A recent discussion has taken place between the dental advisers in the North Western region about dentists undertaking dental therapy duties.
The question has arisen due to the position of dental applicants to the national dental performer list filling their time, whilst waiting for inclusion, by being engaged as a dental therapist. Is this possible or appropriate?
The General Dental Council has stated that registered dentists can provide dental therapy services due to their scope of practice being inclusive of the scope of practice for dental therapists and hygienists. However, what the GDC has failed to do is qualify under what circumstances can this be done in relation the NHS Dental Regulations.
It is fairly obvious that this situation could be undertaken outside of the NHS regulations, i.e. privately.
It is not as clear that this can be done under the NHS regulations. A registered dentist has to be included on the dental performer list to provide NHS dental services and submit a claim, para 21. A registered dental therapist can provide services under the NHS regulations as below in para 22. What a dental therapist cannot do is submit a claim as they are not included on the dental performer list.
The consensus of opinion, between the dental advisers, was that a registered dentist could not provide dental therapist services under the NHS regulations as being a registered dentist they have to be included on the dental performer list to provide services under the contract, as per the regulations.
This does not preclude a dentist providing dental therapy services privately.
David Bradley BDS
Dental Adviser NHSE & Improvement Lancs and South Cumbria.
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References
General Dental Services Regulations 2005 Schedule 3 part 4:-
Dental practitioners
21. A dental practitioner(1) may perform dental services under the contract provided—
(a) he is included in a dental performers list for a Primary Care Trust in England; and
(b) his inclusion in that list is not subject to a suspension.
(1) The term dental practitioner is defined in section 128 of the Act as a person registered in the dentists register under the Dentists Act.
Dental care professionals
22.—(1) Prior to the coming into force of the first regulations under section 36A(2) of the Dentists Act(1) (professions complementary to dentistry)—
(a) a dental hygienist; or
(b) a dental therapist
may perform dental services under the contract provided he is enrolled in the appropriate register established in accordance with the Dental Auxiliaries Regulations 1986(2).
(2) Upon the coming into force of the first regulations under section 36A(2) of the Dentists Act—
(a) a dental hygienist;
(b) a dental therapist; or
(c) a professional or member of a class as specified in regulations made under section 36A(2) of the Dentists Act,
may perform dental services under the contract provided—
(i)he is a dental care professional; and
(ii)his registration in the dental care professional register established under section 36B(3) of the Dentists Act is not subject to a suspension.
(1) Section 36A was prospectively inserted into the Dentists Act by article 29 of the Dentists Act Order.
(2) S.I. 1986/887; relevant amending instruments are S.I. 199/3460 and 2002/1671.
(3) Section 36B was prospectively inserted into the Dentists Act by article 29 of the Dentists Act Order.
Performers: further requirements
23. (1) No health care professional or other person other than one to whom paragraph 22 applies shall perform clinical services under the contract unless he is appropriately registered with his relevant professional body and his registration is not subject to a suspension.
(2) Where—
(a) the registration of a dental practitioner, dental care professional or other health care professional; or
(b) a dental practitioner’s inclusion in a dental performers list,
is subject to conditions, the contractor shall ensure compliance with those conditions in so far as they are relevant to the contract.
(3) No health care professional or other person shall perform any clinical services under the contract unless he has such clinical experience and training as are necessary to enable him properly to perform such services.
Conditions for employment and engagement: dental practitioners performing dental services
24. (1) A contractor shall not employ or engage a dental practitioner to perform dental services under the contract unless—
(a) that practitioner has provided it with the name and address of the Primary Care Trust on whose dental performers list his name appears; and
(b) the contractor has checked that the practitioner meets the requirements in paragraph 21.
(2) Where the employment or engagement of a dental practitioner is urgently needed and it is not possible to check the matters referred to in paragraph 21 in accordance with sub-paragraph (1)(b) before employing or engaging him he may be employed or engaged on a temporary basis for a single period of up to 7 days whilst such checks are undertaken.
General Dental Council, Standards
General Dental Council, Scope of Practice September 2013