Survey
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
* Your assessment is very important for improving the workof artificial intelligence, which forms the content of this project
Forensic dentistry wikipedia , lookup
Remineralisation of teeth wikipedia , lookup
Focal infection theory wikipedia , lookup
Calculus (dental) wikipedia , lookup
Special needs dentistry wikipedia , lookup
Dental emergency wikipedia , lookup
Dentistry throughout the world wikipedia , lookup
Page |1 Opening Statement to the Joint Committee on Health and Children Dr. Eamon Croke, President, Dental Council Thursday 8th October 2015, Committee Room 2, LH2000, Leinster House The Dental Council is grateful to the Chairman of the Joint Committee on Health and Children, Mr. Jerry Buttimer, T.D. for his invitation to meet with the Committee. The Dental Council have been in correspondence with the Committee following a letter from Mr. Paul Kelly, Principal Clerk, of 16th October 2014. This letter resulted from the meeting of this Committee with representatives of the Clinical Dental Technicians Association of Ireland (CDTAI) on 1st October 2014 and I will return to the matter of that letter in the course of our submission. Firstly, I would like to outline the role of the Dental Council. The Council was established by the Dentists Act, 1985. The primary function of the Dental Council is to protect the public. It does so by promoting high standards of education and professional, ethical behaviour for all its registrants. The Council is composed of 19 members. There are three main Committees of the Council: Education and Training: this Committee oversees undergraduate training and continuing professional development. It works in conjunction with the Irish Committee for Specialist Training in Dentistry in establishing and evaluating standards in postgraduate training. Continuing professional development is not mandatory under the Act; Fitness to Practice: this Committee assesses complaints in relation to the behaviour, performance and physical and mental wellbeing of a dentist. In doing so, it may establish grounds for an Inquiry, hold an Inquiry and report to Council on the findings of an Inquiry; Auxiliary Dental Workers: this Committee is responsible for establishing the classes of auxiliary dental workers, their scope of practice, training and ethical conduct. The Council’s term of office is 5 years. There is mandatory registration for dentists and specialists, of which there are two recognised specialties, orthodontics and oral surgery. Mandatory registration is in place also for dental hygienists, clinical dental technicians and orthodontic therapists. The Council has a voluntary register for dental nurses and is working very closely with dental technicians to establish a voluntary register. The Dental Council awaits a new Dental Act to allow it to fulfil its primary duty and meet the demands of a world 30 years removed from the present Act. The Council have made submissions on a range of functions it would envisage as appropriate to its ability to regulate the dental team. The Council has been consistent in seeking new legislation that Page |2 would permit effective, flexible regulation which is evidence-based, reasonable and proportionate. The Department of Health consulted widely on the legislation to replace the present Act and published a report on its findings in June 2013 (Report of the Consultation Process on new legislation to replace the Dentists Act, 1985). The Council met with the representatives of the Professional Regulation Unit, Department of Health recently to discuss their ‘Summary of Policy Issues for inclusion in the new Dental Bill’. (Appendix A) The key policy issues we proposed to the Department of Health included: Fitness to Practise: The Council would urge, in the strongest terms, that the wording in Part V of the Dentists Act, 1985 in relation to Fitness to Practise be retained and amended rather than introducing the very prescriptive provisions of both the Medical Practitioners Act and Nurse and Midwives Bill. The Council’s experience of operating the provisions of Part V of the current Dentists Act is that the procedures work well for managing fitness to practise matters. The provisions in both the Medical Practitioners Act and Nurse and Midwives Bill create a significant and unnecessary administrative burden and provide for excessive opportunity for technical judicial review proceedings to be taken. It is the Dental Council’s view that detailed procedural provisions do not need to be included in the legislation as statutory bodies (and their committees) have a constitutional obligation to observe fair procedures. In preparing this submission, the Dental Council consulted with other regulatory bodies and was strongly persuaded that this is the appropriate course of action, particularly in the light of the experience of the Medical Council in implementing the provisions of the Medical Practitioners Act, 2007. The Dental Council notes that the Fitness to Practise provisions of the Pharmacy Act, 2007 are less prescriptive than either the Medical Practitioners Act, 2007 or the Nurse and Midwives Bill, 2010. The Dental Council broadly supports the main provisions of both the Medical Practitioners Act 2007 and the Nurse and Midwives Bill 2010 in providing for the creation of a Preliminary Proceedings Committee (PPC), which is separate