As UK dentistry’s trade union and professional body, we want to ensure that the proposals for provisional registration for overseas dentists are fair and safe. We are considering the overseas dentists themselves; their supervising dentists; other colleagues; and the general public. We have explained our concerns in a detailed response to the recent Department of Health and Social Care (DHSC) consultation on providing the GDC with powers to introduce provisional registration for overseas dentists.
These proposals have generated huge interest among the dental community in the UK and abroad. We continue to receive many enquiries, which shows the demand of those who wish to take up this new form of registration in the future. Overseas dental professionals already make a huge contribution to UK dentistry, and with these proposals many more will see the UK as a good place for their future career.
We feel it is really important that new applicants get full and realistic advice about the options and also the potential drawbacks. Unfortunately, promises are already being made to prospective candidates about a system that is not yet in place, so we would advise everyone to scrutinise such promises closely and contact us for further advice.
There is as yet little detail available about how it will all work. The recent DHSC consultation will only give the GDC the legislative powers to develop provisional registration. The GDC will have to do the rest. Then assuming the Government wishes to go ahead, another consultation will follow. It will be some time therefore before we see any new system in place.
Ensuring high standards of care
The GDC has been clear that regulatory standards should not be compromised, and that it will work with the profession to develop the new system.
There is a lot to consider, starting with the capacity of the GDC, the NHS, in practices and other settings, to run the system. In addition, we must examine the following points:
Before the overseas dentists start work
- Processes in which prospective provisional registrants will be assessed initially in terms of their practical clinical skills
- The way in which they will join the place where they will work under supervision
- Details of how the supervisory arrangements should work, and the training needed for prospective supervisors.
As they start their new positions
- Contractual arrangements between the parties ensuring that the provisional dentists are fully supported and treated fairly
- Annotation in the register of those providing supervision
- The way in which full registration is eventually achieved and confirmed
- Patient information necessary to ensure awareness that treatment is being provided by a dentist under supervision, and patient confidence in this new approach.
Logistics of the plan
- Timescales for holding provisional registration
- Processes to join performer lists and NHS dental lists, and the effects on the systems and regulations in all four UK nations.
Ensuring a safety net if things go wrong
- Indemnity arrangements for the provisional registrant and the supervisor
- Clarity and support for practices around the issue of vicarious liability; the liability that other people would face for the unlawful or reckless actions of the provisional registrant.
There is a general assumption that, if implemented, provisional registration will take place in an NHS dental practice setting, given that increasing the number of NHS dentists is the underlying objective of the proposal. Ensuring patient safety and providing robust support for provisional registrants may well mean that a more formal educational and assessment route will need to remain part of the process. We need completely new infrastructure to support the project in whatever setting it will be provided.
How much will this all cost?
To develop detailed proposals for the system, discuss, consult, and implement them will be the responsibility of the GDC. The regulator is financed by annual retention fees, so can registrants expect a significant fee increase? We have suggested that the set-up costs should be borne by the DHSC given that the proposal is part of the NHS dental recovery plan. Prospective provisional registrants also need to be aware that once the system is up and running, the fees will reflect the associated costs.
Implications for the Overseas Registration Exam
The GDC has also been working on improving the Overseas Registration Exam (ORE). More places and sittings are now available for both parts, and there are reports of the exams not running to capacity. The GDC is also looking at expanding the number of providers from next year.
For this reason, the advice for dentists currently considering moving to the UK is to apply to take the ORE rather than waiting for provisional registration to come in. Given that there are existing, under-utilised systems in place, is introducing a complex new route to registration really the best way to address the Government’s policy objective? It may be better to improve the current system.
Ethical considerations
There is another important point to be made about the DHSC proposal. Is it really ethical for Government to encourage overseas dentists to work in an NHS dental contract system that is demonstrably broken and in which UK dentists no longer wish to work? Would it not be more appropriate to undertake the full reform that is being called for across all UK nations, while also ensuring that the processes of the GDC are significantly improved?
There are risks for overseas dentists, for supervisors and practices, and for patients.
For overseas dentists who leave their home to make a new start, there is the insecurity of what contractual arrangements they will have, whether the support they receive will be appropriate, and whether they will eventually achieve full registration through the provisional route. There have been cases of exploitation of overseas dentists, so we cannot stress enough how important it is to be a member of the BDA so that we can advise on contracts and working arrangements.
Supervisors need to undertake relevant training and ensure they understand the specific needs of the person they are supervising. This will in turn affect their own capacity to provide dental services and they or the practice will be vicariously liable for the work of the provisional registrant. Supervisors may have experience of their own Dental Foundation or Vocational Training and may have trained others. They may have knowledge of the processes overseas dentists registered with the GDC need to go through to confirm they have the necessary experience and training to work in the NHS. This background might help, but the nature of the new arrangements will be different.
The GDC is tasked with designing a system that at its heart protects patient safety, and we wish to contribute to this. However, there could well be situations where the supervisory arrangements do not work appropriately, the provisional registrants lack specific competencies, and the pressure of the system leaves the professionals stressed or insecure, leading to patient safety issues.
Capacity is also an issue in the context of the current shortage of dental nurses. There is a need to ensure provisional registrants work with fully registered and experienced dental nurses, but ongoing recruitment issues may make this difficult.
What next?
We are at the beginning of this journey into a potential new registration category for which the whole system will need to work together. We will do our bit to ensure that the system works for provisional registrants, supervisors and patients.
Our role is to support dentists throughout their working lives, and this involves providing clear, timely and realistic advice to our members.
Contact us early; become a member to access our resources and services; and be assured that we have your best interests at heart in our work.
