MOHAP complaints against doctors, nurses and allied professionals: the process from your side

MOHAP's service Complaints about private health facilities and their medical staff covers MOHAP-licensed private medical and pharmaceutical facilities, and the people who work in them, in Sharjah, Ajman, Umm Al Quwain, Ras Al Khaimah and Fujairah. Complaints about care in Dubai and Abu Dhabi go to the Dubai Health Authority and the Department of Health – Abu Dhabi instead.

A complaint can be filed by a UAE citizen or resident who is "a mentally sane adult above the legal age (21 years)", or by the patient's guardian, a family member or an authorised representative. It is submitted through the MOHAP website, the MOHAP app or a customer service centre, with a complaint form and any relevant medical documents. MOHAP gives a service time of "45 days (according to complaint procedures)". Financial and insurance disputes are redirected rather than handled as medical complaints, and MOHAP states that its decisions can be used in judicial proceedings.

The Executive Regulations of the Medical Liability Law add formal rules (Cabinet Resolution No. 40 of 2019, Art. 8). The complaint is written in Arabic, or translated, states its subject precisely and identifies the complainant and the patient. The complainant may amend it, add documents or withdraw it until the committee's report is issued. Courts and the Public Prosecution must pass any medical-error case they receive to the health authority, so a file can reach MOHAP from a police station or a court as well as from a patient.

If you work in a federal government facility

The complaints service is written for private facilities. In a federal government hospital or clinic, such as one run by Emirates Health Services, the Medical Liability Law still applies, but for discipline the Executive Regulations point federal government staff to the federal human resources law, Federal Decree-Law No. 11 of 2008 (Cabinet Resolution No. 40 of 2019, Art. 18). Ask your employer's HR and legal teams which procedure they are following.

MOHAP sorts complaints into two kinds, and the route your case takes shapes the questions you will be asked.

The technical test in a medical complaint

Under Article 6 of Federal Decree-Law No. 4 of 2016, a medical error arises from one of four causes: ignorance of technical matters that any practitioner of your grade and specialty is expected to know, failure to follow recognised professional and medical standards, failure to exercise due diligence, or negligence and lack of care and precaution. Article 17 excludes liability for, among other things, recognised complications not caused by an error and a different method that still meets accepted standards.

The committee examines the patient and works from the original medical file (Art. 19). That is why your contemporaneous notes carry more weight than anything you write after the complaint arrives.

Protections in how the committee sits

• Conflicts: a member may not sit if related to a party up to the fourth degree, if they work under a party's management or supervision, if they treated the patient for the same condition or if you consulted them on the case (Cabinet Resolution No. 40 of 2019, Art. 12). Raise any such link in writing, early.
• Gross error threshold: classifying an error as gross needs two-thirds of the members present (Art. 11), and the committee must state which criterion it relied on.

MOHAP does not apply one penalty scale to everyone. Two federal laws divide the workforce, and each has its own list, its own ceiling and its own grievance route.

Both laws say that no penalty may be imposed without hearing your statements and your defence, and both say that failing to attend without an acceptable excuse does not prevent a decision. Treat an invitation to be heard as the key date.

The duties each law sets

• Doctors and dentists: Article 17 of Federal Law No. 5 of 2019 requires accuracy and honesty, no exploitation of patients, non-discrimination and respect for professional ethics. Article 24 lists prohibited acts, from out-of-scope practice to referral commissions, and Article 19 restricts self-advertising.
• Nurses, midwives and allied professionals: Article 8 of Federal Law No. 6 of 2023 requires work within the scope of your licence, accuracy and honesty, accurate records, confidentiality, reporting duties, no exploitation of patients, and that you "develop his self-skills and keep up with updates in the area of his specialty".

Pharmacists

The Executive Regulations of the Medical Liability Law still cite an older pharmacy law for pharmacists' discipline. Pharmacy is now governed by Federal Decree-Law No. 38 of 2024, under which MOHAP licenses pharmacists in establishments licensed by the Emirates Drug Establishment. We have not confirmed which disciplinary provisions now apply to pharmacists, so ask MOHAP or your lawyer to identify the article cited in your case.

• Temporary suspension: while a Medical Liability Committee report is pending, or while other violations are investigated, the health authority may suspend your licence for "a period of not more than thirty days renewable to similar periods" (Federal Decree-Law No. 4 of 2016, Art. 23). It is a precaution, not a finding.
• Notice of outside investigations: any body investigating a practitioner must first notify the licensing health authority by official letter naming you, your employer and the subject. MOHAP may send an employee to attend the sessions and submit documents, and must receive the findings (Art. 22; Cabinet Resolution No. 40 of 2019, Art. 16).
• No arrest over an error without a report: no investigation, arrest or temporary detention of a practitioner over a medical error may take place unless the health authority has issued a final medical report confirming a gross medical error (Art. 24).