from the Fitness to Practise Committee (FTP), the establishment of a Health Committee (HC) and for a wider range of sanctions. The Council would welcome provisions allowing for complaints to be referred by the PPC to mediation where the PPC establishes that there is no prima facia evidence of a complaint on one of the grounds set out in the Act. The Council also welcomes provisions allowing the PPC to refer matters concerning the unfitness to practise of a practitioner to the Health Committee because issues concerning the health of a practitioner often only come to light as a result of receiving a complaint on other grounds. The Dental Council notes that the Medical Practitioners Act, 2007 provides for a majority of practitioners on all Committees, except the Fitness to Practise Committee, where the majority must be non-registrants. The Dental Council is generally satisfied with the provisions of the Medical Practitioners Act in this context and considers that this is a Page |3 workable provision, on condition that the Dental Council may determine the competencies required for appointments to both the PPC and FTP Committees and that the Council makes the appointments to these Committees. In the Dental Council’s view, the personal qualities and professional expertise of the members of both Committees is of paramount importance. While the provisions of Part V of the Dentists Act are generally adequate the addition of the following provisions would greatly increase the effectiveness of the FTP Committee: provide for the appointment of registrants from the relevant class of auxiliary dental worker when the case involves a member of that class. allow for evidence to be heard by video link allow a practitioner to consent to censure or remedial action (as per the Medical Practitioners Act). This provision should also allow the practitioner to consent to the attaching of conditions for the retention of his/her name in the register allow for the Committee to consider matters summarily, following a recommendation from the PPC (by way of statement or sworn affidavit), and following such consideration, to recommend a sanction of advice, admonish, censure or direct a practitioner to refund some or all of the cost of treatment fees allow the Council to attach conditions to a registrants practise if there has been a finding of fact at Inquiry, even though this may not constitute professional misconduct. This provision is in the current Dentists Act but it is not in some of the more recent regulatory legislation allow for the FTP Committee to hear matters concerning unfitness to practise where there are also other allegations (i.e. that the totality of the matter is dealt with by one Committee), and that the Committee may hear such matters in private provide for the publication of Fitness to Practise Committee reports where there is a finding of fact or where an allegation has been proven, after the report has been considered by the High Court and/or Council. Having reviewed the legislation applicable to the other healthcare regulators, the Dental Council is of the view that the provisions of Section 42 of the Pharmacy Act, 2007 are preferable. This allows for Fitness to Practise Committee hearings to be held in public but that the Committee may decide to hold a hearing in private after considering submissions from either the complainant or registrant in this regard. The Council believes that the registrant’s name should only be made public if there is a finding of professional misconduct or if conditions restricting a professional’s practice are attached to a registrant’s registration. In the Dental Council’s view, the same range of sanctions that apply to practitioners should apply to the entity registering dental premises, including the power to temporarily close dental premises, to attach conditions to the ongoing registration of Page |4 dental premises and the power to erase (permanently shut down) dental premises. The Council would wish to have an additional provision giving the Council the right to apply a significant and punitive fine on the entity registering a dental premises (e.g. in excess of €100,000). Regulation of the allied dental health professions: The Dental Council strongly disagrees with the provision in the ‘Summary of Policy Issues for inclusion in the new Dental Bill’ (Appendix A) that only those auxiliary dental workers who work independently will be registered. The Dental Council believes this proposal to be regressive and potentially harmful to patient safety and the development of the dental team. The Dental Council believes that all members of the dental healthcare team should undergo mandatory registration with the Dental Council. This regulatory system already applies in the UK where all registrants are accountable to the General Dental Council (GDC) and may be the subject of professional misconduct proceedings. In the Council’s view the same procedures / range of sanctions as apply to dentists should be provided for in relation to auxiliary dental professionals. All dental healthcare professionals should be motivated by the three-fold aim of safeguarding the health and safety of patients, promoting the welfare of the community and maintaining appropriate standards in all aspects of his/her life, both personal and professional, so the public have confidence in the dental profession. The sharing of common ethical