The context in which we are working has changed considerably since the publication of our last strategic plan. The COVID-19 pandemic, the UK’s departure from the EU, changes occurring in dentistry, and economic uncertainty mean patients and the public, dental professionals, dental service providers and the GDC face different challenges.
Regulation cannot address some of the challenges that we outline below, and in setting them out we are not indicating that we will be acting to respond to them. Instead, we are explaining the contextual factors that influence both what we do and how we do it. Some parts of the context impact on the GDC directly and will affect what we do and our priorities. In other cases, the impacts will be on our stakeholders and affect how we undertake our work as they respond to the context.
Patients and the public
A variety of factors have affected how patients and the public are able to access dental care, not least the COVID-19 pandemic, changing the context in which we undertake our regulation. This is shown in the research we and others have published.
Some impacts have limited access to dental care and appear to disproportionately affect some members of the public, more than others. There are concerns across the sector that the inequalities that existed before the pandemic have widened.
Changing models of dental care also continue to offer new benefits to the public, but sometimes also bring new risks. The COVID-19 pandemic drove an acceleration in models of dental care that triage patients without having to attend a dental practice. That benefit is coupled with anxieties that some risks, such as the detection of oral cancer, may be enhanced.
Members of the public are also engaging with new models of private dental care, and aesthetic practice delivered by dental professionals, which are making these services more accessible. However, new models of care are not without risk of harm. They can push at the limits of what regulation was designed to do and draw attention to gaps in the regulatory model across the UK.
Dental professionals continue to work in challenging circumstances as they deliver their services to patients and the public. The COVID-19 pandemic has caused massive disruption to dental services and dental professional education with effects which will take time to work through. We recognise that this has caused enormous stress for dental professionals and we applaud the enormous efforts made by so many to sustain patient care despite all the difficulties. The direct and indirect consequences of the pandemic include:
- Concerns about the potential for disruption in dental services to lead to an increase in the number of complaints and concerns over matters those dental professionals cannot control, such as the availability of appointments.
- Concern about dental professionals choosing to leave their roles or adapt their working patterns, reducing the overall workforce even if the number of registered professionals remains stable.
- The need rapidly to adapt approaches to education and training for students, trainees, and new dental professionals to address constraints imposed by COVID-19 precautions and to support new entrants to the professions starting their careers in difficult circumstances.
As the sector responds to the challenges to access to dental care, it becomes ever more important to make the most of the skills of whole dental team. There are of course areas where the dental team has already responded to take on additional activities or roles within their scope of practice where they are trained, competent and indemnified to do so. However, as each nation’s health service and private providers consider how they respond to patient and public demand, the regulatory framework will need to adapt to ensure continuing public protection while not inhibiting innovation.
Regulation will increasingly focus on supporting members of the dental team to make their own judgements about the scope of their professional practice, based on their professional competence, rather than arbitrary lists of tasks. That’s an important change of approach, and we recognise that some members of the team may need additional training and support to do this safely and confidently.
Provision of dental services
There is an imbalance between the need for dental care and the capacity of dental services to provide that care which has come under increasing pressure.
The effects of the UK’s departure from the EU are still playing out because of the UK Government’s decision to temporarily extend recognition of European dentist qualifications, but this arrangement is due to be reviewed in 2023. Any change may influence the decisions of European dentists about whether to choose to work in the UK. The suspension of the Overseas Registration Exam in 2020 and 2021, because of the restrictions of the COVID-19 pandemic, temporarily cut off the route to registration for dentists trained outside the UK and EU. While there are positive steps being taken as result of the UK Government’s plans to remove legislative restrictions on the GDC and introduce new flexibility for routes for international registration, these will take time to implement and cannot be the short-term solution to address challenges in the dental workforce.
Decisions made by the governments of the four nations have implications for the level of NHS provisions and so indirectly for the balance between NHS and private care. Dental service providers are considering their business, contractual and treatment models to make the most of opportunities to deliver services using new models of care and to address financial instability. In some cases, dental service providers have made the decision to move away from NHS services, and this is having an effect on access to dental care. In England, changes are underway for dental services commissioning through the integration of health and social care.
The quality of regulation is very closely linked to the quality of the legislative framework within which it is delivered. In the case of the GDC, that legislative framework has not been fundamentally updated for four decades, and its weaknesses are increasingly apparent. The Government ran a consultation in 2021 which proposed legislative reform for all the healthcare professional regulators, which would allow them to operate more flexibly and move more of their efforts toward prevention of harm rather than responding to the consequences of it.
We strongly support this approach and believe that greater legislative flexibility would allow us to deliver our functions more effectively and more efficiently. But the timetable for reform remains very unclear. It is possible that legislative reform and its operational consequences will be of central importance during the coming strategy period, but that is far from certain. In the light of that uncertainty, we will prioritise our efforts in areas where there is the greatest potential for improvement within the current legal framework, while also continuing to prepare – and press – for progress on legislative reform.
There will be more rapid change in the legal framework governing the registration of dental professionals on the basis of qualifications gained outside the UK. We want to ensure that the international registration system protects patients while also being fair to applicants. The removal of over-prescriptive legislative rules will allow us to do that more effectively than is possible now. Making changes to our routes to international registration is not a fast process and will require careful consideration of the measures to protect the public and to establish new processes.