Briefing on the new GDC Standards
The GDC has released the new Standards for the Dental team with supporting guidance, which all registrants must follow. This Briefing is the first overview for members, as a brief guide with some initial actions to take, whilst the ramifications of the new Standards are fully explored and CODE Modules and iCOMPLY are updated. It is necessary to read this Briefing in conjunction with the GDC Standards and guidance. This Briefing is designed to help you to prioritise your actions to comply with the new Standards.
CODE Advice and support for members
As with all new regulations, the interpretation and understanding of the new Standards will unfold as experts investigate them and they are tried and tested in practice and at the GDC. CODE will continue to update its guidance as this experience becomes available. The latest version will be uploaded on the CODE website and posted to you and it will supersede any previous guidance. As a dental professional you will need to apply your own professional judgement to any particular circumstance and take advice from your indemnity provider where necessary.
- The Standards and guidance are being analysed by experts in order to incorporate them into the CODE Management System
- The CODE Modules (templates) will be updated to adopt the new Standards, updated modules will be released in the coming months
- New Modules, policies and procedures will be created as necessary and released to members in the coming months
- iCOMPLY will be modified with new activities to meet the Standards and to incorporate the new and revised Modules
- The iCOMPLY Application will be updated to automatically schedule the GDC compliance activities on the online calendar
- CODE will continue to review guidance and update the modules and iCOMPLY as understanding deepens or the Standards are modified
Standard 1.9 says:
You must find out about, and follow, laws and regulations affecting your work. This includes, but is not limited those relating to:
- Data protection
- Human rights and equality
- Registration with other regulatory bodies
CODE continues to provide you with policies, procedures and activities to meet the laws and regulations in dentistry and you are reminded to carry out the necessary compliance activities with iCOMPLY.
The old ‘Standards for Dental Professionals’The previous GDC ‘Standards for dental professionals’ and its supplementary guidance booklets are no longer in effect, you can see a list of the archived guidance documents in the Appendix to this Briefing. Even though the previous Standards are no longer in effect, any fitness to practise complaints received where the conduct took place before 30 September 2013, will be judged against the previous Standards and guidance.
Download the new Standards for the Dental Team
The Standards were released by the GDC on September 30th 2013 and currently consist of the following documents:
Plus there is a new CPD guide:
The Standards are based on 9 principles:
- Put patients’ interests first
- Communicate effectively with patients
- Obtain valid consent
- Maintain and protect patients’ information
- Have a clear and effective complaints procedure
- Work with colleagues in a way that is in patients’ best interests
- Maintain, develop and work within our professional knowledge and skills
- Raise concerns if patients are at risk
- Make sure our personal behaviour maintains confidence in us and the dental profession
Important aspects for you to consider
Displaying information – set this up now
In addition to NHS requirements, the new Standards include the requirements to display the following information clearly in an area where it can be seen easily by patients:
Note that simple price lists should also be in practice literature and on your website and the complaints procedure in your practice brochure or in a separate leaflet. Standard 5.3.1 says “you should give the patient a copy of the complaints procedure when you acknowledge their complaint so that they understand the stages involved and the timescales”. This requirement will be added to the updated CODE Complaints Procedure (G 110) in its next issue.
- The fact that you are regulated by the GDC; and the nine principles contained within Standards for the Dental Team. You can to create your own poster displaying this information, or you can download one of these:
- The details of all registered staff working at the practice, including names, job titles and GDC numbers
- Your complaints procedure so that patients do not have to ask to see it
- A simple price list, patients should not have to ask for this information. This should include a list of basic items including a consultation, a single-surface filling, an extraction, radiographs (bitewing or pan-oral) and treatment provided by the hygienist. For items which may vary in cost, a ‘from - to’ price range can be shown (such as crowns)
Consent has changed from Informed consent to valid consent. Whereas informed consent means being given information, valid consent is defined by NHS choices as “it must be voluntary and informed, and the person consenting must have the capacity to make the decision”. The Standards provide detailed guidance on valid consent in Standard 3.1.3:
You should find out what your patients want to know as well as what you think they need to know. Things that patients might want to know include:
Valid consent is defined as on going process, not a signature on a form, that the patient must have the mental capacity to make the decision and that the information provided was appropriate for the patient and has been understood. It is important to understand the new consent requirements and the need to comply with the Mental Capacity Act (M 289).
- Options for treatment
- The risks and the potential benefit
- Why you think a particular treatment is necessary and appropriate for them
- The consequences, risks and benefits of the treatment you propose
- The likely prognosis
- Your recommended option
- The cost of the proposed treatment
- What might happen if the proposed treatment is not carried out
- Whether the treatment is guaranteed, and if so how long it is guaranteed for and any exclusions that apply
The necessity for detailed contemporaneous (made at the time of the treatment) record keeping is an important aspect of all of the new Standards and not only of Principle 4 – Maintain and Protect Patient information. For example recording the check of the medical history at every appointment, keeping detailed and contemporaneous records of on going consent and how it was reached, keeping written records of patient complaints (separate from the patient notes), keeping details if you assess the risk of providing treatment if you have to work without another appropriately trained member of the dental team and writing details about referrals and discussions you have with colleagues about a patient’s treatment.
Another aspect of record keeping is Information Governance. Principle 4.5 says “Keep patients’ information secure at all times, whether your records are held on paper or electronically”. The CODE Information Governance Kit includes the following Modules:
Information Governance Kit (M 217), IG Improvement Plan (M 217A), IG Policy (M 217B), IG Procedures (M 217C), IG Lead Job Description (M 217D), Staff Confidentiality Agreement (M 217E), Subcontractor’s Confidentiality Agreement (M 217F), Information Asset Log (M 217G), Mobile Equipment Log (M 217H), Mobile Equipment Terms and Conditions (M 217I), Compliance Monitoring Form (M 217K), Computer and Software Access Log (M 217L), Security Risk Assessment (M 217M), Business Impact Analysis (M 217N), Patient Leaflet on Personal Information (M 217P), Sensitive Information Map and Risk Assessment (M 217Q).
Whilst these modules were primarily created for NHS practices to meet the requirements of the online IG Toolkit Assessment, they are now important for compliance with the GDC standards. Consider following guidance in Information Governance Kit (M 217) and implementing IG Improvement Plan
(M 217A). Please note that there will be some modifications when the GDC Standards are fully explored and in particular when there is more information about encrypting electronic information and sending information using a secure method (Standard 4.5). Updated sections will be highlighted in red text so that members will be able to incorporate them later.
Principle 6: Working with colleagues in a way that is in the patients’ best interests
Below are the CODE Module references for part of Principle 6; any forthcoming updates within the modules will be in red.
6.6.1 All team members including those not registered with the GDC, should have:
- A proper induction when they first join the team (M 225)
- Performance management, including regular appraisals (M 226)
- Opportunities to learn and develop (M 223) and team meetings in iCOMPLY
- A hygienic and safe working environment (M 257), (M 250)
- A work environment that is not discriminatory (M 233 EQD) and (M 236)
- Opportunities to provide feedback iCOMPLY Staff Satisfaction (G 140) and team meetings
- A way to raise concerns (G 111) Whistleblowing and (M 233-WBP) Whistleblowing Policy