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This paper argues that dentists should act in a professional manner and take a collegiate approach to establish a support system for ‘colleagues in need’ when facing General Dental Council Fitness to Practice Committees similar to that provided for doctors in comparable circumstances.
CPD/Clinical Relevance: The incidence of an allegation made to the GDC, which are associated with registrants' mental and behavioural disorders, and subsequently avoiding difficult procedures, was 3.57 per 100 dentists in 2017.
Article
Like the medical profession, there has been considerable unease within the dental profession regarding the regulatory processes in recent years. Several publications have suggested that it has been found wanting.1,2,3,4,5,6,7,8,9,10
Similarity of regulation between the dental and medical professions
Dentists and doctors are each one of the 32 regulated occupations. Both professions are regulated by bodies established by UK law, the General Dental Council (GDC) and the General Medical Council (GMC), respectively. Both of which provide:
Checking of the quality of education and training standards;
Maintenance of a register;
Standard setting;
Investigation of complaints and decisions regarding the registrant's Fitness to Practice [FtP].
Both Councils are themselves regulated by the Professional Standards Authority for Health and Social Care, which sets the standards for regulators in their document Standards of Good Regulation.11 So there is a very strong similarity between their regulatory processes.
Problems with regulation
Whilst there has been little research into the dental regulatory process, there has been into the medical regulatory process.
A GMC survey noted doctors' loss of confidence in regulation appears to be driven by concerns about:12
Doctors' wellbeing during the process, including stress levels;
The amount of time that such investigations can take; and
Recent data on suicide rates among doctors under investigation.
Doctors who were subjected to investigation within the previous 6 months were twice as likely to harbour thoughts of self-harm or suicide than those who either hadn't experienced a complaint or had had a complaint longer ago;
Doctors referred to the GMC were most at risk of mental ill health, 26% suffering depression, 22% suffering anxiety and 15% having thoughts of self-harm;
Defensive practice was common, with 79% of those who had experienced a complaint saying that they had changed their clinical practice as a result. They used tactics such as avoiding difficult tasks, ordering too many investigations and, in some cases, acting against their professional judgment;
Of those who had been subject to a complaint, 1 in 5 felt victimized for having raised concerns about poor clinical or managerial practice, and almost four out of 10 (38%) said that they felt bullied during the investigation.
British Medical Association (BMA) for Doctors unit head, Mike Peters, said: ‘The research highlights the stress of going through a complaints procedure and, importantly, how this may have an effect on a doctor's practice with possible subsequent patient safety implications.’14
There is published anecdotal evidence that dental registrants also find the process stressful.10 Speaking directly to dental registrants who have experienced the process, it is clear that the process was extremely stressful.
Time
The GDC does not meet its own aspirational target times (Table 1). Res ipsa loquitur.
FtP Stage
Target Time
Mean% Outside Target
Initial assessment
10 days
1%
Investigation
6 months
43%
Initial hearing
9 months
48%
Suicide
Doctors and dentists in the USA have similar suicide rates, 1:87 and 1:67, respectively.16 A GMC report17 found that 28 doctors committed suicide whilst under FtP investigations between 2005 and 2013. No survey has been published regarding dentists, but a dentist in Wales was reported to have committed suicide in 2010 after being prosecuted for fraud.18 However, this is a topic we are reluctant to talk about. Inevitably, some registrants of both professions have allegations reported relating to mental and behavioural issues which may be accentuated by stress related to the FtP process.
With regard to FtP, a GMC survey12 found: 45% of doctors say that they are either ‘not very confident’ or ‘not at all confident’ in the regulation of doctors by the GMC. Of General Practitioners, 49% are ‘not very’ or ‘not at all confident’ – more than doctors in any other role. If this level of disquiet were to be replicated by surveying the dental profession it would be of greater significance as a greater proportion of dentists are general dental practitioners.
‘Some distress is therefore inevitable, but the onus is on us to do whatever we can to reduce the fear and upset doctors experience, without in any way compromising our duty to investigate thoroughly in order to protect patient safety.’
In 2012, the GMC first commissioned the BMA to run the Doctor Support Service following a successful pilot in 2012. Since then, the contract has been extended and it has provided assistance to hundreds of doctors. The Doctor Support Service19 provides:
‘6 hours of telephone support, subject to availability, from the time a complaint is received by the GMC until the matter is concluded. Or from the time you receive notification from the GMC that your license to practice is at risk.
Face to face support, subject to availability of supporters, on the first day of a hearing and one further day if the hearing runs for more than a day.
An orientation visit on the morning of your hearing, if you would find it useful to look around the hearing room before it starts. You can arrange this with your supporter.
Or watch a tour of the hearing centre.’
The GMC also advises which protection provider (Medical Protection Society) provides its members access to counselling for stress as a result of receiving and dealing with complaints, clinical negligence claims, disciplinary matters, and other medico-legal issues.20 It also provides a list of alternative sources. The GDC also acknowledges that the regulatory process is stressful to registrants, but does not fund a support service. It states that its staff have been trained by the Samaritans. The GDC does not advise that Dental Protection provides a counselling service for its members, but provides contact details of other resources available (Table 2).
Sources
Alcoholics anonymousBDA Benevolent FundBar Pro Bono UnitBritish Doctors and Dentists GroupCarers UKCitizens AdviceDentists' Health Support Programme [DHSP]Dyspraxia UKMind BLMKNHS Practitioner Health ProgrammeNarcotics AnonymousPractitioner Advice and Support Scheme [PASS]RefugeSamaritansScopeTurn2UsVictim Support
Since its formal adoption in 1996 by the Royal College of Physicians and Surgeons of Canada, the CanMEDS competency framework has become the most widely accepted and applied physician competency framework in the world. It represents the work of hundreds of College Fellows and volunteers. It is based on: empirical research, sound education principles and broad stakeholder consultation. CanMEDS recognizes that, to provide optimal patient care, healthcare professionals should promote a collegiate culture that recognizes, supports and responds effectively to colleagues in need.22
It is very clear that colleagues facing the GDC's FtP process are colleagues in need. The failure of the Dental Profession to follow the example of doctors and provide a national dentist support service for dentists facing the regulator's FtP process is a clear failure to support colleagues in need and thus a shameful example of a lack of professionalism.
Apart from responding to colleagues in need, a service should hopefully reduce the risk to patients of traumatized registrants returning to practice without any follow up.10
Conclusion
The GMC has stated:‘This is a time of unprecedented unease regarding regulation. Individually and collectively registrants should rise to the occasion by making time to think, talk and work together.’23
Registrants should reflect that, in 2017, the GDC received 1,643 concerns,24 of these 1,48925 related to dentists. There were 41,705 dentists on the register in 2017. The risk of an individual registrant having a concern made in 2017 was 1,489/41,705 = 3.57 cases per 100 dentists. There but for the Grace of GOD goes any one of us.
Our objective should be to establish a national support service, free for all dental registrants who have concerns made to the GDC. Individually, registrants should:
Encourage the British Dental Association as the representatives of the Dental Profession to lobby: the Department of Health and Social Care; the Professional Standards Authority; and the General Dental Council.
Write directly to Nadine Dorries MP, Parliamentary Under Secretary of State (Minister for Patient Safety, Suicide Prevention and Mental Health). Can you really afford to pass by on the other side of the road?