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GDC Chair addresses delegates at the LDC Conference, Harrogate, 9 June 2023

09 June, 2023

GDC Chair, Lord Toby Harris, has today spoken to delegates at the LDC Conference 2023, he said (checked against delivery):

Good morning, and I am very pleased to have been able to join you last night at the annual dinner and to be here speaking at your conference today.

And thank you Mark [Chair of LDC Conference 2023] for that introduction. I read your stirring words about this conference, about the intimate connection that the professions have with the people they serve, and the importance you place on NHS dentistry. Like you, and everyone represented here, the public is at the heart of what the GDC does, and as you know our primary purpose is to protect patient safety and maintain public confidence in dental services.

And central to that is my belief that we can only be a truly effective regulator if we are able to develop and maintain strong, effective collaborative working relationships.

So that is why I put a particular importance on the regular meetings that the GDC team has with our different and diverse stakeholders across the profession, including the professional associations and membership bodies, education providers, other groups such as indemnifiers, patient advocacy groups and the charities that support dental professionals, as well of course with Government, the CDOs and the departments of health, across the four nations of the UK.

It’s also critical that the 115,000 registered dental professionals - and thousands of students who are studying to become dentists or dental care professionals - clearly understand who we are and what we do.

That’s why we send out the monthly newsletters - newsletters that are read by well over half of all dental professionals. It is why our student engagement programme has involved over 2,500 students and newly qualified dentists in the last 12 months.

We also had a stand and GDC speakers at the Dentistry Show in Birmingham and the Scottish Dental Show in May. Attending these sorts of events is important as it is an opportunity for the GDC to provide workshops and presentations where people can engage with us in person. 

They are an invaluable opportunity to listen to what our stakeholders have to say, and to hear from dental professionals first-hand. To give them the opportunity to share their challenges and concerns with the GDC. At those events, questions ranged from practical topics such as CPD requirements and registration, to updates on international registration and discussions about the GDC’s consultations to which we have been encouraging dental professionals to respond.

And while these consultations support our ambitions to focus more of our regulatory activities on prevention rather than enforcement, it is important that we hear what you think and feel about these changes, as they are about our standards and guidance and how you deliver care to your patients.

And this desire to improve collaboration and build relationships has been the motivation to create the Dental Leadership Network.  It first met in November and seeks to bring leaders from across the professions together to share common challenges and opportunities.

Topics discussed there have included 'leadership in dentistry’, and ‘developing the whole dental team’. The next meeting on 6 July will focus on what we are calling ‘the system’ – with the aim of developing a shared understanding of what the constraints, opportunities and the role each organisation has to play, from the perspective of dental leaders and dental professionals.

Many of you will have been invited already, but if you want to find out more about the Dental Leadership Network please speak to my GDC colleagues, who are with us today and will be happy to explain more.

As Chair of Council, I also meet regularly with stakeholders. This not only provides a valuable way of sharing GDC priorities, but gives me the opportunity to hear from leaders, like you, across the profession who represent the dental professionals that we regulate, to understand your priorities and challenges, and to identify ways we can work collaboratively to address these.

We may not always agree. However, what is important is that we listen to each other and have a constructive dialogue.  Another reason why I am so pleased to be here today.

Mark, you have warned that the business model in the NHS is forcing so many into the private sector.

Hardly a day passes without news stories or Parliamentary questions about how difficult it is for many patients to access dental services.

Indeed, the GDC’s research on the public’s views and experiences of dentistry, published a couple of weeks ago, showed that people continue to experience serious issues in accessing dental care, particularly on the NHS, and that the proportion of patients accessing private dental services has risen.

Our research also showed that around a quarter of patients are making an active choice to reduce their dental care due to concerns over costs. Those who are struggling with the cost of living may be more likely to visit a dental professional only when they are experiencing a problem or know they need treatment, rather than for check-ups and prevention.  These are troubling findings, and we will continue to monitor this through future research.

