Dental Protection has responded in detail to the GDC’s recent consultation on its proposals to increase the Annual retention Fee (ARF) by 64%.

The GDC has justified the unprecedented scale of the increase in the ARF primarily on the basis of the increase in the number of ‘complaints’ that it has to deal with. In calculating its likely operating costs, the GDC has also predicted that this volume of incoming ‘complaints’ will continue to rise for the foreseeable future, and appears to have assumed that the number of Fitness to Practise (FtP) investigations will need to rise at least in proportion to this. The only conclusion that one can draw from this is that the GDC sees no need for any reassessment of its approach, and no potential for improving what has become an increasingly dysfunctional and unnecessarily costly system.

Dental Protection fundamentally disagrees with the GDC’s flawed starting position. In explaining Dental Protection’s concerns, Kevin Lewis, Dental Director commented:

'The GDC has not been entirely transparent in its public statements, to some extent reflected in the consultation document, as regards the growth in ‘complaints’. It would be more accurate and less misleading to refer to the number of matters reported to the GDC. It is inappropriate to imply that these matters are mostly, or wholly complaints initiated by patients about the quality of the care and treatment they have received. Individual pieces of information which reach the GDC are very often not complaints at all, but matters which can and should have been acted upon by other parties or organisations. They become Fitness to Practise matters by default.

Referrals to the GDC are often an abdication of the responsibility by a third party with the intention of shifting the associated costs and risk of challenge, and we do not believe that the GDC has taken a sufficiently firm line in its dealings with many of these organisations.

In this and other respects, the GDC’s assumptions, which seek to justify the proposed increase, touch upon areas that we have regularly discussed with the GDC. Having expressed our concerns in this regard on so many occasions, it is disappointing that the GDC still seems to see no alternative but to continue on the path on which it has embarked (despite criticisms not only across the width of the dental profession but also from the GDC’s own regulator, the PSA), rather than to question why no other healthcare regulator in the UK shares the GDC’s approach where Fitness to Practise matters are concerned.'

Dental Protection has the further advantage of dealing with many other dental regulators around the world on almost a daily basis, and has previously expressed the view that the regulatory activity by the GDC in the area of FTP is wholly disproportionate and without parallel internationally, and nor does it meet the stated aim of 'right touch' regulation.

In our experience, no other dental regulator in the world is so far removed from the principles of ‘right touch’ regulation where Fitness to Practise is concerned. The GDC regularly investigates matters that would not concern any other dental regulator in the world that we work with. Given recent events, it is simply unsustainable for the GDC to believe that it alone has the balance right.

Dental Protection has drawn the GDC’s attention to a long list of areas where there are available opportunities to contain the cost of its FtP procedures, and believes that the recent advertising campaign by the GDC may even have compounded the problem.

Kevin Lewis added, 'The failure of the GDC, when designing these advertisements, to encourage patients to use the in-house complaints procedures that the GDC requires every registrant to make available for their patients to use, has raised genuine concern that the GDC may have lost touch with what it is tasked to achieve.

It is perverse for the GDC to require registrants to make available, and to operate, effective in-house procedures for managing patient complaints, and then to waste registrants’ ARF payments on a proactive advertising campaign which deters patients from using these in-house procedures, instead directing them to complain to the Dental Complaints Service or GDC. This wastes ARF income both in the cost of the advertisements and in the cost of processing complaints that could and should have been resolved in-house by registrants at no cost to the GDC. It is little wonder that the dental profession has become exasperated by its regulator.'

Read the full text of Dental Protection’s response here