — risk of double jeopardy.
• Matters that are wholly civil / contractual / personal in nature.
• Manifest factual inaccuracies in the referral.
• Procedural irregularities — letter served out of time, missing documents, mis-identified registrant.

Linking the screening response to later stages

• Stage 0 — Interim Orders: the screening response will be read by any later IOT panel. Make sure nothing in it inadvertently supports the necessity case.
• Stage 1 — Evidence analysis: lock in the analytical framework for the case papers when they arrive.
• Stages 3 and 4 — Unused material and equality of arms: use the screening response to start asking for the right material at the right time.
• Stage 5 — Hearing preparation: the screening response is part of the substantive evidence record if the case goes the distance.

If you would like help on this stage

Regulation Resolution Solicitors act exclusively for healthcare professionals facing NMC, GMC, GDC, HCPC, GPhC and Social Work England proceedings. We offer fixed-fee written advice on any of the stages in this pack — analysis of evidence, redactions, unused material, disclosure, hearing preparation, cross-examination and bundle work. Email [email protected] or visit www.regulationresolution.co.uk.

Important. This document is general guidance for registrants facing fitness-to-practise proceedings before UK healthcare regulators. It is not legal advice and does not replace a conversation with a regulatory solicitor. The points it makes turn on the facts and evidence in any individual case. Where the matter is serious — dishonesty, sexual misconduct, criminal proceedings, vulnerable patients, or an interim order hearing — do not act on this document without specialist advice. © Regulation Resolution Solicitors.

Regulation Resolution Solicitors — Screening stage response templates

Acknowledgement · Partial response · Full substantive response

These three template responses represent three escalating levels of engagement with the regulator at the screening stage, from a bare acknowledgement through to a full substantive response. Each template is structured around the four sections every screening-stage response should cover: career history, response to the allegations, training and reflections done since, and submissions on misconduct or impairment.

Choose the template that best fits your situation, using the “Use this template when” criteria set out under each one. Adapt the placeholder text in square brackets to your facts. Where the guidance says “do not include”, leave that material for the investigation stage.

These templates are general guidance. Every case turns on its own facts — if your case involves dishonesty, sexual misconduct, criminal conviction, vulnerable patients, or an interim order hearing, please contact a specialist regulatory solicitor before sending anything to the regulator.

How to use these templates

• Read all three templates below and the “Use this template when” criteria under each, then decide which level of response your case calls for. When in doubt, the safer course is to say less.
• Open the matching template below and read the section-by-section guidance before you draft.
• Draft once. Set the draft aside for at least 24 hours. Read it cold against the regulator’s letter, then against the evidence you hold, then against this template’s “what to leave out” lists.
• If anything in the draft is uncertain, especially the section 4 submissions on misconduct or impairment, ask for a fixed-fee review before sending.

Template 1 — Acknowledgement letter

The most cautious of the three responses — an acknowledgement only. The objective is to confirm you are engaged with the process without giving any version of events or any material the regulator could use against you later. Save your full account for the investigation stage.

Use this template when: you have not seen the evidence; the allegations are serious; you have not yet completed remediation; or there are no clear factual errors to correct urgently.

Letter format

Send by email and post. Keep to one page. Plain prose, no headings inside the letter itself.

[Your name]
[Your address]
[Your registration number]
[Date]

[Case officer name]
[Regulator — NMC / GMC / GDC / HCPC / GPhC / SWE]
[Regulator address]

Dear [Case Officer],

Re: [Your reference / case number]

Thank you for your letter of [date] enclosing the referral against me. I am writing to acknowledge receipt and to confirm my engagement with the process.

I confirm that the contact details you hold for me are correct. If they change at any point, I will notify you within seven days.

I have noted the issues raised. I do not propose to set out my response to those issues at this stage, as I have not yet had sight of the evidence on which the referral is based. If the matter is referred for investigation, I will engage fully and provide a substantive response in light of the disclosure provided.

I remain in practice and continue to discharge my professional responsibilities in accordance with the [Code / Good Medical Practice / Standards of Conduct, Performance and Ethics — select as appropriate].

I would be grateful if all future correspondence could be sent to me in writing at the address above.

Yours sincerely,
[Your full name]
[Registration number]

Section-by-section guidance

1. Career history

• Do not include a career history at this stage.
• Mentioning length of practice, roles or specialism creates a record the regulator can later test against the evidence. Keep that material for the investigation response, when you can present it in context.

