1. Workforce and recognition of qualifications
EU dentists working in the UK
While the UK was a member of the EU, EU citizens with a dental degree from an EU country benefitted from automatic recognition of qualifications based on the principle of free movement for EU citizens across the European Union. This meant that dentists qualified in the EU could come to work in the UK, as long as they had relevant language knowledge; registration was straightforward. There is no change to this during the transition period.
Around 16-17 percent of the UK dentist workforce is registered on the basis of an EU/EEA degree; this includes UK citizens who have studied in Europe. The registration of those currently registered should not be jeopardised by Brexit.
With regard to EU citizens coming to work in the UK in the future, the process for the recognition of their qualifications is unclear at the moment as it depends on government negotiations with the EU on the 'future relationship'.
The focus of government is currently on a trade deal – it is unclear how much focus is given to areas that are more 'service' related. One possibility is that EU citizens will be expected to sit professional exams, as their non-EU counterparts already do, and the GDC currently has an working group looking in detail at these potential changes. Whatever the future system for recognition, there is already a waiting list for registration exams, and we believe that significant additional numbers of sittings may be difficult to arrange.
While the GDC has introduced application fees, the creation of a new or changed system is likely to have to be funded, or at least cross-subsidised initially, by existing registrants via the GDC's Annual Retention Fee (ARF) income.
It is also likely that EU nationals will have to do a more formal process of Performers List validation by experience (PLVE/VT equivalence) as their exemption from the formal programme as it is currently would also cease. This, in turn, would necessitate higher numbers of practices being willing to provide the training, and will also affect employment status (see more below).
UK dentists working in the EU
The same EU freedom-of-movement rules have also enabled UK dentists to study and work in other EU countries until now.
As UK citizens will not be EU citizens in the future, they will no longer be able to benefit from free movement and automatic recognition after 31 December 2020. Instead, professional recognition is most likely to depend on the arrangements for third-country nationals in any given country, subject to future relationship negotiations.
We await clarity on how European universities will approach applications from UK students, but we assume they will be subject to the same requirements as other third-country nationals. Also, as per above, they may need to sit registration exams to work in the UK.
2. Immigration arrangements
Currently, EU citizens do not need a work visa to work in the UK. This, in combination with automatic recognition of qualifications, has made the UK an active recruiter of dentists from the EU/EEA. This is particularly true for the dental corporate sector, but also for more traditional practices.
In the future, the UK Government has stated its intention to not treat EU citizens any differently to citizens from elsewhere, and they will be required to comply with a new 'points-based system'.
The plan is that all EU/overseas citizens will have to compete for work visas, where only the person who obtains a job offer is given the permission to work in the UK, for a defined time, after which they can apply for indefinite leave to remain.
The requirements of the immigration system to reach the necessary points for a visa are likely to be fairly easily met by most dentists; however, we are concerned that this process may mean more red tape, delays and costs for all involved, especially dental practices used to recruiting from the EU to fulfil their workforce needs.
To alleviate longer time frames for recruitment, the Government has proposed to scrap the labour market test, under which jobs first have to be advertised through specific routes in the UK before international applicants can be considered.
Dental practices and their owners will take on the role of 'sponsor' for dentists from abroad as they currently do for those from outside the EU and be responsible for the associated costs.
Tier 2 visa arrangements will usually need to be on the basis of an employment contract; therefore practices may need to work with more employed, rather than self-employed, dentists in the future.
While the Government has removed the immigration cap for employed doctors and nurses, this exemption does not currently apply to dentists, so it is unclear on whether visas will or will not be easy to obtain.
The Migration Advisory Committee has recommended to the Government that the limit on the number of Tier 2 visas be relaxed; the expected minimum earnings threshold is £26,500; and the requirements will include a high level of English language knowledge. The proposals are currently going through parliamentary processes and we will keep a watching brief on this.
We do not know what impact a more 'hostile' environment (whether perceived or evidenced) might have on EU citizens who have lived in the UK for some time, and may have trained here, but hold citizenship of another EU country – some may choose to leave the UK. The changes, and a lower exchange rate for Pound Sterling, may also make the UK a less attractive place to work for dentists in the future and have an impact on the dentist workforce in the UK
While most of the attention around dentist workforce issues in relation to Brexit is often focused on general dental practice, it is important to point out that dentists in the community dental services, in hospitals, and in academic and research roles, are affected in the same way, and that shortages in those areas are also of concern to us.
The Government has set up the EU settlement scheme for EU/EEA nationals currently living in the UK. Dentists and their members of staff need to apply for settlement before 30 June 2021 in order to remain in the UK without the need for future visa status, unless they have obtained citizenship. This includes individuals who have previously applied for residency in the UK; their status will be converted to the new scheme, but they must apply.
3. UK economy
There are many commentators on the state of the negotiations process and its impact on the UK economy.
Pound Sterling has suffered significant losses at several points since the referendum, the UK credit rating was downgraded in September 2017, and economic growth predictions remain relatively subdued, with some fluctuations.
Any economic downturn over the next few years and continuing acrimony between the trading partners could lead to higher prices and may impact on people's standard of living.
Research suggests that economic downturns can affect patient behaviour in seeking dental treatment, and we are concerned that this could affect dental practices' incomes – for both NHS and private dentistry.
We are keeping an eye on this issue and raising it at appropriate stakeholder meetings.
4. Medicines and medical devices
UK medicines and medical devices have been subject to a central EU system of accreditation.
While the UK Government has stated an intention to stay within the realms of the existing regulatory framework within this area, it is questionable whether this can be achieved without active participation in those frameworks; the discussions around regulatory alignment will be relevant here in the future.
We have concerns that if the process cannot continue as it is, there may be difficulties over the timely provision of medicines, including those used in dental practice, and the rules for importing and exporting medical devices.
In addition, there are questions around the speed and efficiency of importing medicines and medical devices if there are border controls that could significantly delay transport and delivery.
Over time, it might be possible for the UK to establish its own processes, mirroring existing ones going forward, but as there will be cost involved in the administration of these processes, we are concerned that thesecosts may be passed on to those who use, and need, medical devices and medicines.
5. The Irish border issue
Brexit took place on 31 January 2020 after the Withdrawal Agreement was passed in the UK and EU. To avoid a hard border between Northern Ireland and the Republic of Ireland, there was agreement that Northern Ireland would continue to follow EU rules on agricultural and manufactured goods after the transition period, while the rest of the UK is not bound in this way.
Additionally, the whole of the UK will leave the EU's Customs Union, but Northern Ireland will continue to enforce the EU's customs code at its ports. This will mean some new checks and processes for goods moving between Northern Ireland and other parts of the UK.
The UK and EU will now have to negotiate the nature and extent of those checks. This will mainly affect suppliers but could mean delays for dental practices in receiving their goods from next year.
It is also unclear what will happen after December 2020 about the movement of people between Northern Ireland and the Republic of Ireland. There is a flow of workforce into both directions– registrants living in the Republic and working in Northern Ireland, or vice versa; and the same also applies to patients, who might seek care in a different part from where they live.
As detailed above, BDA Northern Ireland is participating in a Department of Health working group on Brexit and we will keep members updated on this issue.
