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By law all complaints received by the GCC must be considered by an Investigating Committee (consisting of both lay and registered members). Their role is not to decide on the details of the case, but decide whether there is a case to answer:

Would the conduct (if proven) be unacceptable professional conduct?

  • Is there enough evidence to make a case?
  • Is it in the public interest to consider the case?
  • Where they find a case to answer, it is put forward to a full hearing of the Professional Conduct Committee (around 12 cases a year).

While the majority of IC cases are closed with no further action without comment, occasionally the IC will find there is no case to answer, but nevertheless use the opportunity to provide advice to the registrant. This advice will not be recorded on the public register, as it is not a formal sanction, but the fact that advice was issued may be called upon if another complaint is made against the same registrant.

Background to the case

A patient made a complaint alleging that the chiropractor (the registrant) had injured them in the course of their treatment. The Clinical Advisor instructed by the GCC did not identify any concerns with the approach to treatment, however they noted that the notes provided by the Complainant and the Registrant differed significantly.

Standard H3 of the Code (2016) states you must:

H3: Ensure your patient records are kept up to date, legible, attributable, and truly representative of your interaction with each patient.

The registrant explained that they had left the clinic where they had treated the patient. The registrant had provided the GCC with a copy of their contemporaneous notes, while the patient had been given notes that had been edited later as part of a handover before the registrant left the clinic. The registrant apologised to the complainant for the confusion.

Investigating Committee Finding

The Investigating Committee accepted the registrant’s explanation, and noted that he had now changed his practice to specifically highlight any retrospective changes made to clinical notes.

The Committee found that there was insufficient evidence capable of supporting a finding that there had been intentional or dishonest behaviour by the Registrant in respect of his clinical notes.

Learning

Although it has always been good practice to highlight any retrospective changes to clinical notes, from the 1 January 2026, it will specifically be part of the Code of Professional Practice.

Standard J2 in the Code of Professional Practice (2026) states:

J2: (you must) be accountable for keeping patient records up to date, legible, and attributable. Your record must accurately represent each interaction with the patient. Retrospective amendments or additions to patient records must be identified clearly.

As a result of this specific case, it has become clear that not all digital clinical records systems on the market used by Chiropractors and Clinics have the functionality to show edits and retrospective adjustments made to records.

You may wish to contact your provider to ensure that this feature will be available for 1 January 2026, or consider a workaround to ensure the accuracy of any retrospective amendments made to patient records.

Further Reading