Overview of the consultation

Between July and August 2025, the Department of Health & Social Care opened a consultation titled 'NHS dentistry contract: quality and payment reforms' seeking views on proposals on quality and payment reforms for NHS dentistry in England. More information can be found on the dedicated consultation page. 

Consultation 

Questions for the dental sector

Unscheduled care

We propose to introduce contractual changes that mandate a proportion of contracted activity to be dedicated to unscheduled care, where unscheduled care includes both care that is required in 24 hours or 7 days, as set out in NHS England’s ‘Clinical guidance: unscheduled urgent and non-urgent dental care’.

Dental practices would receive a set fee of £70 for each course of unscheduled care treatment provided. Additionally, dental practices would receive a fixed payment equivalent to £5 per appointment required to deliver the agreed number of unscheduled care treatments.

Do you agree or disagree that compared to current arrangements, our proposal will better support practices to provide more unscheduled care to patients?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that the proposed payment arrangement is fairer than the current arrangement of a variable 1.2 UDA value?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that our proposal will make it easier for people to get an unscheduled care appointment?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

If you have any comments on the proposals in this section, please include them here. You may wish to explain your answers or highlight considerations for implementing and supporting the proposals:

Dental Protection supports the proposals to mandate a proportion of contracted activity for unscheduled care. We also agree that the revised payment model offers a fairer and more effective incentive compared to the current variable UDA rate for urgent care, as well as providing clearer, more equitable reimbursement across different practices

However, the real impact on access will depend on implementation. In theory, these proposals should improve availability. However, this will only materialise if practices are supported to ringfence and release appointments. We would also ask for clarity on whether a minimum number of appointments will be required and how this will be monitored.

There is also a risk that smaller practices, who have limited flexibility in scheduling and staffing, may struggle to implement changes, particularly within a short space of time, compared to larger corporate providers, who are typically better resourced. Regional equity must also be considered - without consideration, variation in capacity between areas could exacerbate regionally unequal access. Practices in areas with higher overheads, smaller dental teams, or limited space may also face particular challenges.  

Overall, while we agree with the aims and structure of the proposals, their success will rely on thoughtful implementation, regional oversight, and ensuring that the necessary capacity can be created within practices to support accessible increases in unscheduled care.

Patients with complex care needs

We propose to introduce 3 new complex care pathways, paid at a set fee per pathway, for patients who meet the following criteria:

• at least 5 teeth with caries (tooth decay) into dentine with no periodontal (gum) disease paid at set fee of £272 (pathway 1)
• at least 5 teeth with caries (tooth decay) into dentine with currently unstable periodontal (gum) disease paid at set fee of £680 (pathway 2)
• a new diagnosis of grade C periodontal (gum) disease paid at a set fee of £238 (pathway 3)

Do you agree or disagree that our proposal will improve care and treatment for those with significant decay?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that our proposal will improve care and treatment for those with rapid progressive gum disease?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that the proposal is fairer than the current system of remuneration?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that our proposal will better incentivise you to provide care to patients with more complex care needs, when compared to the current system?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Some children and young people may benefit from being treated on care pathway 1. Do you have any comments on this proposal in relation to the treatment of children?

We recognise that some children and young people may benefit from being treated under care pathway 1. This pathway offers the potential for more detailed and appropriately funded care for this group, which we welcome given the challenges of managing extensive decay in younger patients.

Successful implementation must consider individual needs and differences, particularly with children where behavioural, emotional or other factors require additional time and support. Referral pathways must remain robust for children who require enhanced treatment or specialised support.

If you have any comments on the proposals in this section, please include them here. You may wish to explain your answers or highlight considerations for implementing and supporting the proposals.

Dental Protection supports the principle of introducing adjusted pathways for patients with complex needs – we believe this represents a fairer approach than the current system. The proposals may help direct resources where they are most needed, but clarification is required in several areas.

First, the utilisation of ‘‘no periodontal disease’ vs ‘currently unstable periodontal disease’ and ‘Grade C periodontal disease’ in the different pathways appears confusing. These terms describe different elements of the BSP classification and we recommend that further clarification is provided about what is captured in each pathway – for example, a patient with periodontal disease in remission is still a patient with periodontal disease but they don’t fit any of the definitions currently.  For pathway 2, the management of ‘currently unstable periodontal disease’ attracts an additional fee of £408 whereas pathway 3 for Grade C periodontitis attracts a fee of £238. Which pathway would a patient with Grade C periodontitis – currently unstable - be treated if >5 teeth need restoration? We suggest review of the categories to provide greater clarity.

We also urge clarification of how these pathways apply when specialist referral is required e.g. for Grade C grading where specialist management is indicated. Clear guidance should accompany these changes to ensure patients can access the right care at the right time rather than being guided down a particular pathway due to specific funding.

Skill mix and evidence-based clinical interventions

In order to support practices to make better use of the skill mix of their team and to improve delivery of fluoride varnish, we are considering introducing a new course of treatment for children for fluoride varnish to be applied by extended duty dental nurses (EDDNs). 

