Last week, NHS England issued further information about the marginal changes to be implemented from 1 October onwards. This set out that from 1 October there would be a range of changes to the FP17 to reflect the package of measures that NHS England outlined in July.
DCPs providing NHS treatment
The FP17 now allows the submission of claims in relation to treatment completed by dental therapists and others. This is done by adding the Dental Care Professional’s (DCP) General Dental Council (GDC) number to the form.
While the guidance on completing the revised FP17 says that it needs to include DCPs “involved” in providing the course of treatment, we understand that this does not mean that practices need to add the GDC number of every dental nurse assisting a course of treatment. The GDC number only needs to be added where the DCP has provided the treatment themselves. We have asked that NHS England amend the guidance to give necessary clarity on this point.
"There is clearly a need for NHS England to provide wider guidance and clarity on how it realistically sees DCPs providing NHS treatment."
Where practices are wishing to make use of DCPs to provide NHS courses of treatment, they should ensure that they have appropriate conversations with staff around competence, confidence, and any necessary training. DCPs should only undertake work that is within their scope of practice, which they are trained, competent and indemnified to do. Patients should be informed that they will not be seen by a dentist. Dentists and DCPs may wish to also consult their indemnity provider to ensure that proper arrangements are in place.
There is clearly a need for NHS England to provide wider guidance and clarity on how it realistically sees DCPs providing NHS treatment. There is understandable apprehension from many dentists about how they are to proceed in the absence of such advice. We will of course share any guidance with you as soon as we receive it.
There will also be changes to the FP17’s clinical dataset to support the payment of additional Units of Dental Activity (UDAs) for band 2 treatments. However, while data relating to the latter will be collected from now on, the payment of additional UDAs will not come into effect until regulatory changes are agreed by Parliament.
We have recently responded to a consultation on these regulatory changes, and we hope that NHS England and the Department of Health and Social Care will be able to ensure that they are implemented as soon as feasible. As the update indicates, it is expected that this will be from the end of November.
We have asked NHS England for the additional UDAs to be backdated to 1 October, but it is our understanding that this will not be legally possible, and the additional UDAs will only apply to courses of treatment opened after the regulations come into effect. This is a matter that requires clarity from NHS England to give dentists certainty about the claims they are submitting going forward.
Personalisation of recall intervals
There have also been changes to the FP17 to collect data to provide assurance that dentists are applying personalised recall intervals in line with NICE guidance, consistent with existing expectations.
Minimum UDA value
Contracts with a UDA value below £23 per UDA should already have received communication about the increasing of their UDA value to £23 and this will apply from 1 October onwards. As we’ve previously stated, we don’t think £23 per UDA is an appropriate minimum UDA value and we will continue to make that case to NHS England.
"NHS dentistry is facing a tipping point, and we need urgent action that is focused on real reforms."
It is frustrating that many months on from the announcement of these marginal changes to the contract, there is still a great deal of uncertainty and a lack of clarity on aspects of what dentists and their teams are now expected to do in NHS England’s communications, and this is now exacerbated by practices having the added requirements around the clinical dataset with none of the benefit of additional UDAs for more extensive and complex treatment.
We’ve said repeatedly that the contract reform process cannot continue at a glacial pace. NHS England rightly says that these marginal changes are the first significant change to the contract since 2006, but that is more an indictment of the failures of the last decade than it is an endorsement of this package. NHS dentistry is facing a tipping point, and we need urgent action that is focused on real reforms – like getting rid of the UDA altogether – rather than further tweaks to a long-discredited contract.
Head of Policy and Research