NHS dental payment reform: business and regulatory impact assessment

Purpose and Intended Effect

Context

NHS dental services is a critical health care service, with over 95 per cent of the Scottish population registered for NHS provision.

The service has been disproportionately impacted by the recent experience of the pandemic. As around 70 per cent of dental care and treatment involves the use of an aerosol generated procedure (AGP), during the pandemic dental services were subject to heightened infection, prevention and control procedures. These procedures were in place from the onset of the pandemic in March 2020 to April 2022.

The sector remains in a recovery phase following the relaxation of controls. For the period 2022/23 over 3.8 million courses of treatment were provided. There are around 1,050 dental practices in Scotland, providing a mix of NHS and private treatment. The majority of dental practices are independent providers, with General Dental Practitioners (GDPs) making arrangements with the relevant NHS Boards for the provision of NHS dental services in their respective areas. A small number of sites comprise Public Dental Service, where the dental teams are employees of the relevant NHS Board.

Objectives

Presently GDPs are paid under the Statement of Dental Remuneration (SDR). This comprises a range of payments, including fee per item, capitation, allowance and direct reimbursement.

Payment reform largely focuses on the fee per item element. Comprising at present over 700 codes payment reform will comprise a new Determination I of the SDR with 45 codes. The intention is to move away from a low trust, high bureaucracy model where payment under fee per item is conflated with clinical governance, to a simpler system that maintains the principle of fee per item but ensures NHS dental teams have much more clinical discretion in treating NHS patients, and reflects modern dental care and treatment.

Rationale for Government Intervention

The Government views payment reform as the single most pressing requirement to safeguard NHS dental service provision.

As described above, the sector is presently in a recovery phase. There are a number of challenges facing the sector, legacy effects of the pandemic, the impact of Brexit on the supply of EU dentists, and the cost-of-living situation on costs of provision. All of these factors combined mean that the sector is going through a period of intense stress. The main rationale of payment reform is to place the sector on a sustainable financial footing ensuring the provision of NHS dental services across all of Scotland for the medium- to longer-term.