Open letter to David Behan, CQC

Open letter to David Behan, Chief Executive of CQC.

Are you really listening?

It is interesting after two full years of regulating dentistry in an illogical and frustrating manner, CQC has now changed its method of charging dentists for its dubious services to the nation. Has the CQC changed to some form of listening mode, rather than the one way, top down approach?

If so, the door is open, I’ll push and see . . . . . .

Dentists told the CQC 24 months ago the previous method of charging was not right but CQC ploughed on in its dictatorial way. I remain uncertain if the new method of charging announced this week is fair, especially when compared with the general medical practitioners, who have their own problems? Why are the medical practice annual registration fees so much less when CQC policy has insulted dentists by saying that medical practices are much busier than dental practices, so they get a two week notice of inspection. By implication, CQC thinks dentists are sitting around twiddling thumbs, therefore our profession can be given 48 hours notice of an inspection. If the medics are busier, they must need more inspection, therefore higher fees. Please explain, Mr Behan.

Inspections of dental practices are now to be three yearly, we hear, so why do total fees collected remain at effectively the same level? And if the CQC is not recovering 100% of regulatory costs from the medical practice sector, the dental sector should pay at the same rate or raise the medical fees. I suggest a solution, CQC should halve dental practice registration fees to make a semblance of equality.

From the early days when the CQC engaged with the dental profession, there has always been a stance of being in charge, the profession are in an adult-child relationship, and dentists must do as we are told. Otherwise the blunt, and oft-repeated threat is that our practices will be closed down. Even now your Fixed Penalty Notices are doled out without warnings, it seems, and are wildly disproportionate to the "crime". During March 2014, CQC sent a communication by email only, it was mandatory, a survey of dental chair numbers. This email contained a threat of a larger registration charge of £1300 if not completed. What if the email was not delivered, or found its way into spam folder? CQC still likes to use the big stick, even in a simple email question. Did the inspectors not record the number of dental chairs in each practice during the exhaustive inspection process?

Recently one colleague told GDPUK forum his practice passed a recent inspection with one proviso, the floor mops were stored the wrong way round, they must be kept with the mop head upwards. The inspector insisted on a further visit to check this, before signing off the livelihood of the practice. Life saving equipment counted for nothing, cross infection controls all passed with flying colours, reams of paperwork counted were discounted, vocal satisfied patients - nothing. The practice might be carrying our complex implant operations, or microscopic endodontic treatments. But it all came down to the mops. But if those mops are not the right way up - that is just not good enough - the public must be protected.

Yet another example of how the CQC have not adapted nor heeded the dental profession has been the issue of having a Nutrition Policy, Outcome 5. Even as a simple dental practitioner, it is easy to understand why, for example, a care home should have a policy for the nutrition of the residents. However, the fact that every dental practice, up and down the country, has to have a Nutrition Policy for its patients is a farce. Dental practices are not care homes, we do not have in-patients, we do not feed our patients. Let's see some sense and remove this glaring foolish error.

Inspections have also been done badly by the CQC, using lay inspectors, people with training in care homes or pharmacies who cannot check dental aspects with a knowing eye. They can carry the clipboard, they can empathise with patients, but what do they know about running a dental practice? A simple example - emergency drug boxes contain dangerous items - but they have to be easily accessible and not double locked and secured in a locked room, otherwise they cannot be accessed in an urgent moment. Dentists would understand this, some inspectors have not.

As a dentist myself, I do not know enough to properly inspect a nuclear power station, or an abattoir, and many other places. I am sure the right people check on power stations but my point is that the real knowledge of any sector, any profession or industry, is held by people who are immersed in that sector. Inspectors from the sector know the shortcuts, they know the boxes that are ticked without real care, they know where the secrets might be hidden, the true ins and outs.

The Health and Social Care Act dealt the CQC a hand that was difficult to resolve. Each health sector has to pay for the inspections and administrations for their activities, but dentistry continues to feel it has been given a tougher set of cards, then bullied by CQC carrying a big stick.

My message, Mr Behan – listen more, get off the back of the profession, cease the bullying style, and equalise the disproportionate fees our sector bears.

References:

CQC release http://www.cqc.org.uk/public/news/registration-fees-1-april-2014

Notes from CQC http://www.cqc.org.uk/sites/default/files/media/documents/20140331_fees_2014-15_legal_fees_scheme.pdf

GDPUK disucssion thread: https://www.gdpuk.com/forum/gdpuk-forum/cqc-no-fee-increase-in-registration-for-dentistry-16500