GDC keeps ARF the same for 2019 – Ian Brack explains why

Seb Evans (SE): Why have you decided to keep the annual retention fee (ARF) at the same level?

Ian Brack (IB): I need to look at the risks and opportunities the organisation faces every year.

We’ve always got to bear in mind what our statutory purpose is. We’re all about protecting the public and ensuring confidence in dental professionals, but we have to do it in a sustainable manner.

We’re constantly looking to cut our costs, and we’ve continued to do that. We want to get to a point where we are able to sustainably and meaningfully reduce the ARF. But, with all that in mind, what I’m looking at is the landscape around the GDC.

Within the GDC there are internal risks. Those risks relate to the change processes we’re going through. We’re an organisation that is carrying out an end to end review of fitness to practise (FtP). We’re already doing things that are changing the way we’re working. This has financial risk involved in it because it has costs.

We’re relocating, we’re moving staff to Birmingham and establishing a significant operational hub there. This building (in London) will stay our national headquarters, and one reason for that is that we get it for a peppercorn rent, but many of our operational staff will eventually be based in Birmingham. That’s a big change that will bring long-term savings but there are up-front costs involved and of course we’ve got risk involved in that too.

And we’ve got Shifting the Balance, which we’ve got to deliver. Shifting the Balance involves investment. It involves investing in new upstream ways of working. You’ve got three major areas of alteration and change in the organisation with the associated risks.

Externally, the UK is leaving the EU. Everyone is going to be affected by Brexit one way or another. You’ll have impacts on the overall UK economy, potentially good or bad, we don’t know. That’ll affect dental professionals and the whole economy, it’ll change the labour markets along with all types of things. So there’s a degree of uncertainty just generically about leaving the EU.

But there is also something very specific about leaving the EU for the GDC. If we leave with a hard Brexit, an unnegotiated settlement, then we’ll lose Mutual Recognition of Professional Qualifications (MRPQ), and that matters a lot to us. MRPQ creates the right to automatic registration for dentists qualifying in EU countries. If we don’t have MRPQ anymore, and there is a real possibility of that, we have to find another way of registering EU qualified dentists, which last year made up 23% of our new applicants.

The obvious way to do that is the Overseas Registration Exam (ORE). The problem with that is it’s already an expensive system to run. If we end up needing to significantly expand that capacity, to accommodate the 400 plus applicants who would have otherwise have been automatically registered through MRPQ, there will be cost implications for the GDC.

Of course, those 400 plus dentists each year from the EU could stop coming to the UK. Setting aside the problem that would cause from a workforce point of view, which is an issue for the Department of Health (DH), that would mean a reduction in income, something in the region of half a million per year. But it starts to get much more serious if existing dentists from the EU decide to leave and were not replaced. As a very rough example, if a third of existing European registrants were to leave the UK register and the supply of new EU dentists were to fall away, that would represent a drop of around £2.5m each year for the GDC.

A big factor in all of this is whether MRPQ ceases to apply or not and whilst I know that the intention is that a negotiated deal will retain it, I don’t know whether this will come to pass. But what I do know is it’s a real possibility, so I’ve got to plan for it.

I went to the council and advised them that this is not the time for us to reduce the ARF. It’s disappointing, because we’ve done a lot of good work and things are going in the right direction.

SE: We’re seeing savings in FtP hearings, where have these come from and are the changes you’ve made having the desired affect?

IB: It’s a good story and bad story. The good story is we’ve made efficiencies and savings. We’ve cut costs out of the organisation that didn’t need to be there, we’ve streamlined processes, some of which you’ll see more of in the 2018 accounts. Already we’re cutting delay out of the system, which creates savings.

The problem is, last year, FtP also didn’t do all the work it needed to do, work slipped behind. Some of the things that look like savings in the annual report and accounts are better described as deferred spend. Spend we budgeted for in 2017, money that we should have spent, that we wanted to spend, and it didn’t happen because the work slipped. When you get that, you’ve not actually got a saving, the money is going to have to be spent, probably this year or next.

