Written evidence submitted by the British Dental Association (GDC0082)

             
              Executive summary

 

 

 

 

 

 

 

 



Introduction and initial comments

 

1.      The British Dental Association (BDA) is the professional association and trade union for dentists in the UK. It represents dentists working in general practice, in community and hospital settings, in academia and research, and in the armed forces, and includes dental students. The BDA promotes members’ interests, advances the science, arts and ethics of dentistry, and contributes towards improving the nation's oral health.
 

2.      The BDA is fully committed to public protection and the need to ensure that the professionals on the GDC’s registers are fit to practise. We also agree that, where there is a genuine complaint about a registrant, that complaint needs to be made and dealt with appropriately and proportionately.
 

3.      The BDA is supportive of the Professional Standards Authority’s (PSA’s) principles of ‘Right-Touch Regulation’, which clarify that regulators should act in ways that are proportionate, consistent, targeted, transparent, accountable and agile.[2] We also support a professional duty of candour.

 

4.      On the basis of these principles and the provisions of the Dentists Act 1984 (as amended), the main role of a regulator should be to quality-assure education of the profession(s) it regulates; keep a register (or registers) of professionals who have shown that they are qualified and fit to practise the profession; apply sanctions to professionals who do not meet the relevant standards; and ensure that individuals who are not appropriately qualified to practise the profession are stopped from doing so. Together, these functions protect the public from harm, if they are well-run and well-managed. Such regulation should also help to maintain public confidence in the profession. The Association supports this form of regulation.

 

5.      A regulator is not a complaints body for issues that are not related to the fitness to practise of registrants. It has no role in dental service provision and cost setting for such services. In addition, it should ensure that a clear evidence-base supports any actions it takes or statements it makes.
 

6.      There are many concerns that have been raised about the General Dental Council (GDC), particularly within the last one to two years. There have been failures in relation to public protection, votes of no confidence by the profession, special investigations by the Professional Standards Authority (PSA)[3] , a finding of unlawfulness in the High Court, questions in Parliament about its suitability to regulate, an adjournment debate on its performance, and a disregard of the GDC for its own stated policies and standards.
 

7.      It has misrepresented the outcome of the judicial review into the ARF consultation[4] [5] and stood by this portrayal when challenged. It has also misrepresented the level of complaints against dentists by not differentiating between fitness to practise and other complaints.
 

8.      Whilst we support a regulator for the dental profession, we believe that no regulator should be allowed to act without impunity. It is not possible for the GDC to promote a duty of candour amongst its registrants if it does not subscribe to it itself. The impression the leadership of the GDC has given in the past year in particular is one of a regulator that is immune to criticism.
 

9.      The BDA believes that the profession’s trust in its regulator is currently at the lowest point we have ever experienced, and it is likely to take years to improve this situation. It is clear that the GDC does not have a role in representing the profession, and right that its raison d’être is the protection of the public. But it does have a role in maintaining public confidence in the profession, and it has a legal framework in which it should work. There is overwhelming concern that the GDC is currently moving outside both of these principles. We therefore welcome this accountability review.

Section 1: The Professional Standards Authority’s annual performance review
 

10.  The PSA’s last performance report (2013/14)[6] stated that the GDC had failed to meet two out of five standards for registration, and six (possibly seven) standards out of ten for fitness to practise. This has implications for public protection.
 

11.  The PSA raised concerns that the independence of the GDC’s Investigating Committee was in danger of being compromised by internal practices and ways of working (PSA report 2013/14 points 11.4-11.11). The GDC published summary findings of a report into this issue[7] but not the full report.
 

12.  At the time of the publication of the last performance report, the PSA was investigating a separate issue of process and whistleblowing (PSA report 2013/14 point 11.10). We are not aware that that report has been published at the time of writing.
 

13.  The PSA performance review (pages 69 onwards) particularly notes a lack of appropriate risk assessment and recording thereof (point 11.39), inappropriate timescales for referrals to interim orders and formal consideration of cases (11.42) and the GDC’s insistence that it saw significant increases of interim order referrals and complaint levels.[8]
 

14.  The above issues are clearly relevant to public protection. They also affect registrants who find themselves in a state of limbo in relation to their future, in particular if the case is not one of actual fitness to practise but has instead long been resolved between the patient and the practitioner before it is considered by the Investigation Committee or a practice committee.
 

