Dento-legal experts fear revalidation plans

The General Dental Counci (GDC) needs to provide greater detail about the cost and fairness of its revalidation proposals for dentists.

That’s according to dental legal experts, the Dental Defence Union (DDU).

In its response to the GDC’s consultation document [1], the DDU highlights a number of concerns about the GDC’s plans for external verifiers to oversee compliance and the right of dentists to appeal against their decisions.

Rupert Hoppenbrouwers, head of the DDU says: ‘Given the existing regulatory load placed on dentists, most recently the need to register with the Care Quality Commission, we believe revalidation represents another massive change. We accept that revalidation is inevitable and we support the GDC’s intention to introduce it in a way which places minimum additional burdens on practising dentists.

‘However, in our view, the consultation document does not provide any comfort that the procedure envisaged will have enough safeguards to be sufficiently fair, proportionate, robust, transparent and consistent.’

He adds: ‘We are concerned that there is a lack of detail about the way external verifiers will be chosen and their decisions audited and rigorously quality-assured. To take just three areas:
• It is unclear how the GDC is going to assure itself and the public that external verifiers are independent
• What procedures will be in place if a dentist believes that the external verifier is not capable of undertaking the role or a conflict of interest develops?
• What controls will be put in place by the GDC to ensure the fees charged by external verifiers are reasonable and affordable to practising dentists?

‘In addition, dentists who were removed from the register for not complying with revalidation would lose their career. The process that leads to such a sanction must be consistent with their rights to a fair procedure under Articles 6 and/or 8 of the European Convention on Human Rights. The consultation document does not provide such reassurance. For example, we believe that the GDC must first be seen to have investigated the reasons for a dentist’s non-compliance and be able to demonstrate it was reasonable to take this step. We believe erasure for any reason should only arise after a proper application of the GDC’s fitness to practise procedure.’

He goes on to say: ‘On the basis of the consultation document, we could not currently suggest to our members that the proposed procedure will be fair and there must be considerable concerns about the expense, not just for dentists who will be revalidated, but who will ultimately bear the expense of “accrediting” and quality assuring external verifiers? In the interests of DDU members, who represent a third of UK dentists, we hope to enter discussions with the GDC on more detailed proposals which can then be the subject of a further consultation.’
1. Revalidation for dentists, our proposals, GDC, 14/10/10

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