and professional behaviour by all dental healthcare professionals would be reinforced by fitness to practise procedures for all registered members of the dental healthcare team. This aim will be negated if the proposal is legislated for as it is proposed. At present there is no statutory provision for removing an auxiliary dental professional from the register, other than if the registrant fails to pay his or her retention fee. Auxiliary dental professionals do carry out treatments and it is appropriate that they are accountable from both an ethical conduct and clinical perspective. Dental hygienists can administer local anaesthetic, suitably qualified dental nurses can take radiographs, and orthodontic therapists may fit and adjust removable orthodontic appliances. A proposal to greatly expand the scope of practice of dental nurses to include additional intraoral procedures has been with the Minister for approval for almost two years. It is important that such workers are professionally accountable for their actions. Similarly, if a dentist and an auxiliary worker were convicted of the same type of indictable offence (e.g. sexual assault), the Council may decide to erase the dentist from the register but it could take no action against the auxiliary dental professional. The numerical size of the dental healthcare team in Ireland is small compared to that of medical healthcare personnel so it is sensible to have all members of the dental healthcare profession under the aegis of a single regulatory body. This will promote the Page |5 continuing development of holistic, evidence-based and patient-centred regulation. In keeping with this view the Dental Council proposes that all dental healthcare professionals should have representation on the Dental Council under the new Dental Act. The Dental Council believes that this is a cost-effective, efficient regulatory proposal as it makes efficient use of resources and skills. The Dental Council also believes such inclusion is consistent with best practice in the other dental regulatory systems that the Dental Council has examined and will enhance patient safety and confidence in the dental team. The issue of illegal or ‘denturist’ practice highlights a quintessential issue to any discussion on dental regulation; without registration is regulation effective, transparent, consistent and how is accountability enforced? How does one know who is to be regulated when one may not know who or where they are? Other concerns which arise in the absence of registration include: Council has, heretofore, regarded that any intra-oral treatment poses a risk to patients and should only be carried out by a registrant. Registrants such as dental hygienists and orthodontic therapists have a real potential to damage or infect patients if this work is not carried out by a suitably trained and accountable professional From a patient’s perspective, registration enshrines the fact that he/she is being treated by a professional dental team Registration means that registrants have to comply with ethical and practice standards (CPD, infection prevention and control etc.) Allows for autonomous practice and decision making Having a registrant professionally accountable to the Council enhances an allied dental health professional’s ability to deal with poor standards within the practice Removing professional status will diminish the stature of dental nursing and dental hygiene in the eyes of new entrants and may impact on the quality of future cohorts of students The status of auxiliary dental workers may be diminished in the eyes of the public The programmes offered by educational institutions will be diminished. The Council is very concerned with the proposal to reduce regulation where the risk is perceived to be low. This trend carries advantages in other areas but in healthcare it removes those not registered from the direct regulatory influence in the development and maintenance of a safety culture. To ensure it has the capacity to fulfil valid regulatory function, to enhance patient-centred safer, better healthcare, the Dental Council requires the new Dental Act to provide mandatory registration for all members of the dental team, including dental technicians, and not solely the registration of those members of the team who can practice independently. It is the stated desire of all organisations representing those who work legally within dentistry that mandatory registration should be provided by the new Dental Act, for all dental healthcare professionals, and appropriate regulation must follow. Page |6 The issue of registration and regulation is at the core of illegal practice, which the Clinical Dental Technicians Association of Ireland (CDTAI) brought to this Committee’s attention on 1st October 2014. In that meeting the representatives alleged “that there are significant numbers of people illegally practicing as Dental Technicians in Ireland and further alleged that there has been a complete failure on the part of the Dental Council to regulate the profession”. The Registrar of the Dental Council repudiated the false allegations made by the CDTAI delegation in his letter to Mr. Kelly of 23rd October 2014. The Dental Council, under the Dentists Act, 1985 has no power to inspect or close illegal practice. The limitations imposed on the Dental Council by the present Act to deal with alleged illegal practice