What services can Right Path4 offer?

•If you‘ve had your CQC visit you might be interested in what’s likely to be happening next

•If you’re waiting for the call, you might like to call us first (50% of dentists)
•If you’re developing your business for the future, you could use the CQC as a good start
•If you’re considering buying a Practice and...

What services can Right Path4 offer?

•If you‘ve had your CQC visit you might be interested in what’s likely to be happening next

•If you’re waiting for the call, you might like to call us first (50% of dentists)
•If you’re developing your business for the future, you could use the CQC as a good start
•If you’re considering buying a Practice and want sensible, friendly and timely advice
•If you’re selling your Practice and want to maximise your return
•If you want a sensible solution to running your Practice smoothly (We have it)
01892 521245 (Office day and evening)



Happy New Year from RP4 - 2018 Special Offer!





If your practice would like to join RP4 today, there is a special offer * for GDPUK Members (£59.95 a month INCL VAT).

*New GDPUK members are invited to a friendly online tutorial (Google Hangout) where you share our screen and we set up the RP4 system for YOUR practice so that it’s ready for you to start using right away and we’re supporting you 7 days a week!

You can join now using this link - https://pay.gocardless.com/AL00016VCPR74Z



RP4 are the EXPERTS by experience, there’s no joining fee and no ongoing contract tie in. RP4 BLUEPRINT are the ‘go to’ people for more than 750 practices. Our Experts are all dentists with detailed experience of working with the Regulators and Indemnity Providers at the highest level.

Below is video created by Keith, which explains the RP4 System.




Sign Up Today, click here to start today.



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Is the GDC supertanker turning? by Keith Hayes

Is the GDC supertanker turning? by Keith Hayes

Last Monday 14th August 2017, I had another meeting with Jonathan Green (Head of FtP) and Matthew Hill (Head of GDC Strategy). 
It was a no holds barred meeting and I was free to ask any questions. I wasn't locked in dungeons under 37 Wimpole Street at any point! 
Here is the agenda of the 90-minute meeting, along with the GDC answers in blue. 

It raises some important considerations about what we need to do as a Profession. I think we need to think about the answers and discuss a strategy for the Profession. 

Continue reading
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© GDPUK Ltd 2017

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GDC hearings: The imbalance of probabilities

GDC hearings: The imbalance of probabilities

GDC hearings: The imbalance of probabilities

Can we make the Regulators serve the Public and the Profession in foro conscientiae (the court of the conscience), rather than just a notion of what the regulations might say?

I have attended and been asked to make some input into a variety of cases recently involving several different Regulators.

It has become clear that there is a real danger that rules and regulations which may have been drafted for the protection of the Public and the guidance of the Profession are sometimes widely misinterpreted at best and occasionally deliberately corrupted and applied at worst.

How does this occur?

Whilst it might be considered that most regulation has been drafted to improve standards and reduce the risk of poor practice continuing; it is quite obvious that it can be applied in a manner to exert control or ‘manage’ the Profession. Sometimes this may occur deliberately and because it broadly serves the purpose of a government administration, it is allowed to continue at least as long as it serves a purpose. Sometimes it occurs at a much lower level and whilst not serving any particular purpose, it is allowed to continue because there is nobody at that level who is prepared to question it.

I’ve got nothing against shop assistants, however I wouldn’t be wanting them to draft the GDC Charge Sheet which might end a Professional career. There is a high turnover of staff at the GDC which I suggest leads to a poor understanding and there appears to be a low level of dental knowledge.

What this might mean if you are in the dock

One of the cases to which I refer involved a young colleague, and for whom funds were raised at very short notice thanks to the excellent GDPUK membership.

If you read the Charge Sheet, you would be forgiven in believing this dentist was a real danger to the Public. However I’m sure that you will all remember me reminding you to read between the lines whenever you are dealing with a Regulator. That is certainly necessary in this case.

Example appearing on a Charge Sheet

(i)            The use of a double cantilever (the bridge was fixed-fixed)

(ii)           Not adequately assess that a RCT was required (the tooth was root treated and had been a symptom free bridge abutment for 20 years)

(iii)          Fitted an inadequate post which was a) short of the apex, b) not extending to the apical third and c) was inadequate in width. (The post was temporary and deemed too wide).