15.  The GDC recently announced that it has cleared its backlog of cases[9] and made a number of other substantial savings in relation to the handling of its FTP function. While this is to be welcomed in the interest of patients and professionals, it is also of significance because the raising of the ARF for 2015 and the ensuing court case brought by the BDA was based on the GDC’s declarations that the backlog and expected new complaint numbers were so high that the rise was necessary to pay for this increased activity in its FTP function[10]. Evidently, much of the necessary work was undertaken within existing budgets by the end of 2014.
 

16.  A Section 60 Order is currently being considered and is expected to provide the GDC with additional powers to make further improvements to its FTP function. The approximate cost for the implementation of the new powers and the introduction of case examiners and new processes has been stated by the GDC as being “less than £400,000”[11]. The new process is also expected to bring further savings in the following years. It is therefore even less transparent why the GDC needed to collect an additional £10.4m from dentist registrants in 2015.
 

              Section 2: ARF consultation and Judicial Review

17.  The GDC embarked on a consultation on 30 June 2014 on raising the annual retention fee (ARF) for dentists for 2015 from £576 at the time to £945 per year. There was an outcry amongst the profession, based not only on the unprecedented rise in itself, but on the lack of clarity in the reasons for it.
 

18.  The GDC’s consultation document[12] proposed the rise on the basis of an increase in complaints levels between 2010-2013, projected complaint levels for 2014 and 2015, and a projected funding gap to 2017. It accompanied the projected complaint levels with projected numbers of fitness to practise cases, i.e. cases that would have to come to a full hearing.
 

19.  From the outset, the BDA contested the figures and argued that they were unclear for a number of reasons. Of particular importance, the conversion rates – the ratio of the number of complaints received to the number of actual expected cases – were not quoted or explained, but were much higher than conversion rates in previous years. Secondly, the budget figures outlined in the consultation paper did not match the figures in the GDC annual report[13], which had been signed off by the Council two weeks before the consultation went live. 

20.  The BDA sought legal advice and also engaged an independent firm of forensic accountants, FTI Consulting, to consider the consultation document in terms of the clarity of the information provided. FTI Consulting concluded that the GDC had not explained adequately the financial reasons for the proposed increase in the level of the ARF, or provided calculations and evidence in support sufficient to determine the amount of the increase, if any, required.
 

21.  The BDA’s response to the GDC consultation included a pre-action protocol letter warning of an intention to seek judicial review of the Council’s process. We also subsequently proposed that the GDC should hold a fresh consultation and asked for a response to a number of outstanding information requests.  The BDA filed a judicial review application in mid-October, when the GDC made clear that it would not reconsider or re-consult as suggested.

 

22.  Dental Protection, part of the Medical Protection Ltd group of companies and a global indemnity provider for dental professionals with in-depth knowledge and involvement in the fitness-to-practise process, provided a considered response to the consultation outlining the issues in need of addressing. This included details of what Dental Protection called the flawed premises of the proposed rise and the GDC’s disproportionate regulatory activity[14].
 

23.  The BDA also sent a formal complaint to the Chief Executive of the GDC in relation to a number of freedom of information requests to which it had not satisfactorily responded in the required timescale. The response to this complaint was provided after the decision on the ARF increase had been made.
 

24.  The GDC made the decision to raise the ARF for dentists to £890 on 30 October 2014 and made the relevant regulations. The Council appeared to justify the decision on the basis of appropriate levels of reserves, not on the previously published policy of what it costs to regulate each registrant group.
 

25.  While the GDC had received close to 4,500 responses to its ARF consultation, this response was downplayed as “4% of their total registrant base”.  This is in fact a very significant response rate relative to other GDC consultation exercises, and also fails to give any recognition to the number of responses from organisations representing large numbers of dental professionals, including the BDA.

 

26.  The BDA raised the following concerns about the GDC’s handling of the consultation in its additional pre-action protocol letters:
 

-          questions over the validity and the appropriate usage of the GDC’s underlying policy for the change in the ARF

-          questions over the discrepancy between the consultation document and published financial information

-          questions over the reliability of ‘trend’ information quoted by the GDC

-          questions over transparency with regard to the instructions given to accountants KPMG in relation to a review instigated by the GDC Senior Management Team of the underlying assumptions for the increase in the ARF.

