The Chair of the Welsh General Dental Practice Committee (WGDPC) recently wrote to the new Health Minister to warn him of the pitfalls and problems that many practices are facing with the new contract and to enquire of his strategy for dentistry. Regrettably his response was to direct the matter to the monitoring group. This group has no independent oversight and is effectively marking its own homework.
There are no formal terms of reference, but the group includes various stakeholder representatives including the NHS Business Services Authority (NHSBSA) and software suppliers. The monthly agendas are set largely by Welsh Government and Health Board (HB) representatives. I am there to raise issues and to challenge whether the discussions fully reflect the experiences being reported by contractors across Wales.
It is evident that the Government believes the primary challenges facing practices are operational rather than contractual. This has been repeated in various communications from the Chief Dental Officer (CDO). I would contend this is simplistic and an unsubstantiated viewpoint. Several elements of the contract that were shaped by Government policy drivers are now increasingly problematic. One of the best examples is the Dental Access Portal (DAP).
The Dental Access Portal: Problems emerging in practice
The DAP was the Government’s goal for several years. During contract negotiations the mode of use was hotly debated, and it was evident it was being driven by Government policy ideology rather than robust modelling of patient flows within the final contract conditions. We raised the spectre of unintended consequences of the DAP which are now materialising.
In April, Welsh Government reported approximately 100,000 patients registered on the portal and suggested that public awareness activities had been successful. By May, concerns emerged regarding patient availability in some areas, particularly rural communities, with some practices struggling to receive sufficient allocations of new patients.
Now in July there is growing concern about the practical operation of the system. HBs report cumbersome allocation processes, difficulties contacting patients and instances where allocated patients require significantly less treatment than anticipated. Practices also highlight concerns about the impact on contract delivery, achievement of annual contract value expectations and associate earnings. Meanwhile practices are not allowed to accept NHS patients directly, despite getting frequent requests from patients who struggle with the DAP.
High ‘did not attend’ rates are creating financial pressure
This level of DNAs is having direct financial repercussions on practices as chair time is hugely wasted.
Another concerning issue for practices is that ‘did not attend’ (DNA) patients and non-response rates are now running at approximately 25–30%, creating operational challenges for practices attempting to fulfil allocation requirements. This level of DNAs is having direct financial repercussions on practices as chair time is hugely wasted.
During negotiations we made strong arguments for recompense for DNAs expressly for the reason of financial instability that higher DNA rates would cause; particularly in an untested system. Unfortunately, the monitoring group is not a space to negotiate changes, so this remains a live issue for us in future negotiations.
Ongoing challenges with claims and software systems
Technology remains another recurring theme. At the start, issues were identified with patient charge calculations, as well as claim processing difficulties affecting certain users. Welsh Government and suppliers moved quickly to address those concerns.
In May, NHSBSA reported that only a small number of technical issues remained outstanding, while work continued with guidance, validation processes and future replacement systems. However, in June we raised with the CDO that the Government’s issuance of CCN94 caused considerable disruptions when code 9348 was incorrectly disallowed in several care packages. This caused a great deal of disruption with claims, but no apology was forthcoming.
Software limitations remain a significant concern in July. Contractors report that some systems do not yet properly reflect regulatory requirements, particularly in relation to miscellaneous care packages. These operational issues would not have occurred if the previous Government had followed common sense and agreed to our argument for a year to pilot the system.
Administrative burden and audit drag
One of the strongest messages WGDPC continues to hear from practices relates to an increase in administration workload. Concerns have been raised that some practices are still trying to adapt to new systems while simultaneously facing audit activity that many believe is arriving too early in the implementation process.
During negotiations we argued administration needed to be streamlined and automated and we spent significant time arguing for a reduction of duplicate reporting and a rationalised system. We were assured that the new contract, with improved reporting, would naturally support this. The reality is very different, with NHS patient numbers being a good example of creating hinderance by the system that is meant to cover data gaps.
Contractors report that the administrative burden associated with the new arrangements is considerably higher than anticipated.
Contractors report that the administrative burden associated with the new arrangements is considerably higher than anticipated. Excessive administrative pressure risks undermining confidence at a time when practices are still establishing new ways of working.
Continuing uncertainty around national guidance for level two referrals
In April, questions were raised around patient charges where patients are assessed and subsequently referred into specialist services, with inconsistencies reported across Wales. By July, discussion had expanded to include level two services, charging arrangements for preventive care and radiographs, and the continuing need for clear national guidance. HBs sought explicit wording confirming that level two services delivered within GDS arrangements should not generate patient charge revenue. Welsh Government officials indicated that regulatory amendments may provide an opportunity to resolve some of these uncertainties.
For contractors, these issues matter because uncertainty inevitably leads to inconsistent implementation. Patients should receive the same information regardless of where they live, and practices should not be left interpreting regulations differently from neighbouring HBs.
Consistency across Wales remains essential
Whether discussing contract variation notices, patient information materials, charging arrangements, referral pathways or audit approaches, stakeholders have repeatedly highlighted the need for national consistency. In April concerns were raised about differing approaches to contract variation notices, prompting work towards a standardised national format. In subsequent meetings, similar concerns emerged around charging guidance and implementation practices.
For NHS dentistry to function effectively under the new arrangements, contractors need confidence that the rules are being interpreted consistently throughout Wales.
How you can help shape the next phase
Over the coming months, WGDPC is likely to seek further feedback from contractors and associates through surveys, direct evidence-gathering exercises and focused engagement on specific aspects of implementation. Areas of particular interest may include experiences of the DAP, administrative burden, software functionality, contract delivery, patient behaviour, audit processes and workforce impacts.
When opportunities to share your views arise, I would strongly encourage you to participate.
The experiences at practice level often differ from those visible through management data alone. Detailed feedback from contractors and associates provides the evidence required to challenge problems, identify solutions and influence future discussions with Welsh Government, HBs and NHSBSA. It also helps ensure that any future refinements to the contract are informed by real-world experience rather than ivory tower assumptions.