are widely recognised, and were highlighted in the Competition Authority’s Report Competition in Professional Services: Dentists, 2007 (Executive Summary, 5). In addition, the Registrar informed Mr. Kelly that while the Dental Council does not have a Register of Dental Technicians, dental laboratories are regulated by the Health Products Regulatory Authority (HPRA). The issue in question is the illegal, direct provision of removable dental prostheses (dentures) to the public by unregistered and unqualified ‘denturists’ who may also, legitimately, provide dental technical support directly to the dental profession. The Dental Council has similar concerns to those expressed by the CDTAI and has done so for many years, prior to the registration of the first Clinical Dental Technician (CDT). The inability of the Dental Council to directly intervene in illegal practice is known to the CDTAI, as Clinical Dental Technicians (CDT) have representation on the Council’s Auxiliary Dental Workers Committee. Many hours have been given to the CDT representatives, within Dental Council and in informal meetings, to explore their concerns. They are fully aware of the limitations of the Dental Council’s power and the CDTAI has misrepresented the Councils powers to you. The Board: The proposal that a new Dental Act would limit the Council size to a maximum of 12 members will irrefutably change the successful operational traits of the Dental Council. While the Council appreciates that one of the main aims of having a non-dental majority is to minimise the perception of professionals protecting professionals when considering fitness to practise cases, it is important to realise that most of the work that Council undertakes relates to dental education and general practice. To operate effectively, it is vitally important that the voice of dental educators, specialists, as well as members of the general practice dental team are represented at Council. The reduced Council membership reflects the business model for a board overseeing the hiring of a CEO (Registrar) and directing the overall strategy and output of the Council. This will require a very significant increase in the number of staff. One of the main strengths of the present membership is that the Dental Council has an in-depth knowledge of the profession at all levels due to representation of general practitioners, specialists and other members of the dental team. The proposed reduction in number could challenge the Council’s effectiveness and consistency. There Page |7 is no evidence to indicate a lack of transparency, objectivity and accountability in the functions of the present Dental Council. The Dental Council would advise that regulatory impact analysis specifically assess the necessity and effectiveness of the proposed changes in light of the Council’s day-to-day workload and international best practice. Regulation/Inspection of dental practices: The Dental Council is strongly of the view that, in addition to the regulation of practitioners, the places where dentistry is practiced should be subject to regulation. Therefore, the Dental Council welcomes the provision made in ‘Summary of Policy Issues for inclusion in the new Dental Bill’ that “the new legislation will provide for the regulation and inspection of dental practices/premises. It will also provide that regulation and inspection powers will be held by the Dental Council”. The provisions concerning the registration and regulation of practitioners are well established and the Dental Council’s proposals would strengthen the current environment. The Council is seeking provisions that would allow it to establish and maintain a register of dental premises (see “Corporate Dentistry” below). Having a strong inspectorate is the cornerstone of the effective regulation of dental premises. The Dental Council is mindful of the report of the Implementation Steering Group (Commission on Safety and Quality Assurance) on Building a Culture of Patient Safety, July 2008 and the recommendations therein. The Council is in agreement that the licensing of public and private dental facilities should be mandatory and that the issuing of licences should be based on ‘stated standards enforceable through inspection and the imposition of sanctions if necessary’. Furthermore, the Dental Council believes that these standards while being ‘transparent and fair’ must also be balanced and evidencebased to allow a level of engagement that will lead to improved patient safety and quality of service. The Dental Council believes it is best positioned to oversee the registration and inspection process because of the expertise it has developed over years of regulating dental practitioners. Legally and administratively it makes sense for one body to regulate both dental practitioners and dental practices, and for that body to have an inspectorate. The Dental Council has the ability to ensure effective, proportional and transparent administration of a registration and inspection system for regulating dental premises. It has the ability to assess new regulations and to advise and be accountable to the Minister. Most importantly, it is probable that serious breaches of regulations concerning dental premises will also uncover matters which may form the grounds of a complaint against one or more dental healthcare professionals. In order to deal with such matters expeditiously