NHS dental payment reform: equality impact assessment record

Equality Impact Assessment Record

Title of policy/ practice/ strategy/ legislation etc.

NHS Dental Payment Reform

Minister

Minister for Public Health and Women's Health

Lead official

David Notman

Officials involved in the EQIA

name

David Notman

Susan Osbaldstone

Jillian McGhee

team

Dental Team

Dental Team

Dental Team

Directorate: Division: Team

Primary Care: Dentistry, Optometry and Community Audiology

Is this new policy or revision to an existing policy?

New policy

Screening

Policy Aim

To introduce payment reform for independent contractors General Dental Practitioners who provide General Dental Services (NHS dentistry).

At present there are a number of access challenges across Scotland for patients attempting to access NHS dental treatment. The Government has therefore brought forward at pace a new suite of fees intended to incentivise NHS care and treatment, and sustain NHS dental services as a national service in Scotland.

The new model reduces bureaucracy, provides greater clinical freedom to NHS dental teams and reflects modern dentistry. It is intended as the first step towards a truly modern NHS dental service which appropriately assesses, responds to and supports the oral health needs of every patient in Scotland.

Payment reform affirms the Government's commitment to sustaining and improving patient access to NHS dental services, in line with our Policy Prospectus.

The policy contributes to Scottish Government's national outcomes for health, as access to NHS dental services is a critical dependency for oral health outcomes.

Who will it affect?

Payment reform will affect the sector (as providers of NHS dental services) and patients, as users.

Access Improvements

The main aim of payment reform is to sustain NHS dental services by offering higher fees to incentivise NHS treatment and improve access to NHS dental services. The reform will therefore benefit both the sector by improving the NHS offer, and patients, with increased NHS provision.

The publication of the Oral Health Improvement Plan in 2018 made the commitment to undertake a wider reform of NHS dentistry, and in particular address concerns highlighted by the sector to prioritise payment reform, for an administratively simpler and more clinically-focused payment system.^[1]

We foresee then secondary benefits as the new payment system will offer dentists greater flexibility in treating patients, with the opportunity to use modern dentistry care and treatment. For example, patients will benefit from treatment items being brought in line with current best practice guidance, particularly around periodontal treatment.

The resulting payment reform comprises a high-trust, low bureaucracy model comprising 45 items for payment (compared with over 700 items presently)^[2]. While the number of items has been reduced significantly the actual care and treatment that may be offered to NHS patients will be enhanced. The new system will therefore be much easier for patients to understand, the NHS offer can now be presented in summary to patients.

Costs to Patients

Our priority is to ensure patients in all parts of Scotland have access to an NHS dentist; this is the principal aim of payment reform.

At present, those patients who are not eligible for free NHS dental care and treatment pay 80% of the fee cost of the treatment they receive. Payment reform comprises new higher fees to sustain the provision of NHS dentistry. This means for some patients they may have to pay more for their NHS treatment than at present.

Around 40% of people in Scotland are exempt from NHS charges – including under 26s' and those on certain benefits – and these people will continue to receive free NHS dental care and treatment. Payment reform also continues to protect free dental examinations for everyone - Scotland is the only country in the UK to offer this.

NHS patients who pay for their treatment will continue to pay 80% of the treatment costs up to a maximum of £384, as is the case currently. Those only requiring preventative treatments, such as oral health advice, will typically see a smaller increase in charges than those requiring more complex restorative procedures. We have had to increase fees for restorative treatments more significantly to reflect their current market cost and protect these treatments for NHS patients.

For those not exempt from NHS dental charges but on a low income, financial support is available via the NHS Low Income Scheme. For example, where patients are over 65 and whose only income is social security benefits, they would be entitled to a full remittance certificate under the NHS Low Income Scheme.

In summary the Government has had to take a difficult decision against challenging public finances to balance the need to sustain NHS dental access and costs to patients, while preserving existing help and mitigations to patients. The purpose of payment reform is to sustain NHS dentistry and in so doing prevent the emergence of a two-tiered dental service where only people who are able to afford private care can access oral health treatment.

Whilst costs to certain NHS patients have increased, these need to be set against the equivalent costs in private dentistry. Patients unable to access NHS dentistry and requiring private treatment typically pay between 6 and 10 times the NHS cost. NHS fees and the resultant patient charge remain significantly below the cost of private care for the equivalent treatment. In preserving universal NHS dental care all patients benefit.

What might prevent the desired outcomes being achieved?

At present there are a range of challenges facing the sector. The sector continues to recover from the long interruption of activity under pandemic restrictions. It was in April 2022 that sector-specific infection, prevention and control restrictions were eventually lifted allowing NHS dental teams to see normal patient workloads.

In the meantime there has been significant macroeconomic disruptions affecting laboratory costs, labour and other running costs for the dental sector. These are all exogenous factors that have a major bearing on the financial viability of practices, and the decision-matrix between NHS and private treatment. Dental practices like all sectors in the economy are facing an unprecedented cost-of-living challenge, as well as needing to attract specialist staff.

The Government views payment reform as the single most important step in moving the sector forward. However, it is not a panacea and instead should be viewed as setting the foundation for sustaining NHS dentistry into the medium- to longer-term.