If the Charge sheet is a nonsense, the solution is simple. The Panel changes it, strikes it out or substitutes different wording. In other words, it moves the goalposts. The Panel, which is independent by hearing both parties then asks its own questions of the witnesses. It is advised by experts and can choose which expert it ‘prefers’. The expert appearing on behalf of a registrant might then be warned by the Prosecution barrister that the GDC may take action against them. The prosecuting barrister is instructed by the GDC and regularly prompted by their expert witness.

In one of the cases to which I refer, four patient witnesses who had made a complaint were called. One of the witnesses was travelling to London and it was found that she intended to speak in favour of the Defendant and it was agreed therefore that this patient would not be heard.  

The Panel seemed to have some ability to read between the lines, but in the end ‘prefers’ the testimony of two patients. One of these patients produces a hand annotated diary of the treatment dates containing some dates that the defendant was actually not in the practice (a screen shot of practice diary was produced as evidence). The patient was receiving treatment from more than one dentist at two different practices simultaneously, but on the ‘balance of probability’ is to be believed. This patient was heard to say that she was seeking ‘redress’ on at least four occasions.

Our young colleague describes how he always uses rubber dam for RCT and yet on his last day in the practice he finds there is no rubber dam available. He admits that on this single solitary occasion, rubber dam was not used. The patient has pleaded that a temporary post crown be placed (the same inadequate temporary post that was short of the apex) and he accedes to the request of RCT and temporary post, since the broken tooth was within the patients smile. He uses rotary RCT instrumentation, floss on hand instruments and high volume aspiration. The patient is the same one who was not given the opportunity to give further evidence in support or denial of the registrant. Our young colleague is guilty therefore of serious clinical failures and therefore misconduct.       

Another patient gives evidence about never having received treatment he has paid for, but the Panel agrees that this evidence is just not credible, which it isn’t.

A fourth patient was having a long and complex treatment plan part of which had been incomplete and following a tooth fracture needed to be modified. The patient didn’t clearly understand the new treatment plan and for that our colleague was criticised.

It’s worth mentioning that there were NO PATIENT RECORDS available because there had been a burglary declared immediately following the practice change of ownership. This was highlighted to the Panel. 

Communication was a big word in this Hearing. Other significant words are ‘insight’ and whether or not the Panel consider that this is ‘embedded’ sufficiently. Our young colleague was supported by Sir Peter Bottomley in person who made a statement and also by the testimonials of 47 patients.

The GDC however do not need to give weight to the above in making their determination, although I noted that the prosecution barrister frequently returned to the GDC to ask for further instructions. I think it worthy of note that the Panel describe our young colleague within the Determination as follows ‘It is clear from all of this evidence that you are viewed as a competent and caring dentist, who will go out of his way to assist his patients.’

Do the GDC therefore need to apply Conditions, because that’s what they did? 

Please read the GDC Determination when it is published.

So what?

If you recognise any of the issues above, you are guilty of misconduct and your standards will be deemed serious failings. Approximately 1 in 7 dentists in the UK currently face some form of investigation which could result in imposition of sanctions either through the GDC, CQC or NHS and this number is growing constantly. This might mean that we have the worst performing Dental Profession in the World bar none or that we have the most disproportionate Regulators.

You may consider yourself lucky and are happy to cross the bridge with your indemnity organisation when your time comes; or you may be sufficiently confident to wade across the raging torrent alone when your indemnity organisation makes an unexpected discretionary decision against you.  

What type of indemnity organisation are you currently paying for?

How can it be legal?

You are required to have professional indemnity and it is considered a serious failure if you have ANY gaps in your cover period. Indemnity providers however do not guarantee to provide legal representation to you and if they exercise their discretion in favour of their balance sheet (or dressed up as other members interests) you will find yourself alone or facing a huge legal bill.

A recent Hearing which I attended over 7 days starts at £32,000 and it’s uphill from there.

Does anything need to be done about this?

You read the PSA report published 21st Dec, I hope.  https://www.professionalstandards.org.uk/docs/default-source/psa-library/investigation-report---general-dental-council.pdf?sfvrsn=6

What exactly have we learned about whistleblowing from the Sir Robert Francis Report (Mid Staffs)?

And you can see how the whistleblower was treated, you can see what the PSA thinks about it and you have seen how the GDC are going to be dealing with your ‘serious failings.’

