Frequently Asked Questions

Learn more about potential changes to the Professional Liability Program.

What has RCDSO decided about PLP?

At the December 2023 meeting, Council directed staff to proceed with exploring the transfer of the Professional Liability Program (including current liabilities and staff) to a third party, with the goal of allowing the program to continue to operate, under separate ownership.

Council asked staff to begin the procurement process under the guidance of a Procurement Review Group. An external mergers and acquisitions advisor, PricewaterhouseCoopers (PwC) has been retained. Currently, the College is in negotiations with a third party liability provider and registrants should expect an announcement by late summer.

Council is provided with regular progress reports and deliberations are viewable on the RCDSO YouTube channel.

Is PLP still accepting new claims?

Yes, it is business as usual for PLP and there have been no changes made to the operation of the program. Stability for both patients and dentists will be maintained throughout the transition process. New and existing PLP cases will continue to be handled in the usual manner.

Once a provider has been selected, additional information will be provided to all registrants. Current registrants have coverage via the program until the end of 2025. When registrants pay their fees in fall of 2025, professional liability coverage will continue for the entire 2026 calendar year.

Dentists should continue to contact PLP directly for advice or assistance with potential, new or existing claims online at plp.rcdso.org or info@plpservices.org.

What is the College looking for in a new provider?

Expectations of the new program include:

Minimum liability limits, as determined by the RCDSO.
A comparable rate for all dentists (generalist or specialist) or types of dental procedures performed.
Tail coverage for dentists if they move to another jurisdiction to practice, when they retire, or if they pass away.
Acceptance of current PLP policy wording, or close to it, with no unreasonable additional terms, conditions, or exclusions adverse to the profession or public.
Coverage in the group model for all dentists to whom the college grants a licence
Integrating PLP’s current staff into the new program.
Supporting dentists beyond the claims process such as: providing advice to de-escalate and manage difficult situations; drafting legal release documents that provide refunds properly; supporting and guiding dentists through a litigation process.
Risk management initiatives such as continuing education courses, advisories/publications, and exploring and identifying trends in the profession (e.g. injuries, procedures).
Fair and reasonable cost.

How much will my fee increase in 2026 due to the change in operations of the PLP program?

The College’s PLP estimated fees have been frozen for the past three years, despite rising costs. Those fees were considerably under-market and the program itself was underfunded. The amount the new provider will require for professional liability protection will be higher, resulting in the need for an increase in the professional liability fee for 2026 from $1,000 to $1,400 plus fees.

The total liability cost will be $1,500.

These costs are competitive with other Canadian provinces. In 2026, the increase in liability costs will amount to $500 over previous years. All efforts are being made to keep the fee stable for the next three years.

Will Regulatory fees also increase in 2026?

No. Regulatory fees are frozen for 2026. The proposed by-law changes are available at Public Consultations.

Will there be a CPI increase for 2026?

No. Council proposed waiving the annual CPI increase (almost $55) to help mitigate the costs of the liability increase. The proposed by-law changes are available at Public Consultations.

What will happen at annual renewal with respect to payment of my fees?

Nothing will change. You will use the same process to renew for 2026, and your liability protection will continue to be offered through your registration. To support a stable transition, the College will collect the annual professional liability costs on behalf of the new provider for 2026.

I'm still paying my liability fee to the College during renewal. How does that money get to the new provider?

To ensure a smooth transition, the College will collect liability during the renewal process on behalf of the new provider. The College will transfer the entire amount to the new provider. The College does not keep any portion of the liability cost.

What minimum limits will be required?

Council and the profession made it clear that liability costs should be fair and reasonable.

Consistent with other Ontario health Colleges, RCDSO will mandate minimum limits. Currently, liability limits are $2 million which is consistent with most Canadian regulators’ requirements although a couple require higher limits.

Once the RCDSO no longer owns and operates the program, it will need to find an alternative way to establish requirements for professional liability protection.

RCDSO staff, with advice from the Procurement Review Group (PRG) and legal counsel developed By-Law changes that will establish what each registrant must obtain by way of protection to ensure that the public is protected. The profession had an opportunity to provide feedback from January 24 to March 25, 2025.

Highlights of the amendments include:

Requiring all members to have professional liability protection to be registered;
Establishing an ongoing obligation to maintain professional liability protection; and
Introducing a mechanism to suspend a member if professional liability is not maintained and accompanying reinstatement provisions.

When would these changes become effective?

PLP continues to operate as a program of the RCDSO today. When registrants pay their fees in fall of 2025, professional liability coverage will continue for the entire 2026 calendar year, but the program will be operated by a third party.

Once the agreement has been finalized, additional information will be provided to all registrants.

The profession will not need to seek alternative coverage for 2026.

When do I have to look for a new provider?

It is anticipated that members will not need to look for a new program, as the new provider will take on the existing program and dentists will continue to have seamless liability protection for a period of time. Once paying registration fees for 2026, dentists will have coverage in place for the calendar year.

When a new provider is announced, the goal is to maintain stability and allow for continued coverage for all registrants.

How will the College ensure that dentists have liability coverage?

RCDSO Council approved, in principle, draft amendments to the Registration requirements under the General Regulation (O. Reg. 205/94) of the Dentistry Act.