One of the things for me is that the organisation I’m looking at now understands the drivers of complexity, performance and costs in FtP in a much more sophisticated way than we did when I arrived. As we get better at picking out those characteristics that lead to high costs and potentially delays, we get much better at predicting our performance and forecasting our costs. Each year, we’ll get better at it.

SE: Your annual report and accounts puts your reserves at just above your four- to six-month target.

IB: Correct. The reserves have recovered after several years of being dangerously low and I recognise we are now marginally above the target. But remember, I’m expecting chunks of that to be spent, later this year and next, on the things we’ve spoken about.

SE: You’ve been making a surplus with the ARF to fill your reserves. Now you’re making savings in the FtP process, so surely you will now have even more money going into the reserves?

IB: Yes, but this year we’re spending more money to allow us to safely make the changes we’ve talked about. We’re going to be spending more money, for example on double-running parts of the organisation. So, cost will be higher and we’ve got calls on the reserves, so we need to replenish those. Going on we’ll have the same level of reserves when we come out of the stress period in 2019, and then the fees can hopefully come down.

The reserves are a bucket with a hole in the bottom in that the funds you see going in are also going out and I need to keep putting stuff in until I plug the hole in 2019.

SE: This is how it all looks to dentists:

  • In 2015 the ARF went up and registrants were told it’s to compensate for a rise in FtP cases

  • In 2016 plans to make FtP numbers drop were announced, but FtP cases were still very high and so to compensate for that the ARF stayed high

  • In 2017 FtP cases started to drop, we were told there are more cost savings from the GDC on the way but fees stayed high and this was to replenish the reserves

  • And then this year, FtP cases continue to drop, reserves have shot up and are replenished, but the fees are still staying high and registrants are told you’re doing more work and Brexit might bring expensive changes for the GDC.

From a registrant’s perspective it seems like every year there’s a different reason for the fees to stay high. What stops you coming up with another excuse next year?

IB: I understand that viewpoint. It’s probably not a bad characterisation of what the last four/five years looked like for registrants.

I’ve made the point firstly that there’s a lot of costs still in the system from the spike in the caseload. Yes, caseload is dropping but cases that go to full hearing typically last between one and two years and the main cost for us is incurred in the final third of case lifetimes so there’s still cost in the system from that caseload.

To be fair we had no way of knowing we were going to be leaving the EU. If I didn’t have these levels of uncertainty, yes, I’d be a lot happier about saying to the council that now is the time to reduce the fee. But we do have these levels of uncertainty, I’m personally accountable to the council and to Parliament. I want to be able to say that the GDC is in a position to sustainability and robustly carry out its statutory purpose. The price the GDC has to pay for that is that we can’t do what undoubtedly would make us more popular with the profession at this moment, and bring down the ARF. It’s not the right thing for us to do.

I have to say, we want to bring the costs down, we’re doing what we can, we understand how it feels for registrants. The direction of travel is going the right way. I will be delighted when I’m sitting here and we’ve managed to reduce the ARF. But I also would say that the risks are real, they are there, and I do have to plan for them. It’s frustrating because we’ve made real progress, but it’s the right thing to do.

SE: The General Medical Council (GMC) recently announced a provisional registration fees drop, a full registration fees drop, doctors holding full registration for the first five years, their fees will drop, no transaction charges for retention fees being paid quarterly or monthly, it has vowed for any future increases to be in line with inflation. The GMC appears to be doing its best to be affordable for the profession it regulates and it’s doing its best to make payments easy and more predictable. Why can’t the GDC be more like the GMC?