You tell me, do you need to do something about this?

So where are we now?

From a variety of recent cases we can conclude:

·         The GDC consider failure to use a rubber dam in endodontics to fall seriously below the required standards and therefore to represent IMPAIRMENT and worthy of sanctions.

·         In my view neither the CQC nor the GDC have a currently correct understanding of CONSENT which conforms with the recent Supreme Court judgement of Montgomery – v Lanarkshire Health Board. This needs to be challenged in the High Court.

·         The GDC will always use the ‘balance of probability’ in forming an opinion on which evidence it prefers. 

So where are we going in 2016?

The Profession must for once in its life join together. The issues regarding Consent and use of rubber dam will need to be challenged and this requires more than a well-intentioned individual or some crowd funding. It requires a strongly actioned move being taken by the BDA and the indemnity providers.



Image credit -Michael Coghlan under CC licence - not modified.   

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© Keith Hayes, GDPUK Ltd, 2015

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Get your dental practice on the Right Path

Get your dental practice on the Right Path

When will you have the benefit of RIGHTPATH4 like hundreds of others? £250 once

Many pay £thousands or pay monthly to have an insight into CQC.

Some pay a lot less and once only and gain a whole lot more.

You could save yourself a fortune and join us now.

See what others say:


I just wanted to write to let you know how your package is working for us in our practice.


I’m not sure you are aware but we relocated premises in August 2014 moving from one surgery to three surgeries.  We recruited new staff and increased from five to sixteen, which included a trainee nurse, a nurse who had not worked in general practice for a year or so, an apprentice and a new housekeeper who had not worked in a dental practice.  It did feel like I was running around in circles as I did naively think you just transfer from one site to another.


I then came across the RightPath4 CQC package and purchased it at the start of the year and what an enormous benefit it has been to our practice. 


Having read all the information I delegated everything to all the staff, we then come together during lunch times, staff meetings etc to discuss, plan, and modify.  All the staff have completed the poisoned chalice, which is an interactive series of questions regarding each room.  I can then review their answers and add any questions they were unsure of or did not know, to the agenda for our next staff meeting. It has led to interesting staff meetings, with debates and staff keen to demonstrate what they do and what we should do.


The virtual inspection and clinical governance have been areas that the assistant manager and myself as practice manager have completed, and what a huge help they have been.  They look at: how we work in the practice, who should be doing it, why we should be doing it, when it should be completed, how it is completed and what we need to complete.  We have looked at every aspect at what we do, again, working closely with all the staff, who have helped by giving their input on the paperwork, processes and procedures we need to complete.  We have even kept all our working documents as evidence of how we have moved on.


From my point of view it’s all very well, writing a policy and procedure but does it really work in practice, I found that by getting all the staff involved, helps with morale and motivates them more to know they are being heard, and that their input is valuable and taken very seriously.


I know the package is something which we will use continually, to review and monitor our practice, and any questions I might have, I know I can email you.


Sorry for going on I just wanted to let you know how grateful we are for your package and the help you have given and continue to give to us.


Kind regards,



Noah’s Ark Dental Practice 


For further information on the Right Path 4 service, contact details are below. 


Telephone: 01892 521245 
(Office days and evening)
Mobile: 07831496477 

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.


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How is the CQC going to assess and inspect dental practices in 2015?

How is the CQC going to assess and inspect dental practices in 2015?

How is the CQC going to assess and inspect practices in 2015?

Here’s a check list that I have used BEFORE I plan a CQC visit:

·         Website for opening hours / NHS/private / services & treatment provided

·         Inspection history: Summary including date of last inspection, and including any breaches of regulation(s) or concerns identified at the visit. Date action plan completed.

·         Local Area Team (LAT) information return: Date sent and returned - any issues.

·         Provider information return: Notes re statement of purpose / compliments & complaints.

·         Feedback: A brief high level summary of any patient / other feedback from any other source.

·         Registration: Summary of changes to registration and registration issues, including details of the registered manager.

·         Notifications: Summary of notifications received at CQC, whether received when needed and within relevant timescales.

·         Concerns and enforcement: Summary of any concerns and/or enforcement not already covered above.

You have this information, so why not review it and decide what the CQC will make of it?

What does this mean in 2015?

