Scotland's Oral Health Plan: consultation on the future of oral health

4 Arrangements for General Dental Services

Administrative Arrangements

4.1 GDS is currently delivered by GDPs on behalf of fourteen territorial NHS Boards, or directly through the PDS. Support in the delivery of GDS is provided by 'special health boards' such as NHS National Services Scotland and NHS Education for Scotland.

4.2 Currently NHS Boards can make arrangements with independent contractors, either dentists or Dental Bodies Corporate ( DBsC), to provide GDS. Other dentists who are employed by a contractor can provide GDS on their behalf, and are called assistants. NHS Boards hold lists of both contractors and assistants.

4.3 This consultation presents an opportunity to explore shared services within the administration of GDS. Certain tasks could be centralised to increase the support available to NHS Boards in carrying out their day to day administrative functions. This could include hosting local NHS Board dental lists, and supporting NHS Boards with other functions such as practice inspections, NHS Discipline and Tribunal cases and General Dental Council referrals.

Contractual Arrangements for Dental Contractors

4.4 The present arrangements for the provision of GDS are governed by the NHS (General Dental Services) (Scotland) Regulations 2010 (the terms of service for contractors and assistants are laid down in Schedule 1 of these Regulations). There is no formal written contract between NHS Boards and GDPs or DBsC.

4.5 The Scottish Government believes that these arrangements need to be modernised to more fully reflect a contract between the NHS Board and the practice, while retaining arrangements with each individual GDP. Our proposal is that the NHS Board would have a formal contract with the practice owner(s).

4.6 We believe that a formal contract between NHS Boards and the practice owner(s) would help ensure that the arrangements and obligations for each party are clear.

Locality Planning of Dental Services

4.7 Under arrangements for GDS, NHS Boards have few powers to plan their local service provision. While NHS Boards have direct responsibility for PDS, they have limited control over the numbers of independent contractors providing GDS in their Board area. In recent years the increase in the numbers of GDPs willing to provide GDS has meant NHS Boards have had to consider the appropriate balance of provision between PDS and independent contractors.

4.8 The new role of H&SCPs for strategic planning and commissioning of services, which includes both the GDS and PDS, presents an ideal opportunity to consider their involvement in NHS dental services. In the medium to longer-term we envisage an increasing role for H&SCPs in locality planning for NHS dental services in their respective areas.

Earnings and Expenses Information

4.9 In recent years, the independent pay review body on Doctors' and Dentists' Remuneration ( DDRB), has expressed serious misgivings with the robustness of data available on earnings and expenses of independent contractors providing GDS in Scotland.

4.10 The Scottish Government commissioned an independent financial consultant to gather this information from a representative sample of dental practices in 2015/16. Unfortunately the exercise was met with limited success, and is being rerun for 2016/17. Our proposal is that the supply of this information would be a terms of service requirement.

Patient Registration

4.11 At present patients are registered with individual dentists or DBsC. The Scottish Government would like to explore further the benefits of a patient being registered with a practice, while having a responsible GDP within the practice. This would offer patients the security of continuous registration with the NHS dental practice in the event of their responsible GDP leaving. It would also offer the continued benefit of an on-going relationship with a dentist who has the responsibility to support the improvement or maintenance of their oral health.

Future Provision

4.12 At present there is no explicit requirement on GDC-registered practice owners, or GDC-registered directors of a dental practice, which provides GDS, to work clinically from that particular practice. A dentist, for example can own a practice without actually working in that practice.

4.13 There needs to be a much stronger link between practice ownership and the delivery of day to day patient care, and appropriate action needs to be taken to ensure the continuation of that relationship for GDS in Scotland. The Scottish Government believes this is the correct opportunity to consult on a requirement for GDC-registered practice owners or directors to provide a minimum number of hours of NHS clinical care per week in each practice.

4.14 We also wish to consult on the requirement that bodies corporate must list with the NHS Board for the provision of GDS. This would ensure the NHS Board has a point of contact for taking forward issues relevant to that particular practice.

Allowances

4.15 In addition to item of treatment fees, there are 13 allowances which may be payable to independent contractors. These are payable to either an individual GDP, such as continuing professional development allowances, or to the practice, such as reimbursement of rent and rates. The current system of allowances is complex and administratively burdensome, with different eligibility criteria.

4.16 It is the Scottish Government's view that we need to work towards a reduced number of allowances, including a new practice allowance and a new allowance payable to GDPs, that reward the level of NHS commitment and quality of service provided. We also want to explore what the criteria should be to qualify as a NHS 'committed' practice.

Summary of Proposals:

• Explore whether there should be a national body responsible for shared administrative duties such as hosting local NHS Board lists. This national body could also take on other duties, including practice inspections, NHS Discipline and Tribunal cases and General Dental Council referrals.
• Consider introducing a formal contract between the NHS Board and the practice owner(s).
• Consider whether patients should be registered with the dental practice and have a responsible dentist.
• Work closely with H&SCPs to encourage better local planning of NHS dental services within their respective areas.
• Consider making the provision of earnings and expenses information a terms of service requirement.
• Consider whether GDC-registered practice owners, or GDC-registered directors of a dental practice, providing GDS should be required to provide a minimum number of hours of NHS clinical care per week in each practice location.
• Consider whether to have a requirement that bodies corporate must list with the NHS Board for the provision of GDS.
• Work towards a reduced number of allowances, including a new practice allowance and GDP allowance, that reward the level of NHS commitment and quality of service provided.
• Explore what the criteria should be to qualify as a NHS 'committed' practice.