2. Response to the allegations

• Do not respond to the allegations at all.
• Do not deny in absolute terms. Do not partly admit. Do not explain.
• Confirm only that you have received the referral and that you will engage if the matter proceeds.

3. Training or reflections done since

• Do not refer to any training or reflective work at this stage.
• Reflective statements, CPD logs and supervision notes are powerful at the investigation stage when you can tie them precisely to the specific concerns evidenced. Sending them now risks misalignment with the case the regulator later puts.

4. Submissions on misconduct or impairment

• Do not make any submissions on misconduct or impairment.
• You should not engage with the legal test until you have seen the evidence, taken advice on the threshold being applied, and prepared your reflective and remedial package.

Important: if the regulator has raised the possibility of an interim order, the acknowledgement template is not appropriate. Move to the partial or full response template, and seek legal advice the same week.

Template 2 — Partial response

The middle option — a partial response. The objective is to put forward your strongest points — clear factual corrections, important context, completed remediation — while staying measured on weaker or evidentially uncertain points. Target length: 3 to 5 pages plus exhibits.

Use this template when: you have seen enough of the evidence to understand the case; there are clear factual errors or important context to correct now; remediation is well underway; or there is a meaningful chance of closure at screening if the strongest points are made now.

Letter format

Send as a structured response document with a covering letter and a paginated bundle of exhibits. Use the headings below.

[Your name]
[Address] — [Registration number] — [Date]

Dear [Case Officer],

Re: [Reference] — Response to referral

I refer to your letter of [date]. I have considered the matters raised and I set out my response below. A bundle of supporting documents is attached at Annex A.

I would ask the Investigating Committee / Case Examiners to close this matter at the screening stage on the basis of the factual corrections, contextual evidence and remediation set out in this response. I engage fully with the process and remain available to provide any further information that may assist.

Yours sincerely,
[Your full name and registration number]

1. Career history

What to include

• A short factual paragraph (no more than half a page) covering: year of qualification, principal roles, current employer, regulatory standing (no current restrictions, no live concerns history if accurate), and any specialist post-registration qualifications.
• A single sentence on length of unblemished practice (e.g. “I have practised for 12 years with no previous referral and no employer disciplinary findings”) — only if accurate.
• A brief note of any recent senior or training responsibilities (preceptor, mentor, clinical lead) where these speak to your professionalism.

What to leave out

• Detailed CV-style chronology — keep that for the investigation stage if needed.
• Personal information not relevant to fitness to practise (qualifications unrelated to current role, hobbies, professional society memberships unless directly relevant).
• References to past concerns or referrals you are not asked about — do not volunteer history that has not been raised.

2. Response to the allegations

What to include

• A short structured response to each allegation, in the order the regulator has put them.
• For each allegation: (a) a one-line position (Admitted / Partially admitted / Not admitted on the evidence presently available / Factually denied); (b) a short factual account from your perspective; (c) the supporting context the regulator should be aware of; (d) reference to the exhibit number in Annex A that supports your position.
• Specific, evidenced corrections of factual errors in the regulator’s letter — with the source document attached (rota, clinical record entry, training certificate, etc.).
• Where relevant, the outcome of any employer investigation and the action (or lack of action) taken by your employer.

What to leave out

• Detailed responses to allegations you have not yet seen the underlying evidence for — use the phrase “Not admitted on the evidence presently available; I reserve my position pending full disclosure”.
• Absolute denials in unqualified terms (“I absolutely deny this ever happened”) — these are dangerous if any part of the regulator’s evidence is later borne out.
• Any commentary on the complainant’s motives, credibility or character.
• Defensive or aggressive language. Keep tone neutral, professional and factual.

Tip: structure your response in a numbered table mirroring the regulator’s allegations. The case examiners will read it faster, and it makes it harder for them to overlook your strongest factual corrections.

3. Training or reflections done since

What to include

• A concise reflective statement (no more than two pages). Cover: what happened from your perspective; the impact on the patient/service user/colleague/public; what you have learned; what you would do differently; and what you have already changed in your practice.
• A list of specific remediation steps with dates and evidence: courses completed (with certificates), supervision sessions (with supervisor name, dates and a short summary), audits, mentorship, peer review, and any third-party verified changes to practice.
• Where remediation is ongoing, a short plan with target dates — this shows insight even where the work is not yet finished.
• 2 to 3 short character references from senior colleagues who are aware of the concerns and can speak to your practice and insight since.

