Case file: Advice

Suspicious conduct

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  • Date: 22 September 2023
  • |
  • 2 minute read


A dental associate – Mr J – contacts the MDDUS advisory service suspecting systematic breaches of NHS regulations at the dental practice where he works. These include duplicate claiming of NHS fees and shortened treatment times to allow UDA targets to be met. It is his opinion that his own conduct has been “by the book” and he has announced his intention to leave the practice.

Mr J requests MDDUS advice to ensure he does not get caught up in any formal accusations of fraud.


An MDDUS dental adviser responds by letter. She states that finding a new job would be a wise move. Given that, in his opinion, Mr J’s conduct has been exemplary in terms of treatment delivery and claiming patterns there should be little risk of being caught up in any investigation undertaken by, for example, the BSA.

The adviser does suggest that, before departing the practice, Mr J should raise concerns regarding the apparent departures from the NHS regulations. Should there later be any accusation of turning a blind eye to these problems, Mr J would have an audit trail to demonstrate the apparent mis-claiming was drawn to the attention of the practice owners. How these issues are then remediated would be a matter for the practice to address.

Mr J is also advised to act in accordance with General Dental Council Standards (principle 8.2.5) to raise concerns if patients are at risk:

If you think that the public and patients need to be protected from a dental professional registered with the GDC, you must refer your concern to us. This may be appropriate when:

  • taking action at a local level is not practical; or
  • action at a local level has failed; or
  • the problem is so severe that the GDC clearly needs to be involved (for example, issues of indecency, violence, dishonesty, serious crime or illegal practice); or
  • there is a genuine fear of victimisation or deliberate concealment; or
  • you believe a registrant may not be fit to practise because of his or her health, performance or conduct.


  • Keep an adequate audit trail of your own practice to demonstrate compliance with NHS regulations.
  • Report concerns over potential fraud to the practice owners and raise with BSA/NHSE if appropriate to do so.
  • Keep a record of your actions.

This page was correct at the time of publication. Any guidance is intended as general guidance for members only. If you are a member and need specific advice relating to your own circumstances, please contact one of our advisers.

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