IB: It sounds like a really simplistic answer, but we’re not the GMC. The reason that matters is that the whole business model is different. And so is the law. The legal structures for each different health regulator aren’t the same. Even the Department of Health sometimes overlooks this: other health regulators can do some things we cannot because our legislation just isn’t the same. For example, the Dentists Act requires us to collect ARF fees from dentists in advance of the year of registration. To be able to begin charging dentists in instalments, the legislation and our regulations would need to be changed. But, if we see something being done by a different regulator that we’re legally able to do and that would be beneficial for our registrants, we certainly look at it.

SE: Anything else you’d like to add?

IB: The GDC is going through a lot of change, we’ve got an awful lot going on and a lot to do. I think it’s an exciting time for the GDC, to work here and to do what we’re doing. I think the potential for the profession is exciting.

We’re going to be a changed organisation again next year. We’re bringing the costs down, we’re improving the performance, not just in ways measured by the Professional Standards Authority, but things we believe matter to the public and registrants to do the job better. When we come to you in the first half of next year to consult on the corporate strategy, it’s going to be a real consultation talking about the direction of the organisation for the next three years. It’s going to have real impact, what we do for three years will go into a model where we cost it out and it will produce an ARF. We can argue about the edges of that, but it’s fundamentally what we do that will affect the ARF and how we interact with the profession we regulate. It’s a real opportunity and I really hope the profession is going to take that up and engage with us.

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Comments (13)

Dear Ian Brack

Do you accept that the GDC is currently regarded with unparalleled distrust by the vast majority of the dental profession and that this has directly led to fear driven defensive dentistry, de-skilling, dentists leaving the profession in increasing numbers and thus, a reduction in patient safety?

You really should accept this.

It is clear to me after dilligently reading countless reams of GDC minutes, that previous risk evaluation exercises have proved to be hopelessly pessimistic and inaccurate with financial risks being overplayed. In addition, a figure of 7.2 months of operating excess as a minimum goal for the future does not appear to have any objective grounding in either history or methodology. How was this figure arrived at? How can you fail to appreciate how bad this looks?

Do you really feel that your tarnished organisation that has repeatedly failed to meet its core objectives, that has shown a lack of insight into its many failings, that has fostered a them and us culture with dentists, which is stupid and shortsighted, that has got good evidence of reduced FTPs and that is widely regarded as the most heavy touch regulator, is in such a comfortable position that previous assurances of a reduced ARF if a 4-6 months surplus was achieved, can now be ignored? If that is really the case then I am incredulous.

This is the second opinion piece from the GDC senior team in two weeks. I think that a very timely third piece should be about the culture of fear that the GDC has created for dentists and DCPs and how this culture, which is directly responsible for reducing patient safety, can be reversed. How the current GDC, by an absolutely essential senior team change, can start to repair the trust that has been lost and how worldwide best practice “right touch”regulation can be adopted without delay.

Yours sincerely

Dominic O’Hooley


FTP cases reducing, ARF unlawfully high, reserves replenished and growing to the point the GDC are perfectly comfortable wasting registrants money to pursue retired dentists for private emotional outbursts following a terror attack but absolutely minimal token effort in actually pursuing non-registrants offering tooth whitening or orthodontics (something we actually see as value for our money!)

This profession in the UK is dying a death, and the GDC will be there hammering nails in the coffin while more and more caring, capable professionals leave the UK or the profession all together.

The real reason they’re worried about Brexit? Because all the EU dentists will end up leaving and their coffers will suddenly empty while the remaining UK dentists who haven’t already fled to Australia are put under ever increasing workload and expectations that every other day someone will be lynched for failing to record a BPE until a single sole dentist remains, seeing 700 patients a day with detailed contemporaneous notes doing every job to specialist standard paying any and all income just to exist as bodies gather around them claiming more and more money just to let them keep going while the NHS rocks up every nowand again to inform them that they won’t be paying for the work they’ve done because of some nonsense administrative error. Again. And no you can’t appeal that decision.

No wonder morale is at an all time low, we’re beaten down on every front and just expected to suck it up and keep going.