What to leave out

• A purely defensive reflective statement that blames the system, the patient or colleagues without acknowledging your own role.
• Generic CPD lists with no link to the specific concerns raised.
• Character references from colleagues who are unaware of the referral — these carry no weight and may be challenged.

4. Submissions on misconduct or impairment

What to include

• A short submission applying the relevant legal test to your case. Use the regulator’s own framework (e.g. for the NMC, the Council for Healthcare Regulatory Excellence “CHRE” / PSA test from CHRE v NMC and Grant [2011] EWHC 927 (Admin), considering risk of harm, public confidence and standards).
• Address each limb of the test on the evidence available. Where a limb is not engaged, say so and explain why. Where a limb might be engaged, address it directly and set out the remediation that responds to it.
• A clear ask: closure at screening on the basis that the threshold for misconduct/impairment is not met, or in the alternative that any residual concerns are addressed by the remediation evidenced.
• Where appropriate, an offer of voluntary undertakings as a proportionate alternative to a referral for investigation.

What to leave out

• Final-position legal argument on contested factual matters that you have not yet seen the evidence for.
• Long quotations from case law without applying them to your facts — the case examiners want to see how the law applies to you, not a textbook summary.
• Submissions that engage with allegations beyond those put in the referral letter — stick to what has been raised.

If you are unsure how the test applies to your case, Regulation Resolution Solicitors offer fixed-fee written advice on exactly this point. The advice will set out the test, apply it to your evidence and tell you whether your submissions are pitched correctly.

Template 3 — Full substantive response

The most comprehensive of the three responses — a full substantive response. The objective is to make the case for closure at the screening stage by putting forward the complete factual, contextual and remedial picture. Target length: a structured response document with an executive summary on the first page, plus a paginated, indexed exhibits bundle.

Use this template when: you have seen the evidence; there are clear factual errors to correct; you have strong context; your remediation is robust and evidenced; or there is a real risk of an interim order and you need to put forward a complete risk-reduction case now. The stakes mean you should consider professional input before sending.

Letter format

Send as a structured response document with an executive summary on page 1, a numbered response to each allegation, and an indexed exhibits bundle. Use the headings below.

Executive summary (page 1)

• Three to five short paragraphs at the very top of the response. The case examiners may read nothing else — make these decisive.
• Paragraph 1: who you are, length of practice, current role, regulatory standing.
• Paragraph 2: a one-sentence position on each allegation (admitted / partially admitted / not admitted / factually denied with evidence).
• Paragraph 3: the three or four strongest points in your favour (factual errors corrected, context, completed remediation, employer outcome).
• Paragraph 4: your ask — closure at screening, or in the alternative, voluntary undertakings.
• Paragraph 5 (only if relevant): explicit address of any interim order risk and the risk-reduction package you propose.

1. Career history

What to include

• A full but concise career history (no more than one page). Include: qualification year and institution; chronological list of substantive roles with dates and employers; current role and responsibilities; specialist qualifications and post-registration training; teaching, mentoring or leadership responsibilities.
• Regulatory standing: confirm no current restrictions and no previous fitness to practise findings (if accurate). If there is prior history, address it head-on — the case examiners will see it on their system in any event.
• A short paragraph on the value of your continued practice: scope of your patient/service user contact, specialist skills, current role within the team.
• Two short paragraphs of context on the workplace at the relevant time: staffing, caseload, system pressures, training environment — evidenced by rota records, incident logs, supervisor statements.

What to leave out

• Padding (society memberships, awards, qualifications that do not bear on the issues).
• Anything inconsistent with the documents in your exhibits bundle — cross-check every date and role.

2. Response to the allegations

What to include

• A numbered response, one allegation at a time, in the order the regulator has put them.
• For each allegation: (a) the regulator’s wording verbatim; (b) your position (admitted / partially admitted / not admitted / factually denied); (c) a full factual account from your perspective; (d) specific factual corrections with exhibit references; (e) the contextual factors that bear on the allegation; (f) the actions taken at the time and since.
• A separate sub-section addressing any allegation of dishonesty head-on. Dishonesty allegations are not closed at screening on context alone — you must directly address the Ivey / Re H test and explain why your conduct does not meet it.
• Cross-references to the exhibits bundle for every factual assertion (“Exhibit 7: rota for [date] showing staffing level of X”).
• Outcome of any employer investigation, performance review, supervision plan, or local action — with the underlying documents attached.

