The first deals with the creation of a new Independent Appeal Process for Family Practitioner Services, including GDS, while the second consultation centres on a proposed new Integrated Care System (ICS) commissioning model.
Here is a roundup of the key points of both consultations.
Independent Appeal Process
Provision is being made for a new independent appeal process to coincide with the closure of HSCB and transfer of functions to DoH.
Under the new proposal the appeals process will be confined to only hearing appeals against decisions formerly taken by HSCB, such as inclusion on the dental list. It will also include appeals against a determination by HSCB after investigating a disciplinary matter.
All other GDS appeals will continue to be against decisions made outside the Department i.e. by Business Services Organisation, Northern Ireland medical and Dental Training Agency or the Dental Committee. They will not come under the scope of the new independent appeal process.
We firmly believe that the scope of the new independent appeal process is far too narrow as applied to dentistry.
Dental contractors must have recourse to a fair and public hearing within a reasonable time, by an independent and impartial tribunal. This must apply to all significant decisions taken by the various decision-making bodies. We want the department to understand that these decisions can have as equally a profound financial or career altering impact as the two defined HSCB functions.
Integrated Care System commissioning model
The way in which we design, plan, manage and deliver HSC services is being transformed in the new draft framework for the integrated care system model.
The stated vision is that local providers and communities should be empowered to work in partnership, including HSC Trusts, independent practitioners and the voluntary and community sectors. In other words, an Integrated Care System model whereby local providers and local communities come together to plan care and services for their area.
We are very concerned with the scant reference made to the role of Family Practitioner Services/independent contractors within the new framework.
Equally, there is no explicit reference to dentists being involved directly with the new Area Integrated Partnership Boards (AIPBs). In contrast, the relationship between HSC Trusts and GPs on AIPBs has been highlighted ‘as pivotal’.
The draft Framework does set out an ambition for sectors/professions/organisations to bring the views of their sector as a whole on general topics, feeding into a Partnership Forum or Partnership Board and nominating individuals as members of the AIPB.
In our response, we have made it clear that dentists, alongside their GP and pharmacy colleagues must be afforded the opportunity to provide meaningful, direct input into all tiers of the new local commissioning arrangements. Facilitating local engagement via existing Local Dental Committees (LDCs) would seem a logical starting point. We have also highlighted the importance of maintaining a future role for All Area LDC meetings to maintain dialogue between the profession and local commissioners.
Our overarching ask is to ensure dentists are fully considered and involved in the new commissioning structures being put in place, not least in recognition of the important contribution oral health can make to general health.
Read our full response on the integrated care system draft framework.
Both consultations are pivotal in the future sustainability of our profession and it is our mission to ensure our full response is taken on board with the DoH. We will continue to keep you updated on all progress.