That said, the research also showed that there has been a significant increase in the number of people seeing a dental professional, compared with 2021. And in terms of public confidence, two-thirds of people told us they were confident in the quality of dental services available, with most people satisfied with the dental care they had received.

As many of you will know, the regulatory reforms that we have called for - for many years – are still a long way off. This means that the GDC remains restricted in what we can do fundamentally to improve our regulatory activities.

That said, we can make changes in the absence of regulatory reform, and I will come back to that shortly.

Dentistry and its regulation are complex. There are many organisations performing different functions and the systems across each of the four nations are different.

There are also important issues of widespread concern across dentistry –  and some of these have implications for public safety and wellbeing.

These include – of course – the problems of accessing NHS dentistry; the increase in ‘dental deserts’, particularly in some rural areas; or the increasing numbers of children who have never visited a dentist.  And these all contribute to growing inequalities, with the vulnerable being most affected.

The GDC’s purpose is patient safety and public confidence – but we can only deliver this within our regulatory remit, where we have powers to act.

That’s why collaboration and having effective working relationships across the sector is vital. Especially as many of the issues we face extend across the functions of multiple organisations and stakeholders, and its only by working in collaboration, that we can all contribute and really make a difference for patients.

Central to this debate is the nature – the changing nature – of the dental workforce.

Our registration figures over the last five years show that dentist numbers have increased slowly on an annual basis. That is a fact – but will not accord with the lived experience of those struggling to access the dental care they need.

The BDA recently highlighted that the number of NHS dentists is over 1,100 down on the number’s pre-pandemic. And it is of course the case that we don’t know what the dental professionals on our register are actually doing. Are they in patient facing roles, are they working full or part time, are they working in NHS, private dentistry or both.

Workforce planning does not lie within the GDC’s statutory remit. But the workforce data that we hold could be an essential part of informing the wider discussion about the challenges facing the profession – and for that matter the public - particularly around access to NHS dental services.

So, whilst the workforce challenges are beyond our powers to solve, the GDC may be able to do more to illuminate public debate about these matters.

And that is something I have been discussing with colleagues and stakeholders in recent months.

Everyone I have spoken to about this has seen the value of capturing some simple workforce data: are registrants practicing full-time or part-time; how much of their work is under the NHS contract; and so on.

This simple factual data could be collected as part of the annual renewal process.  We would have to make sure that this did not compromise the core renewal process itself.

It would have to be on a voluntary basis, but I hope that this will have the active support of the wider dental community, so as to ensure that meaningful information can be collected.

If we can get the technology in place, we hope to have this ready for the dentist renewal process at the end of the year.

We are looking to do this because there is a clear need for the information, and we are well placed to collect it. It is not a core function of our regulatory remit, but to do this we would believe be helpful to ensuring that the wider political debate on the future direction of dentistry in the UK is properly informed and soundly based in facts.

I hope that we can rely of the support of the BDA - and you as LDC Chairs - to support this initiative and reassure dentists as to why the data is being asked for and how it will be used.

The issues in NHS dentistry are a big part of why there has been so much attention on international registration recently, and in particular the perceived bottleneck for overseas dentists who want to sit the overseas registration examination. International registration has been a key area of focus for the GDC Council.

New legislation that came into effect in March gave us new powers to modernise our international registration processes.

Over the medium to long-term, our ambition is to create a coherent and comprehensive framework for international registration which is fair to applicants, efficient to deliver – and above all - is rigorous in protecting patient safety and maintaining the high standards of dentistry to which we are accustomed in this country.

Our next step will be to prepare and consult on new rules, likely to be in July, that will come into force next year. These changes to the ORE will enable us to have greater efficiency and flexibility in capacity, and will extend who can deliver the ORE, there no longer being a requirement for providers to be a dental authority.

Alongside that we will run a procurement exercise for the ORE. We also need to draft and consult on new rules to govern overseas DCP applications.

So, a lot happening in a relatively short period of time!