This treatment would be provided between regular examinations, on a risk-based timeline (every 6 months for children with good oral health and every 3 months for children at higher clinical risk).

Do you agree or disagree that this proposal will help enhance skill mix delivery of preventative care?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that this proposal will better support practices to deliver this treatment for children every 6 months (or 3 months for those at higher clinical risk) as recommended in the ‘Delivering better oral health’ guidance?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

We propose to re-categorise fissure sealants as a band 2 treatment (3 or 5 UDAs depending on number of affected teeth) rather than a band 1 treatment, to support utilisation of the treatment for primary prevention purposes.

Do you agree or disagree that our payment proposal is fairer than the current remuneration for fissure sealants?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Please explain your answer:

We welcome the re-categorisation of fissure sealants to Band 2, which better reflects the role of dentistry in prevention and evidence-based care. However, better alignment with ‘Delivering Better Oral Health’ is needed, with clarity on data monitoring to avoid practices later being challenged on increased use of fissure sealants.

We also propose to introduce a new sub-band within band 2 which can be claimed for any patient who requires a denture modification, repair or relining. Do you agree or disagree that our payment proposal is fairer than the current remuneration for denture modification?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

If you have any comments on the proposals in this section, please include them here. You may wish to explain your answers or highlight considerations for implementing and supporting the proposals:

We support the overall aim of encouraging skill mix amongst the dental team. Utilising EDDNs to deliver fluoride varnish applications is a positive step to support a more preventative approach to delivery of care, aligning with guidance and freeing up clinical capacity.

However, there again is the potential that this may only be feasible for practices with adequate staffing, additional surgery space and appointment flexibility. Many practices, especially those that are smaller, inner city or rural practices, will lack the capacity to offer interim appointments between exams. We also believe that the 0.5 UDA value will mean delivery of this service by EDDNs is financially non-viable for some practices. The proposal may therefore disproportionately benefit larger practices or corporates with more available resources.

Reducing clinically unnecessary check-ups

We want to support practices to adhere to evidence-based recommendations on the time between routine examinations. This will be important for creating capacity to improve care to those with more complex care needs, and also to ensure that patients are not paying to be seen for a check-up more than necessary. 

NICE guidance on recall intervals state that a healthy adult with good oral health needs to see a dentist once every 2 years, and a child once every year.

Which of the following list of alternative approaches or strategies do you think could best support practices to adhere to evidence-based recommendations on the time between routine examinations?

Please select all that apply.

• Risk assessment tool to support determining suitable clinical intervals between routine examinations
• Public education
• Sector education
• Reduced payments for band 1 check-ups delivered too frequently without clinical necessity
• Public reporting and benchmarking
• Don’t know
• Other, please specify
• Governance of the system
• Public reporting via dashboards and data, where appropriate and proportionately used

Which of the following would help support patients’ knowledge of what is clinically necessary?

Please select all that apply.

• Risk assessment tool to support understanding suitable clinical intervals between routine examinations
• Public education
• Sector education
• Public reporting and benchmarking
• Don’t know
• Other, please specify
• Expansion of risks assessments for public education
• Utilising knowledge from 2010 pilot sites – these practices will have experience of having these conversations with patients and may have helpful contributions

Quality improvement

We propose to introduce practice funding of £3,400 per year for dental teams to participate in quality improvement activities, with a focus on participation in clinical audit and peer review. National topics will be set each year and will be supported by local clinical leadership.

To what extent do you agree or disagree with the following statements about our proposal to introduce funded quality improvement activities for dental practice teams?

The proposal will support best practice.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The proposal will support professional development of the dental practice teams.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The proposal will increase staff morale and motivation.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Do you agree or disagree that voluntary participation, as opposed to mandatory participation, in the quality improvement activities is the right approach?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

If you have any comments on the proposals in this section, please include them here. You may wish to explain your answers or highlight considerations for implementing and supporting the proposals:

We welcome the proposal to fund quality improvement activities within dental practices, and support the emphasis on clinical audit, peer review, and continuous development. This initiative has the potential to enhance best practice and clinical standards across the profession, while also supporting professional development and reflective learning for dental teams.

We would suggest that a flat £3,400 allocation may not reflect the resource demands for larger teams or multi-surgery practices; quality improvement activities may involve more staff, require greater coordination, or take place across several sites. We would therefore suggest the introduction of a sliding scale of funding – this should reflect the size and structure of practices, to proportionately support equity and support meaningful participation across practice types.

Regarding staff morale and motivation, this will depend significantly on how these activities are introduced, managed, and supported. They should be integrated into working patterns in a way that values team input without adding undue pressure or workload.

Funded support for annual appraisals

We propose to provide practice funding, covered in the annual contract value for contractor-led annual appraisals for associate dentists, dental therapists and dental hygienists providing clinical services to NHS patients, at the rate of 6 UDAs per eligible individual.