Has this non dental bloke ever worked in dentistry. Had he ever had the stress of attempting local anaesthetic on a frightened child. Has he tried making dentures on a gaffer. Has he tried doing a single veneer on an upper central on the fees we get paid. It’s s big NO. Because he hasnt walked in our shoes. So how can this intuder understnd our profession. He calls the GDC a business! This is shocking and he needs to be removed.

Dear Mr Brack,
Thank you for your response. Dentists have completely lost confidence in the GDC. The latest review which was swiftly removed highlighted deliberate targeting of dentists by the GDC even when patients were relucatant to do so. This led to the unfortunate suicide of a young dentist.

How can people who haven’t worked in the dental environment seal the fate of those that are?
How are case examiners trained?
Dentists have lost confidence because time and time again they have come across case reports which are nothing but witch hunts. They dig and dig until they find something! Whether it’s relevant or not to the case – doesn’t matter .
Dentist are treated as guilty from the very beginning irrelevant of the facts of the case.
FOI has shown a case to go on for 7 years with the dentist having no case to answer at the end. How was this an acceptable use of the dentist ARF? It is clear for any one to see the psychological impact this would have on the dentist except the GDC. Dentists don’t resent the fee or the governance, they resent the fact that it is being used to deliberately tarnish and highlight absurd cases rather than focus on those who are genuinely bringing the profession into disrepute.

It won’t be long till a GDC case is worn like a badge of honour because we all will have one to our name.

The funds should be used to tackle DLP who are deliberately creating mistrust between patients and dentist, it should be used against adverts that state pain after an extraction is abnormal.
It should be used to highlight the benefits of attending the dentist and prevention. Rather than – “if you aren’t completely satisfied with your private care please tell us“. Please define completely satisfied. We aren’t satisfied at all with the GDC. What repercussion do the GDC face?

Is the GDC satisfied with the fact that there are now a record number of dentist in fear of being struck off, suffering depression anxiety and contemplating suicide?

When we speak to address these points everything is blamed on legislation.
Would love to hear a genuine response.

“We’re relocating, we’re moving staff to Birmingham and establishing a significant operational hub there. This building (in London) will stay our national headquarters, and one reason for that is that we get it for a peppercorn rent, but many of our operational staff will eventually be based in Birmingham.”

I do not believe that is relocation. That is expansion. This is after a £7.1m redevelopment of the building you rent(peppercorn or not). Do you feel that represents good value for money for the registrants?

I also believe that if you are using Brexit as a scapegoat you should consider the rising costs and the small independent practices that will struggle.

As the interviewer pointed out, every year there is a different excuse. A prime example of short term management and poor leadership.

You have not succeeded in convincing this dentist of any just reason for maintaining the ARF at this extraordinary level.

I think the short answer to the question why was, why not?

James Millar

Dear Mr Brack,

I have previously been a harsh critic of the GDC in the past, especially in the days of the previous registrar. Indeed, I wrote many blogs that were well received by the profession. With the departure of the previous registrar, there was an opportunity for the GDC to begin to repair the damage it had done to the profession by the draconian and inefficient manner in which it had been lead.

There appeared to be a time when the new team seemed to be developing a far more appropriate attitude to regulation, and I therefore felt it appropriate to perhaps watch the situation without commenting further. It was disappointing when Jonathan Green left, although I did feel that with you at the head of the Organisation (for indeed it is NOT a business but a QUANGO I think you will find) then there would be a continuation of the bridge building that was sorely needed.

However, whilst there seem to have been some minor improvements, fundamentally there seems to be no real change in the way the GDC wishes to be perceived by the profession and how it executes its statutory duty. Under the aegis of protecting the public, it is actually doing more to negatively affect the public it serves to protect by continuing to prosecute its role in a draconian and often arrogant manner. There is still huge a lack of insight into the damage it is doing to the morale and the well being of its registrants; damage that can be squarely blamed on the actions of the GDC itself.

