Clarifying inspection requirements: private and NHS dental practices in Scotland
21 March 2019
BDA Scotland has previously responded to Scottish Government consultations on the regulation of dental practices after noticing significant differences in the way Healthcare Improvement Scotland (HIS) and local NHS Boards inspect.
HIS carries out inspections of private healthcare providers in Scotland, including private dental practices, while practices delivering NHS dentistry are inspected by local NHS Boards. Private practices have been regulated by HIS since 2016, while NHS practices have been inspected since 1994.
While the two inspection regimes are broadly similar, there are some significant differences:
Both types of inspection are carried out by Dental Practice Advisers, and follow the Combined Practice Inspection (CPI) approach. The CPI checklist covers facilities, decontamination arrangements, staff training and appraisals, information for patients, access, dental records, health and safety, radiation, infection control, and a range of other issues.
Depending on the degree of risk, private practices could typically be inspected from three-six months to five years. NHS practices are legally required to be inspected every three years but may be inspected more often, if there are significant concerns.
Private practices are required to submit three years of accounts as part of their initial registration to provide assurance that they are financially viable. NHS practices are held to account for their use of public money through the annual declaration to Scottish Government of the percentage of total earnings attributable to NHS income. (Information is collected through the GP234 form, as set out in Determination XV of the Statement of Dental Remuneration).
Private practices are required to pay an annual fee (currently £2,475) for ongoing regulation and inspection. BDA Scotland has suggested that, rather than imposing a flat fee for independent practices, the fee should reflect the size of the practice. NHS practices are not required to pay a separate fee, but face financial costs associated with preparing for and accommodating the inspections by NHS Boards.
Inspection reports from private practices are published on the HIS website. NHS practice reports are issued to the respective NHS Boards and also shared with NHS Education for Scotland to help inform vocational training. Patients and the public can request copies of NHS practice reports from Boards.
We continue to lobby for regulation for dental practices that is proportionate and that does not place onerous burdens on practices.
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