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Brexit and its impact on dentistry

UK dentistry has been affected by the UK's membership of the EU in a wide number of ways. We outline the main areas where Brexit is likely to have an impact on dentistry, and outline our position on Brexit.

The UK left the European Union on 31 January 2020. It is now in an agreed transition period during which most systems will continue to work without change, while the UK government and the EU negotiate the future agreements of cooperation. 

Therefore, most people will not immediately see any changes to their daily lives resulting from the UK's exit yet, and we await more information about the detail of any changes, and these will depend on what is agreed over the next 11 months.

 

The most obvious areas where EU legislation has a direct impact on dentistry include:

 

  • the movement of dentists and dental care professionals (including the various processes for the recognition of qualifications)
  • the import and export of dental equipment and materials, the supply of medicines
  • health and safety legislation
  • data protection regulations
  • research and development

Given the content of the political declaration that went hand-in-hand with the Withdrawal Agreement, the current Government's position is that it expects to have a wide-ranging agreement in place by the end of 2020.

 

However, there is also a discussion about the UK's reluctance to align itself with EU regulations on a continuous basis. As far as the EU is concerned, a lack of alignment, and the potential for divergence from existing and future standards, will affect the nature of any free trade deal and related agreements.

 

The provisions of the current transition period will end on 31 December 2020 unless there is a trade agreement, or an extension to the transition period, to allow for more negotiating time; the latter has been ruled out by the current Government but would, in any case, need to be agreed by the middle of 2020.

 

If the Government cannot negotiate a far-reaching trade deal on the grounds it proposes, there is still a possibility of a 'no deal' scenario at the end of 2020. In a no-deal scenario, current systems that involve any links with the EU would cease immediately on that day, unless new arrangements have been put into place individually. We would expect wide-reaching engagement from Government nearer the time, if this were the case.

 

We will keep an eye on any issues affecting dentistry and update you accordingly.

 

What's our position on Brexit?

Politically, we have kept a neutral position on Brexit both before and after the referendum. 

We are committed to assessing the impact on dentistry of leaving the EU, and we continue to advise our members on the implications of withdrawal from the European Union, as best we can, considering the complexity surrounding the withdrawal.  

What are we doing?

We continue to be involved in Government discussions on the impact for healthcare professionals and the wider profession to represent dentistry, and we have responded to relevant Government calls for evidence and consultations.

We are active participants in the Cavendish Coalition, which brings together organisations across health and social care to consider the implications Brexit, in relation to workforce issues in particular. 

We regularly meet with the GDC to discuss its own work on Brexit in terms of registration, regulation, the alert mechanism for professionals about whom concerns have been raised, and we are monitoring registration figures to see if there is any impact on the UK dental workforce.


We have participated in a Parliamentary round-table discussion on the automatic recognition of professional qualifications, keeping a neutral policy position, whilst arguing for a workable system for the recognition of qualifications in the future.

We have met with the Department for Business, Energy & Industrial Strategy (BEIS) to discuss how the Professional Qualifications Directive has worked in the past in the UK. 

In August 2019, we co-signed a letter with several health organisations calling for the Secretary of State for Health and Social Care to be invited to the EU Exit Strategy Committee. 

Our Northern Ireland Office has met with the Northern Ireland Department of Health to discuss issues. Workforce issues are a top priority in Northern Ireland, and we are participating in the Department's EU Exit Sub-group on Workforce. 

At the European level, we continue to be an active member of the Council of European Dentists (CED), the professional association for dental associations in Europe.

 

We have led on a number of working groups over many years, most notably on dental amalgam and teeth whitening, and a BDA representative had a seat on the CED's Board until the end of 2019. The CED has changed its statutes, enabling us to continue as an (affiliate) member with voting rights on policy issues after Brexit, as decisions taken at EU-level on issues relevant to dentistry will still need to be understood in the UK.

Main themes: dentistry and Brexit

We outline some of the key areas with regards to Brexit and dentistry:


​1. Workforce and recognition of qualifications

 

EU dentists working in the UK

While the UK was a member of the EU, EU citizens with a dental degree from an EU country benefitted from automatic recognition of qualifications based on the principle of free movement for EU citizens across the European Union. This meant that dentists qualified in the EU could come to work in the UK, as long as they had relevant language knowledge; registration was straightforward. There is no change to this during the transition period. 

Around 16-17 percent of the UK dentist workforce is registered on the basis of an EU/EEA degree; this includes UK citizens who have studied in Europe. The registration of those currently registered should not be jeopardised by Brexit.  

With regard to EU citizens coming to work in the UK in the future, the process for the recognition of their qualifications is unclear at the moment as it depends on government negotiations with the EU on the 'future relationship'. 

The focus of government is currently on a trade deal – it is unclear how much focus is given to areas that are more 'service' related. One possibility is that EU citizens will be expected to sit professional exams, as their non-EU counterparts already do, and the GDC currently has an working group looking in detail at these potential changes. Whatever the future system for recognition, there is already a waiting list for registration exams, and we believe that significant additional numbers of sittings may be difficult to arrange. 

While the GDC has introduced application fees, the creation of a new or changed system is likely to have to be funded, or at least cross-subsidised initially, by existing registrants via the GDC's Annual Retention Fee (ARF) income. 

It is also likely that EU nationals will have to do a more formal process of Performers List validation by experience (PLVE/VT equivalence) as their exemption from the formal programme as it is currently would also cease. This, in turn, would necessitate higher numbers of practices being willing to provide the training, and will also affect employment status (see more below). 

 

UK dentists working in the EU

The same EU freedom-of-movement rules have also enabled UK dentists to study and work in other EU countries until now. 