-          that no “clear and robust business case that any increase is essential to ensure the exercise of statutory duties”, had been made, an expectation derived from the Government White Paper Enabling Excellence (2011)[15]

-          questions over predetermination of the decision[16].
 

27.  It was important for the BDA, in the interest of the public and the profession, to move forward with the judicial review before the end of 2014 so that clarity would be provided in time for the GDC’s legal requirement for payment of the ARF by dentists by 31 December 2014.
 

28.  The case was heard on 15 December 2014 and the ruling given on 18 December 2014.
 

29.  The GDC’s consultation was declared unlawful.
 

30.  In his judgment, Mr Justice Cranston said the following: “In my judgment this substantially increased projection of the number of fitness to practise hearings clearly required a transparent explanation and adequate information as to how it was calculated. It is common ground that fitness to practise hearings are the main driver of costs. I accept the claimant’s (i.e. the BDA’s) submission that it was difficult to see how consultees could express an intelligent view on the proposed increases in the annual retention fee unless they had some idea of what information the very substantial projected increase in fitness to practise hearings was based on. None of the key information as regards closure rates and fitness to practise trend information was disclosed as part of the consultation“.
 

31.  Elsewhere in the document, he states, in relation to conversion rates: “The GDC’s answer to the freedom of information request which attempted to explore the issue further was distinctly unhelpful”.
 

32.  The judge explained that the normal course of events in such circumstances was to grant relief to the aggrieved claimant; this would have meant the overturning of the regulations, the quashing of the consultation, and a reverting to the previous level of the ARF for all professionals.  The GDC cited arguments in relation to public interest and its own administrative inadequacy to persuade the judge against such a remedy.
 

33.  We fully understand that the judge was anxious not to compromise the integrity of professional regulation. Such were the GDC’s own declared uncertainties about both its powers and its competence that he was persuaded to accede to the GDC’s request.  He was, nonetheless, at great pains to point out at the hearing: ‘In my judgement…there was a gaping hole in the GDC annual retention fee consultation’. He was explicit that the consultation had been unlawful and that the BDA’s case had been unequivocally successful. Full costs were awarded to the BDA.
 

34.  It is worth noting in this instance that the GDC had known since July that the BDA would consider bringing legal action, and since October that the case was going forward. But it had evidently not initiated potential administrative steps for the eventuality that it might lose the case, and instead fell back on its own administrative ‘chaos’ as the main reason why an unlawful process should not be overturned.

 

35.  Over and above the details presented here, the sheer length to which the BDA had to go – and the associated cost - to elicit appropriate information from the dental regulator in relation to the fee proposals is so appalling that we believe it renders the GDC demonstrably unfit for purpose.

 

36.  This judicial review process was not about the money, however. It was about the appropriate use of registrants’ fees and the transparent use of that funding. Given that the GDC’s backlog of complaints and cases was cleared within existing budgets by the end of 2014, and more efficient processes have apparently already been introduced[17], it is now even less clear for what purpose the additional monies will be used.

 

37.  Prior to the consultation, the GDC appears not to have done any research or other work to consider why complaints were rising or how these could be prevented; a lack of agility criticised by the PSA in its 2014 report and not in line with the recommendations of the Francis report. This, combined with the lack of understanding the Council has of dentistry and its lack of meaningful engagement with the profession not only in the last few months, but even before then, has implications for public protection. The BDA has invited the Council on several occasions over the last few years to consider the impact of the NHS dental contract introduced in 2006, for example – to no avail. A pilot programme on complaints has now begun with NHS England, but several years have been lost during which important work could have been done.

 

38.  We have already referred to the misrepresentation of the outcome of the legal case. Furthermore, in an email to registrants, the GDC Chair declared in relation to the change in fees that “These decisions were controversial, but I am in no doubt that they were right[18]. This shows again a complete disregard for the finding of a court of law.

Section 3 - Parliamentary concerns

 

39.  Eight questions were raised in Parliament over the course of four month towards the end of 2014[19]. These covered issues of the business case for the fee rise, the PSA performance review, and other considerations linked to the fee increases.
 

