“IOC must have comprehensive and clear guidance” to avoid unnecessary conditions

01 March 2023

Dental Protection has welcomed proposed changes to the guidance used by the GDC’s Interim Orders Committee (IOC), but says refinements are needed to ensure the IOC has the most comprehensive information possible, when deciding on whether an interim order is necessary.

Dental Protection has welcomed proposed changes to the guidance used by the GDC’s Interim Orders Committee (IOC), but says refinements are needed to ensure the IOC has the most comprehensive information possible, when deciding on whether an interim order is necessary.

The IOC is a statutory committee of the GDC which considers whether it is necessary to make an interim order to restrict the individual’s practice pending final determination of the matter by the GDC. A decision can be made to impose an order if the IOC is satisfied that it is necessary for the protection of the public, or otherwise in the public interest, or in the interest of the individual concerned. The IOC can impose a suspension (up to 18 months with six monthly reviews), conditions (up to 18 months with six monthly reviews) or decide that no order is necessary. Having such an interim order imposed can have a very significant impact on dental professionals and it is therefore important that such orders are used appropriately and proportionately.

Responding to the GDC’s consultation on proposed revisions to its IOC guidance and Conditions Bank, Dental Protection said there was a need for the IOC to be provided with further and comprehensive details as to specific allegations against the dental professional, to help the IOC decide whether there is a risk to the public. It said this additional information would help to ensure the IOC assesses the risk to public safety consistently, proportionately and appropriately.

Dental Protection called for further refinements to allegations relating to clinical cases, lack of indemnity or insurance, failure to cooperate with an inquiry, sexual misconduct and violence, working beyond scope of practice, and concerns about the health of a dental professional.

The leading defence organisation also said further clarity was needed in the definitions used in the glossary of the IOC guidance, including in respect of the term ‘reviewer’, which is unclear and could refer to the registrant, supervisor or reporter. It said the glossary, guidance and the conditions bank provide important supporting literature and must be clear in order to facilitate appropriate decisions.

Raj Rattan, dental director at Dental Protection, said, “We support dental professionals with IOC processes and hearings day in, day out. We see the impact these hearings have on their careers and well-being and appreciate the opportunity to contribute to this important consultation.

“Dental Protection has strong teams of experts, with considerable experience of IOC processes, who have taken the time to review the proposed changes. While we broadly welcome the proposals, we have highlighted some key areas that require further refinement. The IOC must have comprehensive and clear guidance and supporting literature, in order to make appropriate decisions. Interim orders can have career changing implications for members, so we must get this right.

“While we welcome the proposed amendments to the IOC Guidance, we would also welcome the GDC reviewing the processes by which registrants are referred to the IOC in the first instance. We remain committed to working with the GDC on this matter.”

A spokesperson for the General Dental Council (GDC) said, “We welcome support for our proposed changes and thank all stakeholders who have provided views on how the IOC guidance and related documents can be improved. We always seek to engage a wide range of stakeholders and welcome feedback that can lead to improvements in our guidance to dental professionals. Publicly consulting on the updates we have proposed is a good way to achieve this engagement. We will consider the views submitted and report the outcomes of the consultation, along with the revised guidance, in due course.”