Replacing the Dental Practice Board
A new national dental governance structure is taking shape
- “The role of the Scottish Dental Practice Board (SDPB) has been poorly understood by the profession and a clearer remit and individual accountability might be a good idea.”
- “I have been a practice owner in Scotland for 30 years and have little notion as to the function of the SDPB, save what I read on the internet.”
- “The dental community confuses the SDPB with Practitioner Services.”
- “Never been a fan of the SDPB. Vested interests abound.”
- “You would be hard pushed to find a practising dentist who doesn’t feel that SDPB treat all of us as though we are fraudulent.”
When the Scottish Government published the results of a consultation on its proposed Oral Health Improvement Plan (OHIP) in 2017, the perception conveyed of the Scottish Dental Practice Board was, to say the least, not positive. Even the Board itself recognised that change was needed: “Of the options listed in the consultation document, SDPB believes the ‘do nothing’ one is the least appropriate,” it said in its own response.
The Board’s role is defined in statute, dating back to 1997 and updated in 2010, and its main responsibility is the authorisation of payment of fees to dentists in accordance with regulations. But, the Board noted, “the developments in primary care dentistry over the last couple of decades have moved us well beyond a focus on payments, towards a far wider spectrum. Even the payment system itself is far more extensive than it was, and the Board’s formal interest relates only to the ‘traditional’ elements.
“In addition, the management arrangements for delivering the operational functions on behalf of the Board… changed with the creation of Practitioner Services in the 1990s; and its place within NSS [NHS National Services Scotland] has also changed over the years.
All of this is effectively recognised in the consultation document. The value of our current limited role is, therefore, correctly challenged in the consultation. This then leads us to consider another option – to simply dispense with the Board.”
Scroll forward three years, and the SDPB is still in existence. When the Government published its OHIP in 2018, one of the proposed actions was to “consider how the functions of the SDPB can be subsumed within NHS NSS (National Services Scotland)”. While legislation would be required to formally dispense with the SDPB, that process of transferring responsibilities is now well under way.
The functions of the SDPB continue to be protected by legislation and any formal adoption of its functions is contingent on legislative change. However, two preliminary meetings of its effective replacement, the National Dental Governance Committee (NDGC), have been held so far; at the end of last year and last month. Any decisions made by the NDGC will still have to be endorsed by the SDPB.
Subject to formal approval by the Government, the NDGC will be a sub-committee of the NSS Clinical Governance Committee, “reflecting NSS’s unique position within NHS dentistry in Scotland, where NSS provides a number of services on behalf of all the territorial NHS Boards”. NSS makes payments to NHS dentists on behalf of the Health Boards for the provision of NHS dental care throughout Scotland.
It ensures that treatment and payment is in accordance with NHS regulations. NSS is also the only source of clinical reassurance on the quality and appropriateness for NHS Boards of the NHS dental treatment provided or intended by dentists through NSS hosting the Scottish Dental Reference Services (SDRS).
Under the proposals, the NDGC will meet and report quarterly and publish an annual report. The agenda and minutes will be published online, and meetings will be open to the public. The committee will include a ‘Stakeholder Council’, comprising representatives from NHS Education for Scotland, the British Dental Association, Scotland’s Dental Directors, the Scottish Dental Practice Adviser Group, and the Health Boards’ dental services administration staff.
The committee will be chaired by the NSS Dental Director, currently Paul Cushley. Two representatives from Practitioner and Counter Fraud Services, including the Senior Dental Adviser, and a representative from the office of the Chief Dental Officer will also attend.
The new governance structure will also more accurately reflect the contribution that NHS Education Scotland makes in developing and maintaining skills and knowledge in the workforce and how this positively impacts on performance.
“Transparency, collaboration and consultaiton are intrinsic to the development of these structures”Paul Cushley
While the increasing role of Health Care Improvement Scotland in Quality Improvement is not currently reflected in the membership of the stakeholder council, representation is being actively considered.
Responsibility for the strategic direction of the Scottish Dental Reference Service will sit with the NDGC, while Practioner Services will retain the day-to-day management of the service. A separate project is under way with NSS to standardise payment verification across Scotland’s 14 health boards. The NDGC, it is understood, will use “high level strategic information around performance to allow comparison and challenge performance”.
Paul Cushley said: “The reinvigoration of the governance arrangements gives NSS an opportunity to address many of the criticisms outlined in the Oral Health Improvement Plan. Previous structures have served us well in the past, but the review and changes are required to ensure that structures and processes are fit for the 21st century and are able to adapt to the new model of care and the new SDR going forward. Transparency, collaboration and consultation are intrinsic to the development of these structures.”
Functions of the National Dental Governance Committee
- Where relevant, the NDGC may consult other bodies with an interest in clinical governance in NSS.
- Engage with all other organisations involved in the delivery of dental services to develop the provision of General Dental Services in Scotland.
- Establish and foster formal links with all other regulators operating in the dental domain in Scotland to aid consistent regulatory compliance and improve quality assurance.
- Determine the priorities and authorise the strategy and policy of the Scottish Dental Reference Service (SDRS) with regards to clinical assurance.
- Set the operational targets for the Scottish Dental Reference Service and scrutinise the performance of the Scottish Dental Reference Service with regard to these targets.
- Establish a mechanism to deliver, on behalf of the territorial Boards, a consistent national appeals mechanism for orthodontic decisions made by PSD.
- Review the Payment Verification process (with particular regards to the part 2 clinical governance information) to establish mechanisms to maximize the value of and use the high-level data to help improve Boards’ performance.