40.  Parliament held an adjournment debate on 12 December 2014[20]. This was introduced by Sir Paul Beresford and attended by Dr Dan Poulter, who stated the following:
 

“While the General Dental Council has consulted its registrants on the proposed fee rise, I am aware of, and sympathetic to, a strong body of opinion among its registrants that they are yet to be presented with compelling evidence to justify such an unprecedented fee increase. The proposed fee is more than double the £390 that the General Medical Council requires licensed doctors to pay. That is why, when I met the GDC, I raised concerns about the fee increase and reconfirmed the Government’s position on the need for a strong and transparent case for any such increase.
 

I have also strongly suggested to the GDC that it considers a differential rate for newly qualified dentists. Newly qualified doctors are required to pay £185 for their registration with the GMC, while newly qualified dentists pay the same as established dentists. The GDC stated to me as justification for its fee rise that there has been a 110% increase in the number of complaints from patients, employers, other registrants and the police about the dental profession, and that the cost of handling such complaints has been the key driver of the increase. However, I have not been presented with what I consider to be compelling evidence that a fee rise of that magnitude is justified by a 110% increase in the number of complaints.
 

It is worth noting that other health care regulators, as my Honourable Friend suggested, have experienced increases in complaints but have not felt compelled to raise their fees to the same extent. I therefore understand why the British Dental Association has chosen to test this decision and issued judicial review proceedings challenging the setting of the fee. The hearing is set to take place next week, so I am sure that hon. Members will understand that it is inappropriate for me to comment further on those proceedings.

[…] under legislation, I am unfortunately powerless to intervene directly on fee setting. We recognise the independence of health care regulators and would not want them to be micro-managed by Government; that would be wrong. However, my view is very clearly, as I have outlined, that a strong evidence base is needed to justify a fee rise. Given that other health care regulators faced with similar challenges have not raised their fees to the same unprecedented degree, I have not myself been convinced that the evidence base is strong enough to justify this fee rise. […]”


Section 4 - Dental complaints and satisfaction levels

41.  The Chair of the GDC, Mr William Moyes, has publicly made assertions about the complaint levels in dentistry which do not stand up to scrutiny, but serve to paint a misleading picture of the situation. However, policy makers, the public and the press are likely to trust these statements and will be under the impression that the level of complaints against dentists is more significant than the reality. This serves neither patients nor the profession. Below are some examples.

42.  In a lecture to the Faculty of General Dental Practice (UK) in June 2014[21], he stated:

”It is extremely difficult to get a completely accurate picture of dental complaints across the UK as it isn’t centrally recorded. But in 2012-13:
 

NHS England received 7637 complaints about primary and secondary dental care

The Dental Complaints Service dealt with 1876 cases

The CQC received 1043 complaints

The Ombudsman investigated 3770 NHS health complaints, some of which would have included dentistry (but there’s no breakdown of the figure to help us)

Add to these figures the 2972 complaints made direct to the GDC.

 

In 2013 there were just over 38500 dentists and 62500 dental care professionals on the GDC’s register. So very crudely – and I stress that caveat - these very rough figures could mean that 17 per cent of the profession were the subject of some form of complaint. Even allowing for some overlap between the referrals to different agencies, this is staggeringly high. It also undermines somewhat the proposition that there is a high level of patient satisfaction with dentistry.”

 

43.  While he ‘stresses the caveat’ and ‘allows for some overlap’, he goes on to make an assertion that 17 per cent of the profession were subject to some form of complaint. These figures are misleading for the following reasons:

- the majority of Ombudsman complaints are likely to be medical
- there will be significant overlap of referrals
- some individual practitioners will have more than one complaint against them
- the calculations misrepresent numbers as they include some figures that relate to England only and some that relate to the whole of the UK.
 

44.  In an email to registrants in July 2014, the GDC stated: “We estimate that 1 in 7 dentists or DCPs is subject to some form of official complaint at any given time – to the GDC, to the DCS, to the CQC or to NHS England”.[22] There is no basis given for this estimate, other than the same simplistic and inaccurate basis used in the June 2014 lecture.
 

