What this means
Start with the exact decision in front of you.
During investigation the GOC may obtain clinical records, statements and expert opinion before inviting written representations. The response should address the disclosed evidence and preserve the distinction between original records and later explanation.
Immediate priorities
Organise the position before responding.
Index the evidence against each concern
Request missing material needed for a fair response
Submit focused representations by the stated date
Detailed guidance
The procedure, evidence and possible route from here.
01
Understand how the GOC builds the investigation file
After opening a formal investigation, the GOC may gather clinical records, witness statements and independent expert opinion. The evidence is then disclosed to the registrant for written representations before case-examiner consideration, with complainant comment also forming part of the process. Keep an inventory of every item received, its page range, date and source. This allows missing records, duplicate material and expert assumptions to be identified before the response is drafted.
The investigator gathers evidence; case examiners make the later screening decision. Correspondence should therefore clarify evidence and process without assuming the caseworker has power to determine the final outcome. If material is missing or illegible, request it specifically and explain why it bears on the response. Follow the deadline in the current notice and seek any justified extension before it expires rather than relying on an assumed standard period.
- Index disclosure by source and allegation
- Raise specific evidence gaps promptly
- Use the date stated in the current notice
02
Connect clinical explanation to the contemporaneous record
Optical cases may involve examination technique, referral, prescription, dispensing, consent, communication or record keeping. For each allegation, describe the information available at the time, the decision made and its professional basis. Avoid judging the decision solely through a later outcome. If an expert opinion uses a disputed fact or incomplete record, identify the premise and supply reliable contrary material rather than dismissing the opinion as a whole.
Business or supervision context may matter where work was delegated, equipment failed or a policy shaped practice. Explain the registrant's own duty and the organisational setting together. A systems issue does not erase individual accountability, while a registered business may have a distinct obligation. Where multiple registrants are involved, do not speculate about another person's motives or evidence; state the first-hand facts and documents supporting the account.
- Explain decisions using information available at the time
- Test expert assumptions against source records
- Distinguish personal, supervisory and business duties
03
Use representations to address both evidence and present risk
Structure the submission allegation by allegation, marking admissions, disputes and necessary context. Then address current practice with evidence suited to the concern: audit, peer review, assessed learning, supervision, health management or changed business controls. A course list alone rarely demonstrates application. Show what changed in patient care, how it was evaluated and over what period the improvement has been observed.
The response should end with the outcome supported at the case-examiner stage, without assuming that a final hearing sanction is already being chosen. If advice or a warning is possible, understand its publication and professional implications before making alternative submissions. Keep the final signed response, enclosures and proof of delivery. Later stages may compare that account with oral evidence, so unresolved ambiguity should be corrected transparently rather than left to harden into the record.
- State the position on every allegation
- Demonstrate current change through relevant evidence
- Preserve the exact submitted version and enclosures
Key questions
Keep the analysis tied to this stage.
Accuracy and completeness of the evidence
Whether the concern is resolved or remains serious
What should be placed before case examiners
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Can the GOC obtain independent clinical opinion?
Yes. Its published investigation process says evidence may include independent expert clinical opinion. Check the expert's instructions, material and assumptions when responding.
Will the complainant see my representations?
The GOC process allows the complainant an opportunity to comment on registrant representations. Treat confidentiality and third-party information carefully and follow any specific directions from the GOC.
Connected guidance
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Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.