John Chope column

John Chope explains the importance of making sure your DCPs are registered before it’s too late.

Are your DCPs registered yet?

We are coming up to the halfway point of the two-year transitional registration period for the new DCP groups. This is the period when dental nurses and dental technicians in particular can apply for their practical experience to entitle them to join the GDC DCP register and the period of grace ends on 31 July 2008.

The GDC hoped to encourage the new DCP groups to register early during the transitional period with its ‘three-for-one’ offer of a single one-off discounted registration fee of £72 to cover the entire two years of transition as well as the first year of compulsory registration which lasts until 31 July 2009.

The number of expected new applicants will more than double those already registered. There are currently 33,000 dentists, 5,000 hygienists and 850 therapists registered with the GDC whilst the expected new registrants are thought to include up to 35,000 nurses, 8,000 technicians and 100 clinical dental technicians.

So far the GDC has sent out 39,000 DCP registration information packs and from a trickle of applications last year the Council is now registering about 1,000 DCPs per month. The GDC Registration Department budget for this year is £1m and my guess is that up to a quarter of this amount will be required each year to fund the extra staff and publications costs of this two-year DCP registration project.

When the GDC began this exercise it took around 12 weeks to process an application and many DCPs found it baffling and frustrating. The registration department set itself a target of five weeks from receipt of an application to entry on the register and this month they claim to have at last achieved this goal in most cases.

The DCP application packs have become unnecessarily complicated and confusing with various add-on documents which are only relevant to certain DCP groups and so the Council has decided to design a new simplified application form for each DCP group. It should be much clearer what identification, character and health evidence is required for a successful application and the new forms may also be set up to cope with electronic scanning techniques which would further improve processing efficiency. In the meantime, the GDC has the capacity in the shape of its own registration staff to ramp up its manual processing rate to 3,000 or even 5,000 applications a week.

By the halfway point no more than 6,000 nurses and 500 technicians have registered – a tiny fraction of the possible 43,000 that will have to be registered by this time next year if they are all to keep their jobs. And that is the serious point. If you want to work in the UK as a dental technician or a dental nurse, you have got to be registered – otherwise you will be breaking the law and genuine registrants who are working with you or are relying on you will be imperilling their own registration status as well.

For example, a dentist who, after 31 July 2008, continued to work with unregistered staff who were not in training and who were carrying out the duties that really should be done by a dental nurse or technician, is certain to get into trouble with the GDC. Similarly, any registrant who employed staff and had taken no steps to ensure that their dental nurses or technicians were registered by the deadline, would find him or herself in a very exposed position if called to account by the GDC professional conduct committee. Excuses such as ‘my nurses didn’t want to be registered’ or ‘I only use sterilisation assistants not nurses’ or ‘I thought my technician was registered’ or ‘all my staff are permanently in training’ will hold no water when you are up before the GDC trying to justify your very shaky position.

The GDC expects all registrants employing staff to observe the law including employment law and to treat their employees fairly. This means that if you mislead your DCPs by allowing them to believe they need not become registered, you could one day find yourself on the wrong side of an employment tribunal. Because unregistered DCPs continuing their duties after 31 July 2008 will be working illegally and at risk of criminal prosecution and dismissal, employers have a special duty to advise their DCPs as soon as possible of the consequences of failure to register. All conversations on the subject should be documented and the employee must be advised that they risk dismissal next year.

Because the consequences of working illegally and contrary to GDC ethical guidance are so serious, unregistered DCPs who are at risk of being adversely affected at the end of the transition period must be given plenty of notice by their employer that they are liable to fair dismissal for ‘other substantial reasons’ as defined in the legislation. An employment tribunal is likely to regard failure to become registered as a fair and substantial reason for dismissal if the employer has acted reasonably by advising existing DCPs in plenty of time and by providing advice and assistance on the registration process or on accessing training to become qualified.

Needless-to-say, dental employers should no longer take on new staff without checking their registration status and without properly explaining to them the consequences on their employment of failing to keep up their registration.

I say all this because you should be in no doubt that after 31 July next year, by the time the polite but firm letter from the GDC drops through your letter box asking you to comment on a complaint about the registration status of your own employees or other staff such as hygienists, therapists or technicians who carry out your prescriptions for your patients, an unstoppable process will already have commenced. You will inevitably become entangled in the GDC fitness to practise procedures, a distressing ordeal which is not to be recommended. Please ensure all your team is registered and don’t let this happen to you.

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