45.  In a speech during the All Party Parliamentary Group (APPG) for dentistry in November 2014 Mr Moyes repeated the statistics, this time leaving out the Ombudsman complaints but saying that ‘13% of the dental profession is the subject of some sort of complaint to a national body’. This repeated reporting of misrepresented data, portrayed as fact, from someone in such a position of authority, is irresponsible and unacceptable. It also does not differentiate between fitness to practise and other complaints, or reflect the number of complaints closed without further action.
 

46.  The GDC’s own patient surveys contradict these assertions and do not support the contention of a high level of patient dissatisfaction. The 2013 survey[23] shows that patient satisfaction with dental treatment sat at 96%, with 61% very satisfied and 35% fairly satisfied.
 

47.  On 3 February 2015, the public Council meeting received a presentation from IPSOS Mori, which reported on the latest GDC public and patient survey, conducted during the last three months of 2014. The report is not yet published, but the following are findings quoted in that public presentation:

 

-          1600 members of the public were surveyed through a quantitative and qualitative survey; the sample of those surveyed was representative of the countries of the UK.

-          96% of patients were satisfied with their dental experience (6% very satisfied, 62% satisfied, 34 % fairly satisfied).

-          75% would recommend their practice, and as this was a representative survey rather than a self-selecting one, this shows a good level of will to recommend.

-          2% had formally complained about their treatment or experience, and only 5% had considered complaining.
 

48.  Further, in an NHS England survey undertaken between July to September 2014[24], to which there were 425,000 respondents, 84% rated their NHS dental experience as positive (48% very good and 36% fairly good).
 

49.  In October 2014, the CQC published its report The State of Health and Adult Social Care in England 2013/14. The report concluded that the “last three years of inspections have shown… that the vast majority of dental care provided in England is of high quality” and “lower risk than most other sectors”. It also pointed out that where concerns were raised, particularly around issues of infection prevention and control, dentists had been quick to rectify problems. It also noted a high compliance rate of 95% with CQC standards[25].
 

50.  In January 2015, the Dental Complaints Service (DCS), which has responsibility for complaints resolution in private dental practices, reported to the GDC that between January and December 2014, complaints to the service had decreased by 43% compared to the previous year[26].

 

51.  These findings collectively show that patients are consistently content with both the treatment and the information they receive from dentists, and that the quality of care is generally good. Yet Mr Moyes said at the APPG that “96% of patients claim to be satisfied with their dental treatment but they’ve no idea what might constitute quality of service”. The GDC should recognise, and indeed welcome, a positive pattern in patient satisfaction and concentrate its activities on protecting the public where dental professionals are not meeting professional standards, rather than persisting with attempts to exaggerate the level of public dissatisfaction and involving itself in service delivery issues.
 

Section 5 - Comparative factors

52.  The GDC’s ARF for dentists is now the highest professional registration fee in the UK (figure 1). It is also one of the highest in Europe (figure 2) and extremely high when compared to regulators in Australia, New Zealand and South Africa (figure 3).
 


Figure 1, in GBP
 

 

Figure 2, in Euro, figures quoted for countries as available (EU Manual of Dental Practice 2014)             
 

 


Figure 3, in GBP
 

53.  The GDC quotes ‘economies of scale’ as a key reason why its fee is so much higher than that the GMC charges doctors. However, inefficiencies in its processes over time play a major role here. There is also a significant question to address in relation to whether the GDC is seeking to extend its regulatory activity with the monies it has now gained. In the earlier-mentioned FGDP lecture, Mr Moyes stated that his definition of the GDC’s responsibilities included, in addition to protecting patients, ‘to enable patients to get effective redress when harm occurs’ and to ‘enable patients to secure high-quality care and effective treatment at a fair cost’. The latter two points are clearly out of the remit of the regulator.

 

54.  The significant level of the GDC fee should not be disregarded simply on the basis that dentists are well-paid professionals. Whilst dentistry is a relatively well-rewarded profession, there are many indications that earnings are falling and, in particular, younger members of the profession find it increasingly difficult to find full-time work. Irrespective of dental earnings, the GDC has a duty to use registrants’ funds efficiently and there are many indications that it is currently not doing so.


Section 6 – Transparency
 

55.  Mr Justice Cranston’s judgement in the recent court case (see earlier) made several statements about transparency in relation to the GDC. The BDA believes that there are issues with transparency of the GDC in several other areas as well.
 

