As the COVID-19 situation continues to develop, we know that many dental professionals are continuing to face an uncertain and stressful situation. As the professions’ regulator, our aim continues to be to provide support and clarity where we are able to, based on the two core principles we set out on 23 March:
- Minimising the burden of time and attention we impose on registrants.
- Maximising the flexibility of registrants to manage their professional activities in response to the challenges of COVID-19.
This update covers a number of topics on which we know that questions and concerns remain. We will provide answers where we can and be clear when we are still working to resolve issues – and of course some things will become clearer once we all have a better sense of how long we will be in this stage of the crisis and what happens next. But meanwhile, if there are other issues within our remit which you would like to see covered in these updates, do please let us know.
We know that the departments of health across the UK are putting plans in place to make best use of the dental team through redeployment to support urgent dental care and, increasingly, to support the wider COVID-19 response. NHS England has published guidance today on its approach to redeploying members of the dental team into work outside dentistry. It includes a mapping from the skills of the different dental professions to roles and tasks in other settings which may also be of interest to those in the other nations. It also includes a reference to our guidance on working in non-dental settings which makes clear that we fully support dental professionals who choose to volunteer their services in this way. Any member of the dental team can express an interest in volunteering by completing the online survey.
Large numbers of doctors, nurses and other healthcare professionals who have left their respective registers relatively recently have been returning to work, to support the wider COVID-19 response across the health services. We have been asked whether the same opportunity will be offered to dental professionals. The simple answer is that we are not able to. The other regulators involved have specific legal powers to give temporary registration in an emergency which allow them to make this a very straightforward process. The GDC doesn’t have those powers so we can’t do that – and that’s something only the government could change, it isn’t within our control. If the government were to want us to operate a temporary register, we have plans in place so that we could create one very quickly after the necessary legislation was in place, and of course we are very ready to do so.
The safety of patients and of members of the dental team through rigorous infection control is clearly of paramount importance.
One consequence is that patients cannot currently be offered the range of treatment they would normally expect. Refusing to treat a patient when it is not safe to do so is a perfectly proper professional judgement, which we would not look to question.
Urgent care arrangements are being established by the health services to create settings in which higher risk treatment is possible, including aerosol generating procedures. These arrangements should be used as an important contribution to overall risk reduction. We know there are concerns that these arrangements are not yet fully established in all areas. Where that is the case, a judgement can be made, based on an appropriate risk assessment, of whether there is treatment which can be offered safely. Again, we will not look to question the outcome if a reasonable approach has been followed.
In assessing risks and making decisions on those circumstances and more generally, it will be important to reflect public health advice. Public Health England has updated its guidance on infection control generally and on PPE specifically, including a helpful simple diagram – you can click on the image to see the full size version.
We have heard from some dental professionals and students who have been distressed and alarmed by fake communications purporting to come from official sources. Some of these have falsely claimed that the GDC may penalise professionals who do not volunteer to be redeployed to support the COVID-19 response. We will not. We are absolutely clear that volunteering is an individual decision and there is no possible question of that choice being a fitness to practise issue.
So, please be on the lookout for misleading information and help others by not boosting the circulation of messages, unless you are confident that they come from official sources. Always check on the relevant organisation’s website if at all in doubt.
We have already made clear that we will be sympathetic to people who are finding it difficult to maintain their CPD in current circumstances, and we have made a commitment that nobody will be removed from the register because of a lack of access to CPD during the crisis period.
We know from our existing records that the vast majority have already recorded enough CPD for there not to be a problem in making their declaration this year. We are actively looking at how we can best offer more flexibility to minimise the burden on registrants in this period and will provide an update on that as soon as we are able to.
Financial support and the ARF
We are pleased to see that there is now much greater clarity about the financial support available to NHS contract holders, at levels which underwrite a substantial proportion of practice incomes and allow them to continue to pay staff. But we also recognise that mixed practices and private practices will get limited or no benefit from that, though it is now clear that practices can make use of the furlough scheme and other general government support in proportion to their private activity. Some will also be able to benefit from government support for self-employed people, though the cap on earnings will mean that many associates will not be eligible.
The guidance from NHS England described above also confirms that members of the dental team who work in private practice will be paid if they volunteer for COVID-19 redeployment at a rate appropriate for the work they will be doing. Those who are paid directly or indirectly by the NHS should continue to receive their normal pay.
Nevertheless, financial pressures remain very real. We understand that and we are hearing concerns very clearly both from individuals and representative bodies who are asking us to reduce or waive ARF payments this year. We always want to keep the cost of regulation as low as possible, which is why we were delighted that we could reduce the ARF for dentists last year by 24%. But we get no funding from government – or anywhere else – and our financial reserves are limited, because we have no wish to be holding registrants’ money unnecessarily. Virtually all our income comes from registrants, which puts very real limits on our ability to be flexible. But we are looking at what might be possible – for example in terms of an emergency instalment scheme – and will provide an update well before the beginning of the ARF round for dental care professionals in the summer.
These are challenging times with much personal and professional uncertainty and anxiety. Our goal throughout is to support the professions and, through you, the patients we all serve. All of us at the GDC hope that you and your families are staying safe and well at this difficult time and that the constraints on your professional lives will be short lived.