As UK citizens will not be EU citizens in the future, they will no longer be able to benefit from free movement and automatic recognition after 31 December 2020. Instead, professional recognition is most likely to depend on the arrangements for third-country nationals in any given country, subject to future relationship negotiations. 


We await clarity on how European universities will approach applications from UK students, but we assume they will be subject to the same requirements as other third-country nationals. Also, as per above, they may need to sit registration exams to work in the UK.

 

2. Immigration arrangements

Currently, EU citizens do not need a work visa to work in the UK. This, in combination with automatic recognition of qualifications, has made the UK an active recruiter of dentists from the EU/EEA. This is particularly true for the dental corporate sector, but also for more traditional practices. 

In the future, the UK Government has stated its intention to not treat EU citizens any differently to citizens from elsewhere, and  they will be required to comply with a new 'points-based system'. 

The plan is that all EU/overseas citizens will have to compete for work visas, where only the person who obtains a job offer is given the permission to work in the UK, for a defined time, after which they can apply for indefinite leave to remain. 


The requirements of the immigration system to reach the necessary points for a visa are likely to be fairly easily met by most dentists; however, we are concerned that this process may mean more red tape, delays and costs for all involved, especially dental practices used to recruiting from the EU to fulfil their workforce needs. 

To alleviate longer time frames for recruitment, the Government has proposed to scrap the labour market test, under which jobs first have to be advertised through specific routes in the UK before international applicants can be considered. 

Dental practices and their owners will take on the role of 'sponsor' for dentists from abroad as they currently do for those from outside the EU and be responsible for the associated costs.

Tier 2 visa arrangements will usually need to be on the basis of an employment contract; therefore practices may need to work with more employed, rather than self-employed, dentists in the future. 

While the Government has removed the immigration cap for employed doctors and nurses, this exemption does not currently apply to dentists, so it is unclear on whether visas will or will not be easy to obtain. 

The Migration Advisory Committee has recommended to the Government that the limit on the number of Tier 2 visas be relaxed; the expected minimum earnings threshold is £26,500; and the requirements will include a high level of English language knowledge. The proposals are currently going through parliamentary processes and we will keep a watching brief on this.

We do not know what impact a more 'hostile' environment (whether perceived or evidenced) might have on EU citizens who have lived in the UK for some time, and may have trained here, but hold citizenship of another EU country – some may choose to leave the UK. The changes, and a lower exchange rate for Pound Sterling, may also make the UK a less attractive place to work for dentists in the future and have an impact on the dentist workforce in the UK 


While most of the attention around dentist workforce issues in relation to Brexit is often focused on general dental practice, it is important to point out that dentists in the community dental services, in hospitals, and in academic and research roles, are affected in the same way, and that shortages in those areas are also of concern to us.

The Government has set up the EU settlement scheme for EU/EEA nationals currently living in the UK. Dentists and their members of staff need to apply for settlement before 30 June 2021 in order to remain in the UK without the need for future visa status, unless they have obtained citizenship. This includes individuals who have previously applied for residency in the UK; their status will be converted to the new scheme, but they must apply.

 

3. UK economy 

There are many commentators on the state of the negotiations process and its impact on the UK economy.

Pound Sterling has suffered significant losses at several points since the referendum, the UK credit rating was downgraded in September 2017, and economic growth predictions remain relatively subdued, with some fluctuations.  

Any economic downturn over the next few years and continuing acrimony between the trading partners could lead to higher prices and may impact on people's standard of living. 

Research suggests that economic downturns can affect patient behaviour in seeking dental treatment, and we are concerned that this could affect dental practices' incomes – for both NHS and private dentistry. 


We are keeping an eye on this issue and raising it at appropriate stakeholder meetings.

 

4. Medicines and medical devices

UK medicines and medical devices have been subject to a central EU system of accreditation.

While the UK Government has stated an intention to stay within the realms of the existing regulatory framework within this area, it is questionable whether this can be achieved without active participation in those frameworks; the discussions around regulatory alignment will be relevant here in the future. 


We have concerns that if the process cannot continue as it is, there may be difficulties over the timely provision of medicines, including those used in dental practice, and the rules for importing and exporting medical devices.

In addition, there are questions around the speed and efficiency of importing medicines and medical devices if there are border controls that could significantly delay transport and delivery. 


Over time, it might be possible for the UK to establish its own processes, mirroring existing ones going forward, but as there will be cost involved in the administration of these processes, we are concerned that thesecosts may be passed on to those who use, and need, medical devices and medicines.

 

5. The Irish border issue

Brexit took place on 31 January 2020 after the Withdrawal Agreement was passed in the UK and EU. To avoid a hard border between Northern Ireland and the Republic of Ireland, there was agreement that Northern Ireland would continue to follow EU rules on agricultural and manufactured goods after the transition period, while the rest of the UK is not bound in this way. 

Additionally, the whole of the UK will leave the EU's Customs Union, but Northern Ireland will continue to enforce the EU's customs code at its ports. This will mean some new checks and processes for goods moving between Northern Ireland and other parts of the UK. 

The UK and EU will now have to negotiate the nature and extent of those checks. This will mainly affect suppliers but could mean delays for dental practices in receiving their goods from next year. 


It is also unclear what will happen after December 2020 about the movement of people between Northern Ireland and the Republic of Ireland. There is a flow of workforce into both directions– registrants living in the Republic and working in Northern Ireland, or vice versa; and the same also applies to patients, who might seek care in a different part from where they live.


As detailed above, BDA Northern Ireland is participating in a Department of Health working group on Brexit and we will keep members updated on this issue.

 

More information

Below is a list of links to other information; please note any views expressed are not necessarily ours:

Keeping up to date

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