56.  Council decisions are now increasingly made in private meetings; public meetings are very limited in their discussions. The GDC website states that “sometimes, a limited number of sensitive items may need to be considered confidentially. These are kept to a minimum and are items which, if disclosed, could impact on the GDC’s ability to regulate the dental team or protect patients”[27]. We understand that certain issues will merit an in camera session. We do not, however, understand why these confidential issues have increased so substantially since October 2013 that there is now a substantial private session on each Council meeting day, and why considerations about policy for CPD, revalidation, or indeed the ARF policy and fee level were undertaken in private sessions. This approach limits public scrutiny of regulatory issues to a level that is quite meaningless. This is not transparent.
 

57.  It has been noticeable in very recent times that no significant discussion was undertaken in the public Council sessions about the court case or the Health Committee’s accountability hearing; the GDC has not made reference to the latter at all at the time of writing. While we accept that discussion of strategy will be confidential, it is not clear whether individual Council members show different levels of concern, whether they critically analyse the current situation of the GDC, and in how far the senior management team is properly held to account. This is not in the public interest.
 

58.  The format of the GDC’s consultation documents is not supportive of a meaningful exercise for gauging opinions. The online format is not user-friendly due to space limitations, and there is often no option for the provision of additional comments. Sometimes, there is no email provided to which written responses can be sent.
 

59.  Consultation questions are phrased in a way that produce easily-quotable statistics, such as ‘75% agreed with the proposal’, which then become the basis for policy development when in fact, respondents actually might signal their agreement with significant caveats.
 

60.  Particularly relevant to both the GDC’s ARF policy and the fee level consultations, consultees were asked whether they needed further information to assess the proposals. The BDA, and other respondents as well, clearly did ask for additional information. In the BDA’s case, this was either not received, or received too late to be considered for the purpose of responding to the consultations.





Section 7 - Trust of the profession
 

61.  In the last six months, the following groups took unanimous votes of no confidence in the regulator:

- The BDA’s General Dental Practice Committee

- The BDA’s UK Council

- The BDA’s English Council

- The Conference of Local Dental Committees

- The Scottish Dental Practice Committee[28], which also voted unanimously for a separate Scottish based dental regulator
 

62.  Dentists do not take lightly votes of no confidence; but the GDC’s approach and complete lack of insight into its own failings in dealing with the profession has resulted in an unprecedented level of doubt and distrust. A BDA survey of members in the summer of 2014 produced many comments demonstrating distrust in the regulator. This situation is not good for the profession, but more importantly it is also not good for patients.
 

63.  In that member survey in July 2014, nearly 6,000 members, or 42 per cent of those invited to take part, responded. Of these:
 

- 79 per cent of members were not confident that the GDC is regulating dentists effectively.

- 9 per cent of respondents thought the GDC was fair in the way it treats registrants.

- 12 per cent of respondents thought it was transparent.

- Fewer than 8 per cent agreed that the GDC was proportionate in its dealings with registrants.

- 77 per cent felt the GDC was not interested in their opinions when it holds a public consultation.

- 66 per cent of those who had experience of the GDC’s Fitness to Practise function rated the function fairly poor or very poor.

- 98 per cent disagreed with the proposed ARF increase

- 54 per cent supported an ARF rise in line with inflation.

 

Summary of comments and recommendations
 

64.  The BDA is grateful for the opportunity to provide evidence to this review. We have kept our evidence as short as possible but believe some detail is necessary to clarify the extent of the current problems with the GDC. If the committee would like any further information, we would be happy to provide it.
 

65.  We believe the above submission shows that the GDC currently does not comply with the principles of right-touch regulation, has lost the trust of the profession and is neither transparent nor considerate in its policy-making or its handling of registrant fees.

 

66.  It remains to be seen if the PSA, in its next review, finds the significant improvements in the handling of FTP
cases that the GDC has indicated. The GDC must in any case also work to regain the trust of the profession.