CQC inspection in 2015 will be based on the following and in my opinion biased heavily towards Safe and Well-led. With this in mind, look down this check list and think about how exactly you could show me evidence that this is happening today in your practice.   I’ve put a few examples in each section.  


·         Lessons learnt and improvements made when things go wrong. Evidence? (risk assessments, RIDDOR, improvements made, changes planned etc.)

·         Care assessed to prevent unsafe care and treatment. Evidence? (Medical history checking system, treatment planning, record card audits, retrospective radiograph audit) 

·         There are systems, processes and practices in place to keep people safe and safeguard them from abuse.

·         There are systems, processes and practices in place to protect people from unsafe use of equipment, materials and medicines.

·         There are systems, processes and practices in place to prevent healthcare associated infections.

·         Potential risks to the service and individuals are anticipated and planned for in advance.

·         There are systems, processes and practices in place to ensure all treatment and care is carried out safely.


·         Patients are always involved in decisions about their treatment and the practice obtains valid consent and audits records of this. Evidence? (Record keeping audit, patient information in various formats, fees explained and written treatment plans, agreed practice wide system for recording treatment options understood by patient, pros and cons explained, time given for decisions, Mental Capacity Act understood)

·         Patients’ needs are assessed and care and treatment delivered in line with current legislation, standards and guidance. Evidence? (new patients survey considered, waiting time audit, opinion survey used, disability access audit performed, practice meeting minutes where GDC/CQC standards discussed, staff sign policy documents, system of governance operated)

·         There are effective arrangements in place for referring to other health professionals to ensure quality and continuity of care for the patient.

·         Patients’ oral health needs are assessed and care and treatment delivered, or referred, in line with current legislation, standards and guidance.

·         Staff have the right skills, knowledge and experience to enable the effective delivery of care and treatment.

·         Staff are recruited, inducted and appraised regularly and records are always available on the premises.



·       Patients are treated with kindness, dignity, respect and compassion while they receive care and treatment. Evidence? (Confidentiality always considered, patient survey acted upon, waiting times audited, comments book shows many patients are pleased with care, telephone answered promptly and politely with log kept, emergency spaces available every day, complaints tracker shows all complaints handled carefully, staff training logs, privacy and dignity respected).

·       Are people and those close to them involved as partners in their care.

·       Does the practice promote equality and diversity and recognise the needs of different groups.


·         The practice staff routinely listen and learn from people’s concerns and complaints to improve the quality of care. Evidence? (Practice is growing, has plans for improvements, staff levels constant and staff encouraged to develop competencies, complaints handling regularly updated, everybody encouraged to participate, complaints tracker up to date and good comments in book, NHS Choices etc).

·         Patients receive an explanation of any need for referral with copy of letter and options/consequences.



·         The governance arrangements ensure that responsibilities are clear, quality and performance are regularly considered and risks are identified, understood and managed. Evidence? (There is a written system of governance which is used in training and regularly updated, all staff are competent and have a personal development plan, there is a culture of openness and professionalism).

·         How does the practice engage, seek and act on feedback from people who use the service, public and staff.

·         How do the leadership and culture reflect vision and values, encourage openness and transparency and promote delivery of high quality care.


Let me ask you a few questions.

In your honest opinion, how do you think your next CQC report will look?


Bear in mind that It only takes one person to sink your ship.

Who actually runs your practice on a day to day basis?

Do you have a plan of where you want to be in a year, or five years?

How are you confident that all your staff know what the standards are?

How do you monitor standards of safety, effectiveness, care, profitability, popularity and are you moving ahead?

This is why you must have a system of Governance, I know this, you know this, the CQC insist on this. 

RightPath4 can provide a system of governance mapped to 2015 CQC requirements which is simple to implement and does not cost £thousands or run to thousands of pages. It is easy to bespoke it to your practice and use as an important part of your practice meetings and induction. We have a unique template tool which helps you give confidence to the CQC that your practice is safe, caring, effective, responsive and well-led.

£250, no ifs, buts or VAT

£540 and we’ll deliver it to you and spend a day showing you how to apply it to YOUR practice.  There are no ongoing payments, unless you want us to keep prompting you. (We do offer to update you and revisit your practice at a monthly cost of £70 payable by Standing Order, it’s optional though).

I hope we will be able to continue to help you.

