In the late autumn of 2009 – more than five years ago - I first encountered the organisation that was to create a major change for dentists in England: the CQC.
Its initial interest then was finding out how many purely private dental practices existed in England, and their location, for no such directory existed. To an organisation that had previously worked only with larger institutions such as hospitals and care homes, dentistry was very much a ‘dark art’.
The Labour administration of the time had signed off an expansion of the CQC’s remit to include primary medical and dental care, and private ambulance services. The vision of ministers (according to contemporary documents) was to have “light touch” regulation of most dental practices, since the NHS already had good insight, through the
Dental Reference Service, PCTs and the Dental Services processing operation. Private practices would, however, come in for closer attention as they were perceived to be “un-regulated”.
Fairly quickly it became apparent that the resource and organisation of the commission left much to be desired. Staff appeared to rotate between roles at a significant rate, and maintaining contact with its many internal divisions was difficult.
Following the general election in 2010, my first question to the new minister for dentistry was: “Are you really going to go ahead with this imposition?” The answer - based on the advice of officials - was an implacable yes.
At that point, and with less than nine months to go before registration became mandatory for all dental practices, my focus became ensuring that the dentists I engaged with were able to register and to achieve compliance with the law. Note: this did not mean that I was either in favour of the principle, or especially with the cumbersome process that then ensued.
So five years on from that point, we have a new regime for dental regulation (started April 1, 2015). What’s changed?
The biggest change has been largely behind the scenes and unseen by the profession. The arrival in 2013 of new senior management at the CQC heralded a different strategy. No longer would we have a “one size fits all” approach to regulation, but something that was relevant to the characteristics of – and risks posed by – each sector.
Dental practices – in the CQC’s own words – present lower risks than most health and social care sectors. That’s selfevident and a pity that it took more than three years to recognise. Moreover as a profession, dentists are by and large keen to ensure that patients are safe, satisfied and cared for. As small businesses where cash changes hands and loyalty matters, dental practices are different from many health bodies.
However the 2015 changes are not to be seen as minor, nor a lessening of scrutiny. Inspection teams are now dedicated to specific sectors and can be expected to have greater insight into their particular sphere of interest. Most inspections will now have a dentist or DCP in attendance as well.
Whereas the previous approach often concentrated on just a few aspects of compliance, expect the new regime to look at all aspects of the provision of care and the management of the business. We already know from pilot inspections carried out that this will mean longer inspections and significantly more detail. Be prepared!
New management at CQC has also brought with it a much greater attention to engagement. This has meant more regular meetings with representatives and advisors from the profession. When it became apparent that OFSTED style ratings would be applied (instead of the previous ‘five ticks in boxes’) this was successfully opposed on the grounds that if not all dentists were being inspected, it was unfair for a few to achieve “good” or “outstanding” ratings - that may however change in future years to come as inspections roll out across the board.
Inspections of just 10 per cent might appear at first sight to mean the odds against being troubled are good, however many will be random, and un-announced inspections triggered by complaints, concerns or other issues will continue.
Although the new two weeks’ notice of a routine inspection may appear to give time for ensuring that everything is shipshape, it offers the busy practice little opportunity to ensure that all aspects are dealt with and communicated effectively. Much better to get things right in any event.
It may seem odd (and remember, I am not claiming for a moment that all has been well with the regulatory process, nor even that regulation is the answer to all ills) but the majority of the practitioners I spoke to after the first round of inspections felt the process had been a positive one. Sure, there were a few glaring errors and the knowledge base of the inspectorate was initially patchy to say the least, but most practices were glad that the quality of the care they provided was recognised. It’s clear that the new regime will be different and possibly more stringent. But the prepared practice should not have anything to fear.