A new element of the NHS contract was introduced last month, but even before implementation they were causing headaches for practices. Peter Ingle reports
The newly introduced Complex Care Pathways (CCPs) are intended to provide additional funding for NHS dental patients with significant oral health needs to address failings in the UDA system.
There are three CCPs, introduced from 23 June 2026, are intended to address concerns around patients with significant caries (dental decay) and/or unstable and more severe periodontitis (gum disease). They are: pathway 1, for dental caries in five or more teeth, which pays £284; pathway 2, dental caries in five or more teeth and unstable periodontal disease (£709); pathway 3, first diagnosis of Stage III or unstable Grade C periodontal disease (£248).
Unfortunately, there are signs that they have serious flaws and that there are some pitfalls that could have unpleasant consequences for contractors and performers. Alarmingly, if not surprisingly, the warnings and requests for action from NHS England and the other organisations involved in the implementation of CCPs have not been met with the acknowledgement that there are serious problems.
The pathways have all the stamp of a system implemented in the absence of GDP input. At the LDC Conference in the month prior to their introduction, a delegate noted that the relevant guidance was not yet available. Another issue raised at Conference was whether the CCPs would be truly optional, as has often been claimed. One somewhat confusing take was that most of the pathways could be carried out by skill mix, so while they were labelled complex this was a reference to the disease state rather than the treatment.
However the claim that the pathways are ‘optional’ appears to be rather complex in itself. Offering the pathways appears to have ‘should’ status at present, and while this is not a ‘must’ dentists will need to have valid reasons not to offer them. The consensus among indemnifiers and industry leaders appears to have settled on the pathways being non-optional. Certainly a dentist not offering them on the grounds that they are a nightmare to administer, should not expect to find their indemnifiers at their side when an aggrieved patient complains about the effect on their NHS charges.
The BDA has described the work around reporting and administering CCPs as disproportionate. Like most of the profession they fully support the principle of providing better recognition and remuneration for the care of high-needs patients through longer-term, prevention-focused pathways. However, along with others who were involved in the discussions about the pathways with NHS England, they feel that their concerns have not been properly considered. As a result the released version of the CCPs are significantly more complex than the BDA would have hoped.
The requirement for additional documentation, assessment, reporting, and contractual demands will create a substantial burden for practices with many potential traps. One example is that reporting must be done monthly even in the absence of treatment.
The BDA are also unhappy about the uncertain implementation process. Alongside the late publication of clinical guidance, and concerns over dento-legal implications, a number of software systems are not ready to support CCP administration, or claims.
All of these new administration issues can be added to the unresolved issues around the unscheduled care arrangements, with one industry figure observing that ‘you cannot look at Compass and know where you are anymore’.
It is fair to say that the CCPs did not get a broad welcome at the LDC conference. In the words of a Manchester delegate, the urgent care roll out had been a ‘shambles’. After referring to the inaccuracies in their own schedules they said that based on conversations at conference, this was putting people off using the CCPs. Indeed, with a thought to efficient use of public funds, the delegate hoped that NHS England ‘had not spent a long time on the care pathways’ since they thought uptake was likely to be low. When asked how many delegates would be doing the CCPs, not a single one put their hand up.
There were other more measured complaints from some of those involved in the negotiations around the pathways. One was that on first sight of a draft of the guidance, there was an element that increased the administrative burden, which they specifically pushed back on – yet this had been retained by NHS England.
Dr Jason Wong, the chief dental officer, defended the arrangements, asserting that it was not an administrative burden, saying that there was no extra requirement, ‘apart from a few clicks’.
The last-minute approach and dysfunction at NHS England and the NHS Business Services Authority is summed up by the NHS Dental Services Bulletin England of 7 July 2026.
This announces that: ‘You can now submit the initial declarations when a patient signs up for a Complex Care Pathway. The first interim declarations can be submitted from 15 July 2026.’ The pathways came into effect on 23 June. This was also the start date for the changes to denture modifications. However, it would appear that integrating these remains a work in progress: ‘We will advise you shortly when claims for denture modifications or band 3 treatment can be submitted concurrently with a Care Pathway.’
There is a risk of a PR own goal here for the profession. The problem is not the clinical logic of stabilising high-need patients. The problem is whether practices can safely run these pathways through the systems currently available. Presenting the profession’s issues with the pathways as financial or even operational, is unlikely to garner much public support.
Longer term, there is a risk that low uptake of CCPs could be presented as the profession’s rejection of clinical reform, when it actually is the result of compromised and rushed implementation.
Not for the first time, a lack of testing and trialling of new ways of delivering NHS dentistry has resulted in national roll out before the operational framework is transparent, auditable and workable locally.
Since the dawn of the UDA contract, the profession has been justifiably complaining that there were strong disincentives when it came to looking after patients with extensive treatment needs.
It has taken the NHS and its DHSC masters 20 years to develop their response to this request. The tragedy for both patients and the profession is that the resulting scheme and its implementation as it stands appears unfit for purpose, and may even drive more practices away from NHS provision.