it is necessary to have both regulatory functions under the direction of one organisation. Page |8 An added benefit is that there is an opportunity to minimise the regulatory impact and cost to dental practices (the costs of which would ultimately be passed on to patients) by vesting responsibility for both regulatory functions in one entity. The new Dental Act should provide for the Dental Council to carry out inspections with and/or on behalf of other organisations and these could encompass inspections regarding radiology, clinical waste management etc. There are models in healthcare regulation already that could be adapted for inclusion in the new Dental Act. The framework set out in the Pharmacy Act, 2007 allows the Pharmaceutical Society of Ireland (PSI) to register and inspect pharmacies as well as to statutorily regulate retail pharmacy businesses. The provisions set out in the Food Safety Authority of Ireland Act, 1998 allow the Food Safety Authority (FSAI) to issue improvement notices and orders, and in extreme cases, to close a premises down on the authority of an individual nominated by the FSAI. The Dental Council would wish to see the new Dental Act contain provisions giving it the power to enter and inspect a dental practice (or a place where it is reasonably suspected that dentistry is being practiced) similar to Sections 18 and 66-71 of the Pharmacy Act, 2007. The power to enter a place where it is reasonably suspected that dentistry is being practiced is essential to the ability of an inspectorate to investigate reports of illegal practice, including the illegal provision of dentures directly to the public. The Council would seek these provisions to be supplemented with provisions similar to Section 52 and 53 of the Food Safety Authority of Ireland Act, 1998 that will allow an inspector to issue an improvement notice and/or order and, in the case of a serious breach, for a premises to be closed on the authorisation of the Registrar or individual nominated by the Dental Council. These powers are in addition to the provisions sought under Fitness to Practise requirements regarding allegations against registered dental premises. Corporate Dentistry - limited companies and partnership: The Dental Council is of the view that both the dental practitioner and the dental premises should be registered with the Council, and that the entity registering a dental premises must be accountable to the Dental Council for ensuring compliance with the new Dental Act, both with statutory rules and compliance with statutory codes of practices. The provisions sought are similar to the provisions governing the regulation of retail pharmacies set out in the Pharmacy Act, 2007. The business of dentistry has changed significantly over the last 30 years and has seen the introduction of corporate chains of practices and the development of larger practices with many practitioners. The Dental Council is of the view that registered dental premises need not be owned or controlled by dentist(s), but they must be regulated. The Dental Council has considered this matter from a public interest perspective and considered the legislation and experience of regulating businesses in Page |9 the Irish healthcare sector. It also had an overview of experiences in other jurisdictions with dental bodies corporate. Registration of Dental Premises: It is the Dental Council’s view that the appropriate way to regulate is to provide for any persons/partnerships/bodies corporate controlling a dental premises (this includes clinical dental technicians premises and potentially independent dental hygienist premises) to register the premises on a register maintained by the Dental Council. The registering entity should be responsible for compliance with the legislative provisions of the new Dental Act and any regulations made under this Act (including the improvement notices/orders issued following an inspection). The Act should provide that the controlling entity may be subject to either Fitness to Practise proceedings or prosecution under the Act. This is similar to the provisions under the Pharmacy Act, 2007 governing the regulation of retail pharmacy. The Act should also provide that where a partnership/body corporate is convicted of an offence under the new Dental Act or where there is a finding following a Fitness to Practise inquiry in relation to the registered dental premises, every director and manager of the body shall, unless he/she proves that the offence was committed without his/her knowledge, be guilty of the offence. Regulation of Registered Dental Premises: The Council seeks a statutory provision to make codes of conduct and codes of practice for registered practitioners and registered practices, as well as issuing guidance to the public. These provisions should allow for the renewal of a registration of practices on a periodic basis, inspections and to set out a procedure for the erasure and closure of the practice for failure to pay the renewal fee or where a corporate entity is wound up. The Council would envisage that the statutory code of practice for registered dental premises would be based on stated standards centred on patient safety, a governance framework which promotes accountability, clinical audit, risk management and adverse event reporting. The Council would envisage that the statutory code could, inter alia, include: an obligation to