COVID-19: guidance from the GDC
Page last updated: 3 April 2020
These are difficult and worrying times for us all as we navigate the many challenges we face and try to develop good solutions to problems as they emerge.
The absence of immediate certainty understandably will lead to frustration and concern and, for
our part, we are working to minimise this wherever we can.
In the absence of immediate answers, please know that we are being guided by two main principles. When developing our approach, we are seeking to:
- minimise the regulatory burden on dental professionals wherever possible
- maximise flexibility for dental professionals to manage their professional activities in response to the challenges of COVID-19.
Being redeployed and working outside your scope of practice
The NHS is increasingly asking dental professionals to be ready to support the wider COVID-19 response by using their professional skills and experience outside the normal range of dental and oral health activities. As a regulator, we want to support registrants to take part.
While the same basic patient safety principles should remain (i.e. that individuals use their professional judgement to decide if they are trained, competent and indemnified to undertake the task in hand), the GDC has no interest in second guessing those clinical judgements.
With regards to competence, the health services are currently reviewing how dental skills map to wider medical tasks. For activity which falls outside of this, appropriate training should be provided which will provide professionals with the reassurance they need.
With regards to indemnity, the Coronavirus Act makes provision for this, but registrants should check with their existing indemnifiers and, where appropriate, with the relevant NHS authority, that coverage is in place before commencing work.
Several healthcare regulators have either long-standing or recently granted powers to give temporary registration in emergency situations to professionals whose registration has lapsed.
This does not apply to the GDC at present and it is not within our power to change this.
If and when this changes, we will be ready to support professionals back onto our registers as quickly as possible.
Your professional judgement and our approach to regulation
Expert advice on the clinical aspects of COVID-19 will continue to come from the health authorities of the four nations and we will continue to signpost to this guidance as and when it is updated. But that guidance will inevitably not cover every potential scenario, and therefore, dental professionals will need to continue exercising their professional judgement and weigh the risks in any given situation. They will also need to continue to assess whether they are trained, competent and indemnified to carry out the activity in question.
However, in the recent joint statement from the healthcare regulators we said that we understand that in highly challenging circumstances, professionals may need to depart from established procedures to care for patients and that should concerns be raised, relevant environmental and human factors would be taken into account.
Continuing professional development
We know that all face-to-face CPD activity has now been cancelled due to the restrictions in place, and we understand that this is likely to affect dental professionals’ ability to meet CPD requirements for this cycle year.
We would like to be clear that nobody will be removed from the register due to a lack of access to CPD. In general, any set-back related to the pandemic will be considered sympathetically if 2020 CPD requirements cannot be met.
There are some steps though that dental professionals might want to take when, or if, they are able.
The first is to check how much CPD has already been recorded on eGDC. The five-year CPD cycle offers a lot of flexibility and it’s perfectly acceptable to submit a return of zero hours for the current year, if 10 or more hours were recorded the previous year.
There is also no requirement for CPD to take a particular form and the CPD Provider Guidance provides information about what is required for a CPD activity to meet the verifiable criteria.
Information for students
Thousands of students will have been due to complete their professional training over the coming months, before registering with the GDC.
Teaching and assessments have been severely disrupted, but we have been working with education providers to ensure that as many students as possible can still have a smooth transition into practice.
We, and they, have prepared a joint statement setting out our shared approach which we recommend all students and recent graduates read.
Our approach to fitness to practise
This is not a time for fitness to practise cases to be a distraction but even in current circumstances, people may have legitimate concerns, and it is important that they are able to raise them with us.
If they do, we are under a legal duty to investigate them.
We will continue to record and make a risk assessment of new fitness to practise concerns and we will continue to progress new and existing cases as far as we can.
However, with regards to hearings, except for the small number of cases where we perceive an immediate risk to patient safety, almost all fitness to practise hearings have now been postponed.
For the urgent hearings, we are exploring how we can best run these remotely.
The Overseas Registration Exam (ORE)
Due to the current restrictions, Part 1 and Part 2 of the Overseas Registration Exams (ORE) scheduled for April have been postponed.
We understand this will be a frustration and a concern, both for those booked to sit the exams and for employers in some parts of the country where recruitment has been challenging. While there are too many unknown factors at this point to make a guarantee, our aim will be to re-arrange this round of exams later in the year, in addition to those which are already scheduled, so as to avoid reducing the year’s capacity for places.