What to leave out

• Speculation about the complainant’s motives. If you genuinely believe the referral is malicious or retaliatory, set out the evidence (e.g. timing in relation to a grievance, contemporaneous emails) but do not editorialise.
• Documents that contradict your written account — read every exhibit twice before including it.
• Defensive, dismissive or blame-shifting language. The case examiners are reading for insight.
• Final-position denials of allegations where the underlying evidence has not yet been fully tested — use “not admitted, in the alternative—” framing where appropriate.

3. Training or reflections done since

What to include

• A full reflective statement (3 to 5 pages). Structured under the headings: what happened; my role in it; the impact on the patient/service user/colleague/public; what I have learned; what I have done since; how my practice has changed; how I would manage a similar situation now.
• A remediation portfolio with a contents page, indexed by allegation. For each concern, show: the training completed (with certificates), the supervision arrangements (with supervisor name and dated reflective notes), the audits or peer reviews undertaken, the third-party verified changes to practice, and the ongoing CPD plan.
• Independent verification of remediation: a supervisor’s statement confirming the work done and your insight; an audit signed off by a senior clinician; a mentor’s statement.
• 3 to 5 character references from senior colleagues who are aware of the referral and who can speak directly to your insight and practice since. Include at least one from your current employer if available.
• A short statement on insight: what you understand now that you did not understand at the time of the events; what assumptions or system pressures contributed; what the patient/service user perspective would have been.

What to leave out

• Generic reflective writing that does not engage with the specific concerns raised.
• CPD certificates that bear no relationship to the issues — they dilute the genuinely relevant evidence.
• Statements from referees who are unaware of the referral.
• Anything that reads as performative remorse without underlying change — the case examiners are looking for evidence of real, sustained change in practice.

4. Submissions on misconduct or impairment

What to include

• A structured legal submission applying the relevant test to the evidence. For nursing and midwifery cases, work through the Grant criteria (past acts of impairment; risk of repetition; public confidence; declaring and upholding professional standards). For medical cases, use the GMC’s Sanctions Guidance framework. For other regulators, the equivalent framework.
• Address each limb of the test on the evidence. For each: (a) state the test; (b) apply it to your case; (c) point to the exhibits that support your position.
• Address risk of repetition directly. Demonstrate that the conditions which led to the concerns no longer apply (system changes, role changes, remediation completed, supervision in place).
• Address public confidence directly. Acknowledge what a well-informed member of the public would think, and explain why your remediation and insight address that concern.
• A clear primary ask: closure at the screening stage on the basis that the threshold for misconduct/impairment is not met, or is met but not currently impaired given the remediation evidenced.
• A clear alternative ask: voluntary undertakings (with proposed wording) as a proportionate alternative to referral for investigation.
• Where there is an interim order risk: a separate submission on proportionality, with a proposed risk-reduction package (supervised practice, restricted duties, employer-monitored conditions) that addresses the regulator’s public protection concerns without the need for suspension.

What to leave out

• Long abstract case law summaries — cite the test, apply it to your facts.
• Concessions on impairment that are not strictly necessary — these are difficult to walk back later.
• Submissions on allegations beyond those put by the regulator.
• Anything inconsistent with the executive summary on page 1 — read the whole document end-to-end for internal consistency before sending.

A full substantive response at the screening stage is high-reward and high-risk. If any part of your draft feels uncertain — particularly on dishonesty, sexual misconduct, criminal matters, or interim order risk — Regulation Resolution Solicitors will provide fixed-fee written advice on the evidence against you and on the response you propose to send.

Sending your response

• Send by email and recorded delivery. Keep a complete copy of everything you send, including every exhibit, in a single dated PDF bundle.
• Paginate the exhibits bundle and include a contents page. Cross-reference exhibit numbers in the body of your response.
• Note the deadline in your diary, and a second internal deadline two clear working days earlier to allow for a final read.
• Ask one trusted senior colleague to read the response cold before you send. If they cannot follow your case, the case examiners will not be able to either.
• If you have any doubt about the depth or pitch of your response, contact Regulation Resolution Solicitors for fixed-fee written advice before sending: [email protected] — www.regulationresolution.co.uk

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