The revelations of a recent FOI request showing the cash reserves and short term access assets of the GDC potentially raise questions of the financial fortitude of our regulator.
If indeed the figures supplied by the GDC are correct, and represent the full and correct answer to the question asked, then it would appear they have access to about £11.9million of funds within a 5 day period. (I’ve got that figure from 10.5m less 4.8m at 22/7/14 added to the 6.2m at 1/8/14)
Given that the GDC costs £104,000 per day to run by their own admission, then this sees us with a regulator that looks like it is going to have no more cash by the end of November 2014. Coupled with the £7.1million that it is spending on refurbishing its HQ on Wimpole Street, it doesn’t seem all that surprising now that the GDC is threatening the BDA with its losses if the judicial review fails (if it goes ahead).
The GDC usually takes its run of Direct Debits for the ARF in the first week of December, so this would then have the effect of restoring its cashflow straight away.
However, what if all the registrants cancelled their direct debits? What if the BDA were to lead a concerted effort to get us to do this? It won’t fall foul of the legality of having to pay the ARF, it’s just that the GDC won’t be able to actively take it to help their cashflow; we will give it to them when we decide. As long as it is paid before the end of that month, then we cannot be erased for non-payment of the ARF. Wouldn’t it be great for the BDA to suggest ALL registrants cancel their Direct Debits with the GDC?
If this is the case and the GDC is running out of money, then in all likelihood they will just delay the FtP cases and other hearings until the cashflow looks better. Since these equate to the majority of their expenditure this would be a fairly easy way to massage the situation swiftly; but this then becomes even more intolerable to those stuck in the ever increasing queue for the March to the Scaffold. That means that yet again there will be practitioners that indeed represent a danger to the public still unpunished and still working, along with those in the queue probably because they used the wrong grade of soflex to polish a composite. Is that any way to protect the public?
But what happens if a regulator is effectively insolvent? Has this ever happened before, and if it is boracic, will it get bailed out by the Government? What happens to the role of protecting the public if this happens, and how does this square with the requirement in the Dentists Act to have a regulator? If it does indeed become insolvent and is bailed out by HMG, then this shows us that it is indeed a wholly owned subsidiary of HMG, so if they want it to remain solvent , then they and not us should fund it.
Many a profitable business has gone bust in this and the recessions before due to a cashflow problem, so why should any other type of organisation be immune from this when it gets its sums wrong or experiences an increase in its expenditure?
Would the duty of the GDC then be better served by the CQC instead? After all, the CQC now realises dentistry isn’t that bad, and that it recognises the need for experts to be involved in its inspection processes. It appears to have grown a pair of ears more recently. If we are going to have a super-regulator foist upon us, wouldn’t we rather have one that whilst it still seems a bit dim, does appear to be learning from its mistakes, or continue with one that treats us with arrogance and contempt whilst (possibly) overspending its funding? That’s discussion for another day.
This is all probably hypothetical and the figures have been interpreted incorrectly and they don’t include the contingencies for the refurbishment etc; if so the GDC isn’t going to run out of money .
But if this IS the situation, the GDC isn’t just Broken, it's Broke.
I agree and actually many of the things you suggest are as I have previously mentioned. I did suggest we all cancel our DD's, even have a 'BDA holding Account' perhaps, so that the funds can be released in time, but not until conditions are met. I think that dentists are sensibly very concerned that if they as individuals take this action, they will be picked off one by one by the uncaring GDC. Strength in numbers. If the BDA were to suggest this, I think we can all get behind it and feel safe.
I was always reluctant to suggest swapping one Regulator for another and can see that although the GMC charges a lot less (at the moment) and appear to be more level headed with their FtP; they are currently heading in the same wrong direction as the GDC. Be careful what you wish for!
So that leaves us thinking about the CQC as the overall Regulator.
The CQC are not overseen by anyone else and so this would mean that we wouldn't even have the PSA to act as a check against poor regulatory standards. One of the problems at the GDC has been its move away from the Profession towards people with little or no knowledge of providing healthcare related services. Unfortunately this is still a common feature of the CQC and try though I have, I still struggle sometimes to get this message across. The good news is that the CQC is showing signs of being able to listen and I hope that we may therefore end up in a happier place before too long.
However if you were to now superimpose the registration of dental professionals, I am not at all certain that the CQC would manage this well. I still see on occasions the utter confusion when there is a proposal to sell a practice and the machinations that go on with dates can take some believing. This is because the CQC have tried to fit the dentists into their parameters rather than looking to adapt their system to fit the circumstances. It has been a similar story with the dental inspections. I hope that by examining what has happened, it will be possible to improve what happens in the future, (I believe it will).
Finally all professional matters involving consideration of whether someone is fit to practise must be heard by dental professionals at every stage and also with a view to rectifying the situation as quickly as possible for all concerned. This does not mean trumping up a list of additional charges or pleading for patients to come direct without following the guidelines of speaking to their dentist and mediating locally. Indeed unless there is a concern that the matter is potentially causing a serious risk of harm, it should be a pre requisite that it is considered locally first.
Perhaps we could have a smaller, more professional GDC that just sieves cases after local mediation and refers them for hearing if it is justified (a bit like Crown Prosecution Service). I imagine they wouldn't need to have such a high budget for this and they could be funded by the State. The fees we pay to CQC, could include registration lists, but they will need to attend a course first in what we are asking them to do.
Functions such as quality control in dental education, CPD verification, admission of dentists from countries that do not have English as a first language etc would be a function that could be carried out by the Royal Colleges as a fee based service.