CDO Seeks To Influence Dental Record Keeping Arms Race
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- Published: Wednesday, 27 August 2025 09:44
- Written by Peter Ingle
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Connoisseurs of the leopards eating people faces meme, may want to spare a thought for the CDO, the GDC clinical advisers, and NHS England.
In the latest Your NHS dentistry and oral health update, Jason Wong, CDO England, led with the government‘s ambitious 10 year plan. As things stand, however, all those extra appointments are likely to see a lot less clinical activity delivered than the Department of Health and Social Care would like.
This is because within every hour of surgery time a huge proportion will be spent writing notes. In recent years there has been something of an ‘arms race’ in note writing by clinicians. This is often due to a wish to have some defence against NHS investigations, solicitors’ letters, and of course becoming victims of the GDC’s adversarial Fitness to Practice (FtP) process.
Now, this instinct for self-preservation by dental teams has become problematic for the CDO as he struggles to stir the profession into delivering 700 000 extra appointments.
The CDO is not alone. The GDC including their Lead Clinical Adviser, Shamir Mehta, has previously expressed concerns that records are sometimes excessive. This might have contributed towards the belated acceptance by the regulator, that there may be such a thing as defensive dentistry.
In his latest update, Jason Wong writes that his office (OCDO) has “received feedback from clinical colleagues that some clinicians are spending prolonged periods writing clinical notes.” He goes on to add, “Consideration needs to be given to how easy it would be for the same or another clinician to read and gather the pertinent information from records in a time effective manner. It is important that information is readily identifiable and easily accessible at future appointments. Consider a patient record with multiple appointments per year over multiple years, this then starts to become a challenge.”
His concern is that as notes become more comprehensive, they will not just occupy more of the screen but will take longer to read at future appointments.
Earlier this year the OCDO sought the view of NHS England Dental Clinical Advisers on the main purpose of a dental clinical record covering an assessment appointment. A unanimous response was that the main intention of record keeping should be to allow the treating clinician or other clinicians involved in the future care of the patient to understand what occurred and what is planned. An OCDO suggestion is to reference Standard Operating Procedures (SOPs) to prevent the need to re-write every step of a process or procedure. Any exceptions to the SOP can be added to make the record relevant to the patient whilst keeping the information concise. The SOPs would need to be easily accessible including past and present version changes if a query arose in the future.
It is likely that multiple SOPs may need to be referenced as there may be different clinical steps or processes that occur during the appointment. Once these are agreed, then reference to the relevant SOPs followed can be stated in the notes.
Jason Wong wants to open a conversation about how the dental profession can move to a position where records are concise and focus on pertinent information. As a next step, the OCDO will work with NHS England Professional Standards teams, the CQC and GDC to support a fair and proportionate approach to regulation of dental services.
The OCDO will work with the NHS England Clinical Advisers to ensure a fair and proportionate approach to any record review. Clinical advisers are asked to consider:
- what is realistic and deliverable when assessing records or setting any remediation plans and providing this context in any reports.
- that records are just one aspect of patient care, and a much more holistic approach is required when reviewing the care provided.
All of which sounds entirely reasonable. How confident clinicians will be that they will be treated fairly by all of these bodies, is another question. The defence societies and indemnifiers who have often advised members that ‘if it was not written down it did not happen’ will have many questions before they advise members to spend less time on their notes.
The “if it didn’t happen” school of thought has certainly become embedded in the minds of FtP panels, who when there is a conflict, often prefer the recollections of an aggrieved patient to those of their clinician.
Just one example of the hill to be climbed is case of local anaesthetic batch numbers. Despite a judgement some years ago where Dental Protection established that these did not need to be written in full in the record of each procedure, other organisations were still advising that it was included. Nor did this seem at all unreasonable, given that the GDC continued adding a lack of batch numbers to FtP charge sheets, long after the precedent that it was not essential had been established.
The quest for a consensus on what constitutes a satisfactory dental record is not new. There have been questions about over reliance on templates, and AI offers game changing new ways to keep and compose records. Against all of this, the CDOs campaign however well intentioned, may represent a triumph of hope over experience.
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