It ain’t ARF hot, mum

At a time of year when the politicians are looking forward to their summer break and trying to remember where they put their buckets and spades, the GDC (General Dental Council) appears to have elected to forego the buckets and to reach instead for the biggest shovels it can lay its hands on.

The maxim ‘when you are in a hole, stop digging’ comes to mind, but the GDC’s consultation on the proposed biggest-ever increase in the annual retention fee (ARF) has certainly lit the proverbial blue touch paper and may even have invented a completely new incendiary device. It has also united the profession behind a single cause, which is an achievement in itself. I will return to this shortly.

A convenient truth

For years we have been told, and told again, that the disappearing coral reefs in the warmer waters of the world, are mostly or wholly the result of climate change and global warming. And we understand and are concerned about that because we all share a sense of collective responsibility for any climate change that is felt to be attributable to earthlings rather than other, more natural factors.

Enter Mr Carl-Gustaf Lundin, who is the director of the Global Marine Programme at the International Union for Conservation of Nature (IUCN). Following a recently published analysis by almost 100 respected international experts, of 40 years of data from surveys of coral reefs in the Caribbean (sounds like a tough job to me, but someone has to do it), Mr Lundin has concluded that there are other factors much closer to the ground that have played a much more significant role than climate change. In summary, overfishing and localised coastal pollution in several of the countries around the region, have decimated the marine population of sea urchins and parrotfish.

Mr Lundin, not to mention his eminent team of fellow experts, does not deny that climate change plays a part in threatening coral reefs, both in the Caribbean basin and elsewhere, but – and I am getting to the important bit now – he describes climate change as ‘a convenient truth’ that masks other failings by the countries of that region. It is, he believes, a truth that camouflages, deceives and misleads us into blaming the wrong people and looking for solutions in the wrong places.

Not quite the whole truth

Which brings us conveniently back to the hottest of the hot topics of the day, the GDC and the annual retention fee. It is a ‘convenient truth’ that there has been a (more than) doubling of the volume of ‘complaints’ reaching the GDC in the past three to four years. On the face of it, the proposed increase of a mere 64% in the ARF for dentists seems not only reasonable but almost understandable, and also (importantly) absolutely not the fault of the GDC, but rather, somehow, the fault of the registrants themselves. In short, registrants are causing the problem, so they should pay for it.

But to burglarise the immortal words attributed to (but as I am reliably informed, never infact uttered by) Spock of Startrek fame ‘They are complaints, Jim – but not (all) as we know them.’ Let us be clear. The 3,500 (approx) ‘complaints’ that the GDC predicts for 2014 are not all unprompted complaints by patients who are unhappy about the care they have received. This provenance is frequently implied, but it is not actually true. The GDC’s fitness to practise procedures have become a care home for anything and everything that other organisations haven’t got the time, energy or budget to deal with themselves. In a world where they can’t be seen to do nothing, or in which they haven’t got the appetite to risk any legal challenges, they do the next best thing and let the GDC spend its budget (or more accurately, your ARF) on mopping up what everyone else has offloaded. Some of these offloads are entirely appropriate and necessary, to be honest, while others are complete nonsense and wholly unjustified.

UK dentists are not performing twice as badly (or half as well) as they were four years ago. Quite the reverse, I would suggest. The profession is instead being asked to underwrite the excesses and the disproportionality of the current regulatory environment. The GDC exists ‘To protect the public’ – but from what, and from whom? From dentists, who are busting their guts to care for their patients in a horrendously difficult economic and professional environment. If the GDC was to be sent packing with no increase in the ARF, and be instructed to cut its coat according to its cloth, it would be forced to abandon its more extravagant and often inexplicable divertissements, and focus on the really important fitness to practise issues where patients were genuinely at risk. It would be forced to follow the GMC’s (General Medical Council’s) lead and dispose of more cases at an earlier stage in the process, and crucially, to exert much greater control over the lawyers they instruct to prosecute fitness to practise cases. I would bet that the cases would magically become simpler, the hearings fewer and shorter, and the training of both GDC staff and investigating committee panels would improve by several notches with a commensurate improvement in the quality and consistency of decisions. That is the world in which everyone else is having to live and work these days, so why not the GDC? 

The GDC has clearly been on a media assault in recent months with every GDC speaker on every programme dutifully quoting the complaints statistics. The GDC was at it again in early July in the shape of the GDC’s colour advertisements in the national press, encouraging more private dental patients to make use of the Dental Complaints Service. Many saw this as an ‘own goal’, coming just as the GDC was lamenting the surge in complaints and the need to increase the ARF.

But despite the clumsy PR, and contrary to popular opinion, it is not all the GDC’s fault either. In the autumn of this coalition Government, all the healthcare regulators (including the GDC) have been denied the bill in the upcoming parliament that would have implemented some or all of the recommendations of the Joint Law Commissions on reforms to the regulation of healthcare. Instead the GDC must wait for a further year for a section 60 order to give them (limited) additional powers that might assist them in resolving more cases at a lower and more proportionate level. That will help (if and when it comes), but it is not the whole answer. The GDC must do more – a lot more – closer to home to fix the well-recognised and longstanding problems especially, but not limited to fitness to practise, which is the ever-widening plughole down that most (80% plus) of the money disappears. The GDC knows that, the profession knows that and (as we will discover in due course) I suspect the GDC’s own regulator, the Professional Standards Authority, knows that. 


The residual pretence of self-regulation remains part of the problem, in my view. We like the idea of it but not the reality – nor the cost, hence the ARF furore. Self regulation is an anachronistic illusion and now that the profession has no say whatsoever in how it is regulated, and has little or no trust or confidence in the fitness to practise procedures, perhaps the time has come for the GDC’s operational costs to be funded in the same proportion as the composition of the GDC itself – roughly 50% funded from the profession through the ARF, and 50% from the Government that, through its relevant agencies, nominates and appoints the lay members of the GDC (and the chair). This won’t happen of course, but the GDC needs to feel, understand, and show that it understands the heat that the ARF issue has been generating. Blowing a smokescreen over its own failings, and blaming registrants for generating too many ‘complaints’ is not the way forwards.

Applying the GDC’s own Standards for the Dental Team and the principles embodied therein, the GDC itself would be highly vulnerable right now to a charge of misconduct, and a finding of impairment. I am struggling to remember the last time a registrant in that position was rewarded with a 64% pay rise – but I will give it some more thought and let you know. 

Tell us today how the General Dental Council should be reformed.

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