register the premises where any dental healthcare professionals practise; a requirement to have a named, registered dentist nominated as principal dentist in each registered dental premises; an equivalent requirement in each location where allied dental health professionals practice independently (e.g. clinical dental technicians and possibly dental hygienists in the future); an obligation on the named principal to ensure that Dental Council codes of conduct and practice are implemented practice wide (e.g. cross infection control, maintaining patient records, CPD etc.); P a g e | 10 display clearly the registration certification for all allied dental health professionals in the practice, the registration certificate for the dental premises and the name of the principal registrant; an obligation to ensure that staff are properly registered; an obligation to ensure that registrants have appropriate professional indemnity; a requirement that where there are two or more premises controlled by an entity (person/registered company/partnership) that the entity nominate a dental superintendent who is a registered dentist with a minimum of 3 years, full time postregistration experience; the business name of a registered dental premises or dental business shall not violate any Dental Council code of practice. Principal Dentists and Registered Owner Representatives in dental practices: The Dental Council welcomes the provision made in ‘Summary of Policy Issues for inclusion in the new Dental Bill’ that “the new legislation will provide for the appointment of Principal Dentists and Registered Owner Representatives in dental practices. This provision will also apply to any independent allied dental health practice established”. The Council seeks a provision to make it compulsory for the registering entity to appoint a “principal dentist” to each registered dental premises and for the Council to make rules concerning the experience and qualifications required to fill such a role. The Council would envisage that a principal dentist would have a minimum of three years post registration experience including a period of vocational training (see “Continuing Education” section) or a minimum of 5 years’ experience if the dentist has not undertaken a period of vocational training. Chains of Registered Dental Premises: The Council would seek to place an additional requirement on entities registering more than one dental premises to nominate a “dental superintendent” (with a similar post registration experience requirement to that of a principal dentist). It is envisage that this registrant would be responsible for compliance with legislation / regulations across all registered dental premises controlled by the registering entity. It is envisaged that this would be done by way of regulation. Prosecution of Offences: The Council recommends that the proposed new Dental Act allow the Council to take criminal prosecutions in a manner similar to the provisions under the Pharmacy Act, 2007 and the Food Safety Authority of Ireland Act, 1998. This will permit the Dental Council to address rogue practices in a cost-effective manner. P a g e | 11 Competition Authority Report The Competition Authority recommended in its report on dentistry that bodies corporate should be “explicitly” allowed to engage in the practice of dentistry (Recommendation 10, Dentists Executive Summary October 2007). The Dental Council is strongly of the view that individual practitioners should continue to be accountable to the Dental Council for their clinical practice and that corporate bodies should not be allowed to “practise” dentistry. The inspectorate provisions (see “Inspection Powers of the Dental Council” above) and the requested provisions to allow consideration of complaints against the entity registering a dental premises (see “Fitness to Practise” above) adequately balances the requirement to protect the public, a demand from some practitioners to be able to incorporate their dental businesses and the weakness in the current legislative framework. The Dental Council also submits that the provisions sought adequately addresses the concerns of the Competition Authority with the requirement to ensure patient safety. Staggered term of office (board appointments): It is the strong view of the Dental Council that corporate memory primarily rests with the staff of the Dental Council who have acquired an understanding of the day-to-day functions of any Dental Council and the relevant legislation. The Dental Council does not see any evidence to indicate that staggering the terms of the Council members will improve the effectiveness or consistency of the Council’s functions. There is a steep learning curve for all new Council members and the experience of this Dental Council is that late appointees to the Council are disadvantaged by their late arrival as the other Council members are familiar with their roles by that time. The work of Council has to slow to accommodate the newcomers or they struggle to understand the nuances of their new role, with a potential diminution of their contribution. The Dental Council would encourage a debate on the ideal length of term for Council. Continuing Professional Development for dentists and allied dental health professionals: The Dental Council welcomes the provision in the ‘Summary of Policy Issues for inclusion in the new Dental Bill’ that will