At the moment, international dentists must pass the GDC’s Overseas Registration Exam (ORE) or the Licence in Dental Surgery (LDS) run by the Royal College of Surgeons to begin practising dentistry. However, completing these exams can take years to achieve.
The government’s consultation, launched on May 13, 2024, considers ways for overseas qualified dentists to be able to practice in some form before they have managed to register with the GDC.
In documents released at the launch, the Department of Health and Social Care said it could be “an opportunity to bring dentists into the workforce more quickly so that they can contribute towards providing improved access to dental care for patients, as detailed in the dental plan.”
The council said it represents a valuable opportunity for overseas dentists to demonstrate their skills and experience under supervision while adapting to the UK practice environment.
In its response, the GDC said, “We believe it is important that the proposed legislation provides the right framework for the further work required to develop the rules and system in collaboration with other stakeholders. Our response to the government includes a number of suggestions for amendments to the draft legislation to ensure that provisional registration can work safely and effectively, including in areas such as assessment, quality assurance and supervision, and in ensuring that provisional registration aligns with existing regulatory processes, such as CPD and fitness to practise.
“Ensuring that all those who join the dental professional registers have the skills and experience to practise safely and effectively is fundamental to the GDC’s role as a regulator of dental professionals and key to maintaining patient safety and public confidence in the profession.”
Stefan Czerniawski, executive director of strategy at the GDC, said, “The government’s proposal for provisional registration represents the most substantial change to dental regulation in many years. It is essential that it is introduced in a way which protects patient safety and provides effective support and supervision for the internationally-qualified dentists who become provisional registrants.
“The legislative framework published by the government does much of what is necessary to make that possible, and we are pleased to have the opportunity to suggest ways in which it could be improved.
“Putting the enabling legislation in place is the essential first step, but there will then be a great deal more detailed work to be done, in close collaboration with other organisations across dentistry, to design, develop and implement a system to deliver provisional registration in practice.”
John Makin, head of the Dental Defence Union (DDU), said, “These proposals raise a number of challenges around supervision and accountability. We are concerned about the impact on qualified dentists being asked to supervise a potentially large number of provisionally qualified colleagues. The GDC will need to consult on the rules, as supervisors would undoubtedly be held accountable via fitness to practise proceedings for any failures in their supervision and mentorship. At a time where, sadly, a GDC culture of fear still exists within the dental professions – we cannot emphasise enough how important it will be to get these rules right, and ensure they are balanced, proportionate and fair.
“In addition, we anticipate that it will be extremely challenging to find the required number of dentists to provide appropriate supervision. This is based on our experience of the current difficulties in finding supervision for a small number of dentists who have conditions imposed via the GDC’s fitness to practise process. If these plans were to go ahead, there are likely to be a significant number of provisional registrants needing supervision for a broad range of needs.”
“It’s important that the GDC makes the process of registration for colleagues who qualified overseas as smooth as possible while discharging its key duty, that of ensuring patient safety. To that aim, it’s paramount that those practising dentistry in the UK have the appropriate skills and qualifications.”
Raj Rattan, dental director at Dental Protection, said, “International dental graduates are a key part of the solution to the current dental workforce shortage, and we welcome efforts to make the processes by which they can start practising in the UK more efficient.
“While we acknowledge the preliminary efforts to ensure accountability for provisional registration, we strongly advocate a criterion-based quality assurance framework to provide and maintain high standards of supervision. Full GDC registration as the sole criterion for selection or appointment is not sufficient to make a dentist an effective supervisor. Supervisors must also be familiar with the principles of adult education including giving feedback and workplace-based assessments to fulfil their role effectively.
“It is also important that the indemnity provisions for both parties are considered. What are the legal and ethical implications of provisional registration, and what are the risks for supervisors, and how can these be managed? In particular, the doctrine of vicarious liability needs to be examined with guidance on activity, records, and other supporting documents to mitigate the risk.
“Renumeration, eligibility and performance criteria for supervisors need to be clear and unambiguous to avoid the pitfalls of motivational blindness and the risk of commercial exploitation.
“As well as responding to this consultation, we are keen to not only work with the GDC and the Department of Health and Social Care to highlight these issues but also help to design and implement practical solutions.”