But we want to make sure that we have time to work with stakeholders, to explore and propose new approaches that take full advantage of the new legislation, but at the same time maintain the rigour of our standards while ensuring that there is sufficient capacity to meet demand.

There are currently around 1,500 candidates waiting to sit Part 1. And in response to this, we have recently trebled the number places for the ORE Part 1. There will now be 600 places available for the August 2023 sitting of the ORE Part 1, instead of the usual 200 – and we will maintain these numbers for future sittings in 2024.

Booking will open to candidates next week and remain open until all the places are filled.

We are also in discussions with our provider to increase the capacity of the ORE Part 2, and we hope to be able to say more on this in the coming weeks.

But I do want to clear about this: while improving the throughput of those from overseas who want to be registered in this country is the right thing to be doing, provided we can maintain the standards that the public would expect, it is not some magic bullet that will solve the problems in NHS dentistry.

If the contractual terms by which NHS services are provided are unattractive to many dentists currently on the register, then there is no reason why those same terms will be any more attractive to new registrants – whether they are from overseas or who qualify here.

That is not an issue that the GDC can solve. Ultimately, it is a matter for those who are responsible for those contractual arrangements. It is in the interests of the public that they do so.

Before closing, I want to talk more widely about regulatory reform. We know that our current legislative framework continues to limit our ability to adapt to meet the changing needs of patients and the dental team, and to drive improvements across our regulatory functions.

Some progress has been made, with the recent consultation from DHSC on the regulation of anaesthesia associates and physician associates by the GMC, although we would have some reservations about some of those changes if applied in a dentistry context.

Nevertheless, the pace of change is far too slow and I am frustrated and concerned that there is no timetable yet for the GDC’s reform, and that this is at best several years away.

And it is against this delay in wider regulatory reform that we have been looking again at changes we can make within our current legislation to improve our operations in registration and fitness to practise – not least because we recognise what a stressful experience the latter can be for those involved.

Back in February we confirmed we had introduced some small but important changes to our fitness to practise processes.

These changes aim to reduce the impacts on those subject to investigations – particularly those facing long-standing or multiple investigations. The objective is also to improve case progression, and make best use of limited resources in the absence of regulatory reform.

The changes that we have made mean we will not automatically open cases for matters referred to us from the NHS, where the NHS is either investigating or managing the issues locally. We will only open an investigation if there is a serious or immediate risk to public safety or confidence and, if appropriate, refer the matter to the Interim Orders Committee. 

Finally, the Registrar has, for some time, been reviewing and closing some older cases, those where there is no realistic prospect of establishing that a dental professional’s fitness to practise is impaired.

In registration, we have been focused on improving our performance after a particularly challenging time in 2022, and I’m pleased to say that nearly all our UK registration processes are back to their previous levels.

I’m also pleased that the Registrar has made a small change to the process that dental professionals need to use to restore to the register if there is an issue with their annual renewal.

People who have been off the register for less than 12 months and have always complied with CPD will now be able to sign a declaration that their CPD is up to date, rather than send us a copy of their full CPD record.

This change is much more proportionate and should make it quicker and easier to restore, providing that your CPD record is intact, and you have met CPD requirements. This new process is now in place - in time for the annual renewal for dental care professionals.

Finally, whenever I speak on behalf of the GDC, I always consider what patients or the public would think if they were here in great number, listening to us today.

The GDC’s purpose is to protect, promote and maintain the health, safety and wellbeing of the public.

And patient safety is a goal that all of us here share. It unites us.

We may have different perspectives of what to change or what to prioritise to achieve it – but the important thing is that we individually and collectively place patient safety at the centre of all that we do.

Everyone in this room has a vital role in delivering safe and effective oral healthcare to patients and the public.

I am grateful for all that you do and I look forward to working collaboratively with you, building our relationships and increasing the mutual understanding of both our different, but also our shared, priorities and challenges.

Thank you again for your time.