William Moyes responds to ARF concerns

I know that many of you are deeply unhappy with the GDC’s (General Dental Council's) proposal to increase its annual registration fee (ARF) for dentists and DCPs (dental care professionals). I and my colleagues on the council take seriously the concerns being expressed, which is why I want to make sure we have set out fully the facts behind the proposed increase.

Why is the ARF being increased?

The ARF was last increased in 2010. Since then fitness to practise complaints to the GDC have increased by 110%. This has increased the GDC’s fitness to practise running costs by 88%. We have made significant efficiency savings in that time, which we have used to defray the cost of fitness to practise. But without further significant investment in our fitness to practise processes we will be unable to deal effectively with the very large and continuing increase in our caseload.

The GDC has been criticised, with some justification, for not meeting the standards set for professional regulators by the Professional Standards Authority, which oversees the performance of all the healthcare professional regulators. We are investing substantial sums to tackle these problems. This involves more staff and more fitness to practise panellists to clear a backlog of cases and to process new cases faster; more robust management of staff performance; and improvements to our IT and related systems.

Our ARF policy, on which we consulted you earlier this year, is to base the fee on the cost of regulating dentists and DCPs. So, the proposed increases are what is required to generate sufficient income to match the increase in the GDC’s costs, the main cost driver being fitness to practise cases.

How big is the increase?

For dentists the proposed fee increase is £1 per day; for dental care professionals the increase is 2p per day and as you will be aware, the fee is tax deductible.

What is the GDC doing to avoid big ARF increases in the future?

We are keeping all our costs under review and will make savings wherever we can. The re-development of our main office in Wimpole Street will allow us to locate a majority of our staff in one building, thus reducing our costs overall. It is worth pointing out that our main offices are held on a long-lease at a peppercorn rent of less than £6000 per annum, which has made the re-development a very sound investment.

We are already making  considerable savings in legal costs by building up an expert in-house legal team. We plan to bring more legal work in-house to reduce our costs further.

We are working with the Department of Health on an S60 Order, to introduce a very significant change to our fitness to practise processes. This change – the introduction of case examiners – will not only allow us to improve the way we handle cases but will also save us up to £2million a year.

Encouraging local resolution

We are working with NHS England and other stakeholders across the four countries, with a view to encouraging earlier, local resolution of complaints. We are also analysing patterns of complaints and, where necessary, will be providing advice to the profession on how to prevent concerns being raised.

We believe that the highly successful conciliation techniques used by the Dental Complaints Service (DCS) in dealing with complaints about private dentistry, have much wider application with potential to tackle problems before they become serious and save significant costs. 

But the more effective form of local resolution is by dentists and DCPs within their practices or work settings. Some complaints end up as fitness to practise cases because dissatisfied patients are not offered an opportunity to make their complaint and have it resolved quickly within the practice. We estimate that one in seven dentists or DCPs is subject to some form of official complaint at any given time – to the GDC, to the DCS, to the CQC (Care Quality Commission) or to NHS England.

As a dental profession, you have a very big contribution to make in ensuring complaints do not escalate unnecessarily. So I would ask you please to consider carefully if your patients are clear about how they can raise concerns with you or your colleagues, with confidence that they will be considered carefully and resolved fairly.

Our approach to setting the ARF in the future

We believe the fairest system will be an annual review with the ARF being adjusted downwards or upwards depending on the costs of regulation. As I mentioned earlier our key cost driver is fitness to practise complaints and a reduction of this cost is a responsibility we share with you.

I hope I have been able in this letter to explain our proposal clearly. You may also find it helpful to consult the ‘key facts’ document on our website.
I would like to thank all of you for responding to the consultation so far and be assured that throughout the consultation period, we will continue to seek and implement any efficiencies in the interests of ensuring that the level of the fee is not greater than it needs to be to deliver our core functions.

Yours sincerely,

William Moyes.

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