Do you agree or disagree that our proposal will support the delivery of annual appraisals to these groups?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

Supporting the workforce to feel part of the NHS

We are proposing 3 ways to address some of the issues that affect whether dental teams feel part of the NHS. These are to:

• prospectively enable all continuous NHS service, and not just time on the dental Performers List, to contribute to the calculation of 2 years’ service to be eligible for discretionary support payments, such as long-term sick leave
• seek views on developing an NHS model contract and minimum terms of engagement for self-employed dentists
• publish an NHS handbook for dental teams clarifying the support available to them from the NHS, how the contract works and signposting to other helpful resources

Do you agree or disagree that our proposal to enable all continuous NHS service to contribute to the calculation of 2 years’ service will make providing NHS dentistry more attractive?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

We are considering the merits of introducing minimum terms of engagement and a model contract for associate dentists to ensure that they are treated fairly.

Do you agree or disagree with this proposal?

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

If you have any comments on the proposals in this section, please include them here. You may wish to explain your answers or highlight considerations for implementing and supporting the proposals:

We support the proposal to recognise all continuous NHS service, not only time on the Performers List, for discretionary entitlements. This is a welcome step that may improve morale, fairness, and retention among those delivering NHS care, including team members whose contributions often go unrecognised in formal benefit structures.

We do have concerns around the proposal to introduce a model contract and minimum terms of engagement for self-employed associate dentists. We feel the proposal currently lacks clarity, and it is not clear whether the intent is to mandate contractual structures or simply offer guidance.

While ensuring fairness in associate agreements is important, minimum terms and centralised templates risk blurring the lines between self-employment and employment. From our experience, such interventions, can contribute to working arrangements being deemed ‘akin to employment’. This may expose practice owners to increased vicarious liability risks. Similarly, the requirement to have annual appraisals may further undermine the ’self-employed’ status and may be an unintended consequence of going down this route.

The proposals lack clarity about who will be responsible for undertaking the appraisals and what support or training would be provided for appraisers. It is important that the appraisals add value and are not just seen as a tick-box exercise.

Implementation considerations

We propose to consider further the feasibility of using NHS numbers (or standardised identifiers until the NHS number is confirmed) alongside activity claims to enable accurate payments for treatment pathways given to complex care patients.

What issues should we consider when looking at the feasibility of developing this proposal?

We welcome the proposal to explore using NHS numbers or standardised patient identifiers alongside activity claims to improve payment accuracy for complex care treatment pathways.

However, we consider limiting this approach solely to complex care patients as a missed opportunity to modernise payment and activity tracking across the entire dental service. If a system is being developed to capture such data, it would be more efficient and beneficial to design it with scalability in mind, so that it can track all patient activity. This would help future-proof the system, reduce duplication, and facilitate improved service planning and commissioning.

Questions for all respondents

The proposals in this consultation were developed alongside engagement with the dental profession. They are intended to be quickly implementable and affordable within the existing budget, while the government develops proposals for more significant reforms.

To what extent do you agree or disagree with the following statements?

The package of proposals will improve the current NHS dental contract.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The package of clinical proposals (urgent care, complex care pathways and prevention through use of evidence-based interventions for children) will support practices to prioritise care for those who need it most.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The package of proposals will better incentivise the delivery of high quality evidence-based NHS care.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The package of proposals will better utilise the whole dental team in the delivery of NHS care.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

The package of proposals will support the whole dental team to feel part of the wider NHS workforce.

• Strongly agree
• Agree
• Neither agree nor disagree
• Disagree
• Strongly disagree
• Don’t know

If you have any further comments on these proposals, please outline them here:

We acknowledge that these proposals are designed for rapid implementation within existing budgets and agree they have potential to improve the current NHS dental contract, particularly by prioritising care for patients with the greatest need. However, for some practices the changes could be significant and risk disruption to both patients and service delivery.

We have reservations about whether the package will fully achieve its ambitions of better utilising the whole dental team and fostering a stronger sense of NHS belonging. Success will depend on careful implementation and the level of support available to practices.

Resourcing constraints - time, space, and staffing - may limit the ability of smaller practices to adapt. Without addressing these challenges, reforms may disproportionately benefit larger or corporately resourced providers.

There are also concerns of unintended consequences, such as incentivising behaviours not aligned with patient-centred care. Payment models inherently carry such risks, particularly without robust monitoring and evaluation.

The short implementation timeframe may further challenge practices, who will need to restructure appointment books and communicate changes to patients. Clear and timely messaging will be essential to reduce complaints and prevent practices being challenged, particularly around recall intervals.

Finally, NHS dental teams understandably often are more closely aligned to their practices than to the wider NHS. To support true workforce integration, reforms must go beyond contractual adjustments, offering clear communication of benefits and a stronger sense of NHS inclusion.

Overall, the proposals are a step forward but will require careful, supported implementation to achieve desired outcomes across the sector.