Written evidence submitted by The LDC Confederation (ICS0055)

The LDC Confederation welcomes the Health and Social Care Committee's inquiry into Integrated Care Systems now that they have been established.

The LDC Confederation is a membership body for Local Dental Committees which in turn represent all performers and providers of primary care dental services operating under a General Dental Services contract. The LDC Confederation has four LDC members, representing almost 3,000 primary care dentists across 22 London boroughs.

Before we provide responses to selected points from the terms of reference we wanted to highlight the positive experience and engagement that our member LDCs have had with their respective ICSs. We appreciate that the system is new and that different ICSs are moving at different speeds with different priorities; some have well established local care partnerships, others are not yet established. To date our member LDCs have all enjoyed regular meetings with senior staff of their ICSs[1]. We have found these early engagement discussions helpful and interesting as it is important that the ICSs have a good understanding of the realities of dental services in their areas before they take formal responsibility for them in April 2023. We have found that their ambition and hope for primary care dental services to play its part in reducing health inequalities and improving health outcomes matches that of ours and our members.

The dental contract, however, remains an insurmountable barrier to this being made a reality. The proposals announced recently by NHS England for dental services will do little to help dentistry play its part in meeting ICS goals. We would echo the recent statement from the Health and Social Care Committee in your report on workforce that the current dental contract is "not fit for purpose". If dentistry is to be able to work as part of an ICS and to play its vital part in reducing health inequalities and improving health outcomes then a better contract which actively supports these objectives is required.

●        What does a permissive framework for ICSs look like in practice?

ICSs should have flexibility to meet the needs of their local populations as informed by local care partnership needs assessment and plans. National frameworks for integrating care, digitally led, should be developed with the ICSs to ensure that they are fit for purpose and meet the ICSs' operational needs.

While ICSs should be given flexibility to operate and structure as they see fit we consider that central guidance must mandate that the local representative committees are members of local care partnerships and any other relevant local authority level ICS structure. Primary care dental representation can only come from the local dental committee as that is the purpose in statute. It is extremely disappointing for the NHS to create new structures and discuss representation and engagement and fail to mandate engagement with the local representative committees. This must be rectified at the earliest opportunity before structures become too established and plans are developed without proper input from local professions.

●        What scope is there for variation between ICSs, to enable them to improve the overall health of the populations they serve and tackle inequalities?

As mentioned we agree with the Committee's assessment of the current dental contract as "not fit for purpose". ICS's will need the expertise of dental commissioners to ensure that flexible commissioning is applied in their areas to best effect until the contract is reformed and to manage any subsequent transition. As a result we recommend that our colleagues in dental commissioning are excluded from any redundancies as a result of the restructure. In London the dental commissioning team has undergone regular reductions in its workforce and it cannot sustain any further reductions if ICSs are to be able to make the best of dental care. Instead the ICSs will need to employ their expertise and knowledge to begin to integrate dental care with their plans.

●        How can it be ensured that quality and safety of care are at the heart of ICB priorities?

All providers of dental care are regulated by the CQC and the GDC. As a result the services are providing both safe and high quality care. The focus of the ICB should be on ensuring that those who require access to care are able to access it. Quality and safety for the ICB need not be about the provision of care itself as this is already regulated, but about the access to it and the systems which support a patient to navigate the health and social care system to ensure high quality outcomes. Where there are issues to be addressed in dental practice the ICS should work in conjunction with the LDC and CQC, which is why mandatory representation of the LDC (and other LRCs) is paramount. The LDC Confederation provides a Freedom to Speak Up Guardian function for practices in member LDCs to ensure that issues are addressed as early as possible.  

●        How best can this be done in a way that is consistent with how providers are inspected for safety and quality of care?

As mentioned, dental providers are regulated by the CQC and GDC. This is sufficient regulation.

●        How can a focus on prevention within ICSs be ensured and maintained alongside wider pressures, such as workforce challenges and the electives backlog?

Communication from the NHS about dental care to the public was extremely poor during the pandemic. In addition there remains a great deal of confusion among the public about dental charges and accessing dental care as highlighted by local healthwatch and Healthwatch England. Far better public facing information is required to help patients access care and reduce missed appointments.

We are concerned that the recent announcement from the NHS about "greater compliance with NICE recalls" is nothing more than an attempt to increase available appointments without investment and consider that the gains will be marginal but the unintended consequences damaging. Any messaging around this to the public needs to be extremely careful lest it undermines confidence in the dental profession and the NHS as a whole. We have raised concerns over the NHS focus on recalls in the past as it is an approach which protects and supports a broken system and ignores patient safety, patient choice and the competence of a clinical profession. We urge the Committee to look further into the decision making of the NHS announcement of 19 July[2].

As the ICS is closer to the patient we consider that they should have a greater role in communicating to the public and trust that national communications will be generated in conjunction with them.