DMUK response:
- to the GDC consultation document ‘Shifting the Balance’
The consultation document can be viewed here
Proposals for action
Dental Mentors UK, is pleased to have this opportunity to comment on this consultation document and contribute to improvements in the education and regulation of the dental profession.
Moving upstream
A greater clarity for all dental professionals and students on the standards required to underpin high professional standards is applauded. In addition to enhanced knowledge, support to maintain professional standards should also be encouraged. The benefits of working with a mentor and/or coach cannot be under estimated in helping professionals keep on the right track.
A mentor can assist their mentee to deepen reflective thinking and extract maximum learning from CPD activities for the benefit of patients. Importantly a coach or mentor can help an individual to ensure their learning is translated into improved ways of working and that the improvements are fully embedded within their daily practice
Improving our engagement with professionals
There is much to be gained from a greater engagement with professionals and bodies that work with the profession. Linking the standards to performance management and appraisal to be explored on a local basis is welcomed, as in many cases, the first time a registrant is aware of these links is after they have been the subject of a complaint or a fitness to practice process. New ways of engagement with professionals should be explored with partners and the NHS to ensure that all registrants are aware of the standards and their effect on their working practises. Efforts should be made to engage registrants whose work is restricted to private practice as well as those working within the NHS.
Education
There is great diversity within the dental profession and much of that should be celebrated and enhances the strength and resilience of the profession. However, diversity also brings with it challenges. Education systems and provision of dental services are diverse and even within Europe there are many differences to the way dentistry is practiced within the UK. This can be confusing for dental professionals who qualify outside of the UK. In addition, ethical systems across the globe vary considerably. This can result in differences between patient centred care as operated and promoted with the UK and professional centred care as operated in many countries of the world. Paternalism whilst not regarded as an appropriate ethical response in the UK is viewed as entirely correct in a number of countries. These differences can result in performance issues for professionals and complaints from patients. Materials for registrants who have trained outside the UK are urgently needed and recognition of that is welcomed. Encouraging non-UK registrants to work with a mentor as they transition to working with the UK could be a useful addition to other materials.
Continuing professional development
The development of a quality based model of CPD, drawing on that produced by the Committee of Postgraduate Deans and Directors) (COPDEND), would assist in improving current CPD offerings and help professionals make informed choices when deciding which activities to undertake. CPD should cover a range of methods and tools to ensure different learning styles can be accommodated. Courses are an obvious method that is well understood and can be effective if developed and provided taking account of modern educational theory. On-line learning is a useful addition to a rounded CPD programme, however it should be discouraged from being the only method in which CPD is acquired. Methods that allow questioning, debate, discussion and interaction between professionals should be encouraged. The recognition of the important role coaching and mentoring can play in supporting dental professionals is welcomed. Appropriately qualified, trained and supervised mentors and coaches should underpin provision of these types of activities.
There are many areas which are common to a large number of Fitness to Practice cases for example record keeping, use of radiographs, communication, NHS regulations and consent which the GDC is able to identify from the analysis of Fitness to Practice cases. These areas should be highlighted to the profession as areas of focus they may wish to cover in their Personal Development Plans and CPD.
The ability of dental professionals to formulate Personal Development Plans (PDPs) is inconsistent depending on the training and support they have received. Some dental professionals have PDPs which are regularly reviewed and updated either via appraisal or individually. There are many sources of advice for formulating PDPs, however, mentoring and coaching is invaluable where the professional is not working within an environment which actively supports Personal Development Planning. A trained mentor can work with the individual in the process of SMART construction of the plan and matching of appropriate educational activities.
Peer review is an excellent means of reducing isolation of practitioners, encouraging debate and discussion, and improving the quality of care provided to patients. This method of sharing good practice is relevant to all members of the dental team from all registrant categories. There are some very effective peer review groups operating currently. The GDC should consider, in collaboration with partners, ways of supporting other practitioners to join or initiate peer review groups by, for example, training peer review facilitators, providing a peer review toolkit with documentation and processes, and sharing good practice between peer groups.
First-tier complaints resolution
Methods to actively handle complaints in a positive and constructive manner are to be applauded and encouraged. Complaints form the basis of service improvement if viewed as useful feedback and not perceived as predominately confrontational. However, improved handling of first tier complaint resolution should go hand-in-hand with refocusing fitness to practise and a determined approach for complaints to be handled and resolved at a local level in the first instance.
Working with partners
Working with partners makes sense. An important consideration should be dental professionals who experience performance difficulties as a result of ill health. Better management of such professionals is urgently required. The GDC should proactively work with bodies such as the Dentists Health Support Trust and the Practitioner Health Programme to resolve health concerns whenever possible before regulator processes are instigated.
There should be agreed pathways and support mechanisms for dental registrants who require professional support so that all concerned know how and where to access their support. This may include support with identification of areas for development, personal development planning and identification of appropriate educational opportunities to meet those needs.
It is vital that any organisation has the capacity in terms of workforce, expertise and funding to deal with any changes in their responsibility for regulating the profession.
Trained supervisors and mentors are often required for compliance with local or GDC conditions or undertakings. Further guidance on the roles and responsibilities of supervisors and mentors should be developed to allow consistent application of the conditions across the UK. Dental Mentors UK would welcome the opportunity to be involved in developing such guidelines if this is taken forward.
Refocusing fitness to practise
It is agreed that regulation should be: proportionate; accountable; consistent; transparent and targeted. It would be helpful if all the attributes could be further defined with and examples to clarify exactly what they mean and how they are practically applied otherwise they will remain aspirational.
Further development of the comprehensive model for managing complaints and concerns is welcomed and should ensure that the system addresses practitioners issue. In addition It is important to reduce potential stress for individual registrants to allow them the opportunity to remediate as quickly and effectively as possible.
Overarching comments
The vision of a collaborative system dealing with issues in the right place, delivering the right outcomes for patients and the public at the right cost and within an acceptable timeframe is a laudable one., However there are a number of factors that, if not adequately addressed, could undermine the success of right place, right outcomes and right cost. Some of these are:
- Currently registrants pay into the GDC via their Annual retention fee (ARF) and the costs of fitness to practice are covered by the ARF. If issues (cases) were directed to what would appear to be a more appropriate resolution, probably at a local level, that would require new funding, as no appropriate structure is in place. Health Education England is currently in the process of reviewing their programmes and structures and it is vital that processes that support any fitness to practice issues along with individuals who have skill and experience in investigation and remediation are retained within the system, even if the responsibility is transferred to another body . Resources therefore include skilled individuals and processes locally. Training would be required for review and investigation of complaints and performance concerns.
- Partnerships between the General Dental Council and other organisations, for example Health Education England, NHS England (and their equivalents across the UK), CQC, and the indemnity organisations should be formalized to ensure clarity. Pathways for dealing with issues should be developed so that individuals and organisations are clear about who they should contact and the path this will follow should issues arise. Associated processes should identify the skills and training required for individuals involved in all stages of the process.
We welcome the aspiration to develop a shared understanding of professionalism. Professionalism is a dynamic concept and it evolves as the public and society evolves. It is agreed that conduct and competence has the potential to undermine public confidence (and also trust). The definition of serious shortcomings will require some in-depth consideration. Involving public opinion here could be illuminating. Professionalism is closely related to the character of the professional undertaking their professional duties as such it is difficult to see how an element of ethics and morality can be divorced from the actions of a professional person. We would expect the regulator of a body of professional individuals to retain the ability to comment on both public and private morals of registrants and not attempt to decide what solely impacts on the professional environment in which the registrant undertakes their activity. The professional is a whole person and character flaws generally span personal and public life.
Dental mentors UK
April 2017