BDA demolishes GDC case for ARF levels

Law & Regulation
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BDA says “Enough is enough” and demolishes GDC case for “exorbitant” ARF levels

The British Dental Association (BDA) has said enough is enough, and challenged the General Dental Council (GDC) to live within its means, and to set out when it will lower registration fee levels which remain the highest cost of any UK health regulator.

In a response to a letter from GDC chair Bill Moyes, both published in full on 30th October, the BDA has demolished the regulator's arguments on maintaining exorbitant fees and excessive levels of financial reserves, including need for continuously high investments to comply with PSA standards, uncertainties of the future and the non-disclosure of expected costs of some of the Shifting the Balance agenda.

It has now made the Secretary of State for Health and the Professional Standards Authority aware of the GDC’s approach to keep the ARF at the current level so that they can respond to the arguments set out in the exchange, and reiterated its commitment to work together with the profession, in Parliament and the press to ensure the ARF levels are restored to sane levels.

Bill Moyes letter to Mick Armstrong – 10.10.17.

Excerpt: Implicit in the budget decision is that we plan no change in the level of the ARFs for dentists or for DCPs in 2018. That will mark the third year in which both ARFs have been held flat.

As we said in Shifting the Balance, we will consult in the new-year on a new approach to fee setting for all of the professional groups on our register. That approach will be grounded firmly in the rigorous stewardship of funds raised through fees that the GDC has been embedding. While we can only reduce the ARF if and when it is prudent to do so, we aim to generate a better debate about how we use fee income to achieve regulatory outcomes.

To read Mr Moyes complete letter click HERE.

Mick Armstrong letter to Bill Moyes – 30.10.17

Excerpt: We are aware of the planned consultation but a reduction in the fee by a significant amount (see below) is a must before there is any trust in the GDC fulfilling its statutory duties for a reasonable cost. To say you want ‘regulatory outcomes’ is meaningless. The GDC has statutory duties, and these are what the ARF should pay for.

There is no need to run expensive projects to find out how issues can move ‘upstream’. Much of the work has been done by changes undertaken in the FTP area and the work around complaints handling. This is not costly work for which new staff members and consultants are needed, and further reports produced. It is abundantly unclear why the end-to-end FTP review is budgeted at £726,000 and why it is so difficult to develop learning from FTP outcomes.

This work should be done on a business-as-usual basis in the relevant departments – it is just core business. The profession has a desperate wish for the GDC finally to be doing what it should do consistent with the statute, and do it properly and fairly. Until we can see that the GDC can actually live within reasonable means, we will need to continue to highlight our concerns of transparency and accountability.

In conclusion, when the GDC set its policy on the ARF it stated that: “What Council have decided is that we will only charge registrants the amount that it costs us to regulate them and to issue a right to practise.”

It remains the BDA’s position that it is highly questionable whether maintaining the ARF at current level is consistent with your own stated policy, and is therefore legally justifiable. There is simply no rational connection between building up a reserves level sufficient to deal with six months without income, and meeting the efficient and effective costs of regulation.

We remain at a loss to understand why the GDC needs reserves at such a level, and why dentists are therefore required to move money from their depleted current accounts to sit in the GDC’s burgeoning reserve account.

To read Mr Armstrong’s complete letter click HERE.