Because when a profession is so scared of its very shadow that it can no longer function as it is supposed to, then the ONLY thing that will happen is harm to the public. That these professionals are so scared of virtually every treatment they do, every comment they make (including ones like this), and every action they take is a sad indictment of the way that the GDC is systematically destroying the very profession it regulates.

By retaining the ARF at the same level again, with yet another different reason than before, is symptomatic of the disdain and the contempt with which the profession perceive the GDC have for them. The profession are happy to be regulated, but by a fair, just, and right touch regulator. The continued heavy touch that the GDC continues to use cannot continue if the profession is to survive to be allowed to serve its patients as there will come a tipping point where we will no longer be willing to accept the duress of just turning up to work. If we placed a colleague under this type of stress in our workplace then WE would rightly fear being reported to our regulator.

We are human beings who set ourselves out to care for other human beings. There is no higher privilege than to care for another. However, we make mistakes, we are fallible. You are the same as us, a fellow of the Human race.

We rarely do things wrong deliberately, but we shouldn’t live in fear that the next thing we do both privately or in our jobs could end our careers and destroy our lives.

Please think of the damage that is being done to our profession by this apparent continued lack of insight displayed by the GDC.

Kind Regards,

Simon Thackeray

Why not just write

“Dear Sir,
Please can you give us a clue how you intend to make the lives of dental professionals, specifically dentists, more difficult. Professionally, socially and virtually. Many of us plan to retire, emigrate or gracefully give up. Any future plans such as a tripling of the ARF to bolster pension funds, funding of basement gyms or research into sadistic FTP practices/ suites at Wimpole Street?
Please be honest with us as your recent excuses make reading the Beano seem a refreshing reality.
We realise that your jobs at the GDC are a fleeting before a real job in the civil service., but please think of us professionals who have trained for 5 years or more, invested thousands and go to work with the hope of improving other people’s health and lives.”

Dominic O’Hooley. You stand before us today accused of the following alleged serious breaches.

Being the person with overall responsibility for a large multi-site dental practice business, you failed in your core responsibility to ensure patient safety by the following acts and omissions.

1 – You instilled and developed a corporate culture of fear and mistrust both within your direct teams and also with regard to key external suppliers/partners.

2 – You repeatedly failed to follow appropriate employment law by allowing disciplinary procedures to proceed and sanctions to be enforced for unrepresented staff members. These staff members were also not dealt with in an appropriately timely manner but were often kept waiting for many months for their cases to be heard. You allowed biased and entirely inappropriate senior team members to sit in judgment of junior staff members and many staff were placed on extended unpaid leave before their cases had been properly heard. You accepted the balance of probabilities when deciding whether to sack staff members.

3 – Despite repeated censure by the CQC, you continued to ignore their recommendations for immediate improvements to your core offering, but instead, concentrated on expanding your number of practices whilst engaging in needless cosmetic improvements in your original site, which you used the staff Christmas fund to pay for.

4 – You were criticised in court for the unlawful use of partner data which was not dealt with in the appropriate way.

5 – You displayed no insight when multiple representations were made to you and your senior team about the appalling staff moral, failures of basic functionality and breaches of systems which could lead to patient care issues. You instead put all the blame on your right hand colleague who had no option but to resign.

6 – You decided to take on another role in a second business (not connected to dentistry), and you gambled on your old boys network of cronies, allowing you to milk both roles whilst failing to show proper leadership in either.

7 – It is alleged that you used Google privacy policies and other means to remove embarrassing written material from the internet and also details of your initial recruitment to your current position.

8 – You allowed adverts to be placed within various print and electronic media that encouraged potentially vexatious litigation and failed to protect the professionalism of both your staff and direct partners/suppliers.

9 – You and your senior team used “finger in the air” risk analysis techniques to create the spurious assertion that large payments on account were required to ensure “quality of service” for key partners. You ignored previous written assurances of a dividend and instead continued to collect monies based on alarmist and untested theorising. You have minutes where previous “risk collection exercises” were proved to be groundless but you continued apace anyhow.

