Dental Protection has welcomed the aim to boost the UK dental workforce by streamlining processes to enable overseas trained dentists to start practising in the UK, however it believes the current proposal to provisionally register international dental graduates (IDGs) who have not yet satisfied the GDC’s requirements for full registration, must be underpinned by robust supervision.

The proposal by the Department of Health and Social Care (DHSC) would give the General Dental Council (GDC) power to provisionally register IDGs on the condition that they work under the supervision of a dentist who has full GDC registration.

In its response to the consultation, Dental Protection says the draft order as it stands does not presently go far enough to provide the necessary assurance that the GDC will identify, assess and manage the concomitant risk factors associated with the challenges of supervision of IDGs. It also says the indemnity provision for both the supervisors and the IDGs would need careful consideration.

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Dr Raj Rattan, Dental Director at Dental Protection said:

“International dental graduates are a key part of the solution to the current dental workforce shortage, and we welcome efforts to make the processes by which they can start practising in the UK more efficient.

“While we acknowledge the preliminary efforts to ensure accountability for provisional registration, we strongly advocate a criterion-based quality assurance framework to provide and maintain high standards of supervision. Full GDC registration as the sole criterion for selection or appointment is not sufficient to make a dentist an effective supervisor. Supervisors must also be familiar with the principles of adult education including giving feedback and workplace-based assessments to fulfil their role effectively.

“It is also important that the indemnity provisions for both parties are considered. What are the legal and ethical implications of provisional registration and what are the risks for supervisors and how can these be managed. In particular, the doctrine of vicarious liability needs to be examined with guidance on activity, records, and other supporting documents to mitigate the risk.

“Renumeration, eligibility and performance criteria for supervisors need to be clear and unambiguous to avoid the pitfalls of motivational blindness and the risk of commercial exploitation.

“As well as responding to this consultation, we are keen to not only work with the GDC and the Department of Health and Social Care to highlight these issues but also help to design and implement practical solutions.”

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