Provisional Registration For Overseas Qualified Dentists
Very recently the government proposed in the Recovery Plan that overseas qualified dentists who have not yet achieved full GDC registration to be able to work in the UK more quickly through provisional registration.
Provisional registration would allow an overseas-qualified dentist, under supervision by a fully GDC registered dentist, to practise dentistry in the UK in any dental setting, including high street dental practices, without first needing to pass either the Overseas Registration Examination (ORE) or the License in Dental Surgery (LDS) exam.
The Department of Health and Social Care have launched a consultation about this plan.
The consultation closes on 16th May 2024
The full consultation can be accessed from:
Annex A: Provides a copy of the draft order: The Dentists Act 1984 (Provisional Registration of Dentists) (Amendment) Order 2024 (draft order)
In summary, the draft order will give GDC powers to:
· set up a new status of provisional registrant for individuals holding an overseas dentistry qualification and who have not yet satisfied the GDC’s requirements for full registration, through the creation of a separate list in the dentists register
· determine the level of supervision that a provisionally registered dentist will be required to work under
· produce guidance on how provisionally registered dentists should identify their provisional registration status to patients under their care
· set time limits on the length of time an individual can be provisionally registered, and prevent an individual from provisionally registering multiple times (other than in exceptional circumstances as prescribed by GDC)
Provisional registration will be open to individuals holding an overseas dentistry qualification. This is already the standard required for temporary registration, where GDC also requires that a degree is accepted by UK ENIC (the UK national agency for international qualifications and skills) to confer eligibility for registration. GDC will be given the power to determine how entry onto the register should be managed, including setting appropriate criteria. Once an individual is on the register, GDC will have a duty to mark entries with any restrictions on their practice.
A provisionally registered dentist will be prohibited from practising dentistry unless under the supervision of a dentist holding full GDC registration. GDC will be given the power to determine the appropriate level of supervision, utilising their experience and expertise as the dental regulator. Unlike temporary registration, dentists holding provisional registration will be permitted to practise in any dental setting, so long as they do so under appropriate supervision. GDC will be required to produce guidance to registrants and their supervisors on how patients should be made aware of a dentist’s provisional registration status. A provisionally registered dentist who does not adhere to any conditions or restrictions on their registration, or any guidance, may be subject to fitness to practise proceedings.
In general, the processes which apply to all registered dentists will also apply to those holding provisional registration. This includes:
· the requirement to have appropriate professional indemnity
· fitness to practise processes
· rights to appeal
· the charging of fees
As with those holding temporary registration, provisionally registered dentists would not be eligible to be appointed to GDC’s board.
Provisional registration is designed to be a time-limited status for those who are seeking to achieve full registration to be able to practise independently. Therefore, GDC will be required to set a time limit for the period a person may hold provisional registration status. A person will not generally be permitted to hold provisional registration multiple times, unless GDC agrees there are exceptional circumstances.
Although this provisional registration will allow overseas dentists to work, whilst they are waiting to complete the ORE or LDS, there has not been any indication that they will automatically be able to work within the NHS.
It would be my understanding, that once registered with the GDC as fit to practice the overseas dentist would still have to apply to join the dental performer list and undertake to demonstrate they are fit for purpose to be able to undertake NHS general practice.
This does lead to a dilemma because when an overseas dentist applies to the performer list they normally require a supporting dentist to help with their demonstration of being fit for purpose, however as part of provisional registration the GDC requires that the overseas dentist is supervised and the GDC will decide the level of appropriate supervision. It will of interest, to any provider, as to what that level of supervision is required by the GDC and how that may align with the current requirements in Lancashire and South Cumbria for a supporting dentist when applying to the performer list.
It would be my concern that there will be enough supervisors to meet any demand for overseas dentists to work in any dental setting and what is going to be the level of qualification that the GDC will require for a GDC registrant supervisor.
Currently, when applying to the performer list, the supporting dentist is required to be or have been a Dental Foundation Trainer, undertaken an educational supervision course or have undertaken a form of mentoring course. Will the GDC criteria be the same or similar?
The documentation at the moment does not give any detail about this.
As we would all like to see more dentists working in the UK and especially in the NHS there is the question as to whether these proposed changes to GDC registration will actually provide this and will the GDC actually be able provide the resources to get these provisionally registered dentists through the ORE or LDS in a timely manner before the provisional registration time limits run out?
I would encourage colleagues to read the documentation and if possible have your say through the consultation.
David Bradley BDS
Dental Adviser
April 2024