Most dentists will by now be aware of the GDC’s consultation on increasing the level of the Annual Retention Fee. The GDC is considering a fee increase of 64 per cent for dentists and 6.7 per cent for DCPs. As the GDC asks the profession for more money, there is a sense there is little choice and this is a signal that our regulator will be taking more from us.
The GDC undertook a public consultation to which they report 1,255 responses; they do not state how many stakeholders were consulted or the response rate. It is also unclear how the responses were distributed across different types of registrant and the public. Given that these responses provide part of the rationale for their case for change, a more detailed analysis would have been useful to understand the value of the evidence. The GDC also discusses the introduction of costs orders for those undergoing fitness to practise proceedings. Whilst this may seem attractive to some, there is a real risk that such orders become punitive in real terms. For some
registrants, these orders may not be affordable given they may have suffered a loss of income during the proceedings.
The GDC reports on its own efficiency savings and proposals to make further savings with legislative assistance. It could be that the current consultation and the outcry from the profession is a mechanism of demonstrating to Government the need for rapid change; although the estimated savings of about £2m are unlikely to reduce the proposed ARF by anything more than £20-40, depending on whether or not the saving is applied proportionately to the ARF of dentists and DCPs.
The GDC cites a number of reasons for increasing the ARF, including the 110 per cent increase in complaints; however the increase in proposed expenditure for the Dental Complaints Services is actually relatively modest. It’s actually the Fitness to Practise function which seems to be causing the biggest increase in ARF. Undoubtedly complaints to the GDC will increase, especially as the literacy of the population increases; however when the GDC’s own complaints service places an advert in national newspaper this is likely to be compounded. It is important that any regulator is outward facing and ensures the population is aware of how they can voice concerns; however this particular advert does not appear to be based on any assessment of patient needs. Typically health literacy increases as relative deprivation decreases, it seems likely that readers of certain national newspapers will already have good literacy and are likely to be more aware of their rights. It’s the deprived populations who may not have access to such newspapers that are probably more likely to benefit from increased awareness. By raising awareness amongst the ‘middle classes’ the GDC may even widen an existing
inequality.
Dentists vary widely in their earnings, some dentists may only work part time and have very modest earnings and there may be very active specialists who have considerably higher earnings. At a time when dental foundation trainees are facing a significant cut in their income, it seems very unfair that the GDC plans to increase its fees so significantly. This would only compound the feeling of indebtedness amongst so many young dentists. An increased ARF would also further highlight the fact that some dentists are on low salaries in relatively low risk roles compared to other registrants. It would seem that an
ARF linked to hypothetical risk of all registrants is not the fairest method of setting fees and a more balanced approach may need to be considered.
The GDC has just over a 100,000 registrants of which 38 per cent are dentists and remainder DCPs. The changes in ARF would result in the GDC’s ARF related income becoming £45m. The GMC by comparison has just short of 260,000 registrants and its ARF income is approximately £95m. If we accept
that the cost of regulating dentists and DCPs is different and that the majority of the costs are borne in relation to dentists then the GDC’s costs are at stark contrast with those of the GMC. There are almost six times as many doctors as dentists when comparing the registers. However the GDC’s income from dentists would place their workload at about 40 per cent of that of the GMC. On this basis, something does not seem right and the GDC’s
proposed operating costs could seem excessive. The GMC may just be extremely efficient or it may be that the GDC needs reconsider the scale of its activities and reduce costs by about 25 per cent. The GDC could take the view that the public will ultimately pay for this increase through the market. That is, the cost of delivering dentistry increases and either the fees charged to private patients will increase or the profession will need to lobby the DDRB for rise in NHS income.
In recent years regulation has expanded especially with the introduction of the CQC and following the most recent reorganisation of the health system we also have quasi-regulation from NHS England accompanied by Public Health England. However, this sea of organisations has still not found a way of working together, their processes are poorly aligned and their internal policies are inconsistent between different areas. This variation leads to inefficiency which ultimately drives up costs and contributes to poor quality. In my view, such a significant increase in fees seems harsh and would be unlikely to be accepted in many other industries.
The GDC should work more closely with the other regulators and state bodies to reduce inefficiency and collectively bring down their costs for the benefit of
the wider population.