2019 ARF to remain unchanged – GDC justification and the profession’s reaction

12 July 2018

The General Dental Council (GDC) has announced that the Annual Retention Fee (ARF) will remain unchanged for 2019. In reaching the decision, the regulator weighed the complex picture of external risk it faces at a time when significant investment is being made for long-term improvement, and concluded the time is not right to make the reduction it had hoped to. The various professional organisations, however, have voiced their concerns.

GDC chief executive, Ian Brack, said, “As the GDC’s accounting officer, it is my responsibility to ensure that the finances and systems of the GDC are robust and to highlight significant risks to Council. We have made some significant progress in terms of real improvements and efficiencies over the last few years but the combination of external risks facing the GDC for the coming year and the short-term cost of internal investment we’re making to deliver Shifting the balance and bring further long-term savings led me to advise Council against a reduction in the ARF for the next year.”

In early 2018, the GDC consulted on a new policy for its approach to setting fees and, in doing so, established the intention to base future consultations relating to fee-level on a three-year corporate strategy, costed at programme level. This consultation is set to take place in the first half of 2019.

Ian Brack continued, “Parliament has set the GDC very clear regulatory outcomes that we must achieve, and these focus on protecting the public and maintaining public confidence in dentistry. This will always be our first priority. We focus heavily on finding new ways to deliver our remit more cost-effectively, but we must achieve this sustainably. Next year we’re consulting on our three-year costed corporate strategy, and the activity we propose within that will tell us what the ARF level will need to be to carry out that work. I really hope to hear as many views as possible and look forward to the valuable debate that will undoubtedly bring.”

The BDA have slammed the lack of transparency over the process, arguing that fee levels should be debated and determined in a Council meeting open to the public and linked to a budget and business plan. The BDA had already told the regulator in response to its consultation Clear and certain: A new framework for fee-setting, that not consulting registrants on fee levels again was unacceptable. 

The GDC has not yet published its evaluation and response to the consultation, and the BDA believes that the profession’s trust in the regulator remains as low as ever due to its approach to fee setting and handling – and continuing lack of transparency.

Fees remain the highest of all the UK health regulators and continue to be used to top-up reserves, well beyond the regulator’s own stated requirements. 

 BDA chair, Mick Armstrong, said, “The £890 ARF symbolises the GDC’s cavalier disregard for the profession it regulates, offering new excuses when the old ones have worn thin.

“We require a regulator prepared to live within its means, willing to approach upstreaming and contingency planning with a cool head. Instead we have a body that puts padding out war chests above all else.

“We have long argued that the GDC’s approach to its reserves is fundamentally flawed, but even by their own measure, they now exceed their required need. The levels of uncertainty are the same for all the regulators, yet nobody else seems to be arguing in this way.

“The Overseas Registration Exam – and any new approach to registering EU nationals if necessary - should be self-financing. Yes, there may be overheads, but the bottom line is existing registrants should not have to fund registration costs for new registrants. It is simply not a good enough excuse to hoard our cash.

“When the budget for 2019 hasn’t even been formally agreed by the Council, it is not a good look for the GDC’s Chief Executive to unveil the figures in this manner. The serious concerns about transparency that we keep raising continue and increase. The ARF hasn’t changed, and neither has this profession’s trust or confidence in its regulator. The case for a significant fee cut remains, a coherent argument for a freeze has not been offered.”

The British Association of Dental Nurses, the UK’s professional association for dental nurses, the largest professional group on the GDC Register, has also condemned the GDC’s decision not to lower the Annual Retention Fee (ARF) for dental nurses.

“We made it very clear, in our response to the GDC consultation, that the current ARF of £116 per year is an unreasonable financial burden on dental nurses, the majority of whom are earning minimum wage”, said BADN president Hazel Coey. “Our salary surveys show that a qualified, registered dental nurse with more than 10 years’ experience and working 40 hours per week is earning, on average, around £15,000 a year. This is compared to hygienists and therapists, who can earn up to three times that much.

“A one-size-fits-all approach to the ARF for DCPs is not acceptable – and we call upon the GDC to recognise this fact and lower the ARF for dental nurses. The BADN also recommends a reduction in the ARF for those registrants – not just dental nurses, but all registrants – who work part time.

“Mr Brack states that ‘protecting the public and maintaining public confidence in dentistry’ will always be the GDC’s first priority.  The BADN would suggest Mr. Brack remembers that without registered dental professionals there would be no dentistry; and pays a little more attention to the needs of registrants – who, after all, are funding the GDC through their ARF!”