require dentists and auxiliary dental workers to ‘maintain their own professional competence’ and ‘that the Dental Council can require them to demonstrate competence to its satisfaction in accordance with a professional competence scheme’, but questions how it is possible to do this when the proposals will effectively de-regulate most allied dental health professionals. Mandatory CPD only works if ultimately there is some potential for impact on a professional’s registration for non-compliance. If you have no register, how can you enforce a mandatory code of continuing professional development? P a g e | 12 In 2008 the Dental Council endorsed the principle of Continuing Professional Development (CPD) and advised all registered dentists of the Council’s desire to see mandatory professional development for all registered allied dental health professionals in a new Dental Act. On 1st July 2009 the Dental Council assumed responsibility for the continuing professional development of dentists in Ireland, following the dissolution of the Postgraduate Medical and Dental Board. The Council’s commitment to continuing education is underpinned by its Professional Behaviour and Ethical Conduct Code of Practice (2012) as well as and its Scope of Practice guideline (2014). In April 2015, The Dental Council updated and published a voluntary scheme for dentists, which set out CPD targets that should be achieved over a 5-year period with designated core competencies (http://www.dentalcouncil.ie/competence-cpd.php). In establishing this scheme, the Council’s aim is to encourage each member of the profession to consider the development of their own skills and knowledge and to encourage them into a formal recording process, in preparation for the introduction of mandatory CPD. The core competencies acknowledge the primacy of patient safety. It is the Council’s intention that all registered allied dental health professionals will be accountable to the Council with regard to continuing competence. The Act should allow the Council or the delegated competence scheme to refer issues concerning noncompliance to the Preliminary Proceedings Committee under the Fitness to Practise provisions of the new Act. Foundation (Vocational) Training: The Dental Council is very disappointed that Foundation (Vocational) Training is absent from the ‘Summary of Policy Issues for inclusion in the new Dental Bill’. The Dental Council would aspire to the introduction of a mandatory Foundation Training scheme as it considers it not only an elemental part of continuing professional development but also an essential part of the development of any young dental professional, from a novice to a competent professional in the mentored environment of independent practice. Foundation Training is a period of training following initial qualification and registration that builds on the achievements in the undergraduate curriculum and aims to produce a competent, caring, reflective practitioner. It should enable the practitioner to demonstrate a level of competence necessary for independent practice. This is generally achieved through treating patients under supervision and taking part in structured and unstructured clinical review and learning. A voluntary Foundation Training scheme was established in Ireland in 1999 under the aegis of the Postgraduate Medical and Dental Board. The scheme was initially a 5-year pilot scheme when launched and it flourished until, regrettably, it was wound down in 2011. The Foundation Training scheme in the UK is now mandatory for those working for the NHS, although there are regional variations in how it is run. In Scotland, for example, there is provision for the trainees to fail the programme and be obliged to undertake further retraining. P a g e | 13 The Dental Council acknowledges that the current economic climate would make the introduction of a scheme challenging in the short term. The Council would wish to have a provision in the new Dental Act that would allow for the introduction of such a scheme by way of statutory rule. Full consideration may be given at the point as to how the scheme would fit in with the statutory CPD scheme. The Council would envisage that Foundation Training would be: post registration in the register of dentists of 12-24 months duration take place in both private and public dental environment under the aegis of the Dental Council The Scottish model should be examined as a possible template for a new scheme. Indemnity: Additionally, The Dental Council is concerned that professional indemnity is not addressed in the ‘Summary of Policy Issues for inclusion in the new Dental Bill’; professional indemnity is an indispensable element of patient protection. The current Professional Behaviour and Ethical Conduct Code of Practice states unequivocally that “a dentist shall hold appropriate professional indemnity cover.” The Dental Council is of the view that any registered member of the allied dental health professionals team who can perform intra-oral procedures for his/her patients must have appropriate professional indemnity cover. The Council is of the view the new Act should allow the Council make regulations in relation to indemnity which would include, at a minimum, a stipulation that practitioners are required to confirm on an annual basis (as part of the annual retention fee process) that they have appropriate indemnity.