Comply with IDD
Tracy Webb talks to practice manager Cirwyn Watkins about the impact of new regulation on their practice
October 2018 saw the introduction of yet another piece of regulation that impacts the dental profession. The Insurance Distribution Directive (IDD) affects all private practices offering a dental plan and means that you’re no longer able to promote your plan and any emergency and accident insurance as one product.
Under this new EU legislation, if you continue offering the insurance benefit, customers must be given the choice of whether they want to take it or not. However, DPAS has had a few concerns about this approach, not least that if their plan no longer provides for unforeseen accidents and emergencies, it may lead to patients delaying treatment in these cases due to financial considerations.
There is also the extra layer of administration for the practice in monitoring who is and isn’t covered, and the confusion this could bring to managing the out-of-hours rota. Also, under the directive, the choice of whether to take insurance is entirely down to the patient, so any practice teams advising them either way would put themselves at risk of breaching the FCA regulations.
As such, after seeking very extensive legal advice, we decided to move away from offering insurance in favour of introducing a discretionary ‘scheme’, which is not a contract of insurance, and therefore not impacted by IDD.
Using the scheme in practice
The scheme has been in place since January 2018, and I spoke to Cirwyn Watkins, from The Dental Centre in Gwent, who has used it several times already, to see how it is working in their practice.
Cirwyn said: ‘We first heard about IDD in 2017 from the team at DPAS, and we received all the literature and information we needed to transition to the new Scheme in January 2018. The move over to the new scheme was really so simple and seamless.
‘Regulatory change can often cause practices a massive headache and feel like a big change. But, with this approach there was no hassle whatsoever. We were kept informed by DPAS, received all the documentation we needed well in advance, so there were no big surprises once the regulation came into force. From an administrative point of view, the only difference has been a change in the literature we hand out and the way we explain the scheme to patients.
‘There has been very little additional burden and no disruption to patients. Having one standard scheme for all, rather than continuing to offer insurance but as an optional extra, means there is no confusion about who is covered and who isn’t or the kind of advice and information you can give to which patient, etc. I don’t think that type of approach would work for us at all.
‘We’ve used the scheme several times already since it was introduced. Each case was a trauma incident – one of which took place abroad and dealt with directly by the patient – and everyone received the majority or all of the money requested, so the patients involved were very happy.
‘As a practice we’re also happy because the most important thing for us is that our patients still have the security of being able to access emergency care from their own dentist or an alternative if they are away from home, and that has proven to be the case. Patients aren’t worrying about being hit by a one-off payment, have peace of mind and feel well cared for at an affordable cost, which is what we want to be able to offer them.
‘This means that we feel we’re fulfilling our duty in terms of looking after the overall wellbeing of the patient. From an operational point of view, we’re finding that the payments are being made quickly, which is good for our cash flow.
‘All in all, IDD could have been incredibly disruptive to our practice. But in fact, it has caused barely a ripple and we feel able to continue offering a complete package of care for our patients.’
The scheme: details
The scheme allows patients to request assistance in the event of unforeseen dental trauma and dental emergencies. As a wholly discretionary scheme, it is for the scheme manager to decide how the scheme will respond to the requests for assistance. This means that while the scheme manager expects to accept most requests, there may be circumstances in which the scheme manager may decide to pay no benefit – a fairly obvious example of when that may happen is if a patient suffers a self-inflicted injury.