Kind regards,

Keith Hayes BDS  Clinical Director RightPath4 Ltd.,

There when it counts.

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© Keith Hayes, GDPUK Ltd, 2015

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What's coming from CQC

What's coming from CQC

You’ve got CQC hindsight, but have you seen what’s coming?

The CQC have ‘Fresh Start’ plans for us in 2015        

It’s part of their strategy for 2013-2016, Raising standards, putting people first).

They are more focused than the previous ones and inspectors will be more

experienced in assessing dental practices.

The new standards are divided into eleven Fundamental parts. 

Fit and Proper Person (Directors) and Duty of Candour are 2 new standards.

The CQC have also beefed up their enforcement powers, meaning that they

may not give you a warning before they prosecute.


How do the old ‘Outcomes’ relate to the new Standards?

The simplest way to explain this is for you to complete my CQC survey: https://www.gdpuk.com/index.php?option=com_rsform&formId=57 and then I will send you an explanation of how to relate the old CQC to the new CQC and the new (ish) GDC principles. I will also send you an explanation of what the ‘Key Lines Of Enquiry’ (KLOE) is all about and how it will be applied in April 2015.

What effect have the CQC had so far?

Many of you kindly told me about your CQC thoughts in my survey, (see link above) which is still running.       By sending it back to me, you will now know what or who KLOE is. The CQC inspector will use these KLOE’s to guide the inspection process and make a judgement. The CQC still haven’t decided about publishing these.   

I have summarised what you have told me so far from my surveys and will be discussing them with the CQC. We may yet be able to have a sensible regulator looking at the right things in an intelligent way.

My prediction for 2015 is that FEES, Cosmetic dentistry and dermal fillers will also come under the spotlight.

Brief analysis (from 76 surveys)

I have used this as a pilot survey to determine whether there is a need to gather more information on how well the CQC registration and inspection process is received and what the beneficial effects may have been in driving improvement.

I think relatively few will have experienced re-registration and therefore a low %age answering YES to Q1 may be expected. However it is disappointing to see that 48% still felt that the process has not been made clearer. 

There continues to be much confusion over legal entities and I know (from personal experiences of clients that this is still a problem now, 76% of respondents agree.


81% felt that the inspection was not structured to reflect dental practices; even higher (87%) saying that the nuances were not understood and many said that a dental adviser is required.   

It seems that few felt that they understood what the CQC expectations are regarding safe, well-led and managed practices. I was particularly pleased that our own clients were in general more ‘upbeat’ about the potential benefits of CQC compliance and also felt more empowered and knowledgeable (judging from some open question comments).

The open questions were designed to test whether the process of declaring ‘compliant’ 48 times in the original application had sparked an interest in them to get things done before inspection, just in case. It seems that this was the case in as much as 72% said they had done some things, although I need to look more closely at this figure because some of what was said was fairly minor ‘window dressing’ was one comment.

The most significant results I feel were relating to the perceived benefit of CQC registration and inspection.

The positive improvements noted by patients and staff reached only 14% and the consequential improvements to the business reached 21%. Finally regarding your additional thoughts, there were many suggestions and yet only 6.5% of these were positive. I have concluded that an improved and much larger survey spread amongst a wider audience is required.

OK, so what?

From April 2015, CQC inspection reports will look quite different. Instead of considering just 4 or 5 Outcomes; the inspection will be constructed in a different way to test whether your practice clearly demonstrates that it is safe, caring, responsive, effective and well-led? A CQC inspector has described how the new process enables them to ‘get under the skin’ of the practice and see what is really happening.

Safety is now considered of paramount importance following on from the terrible instances of poor care graphically illustrated in the past few years. Although the CQC had considered that dentistry was relatively much lower risk; there was a severe jolt to this belief recently in Nottingham. The GDC are also convinced that there are also still much greater problems within the Profession. So it is my guess that safety will share top billing with being well-led.

It is hard to imagine that a well-led practice would be unsafe or that there would be many unresolved complaints or that there is a high staff turnover or patients don’t have fees explained properly.

RightPath4 can provide a system of governance mapped to 2015 CQC requirements which is simple to implement and does not cost £thousands or run to thousands of pages. It is easy to bespoke it to your practice and use as an important part of your practice meetings and induction. We have a unique template tool which helps you give confidence to the CQC that your practice is safe, caring, effective, responsive and well-led.