 

67.      We would ask the Committee to consider the actions and attitude of the GDC demonstrated in this submission and a clear requirement for the regulator to:

- become more transparent in its policy and decision-making
- become more transparent in how it uses registrant fees
- subscribe to the principles of right-touch regulation and a duty of candour
- recognise its failures and work to regain the trust of the profession
- work within, not outwith, the legal framework provided by the Dentists Act 1984 (as amended) to               fulfil its role of protecting the public

 

23 February 2015

 

 

[1] http://www.professionalstandards.org.uk/docs/default-source/scrutiny-quality/performance-review-report-2013-2014---print-ready-black.pdf?sfvrsn=0 point 11.52

[2] http://www.professionalstandards.org.uk/policy-and-research/right-touch-regulation

[3] 2013 and 2014/15(not published yet)

[4] http://www.gdc-uk.org/Newsandpublications/Pressreleases/Pages/General-Dental-Council-statement-on-the-outcome-of-the-BDA’s-judicial-review-.aspx

[5] https://www.bda.org/news-centre/press-releases/Pages/An-open-letter-to-the-Chief-Executive-of-the-General-Dental-Council.aspx

[6] http://www.professionalstandards.org.uk/docs/default-source/scrutiny-quality/performance-review-report-2013-2014.pdf?sfvrsn=0

[7] Hudson report 2014: http://www.gdc-uk.org/Newsandpublications/Pressreleases/Documents/Hudson%20Report%20July%202014.pdf

[8] Figures for this can be seen around points 11.44 – 11.52 of the performance review.

[9] http://www.gdc-uk.org/Documents/Fitness%20to%20Practise%20Web%20Brief-Dec2014-JG-FINAL.pdf

[10] http://www.gdc-uk.org/GDCcalendar/Documents/Consultation%20on%20the%20Annual%20Retention%20Fee%20(ARF)%20level%20for%202015.pdf

[11] http://www.gdc-uk.org/Aboutus/Thecouncil/Council%20Meeting%20Documents%202014/5%20Proposed%20Section%2060%20Order%20(full%20version).pdf

[12] http://www.gdc-uk.org/GDCcalendar/Documents/Consultation%20on%20the%20Annual%20Retention%20Fee%20(ARF)%20level%20for%202015.pdf

[13] http://www.gdc-uk.org/Newsandpublications/Publications/Publications/GDC%20AR%202013%20FINAL%20WEB.pdf

[14] http://www.dentalprotection.org/docs/librariesprovider4/dpl-consultation-responses/gdc-consultation-on-arf_response_sept-2014---final.pdf?sfvrsn=12

[15] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/216580/dh_124374.pdf page 11 point 2.6

[16] The presentation of the consultation document, interviews given by the GDC Chief Executive, and the short period between the closing date of the consultation and the initial proposed decision date (two weeks) suggested that the consultation process in itself was disingenuous.

[17] http://staging.gdc-uk.org/Aboutus/Thecouncil/Council%20Meeting%20Documents%202014/8(e)%20Appendix%20E%20Council%20Report%20Q3%202014.pdf

[18] GDC email to registrants 5 January

[19] 207016, 207010, 207011, 208258, 214199, 217750, 218587, 219522

[20] Hansard, 9 Dec 2014 : Column 245WH

[21] http://www.gdc-uk.org/Newsandpublications/viewfromthechair/Documents/PENDLEBURY%20LECTURE-William%20Moyes-June2014-FINAL.pdf

[22] http://www.gdc-uk.org/Newsandpublications/consultations/Documents/Email%20to%20registrants%2014%20July%202014.pdf

[23] http://www.gdc-uk.org/Newsandpublications/research/Documents/2013%20Annual%20Patient%20and%20Public%20Survey%20Topline%20Results.pdf

[24] http://www.england.nhs.uk/statistics/2015/01/08/5536gppsw1201415/

[25] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/364440/CQC_StateOfSocial_2014.pdf

[26] http://www.gdc-uk.org/Aboutus/Thecouncil/Council%20Meeting%20Documents%202014/DCS%20Annual%20Review%202014.pdf

[27] http://www.gdc-uk.org/Aboutus/Thecouncil/Pages/Council-meetings.aspx

[28] The Scottish Dental Practice Committee represents non-salaried general dental practitioners in Scotland and negotiates with the Scottish Government on matters relating to the delivery and remuneration of dental services provided by non-salaried general dental practitioners. It wrote in late 2014 to the Scottish Cabinet Secretary for Health and Wellbeing and the Chief Executive of the GDC to indicate its support for a Scottish based regulatory body.