These safeguards concern the liability and criminal tracks. They do not prevent disciplinary action: under Article 38 penal liability "shall not affect the disciplinary liability", so a criminal matter that ends in your favour does not by itself close a MOHAP disciplinary file.

Count from the date of notification, not from the date you opened the message. Notification of a committee report can be by personal delivery, ordinary or registered mail, fax or e-mail (Cabinet Resolution No. 40 of 2019, Art. 15), so check every channel MOHAP holds for you.

The Supreme Committee of Medical Liability is a permanent federal committee with its office at MOHAP. It may uphold, amend or cancel the first report, and should report within 30 days of referral, extendable (Cabinet Resolution No. 14 of 2020).

1. Read the notice for three things: the route (administrative or medical), the committee, and the date by which you must reply or attend.
2. Secure the record; do not improve it. The Executive Regulations require every action to be documented in the medical file with its type, date and time (Cabinet Resolution No. 40 of 2019, Art. 2). If you must add something, add it as a clearly dated late entry. Editing earlier entries after a complaint invites a second allegation.
3. Contact your insurer and, where needed, a lawyer. Every practitioner must be covered against civil liability for medical errors by a UAE-licensed insurer, and the facility owner arranges and pays for it (Federal Decree-Law No. 4 of 2016, Arts 25 and 26). The law sets no deadline for telling the insurer, so check your policy terms and your facility's procedure, and let them advise on wording.
4. Brief your medical director or quality lead. In an administrative complaint MOHAP asks the facility to respond first, so the two accounts should not conflict.
5. Write a factual chronology. Dates, times, who was present, what was said and what you recorded. Keep memory separate from what the record shows.
6. Respond to the patient's experience, not only the allegation. Explain what you would now do differently and what you have already changed.
7. Check the committee's composition and raise any conflict under Article 12 in writing before the hearing.

The federal route back after a serious outcome differs by profession, and both versions rely on training, reassessment and supervision.

• Physicians and dentists: after a suspension of three to twelve months the authority "may re-evaluate his competence, restrict clinical privileges … or restrict his practice" (Cabinet Resolution No. 67 of 2020, Art. 7.2). A new licence may be granted once the grounds for revocation no longer exist (Art. 8).
• Nurses, midwives and allied professionals: a person whose licence was revoked may reapply when the grounds have ceased. The authority may then impose conditions: mandatory training addressing the causes of revocation, a competence re-assessment, a restricted scope of practice, or practice under the direct supervision of another health professional for a set period. Proof of rehabilitation is required after a conviction involving honour or trust (Cabinet Resolution No. 176 of 2025, Art. 11).
• Revocation that is not disciplinary: a non-physician licence is also revoked automatically if no renewal application is made within six months of expiry, or after six consecutive months of unjustified inactivity (Art. 10); doctors face a similar six-month rule (Cabinet Resolution No. 67 of 2020, Art. 6). If a case keeps you out of practice, ask MOHAP how these rules apply to you.

Good standing during and after a case

MOHAP issues a good standing certificate only after at least three months of MOHAP licensure, and not to a person "sentenced for a medical offense". The national qualification requirements (PQR) describe a good standing certificate as evidence that the professional "has not been found guilty of professional misconduct and has no pending or previous disciplinary orders or criminal proceedings against them". An open MOHAP case can therefore affect an application to the DHA, the DOH or an authority abroad, so plan any move with that in mind and declare the case honestly.

No MOHAP page lists approved remediation courses, and none of the federal laws names a particular ethics course. Training appears in the federal rules as a condition the authority sets case by case, such as the mandatory training that can be attached to re-licensing under Cabinet Resolution No. 176 of 2025. If MOHAP or a committee orders training, complete exactly what is ordered, with any provider it names, and ask in writing before substituting anything.

Self-directed learning does a different job. It shows a committee or employer that you understood the concern and acted on it unprompted. A short, targeted plan reads better than a stack of unrelated certificates:

• One course on the process: the Core Course for Healthcare Professionals Facing a Complaint, Investigation or Disciplinary Action, or Responding to a Patient Complaint or Regulatory Investigation if your case is at an early stage.
• One or two courses on the subject of the complaint, chosen from the table above.
• A reflective component that shows what you would do differently: Developing Insight or Reflective Practice.