Schrödinger's Standards

Schrödinger’s Standards

According to the Chair’s recent postings and their assorted webinars the GDC have not finally committed to changing the Standards for registrants, let alone deciding the nature of any alterations. And yet, by their own admission, they have already done “a lot of work,” considering such changes. 

Readers eager to maintain their registration, may want to consider the thoughts of the GDC’s invited panel at their recent ‘Stage 2’ webinar.

In GDPUK article the GDC standards steamroller we described the vehicle that the GDC have chosen to use to move their preferred changes to the finish line. One of the potential concerns is that no one including the GDC team, can describe exactly what that line looks like. It is apparent though that the key thrust of the changes is to move from a rules based set of Standards to ones which are principles based.

The rules laid down by the present Standards document make fairly clear what is, or is not, acceptable. It is central to the changes being discussed that the new principles will be open to some interpretation. As a result a dental professional’s registration may well be decided by the interpretation they apply to these new and more flexible principles. While for registrants this may of necessity lead to a rapidly made decision in the middle of a busy session, its consequences could be debated at leisure by legal experts and a Fitness to Practice (FTP) panel, in a process than often runs for years.

There were three panel discussions during the recent webinar. In the first George Wright (GW), Deputy Dental Director of Dental Protection, spoke of a tension between flexibility and clarity, explaining that even now members frequently sought clarification of the existing rules based Standards. Laura Cross (LC), BDA board member and former Consultant in Restorative Dentistry, expressed her concern of Standards becoming “a stick” to beat registrants with. She too noted a perceived lack of clarity in the present Standards, as evidenced in some FTP cases. From the Association of Dental Groups, Clinical Director Sandra White expressed a need for clarity on “musts” such as maintaining satisfactory infection control, and that the needs of DCPs and patients should be included. In her opinion the devil would be in the detail. Simon Thornton-Wood (STW), Chief Executive the College of General Dentistry also favoured a mix. In some areas clear rules were required, he hoped for a “mixed model.” For the GDC both Shamir Mehta, their Senior Clinical Advisor and Policy Manager, Kristen Bottrell (KB), appreciated the panels “broad agreement” with the proposals. Attendee Stephen Barter, Head of Clinical Operations at Bupa Dental, said that there was a perception that guidance was often being treated as ‘rules’ at FTP hearings. For this reason the proposed guidance that would form part of the new Standards, needed “a lot more thought and detail.”

An opinion that would be expressed here and in later discussions was that DCP’s could be disadvantaged by a lack of clear rules.  In the first panel an example of chairside support for therapists was given, and that the changes could lead to their possible exploitation.

The second panel session looked into what would be needed to support the changes being considered and in particular the Guidance and Supporting Materials that would accompany the Standards. At present there are 9 core principals, 29 patient expectations, 42 standards, and no less than 176 guidance statements. The new model would offer examples, guidance and support materials. As a sign of changing times Kristen Bottrell spoke about concerns around “defensive dentistry,” an expression the previous GDC chair claimed to have never have heard of. Once again the assertion was made that there was no ambition to alter the Standards, merely update the way that they are expressed.

For those seeking definitions, the GDC provided its explanation of the proposed Principles of Professionalism:

To provide guidance about the standards of conduct, performance and practice expected of dental professionals. Examples of how one might interpret the principles would be included.

The purpose of Guidance:

To provide standalone guidance documents referring to a legal obligation.

Supporting Materials:

To encourage dental professionals to reflect on issues, and to illustrate the GDC position on topics of interest. These materials will be produced to support professional development and insight.

Registrants reading this may wonder how willing they would be to go against “the GDC position” and whether such Supporting materials will be seen as “musts” and so become de facto rules.

Asserting that the GDC does not do clinical standards it was explained that it has an approved list of external guidance sources, including the CQC, Public Health England, NICE, NHS England and the British Society for Periodontology.

In the second session GW raised concerns about access to Supporting Materials for some team members, for example dental nurses who were often not direct members of organisations offering such assistance. Rachael Bell, Interim head of dental at MDDUS explained that in many cases advice provided by indemnifiers was based upon interpretations of guidance used in FTP hearings, in other words too late to help that particular registrant. However, SM who is involved in FTP did not think things would change saying that “we don’t go through the silver booklet now.” LC was concerned about the level that would be chosen for guidance and referred to the Bolam test. KB responded saying that there was recognition of the importance of supporting materials and that they would need to be “dynamic.”

The third section of the webinar, considered implementation. KB said that this will be crucial to the success of the new Standards. There was a need to show stakeholders what the new guidance and supportive materials would look like, how it would affect FTP cases, and there would need to be more discussions before putting forward a proposal. She also said that there was a “loud and clear” understanding of concerns about how changes might impact on the FTP process. A major consideration was that the GDC did not wish the changes to add further to FTP times and that GDC staff needed to be suitably prepared for any changes.

The third panel discussion asked if the considerations that the GDC had were the right ones. RB said that all GDC staff needed to be up to speed on changes and referred to existing concerns about FTP.   The high turnover of staff and need for a proper induction of new personnel had to be allowed for. SW wondered how the changes would be introduced to registrants. ‘Local Champions’ would be comparatively easy to set up for groups such as FDs and undergraduates but it would be more challenging to reach others. STW said that there was a need to make clear this was not a change in the basic Standards. RB had concerns about how the changes would be communicated to dental nurses and those in what Fiona Ellwood, Chair of the National Oral Health Promotion Group and founder of the Dental Mentoring Network, had described as a “dispersed learning environment.” GW too, was worried about the “unrepresented and underrepresented.” He hope that the GDC would liaise closely with indemnifiers, since they would be on the receiving end of many questions. LC reminded the group that overseas dentists and possible apprenticeships would need to be included in any roll out.

The session concluded with KB setting out an anticipated timeline with proposals being made to the GDC council this year, and a formal consultation by the end of 2024. The updated Standards could arrive in 2025.


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