In the next blog article, I’m going to discuss how the CQC are going to assess and inspect in 2015.

Here’s wishing you a Happy, Healthy and Prosperous New Year,

Keith Hayes BDS

Clinical Director www.rightpath4.co.uk This email address is being protected from spambots. You need JavaScript enabled to view it.

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© Keith Hayes, GDPUK Ltd, 2014-5

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Upsetting the Applecart

Pantomime season with a Grimm warning   


I’ve had a busy couple of days and upset some applecarts; perhaps I should apologise if I have bruised any fruit?

On Friday the 21st, I spent an interesting day in Corpus Christi College, in Cambridge with my fellow NADA (National Association of Dental Advisers) colleagues as well as a selection of the great and the good and quite a few of our younger dental colleagues who had come along for the verifiable CPD and to find out what sort of profession they were entering into.

Sarah Rann (assistant medical director East Anglia Area Team NHS England) kicked off proceedings by asking us and then telling us what we should be doing as National Dental Advisers. The only aspect that she missed off her list was influencing the Regulators, (aka upsetting the established applecart by proffering an expert opinion).

We were then treated to a relatively complimentary double act between Barry Cockcroft and John Milne’s views on Contract Reform. There was a large amount of agreement even concluding with synchronised retirement from their respective roles early next year. Barry emphasised that ‘access’ was less of a political hot potato now than it had been and he saw this as one of his successes during his tenure. John talked about the impact of pilots and possible implications.

A little local difficulty about a dental practice not far from Nottingham was briefly mentioned.

A question regarding access to certain less privileged groups was aired and this is where I must apologise. I raised the question of ‘access to what quality of care?’ And I then asked ‘who was responsible for the World Class Commissioning of such ludicrously large and unmanageable contracts?’

Well there was a stunned silence and poor Barry looked like he had been stabbed in the chest. Fortunately John was on hand to ride to his rescue and acknowledge, although not answer the question and then draw stumps on this part of the meeting.  

We were treated to some joined up thinking from David Geddes (National head of primary care commissioning) who discussed intelligently and without too much smoke and mirrors what the future 5 year plan may mean to dentistry, please read this if you haven’t: http://www.england.nhs.uk/ourwork/futurenhs/

Amanda Crosse (consultant in Dental Public Health) went a little off piste with her unguarded comment regarding perhaps planning to have dental NHS commissioning overseen by CCG’s. An interesting idea which seemed to irritate the level headed David and which he was forced into backtracking a little.

David Behan was cut short, the previous part of the agenda having overrun by 50 minutes meant that David only had 10 minutes to get his message across about the new CQC. He did it very well I thought and was only sorry that it was necessary to tell the gathered throng of dental advisers that he was disappointed in their union attitude to pay and perhaps we would like to put something back into the profession. He was having no more of discussing an inflationary fee. Actually I agree and am happy to spend my time for free advising the CQC.

This is where all of you come in…...’Efficacy and the CQC inspection, on the right path now? ‘It’s your opportunity to get the message across and its coming to GDPUK soon.


 Poisoned apples for ‘afters’………..,

The afternoon was devoted to a Brother’s Grimm pantomime about a dodgy dentist with decontamination and NHS gaming tendencies, played brilliantly by Bryan Harvey (DDU), who was frighteningly good at getting into Character.  We were assured that this was not based on any recent situation and I pointed out that it couldn’t have been, since they failed to notify the Press or recall 22,000 terrified patients…., Oops!

The GDC on this NADA inspired day was represented by Mike Ridler (Head of Hearings) who displayed distressing figures on FtP hearings.  Mike expressed his inability to understand the reasons since in his experience there had not been an associated decline in professional standards. Somebody in the audience mentioned that it might have something to do with National advertising?!! Mike did not wish to be drawn further on this.

He obviously didn’t feel inclined to join in with the GDC pantomime either and suggested that if anyone wanted to talk about other ARF type issues they could do this individually later, although it wasn’t his ‘field.’ He then failed to answer the other questions, since they weren’t his field either.   

The meeting closed with another unplanned shedding of apples just as stumps were drawn and flat hats were on; Jason Stokes leapt up on stage and shouted that if the younger members of the audience felt slightly dismayed by opinions voiced by the demobbing great and the good; NOW is the time to make their voices heard. Oyez, oyez!