And by reasons of the above, your fitness to practice is called into question.

Time to get my coat?

Dear Mr. Brack,

In the above article you state;

‘But I also would say that the risks are real, they are there, and I do have to plan for them. It’s frustrating because we’ve made real progress, but it’s the right thing to do.’

I agree the risks are real, for instance there is a real risk that a giant asteroid will smash into Earth wiping out all life, there is a real risk of a mutated strain of influenza causing massive world wide pandemic. There’s all sorts of risk out there, but I’m fairly sure that you don’t need £20 million to protect the GDC from the imaginary risks you think the organisation faces, or indeed the outlandish ones I’ve mentioned. Especially as every December40,000 dentists are giving you nearly a grand each to improve the balance sheet, before we get to the legions of nurses, hygienists, therapists and clinical dental technicians that also stump up their money.

The arguement is always ‘we need more money’ it’s just the excuse changes every year, next year feel free to use the asteroid one, it’s more accurate than most I’ve heard.

Does Mr. Brack not get the gist of what the majority of dentists feel about him and the GDC. Mr. Brack is an unwelcome outsider who has taken over an organisation which was poisoned by the previous head ( a lawyer ) who seemed to detest the very people she was meant to oversee. I cannot understand why an institution, now so universally despised , is being led by someone who has no inkling of what it takes to run a dental practice and has no rapport with the average GDP. The man looks like a cross between a Man pretending to be a Spitfire pilot and a Used car salesman neither of which I would trust with the milk money.

Of course, if as Ian Brack kindly explains, the Brexit conundrum means a shortage of dentists and “the obvious way is the ORE”?
How very narrow minded and of course what utter balls!
Surely we, as a Nation, could consider taking the bold step of training more UK dentists rather than simply denuding other countries of dentists that they have thoughtfully (and expensively) trained for us.
ORE costs more? Oh dear. Why not increase the charge to the applicants then? Why should existing registrants subsidise it? If the cost of a pint of milk goes up, I don’t ask the chap in front at the check-out to chip in.

Direct access and more therapists are required to solve the staffing crisis in dentistry, Michael Watson says.

At the end of last week, the Home Office announced that doctors and nurses are to be excluded from the cap on skilled worker visas.

There will therefore be no restriction on the numbers of doctors and nurses who can be employed through the so-called tier two visa route – giving the NHS the ability to recruit more international doctors and nurses from outside the EU.

In case you were wondering whether ‘doctors’ might include dentists, it does not.

The Home Office statement did say though that the move ‘will also free up hundreds of additional places a month within the cap for other highly skilled occupations, such as engineers, IT professionals and teachers.

But again, no mention of dentists.

Recruitment issues
Also included are ‘leading fashion designers’ and applicants from the TV and film industry.

Good for doctors and nurses, who have great problems recruiting staff for the NHS, but equally so have dentists, especially now that recruitment from the EU has virtually dried up.

One thing we have to consider – all EU dentists are not affected by tier two visa applications, but they are not coming, partly because the pound sterling is down so the ability to send remittance home is reduced.

There is also the fact EU dentists genuinely came to the UK to make a home with their families, they are not going to come to the UK if they do not feel welcome and if there is no long-term future for them.

In addition, dentists from the Commonwealth, for example India, South Africa and Australia lost their dental qualifications having reciprocal status in 1997, so even if dentists from these countries where excluded from tier two visas like doctors and nurses, they still could not work in the UK.

Some say the solution lies with therapists, but according to the Government’s own Strategic Workforce Planning Group, to produce enough dental therapists to plug the gap would take 10 years.

In addition, without direct access, which does not exist in NHS dentistry, but does in private dentistry, dental therapists are not really a solution for the lack of an NHS dentistry workforce, which impacts on patient access.

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