These proposed changes relate primarily to the divestment of PLP. The changes will require that dentists have liability coverage to register and renew their licence with the College at a future date.

These proposed changes are not in effect and do not impact current coverage. Dentists should continue to contact PLP directly for advice or assistance.

Highlights of the draft amendments include:

Requiring all members to have professional liability protection to be registered
Establishing an ongoing obligation to maintain professional liability protection
Mechanisms to suspend membership if professional liability is not maintained
Streamlining registration processes related to work authorization and continuous practice requirements
Adding exclusions to the reinstatement provisions to enhance public protection.

Visit our consultations page to learn more.

What happens to my coverage when I retire?

By direction of Council, one of the expectations we have laid out for the potential new provider is that they provide tail coverage for dentists if they move to another jurisdiction, when they retire or if they pass away.

When will we hear more?

RCDSO will report regularly at Council meetings. We will continue to update the public, registrants and stakeholders as we progress. Registrants can expect to hear more by late summer.

Have you consulted with the profession?

RCDSO has been communicating regularly with registrants and stakeholders through e-blasts, newsletters and Council Highlights. In November 2023, RCDSO sent a survey to the profession on what they consider the most important elements of the program. Over 1600 responses were received. A full report on the survey results was presented at Council in December 2023 and is posted on the website here.

What is happening with PLP?

The Professional Liability Program (PLP) has been providing assistance to Ontario dentists for over 50 years. During that time, numerous staff and Council members have been dedicated to the promotion of patient safety and responsible dentistry.

In 2022, the Audit Committee and the Finance, Property and Administration (FPA) Committee reviewed the PLP program, its history, legislation, financial structure and assessed other comparable programs in Canada. As a result, Council established a PLP Expert Review Task Force to do a thorough review of the PLP program, outline any risks and recommend options to mitigate these risks on or before the September 2023 Council meeting.

The Expert Review Task Force, composed of liability and regulatory experts (including former Council members) met from February to July of 2023 and developed a report for review by the (now) Finance, Audit and Risk (FAR) Committee. After that review, the report findings and FAR’s analysis were presented to Council on September 21st. There, Council unanimously agreed that the College should not continue to directly operate PLP as it is currently structured.

With Council’s direction, RCDSO staff developed an implementation plan, with deliverables and timelines and created a Strengths, Weaknesses, Opportunities, and Threats (SWOT) analysis of four divestment approaches.

At the December 2023 meeting, after reviewing the options and key considerations, Council directed staff to proceed with the option of exploring the transfer of the Professional Liability Program (including current liabilities and staff) to a third party, with the goal of allowing the program to continue to operate, under separate ownership.

Council directed staff to begin a procurement process, guided by the proposed assumptions and key elements outlined, and under the guidance of a procurement review group. The procurement process resulted in the appointment of PricewaterhouseCoopers (PwC) as advisors. The Procurement Review Group was formed in early 2024 and is meeting regularly.

Council is receiving regular progress reports on the divestment project.

Council deliberations are viewable on the RCDSO YouTube channel.

Why was the Task Force struck in the first place?

Several risks have been identified with PLP, foremost among them are reputational, regulatory and financial risks.

RCDSO is one of the few health regulatory Colleges in Canada that directly operates an in-house liability program.

Over the past several years, negative media stories, changing expectations of professional regulation, and the RCDSO’s commitment to act in the public interest have caused RCDSO to consider the benefits, risks and appropriateness of this non-legislated program as an operational department of the College.

One of the College’s primary regulatory responsibilities is to hold dentists accountable for conduct and practice issues; PLP serves as the primary malpractice protection provider for those same dentists. While there is a firewall between PLP and our regulatory programs, this divergence in mandate and function is confusing to both the public and dentists and raises questions about how we can effectively serve both mandates.

The College is also expected to be a responsible steward of its financial resources in achieving its statutory objectives and regulatory mandate, and the direct operation of PLP has presented some challenges to the RCDSO’s financial position including the completion of an adequate non-PLP operating reserve.

What did the Task Force recommend?

The Task Force Report presented a number of options with benefits and risks to help Council determine the best option for RCDSO.

The Task Force identified three options:

Status Quo: RCDSO retains the current structure of PLP with minor modifications that could mitigate risk.
Subsidiary: RCDSO establishes a subsidiary corporation. This would create structural separation of mandate and finances, while RCDSO would retain ownership of the program.
Divest: RCDSO stops directly offering its liability protection program over time and moves to transfer, sell or end the program

The report provided Council with considerable information to help make this decision.

The program has been working well for 50 years, why change now?

There are a number of environmental changes, including public expectations that have changed since PLP was first established.

RCDSO is one of the few health regulatory Colleges in Canada that directly operates an in-house liability program.

PLP’s mission and function are distinct from the rest of the College’s, whose mandate is to “serve and protect the public interest.”

If an unexpected major financial event were to occur (one that exceeds the current reserve fund plus the $20 million available in reinsurance), the RCDSO would be required to draw from its regulatory reserves or to impose a fee to the profession.

I have further questions about PLP changes, who can I contact?

For general information, please contact the RCDSO’s Practice Advisory Service at practiceadvisory@rcdso.org or call 416-961-6555 or toll-free 1-800-565-4591.