Keith Hayes

Right Path Ltd

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Whistleblowing and responsibility

Whistleblowing and responsibility

The UK law related to whistleblowing changed significantly at the end of June with the result that legal protection for employees who report wrong-doing by their employer is only now afforded to those raising allegations of public interest. In other words, now the element of “good faith” required previously has been removed, disputes over personal issues, such as pay or performance management which lack a public interest element, will no longer be protected under the legislation.

So perhaps you should ask yourself; should I be blowing a whistle and what is the purpose?


Team members are often the first to realise that there is something amiss within the practice. However, they may not wish to express their concerns as they may feel that speaking up would be disloyal to their colleagues or to the practice.


Whistleblowing should primarily encourage and enable team members to raise serious concerns within the practice rather than overlooking a problem or 'blowing the whistle' to an external body. It is important that every organisation, whether it be a dental practice or even a body such as the Care Quality Commission (CQC) itself recognises their responsibilities and takes them seriously and intelligently.

Raising awareness of serious concerns when you work within an organisation asks a lot of the individual and this is the reason why it is necessary to emphasise that they are protected in law by taking appropriate actions. It should be a clearly stated Policy that the practice recognises that the decision to report a concern can be a difficult one to make. If what you are saying is what you believe to be true, you should have nothing to fear because you will be doing your duty to the practice and the patients alike. Furthermore the practice will not tolerate any harassment or victimisation and will take appropriate action to protect the team member who raised a concern in good faith.


Sometimes circumstances have a habit of being rather more intertwined don’t they?

Whenever there is a problem within a dental practice, whether this relates to patient care directly or working relationships; it is wise to attempt a locally agreed solution. Usually a discussion of the circumstances involving all relevant team members will itself point to the correct solution. However sometimes the problem may be so serious or the reaction of the management so ineffective that as a GDC Professional Registrant you feel compelled to take matters further. Whilst doing this, it is extremely wise to examine one’s own position carefully. A thorough investigation will include all parties. All concerns will be treated in confidence and whilst every effort should be made not to reveal the identity of the team member who raised it; at the appropriate time they may need to come forward as a witness.

So that’s clear is it?


I want to encourage everyone to re-confirm the legitimacy of their intending whistleblowing and to be certain that they have:

·         Disclosed the information in good faith.

·         Believe it to be substantially true.

·         Not acted maliciously or made false allegations.

·         Not sought any personal gain.


These points could have a significant bearing if you are shown to have decided to speak to the Press or acted in connection with another practice or organisation which work in competition.


There may have been a number of situations where organisations have been subjected to malicious whistleblowing. I imagine that it’s not a pretty sight and I’m afraid it would have a habit of rebounding badly on the perpetrator as well as the victim. Some of these people may even have found it necessary to leave Dentistry.


The more one thinks about it; the more one can see that whistleblowing can be used in a positive way for the general good, but equally it can be used in a negative malicious way.


One may envisage a situation where a regulatory body has experienced ‘difficulties’ with a Provider and has then approached another regulatory body to re-examine the Provider. This used to be referred to as ‘double jeopardy’, although now it could even be triple jeopardy. You may possibly feel that such things could never happen in this fair Country of ours; I couldn’t possibly comment.


How to raise a concern in your practice


As a first step, anyone with a concern, should raise it either verbally or in writing with the Practice Manager or the Principle if it involves the practice manager.

All concerns must be taken seriously and the team member treated with respect and dignity.  The matters involved should then be investigated and the team member advised of what is happening at all times.


Thank you


Thank you for reading this and whichever of the R’s you feel you may be; Registrant, Regulator or Registrar, I would like to remind you that the use of intelligence, proportionality and responsibility are not your exclusive rights.


Our Commitment


RightPath4 is committed to the highest possible standards of openness, probity and accountability. In line with that commitment we look forward to working with all dental practice teams to help them be the best they can be and be justifiably proud of their achievements.

RightPath4 will continue to work on behalf of those in peril on the C, whether that be CQC or GDC and you may be interested in inviting us to visit you. We hope that you will find that you can spend a small amount of money, very wisely!


You could arrange a practice visit from me for as little as £275.00.


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