Can an Overseas Registered Dentist really register as a Dental Care Professional Automatically?
There has been some concern across the profession that overseas dentists are registering as Dental Care Professionals with limited scrutiny from the GDC. In this article, we consider the requirements for registering as a Dental Care Professional (DCP) and whether the General Dental Council’s (GDC) application process is sufficient to protect practices and the public from those not qualified to practice?
It is correct that those who have obtained a BDS degree from overseas can apply for individual assessment with the GDC to register as DCP in the UK. However, dental Organisations have been calling for the GDC to suspend this route to registration over concerns that it lacks a practical assessment.
The British Association of Dental Therapists (BADT) and the Society of Dental Hygiene and Therapy (BSDHT) issued a joint statement in August 2020. The letter stated that there had been a 300% increase in registrations through this route since 2017. While overseas dentists who wish to practice in the UK as dentists have to take the Overseas Registration Examination (ORE) or the Licentiate in Dental Surgery (LDS), which includes a practical assessment within Part 2, there is no such equivalent for the DCP route. The GDC’s figures show that in January 2020, 50% of ORE candidates failed the practical element of the exam. According to GDPUK, an ORE examiner voiced their concern in July 2020 on Twitter, saying:
“I can tell you many of the individuals coming through are shockingly poor. And many of those that pass have been ‘prepped’ well for the exam but will clearly not survive in practice. Fast-tracking straight to Therapy could/will be disastrous!”
It appears the GDC intervened, and the remark was subsequently removed. Nonetheless, Dental professionals are concerned that those candidates can potentially qualify as DCP without any practical examination, voicing concerns about patient safety and professional standards.
These registrations are facilitated by section 36c of the Dentist Act 1984. Notably, however, the same section highlights the GDC’s prerogative to impose further examination on candidates. Furthermore, while the GDC maintains that its assessment process is “robust” and carried out by a three-person panel, the skill set and experience required to sit on that panel remains unclear. According to GDPUK, the Chief Dental Officer declined to comment, as the issue was outside her remit.
However, it is essential to note that the s36c route is complex and by no means easy.
At JFH Law, we have assisted a number of overseas dentists with these applications and can confirm that a significant amount of information is required and scrutinised.
Initial application form
Firstly, applicants need to request and complete the initial pro-forma document from the GDC. The GDC will review the information submitted and the appropriate application form sent within ten working days.
Depending on the kind of application, 4-5 forms will be sent to applicants. The main obstacle is the Learning Outcomes Form. Applicants need to provide their complete University syllabus or curriculum. The applicant must show that the necessary learning outcomes are appropriately evidenced, and the relevant CPD added. There can be no gaps in training, and unless the form is completed correctly, the GDC will likely reject the application. Often, further evidence and references from the university need to be obtained.
- Application Form (including a Character Reference Form)
- Learning Outcomes Form
- Certified copy of BDS or Dental qualification certificate
- Certified copy of the Syllabus / Curriculum from the university or college
- Certified copy of the transcript or mark-sheets for course
- Certificates/ evidence of relevant training courses and CPD
- Evidence of English Language proficiency
- References from employers referring to experience and knowledge as a dental care professional
- Evidence of any relevant postgraduate qualifications (if applicable)
- Certified copy of valid passport
- Passport sized photograph that has been signed on the back by character referee
- Certificate of current professional standing (certificate of good standing)
- Translations of documents which are not issued in English
- One photocopy of the whole application
In addition to the above, up until 31st December 2020, overseas qualified dentists were able to apply for registration through the “exempt person“ route, relying on their own or a family member’s status as an EU citizen to have their application assessed on the same criteria as a UK applicant. This was an individual assessment route that did not require applicants to take the ORE and therefore did not require them to undertake a practical assessment. Whilst this application route also had no practical assessment, there seems to have been little to no criticism of this route to registration as a dentist. This might be because the exempt person route was a highly complex one, requiring detailed knowledge of the legal framework to enable applicants to demonstrate that they were exempt. This route to registration had very little advertisement and therefore was largely missed by many overseas practitioners.
The issue regarding the s36c route is the significant increase in successful registrations, primarily fuelled by agencies actively recruiting applicants, apparently based on the BADT/BSDHT statement referenced above. The GDC changed its procedure for registrations in 2017 following the outcome of several registration appeals. However, according to the website GDPUK, a request to see legal advice relied upon by the GDC at the time was refused. It remains to be seen whether the GDC is looking to investigate their current application process in light of the concerns raised or plan to exercise their examination power under the Dentist Act. While the exempt person route has fallen away due to Brexit, as it stands, the s36c route remains.
Please note that the information contained in this article was correct at the time of writing. There may have been updates to the law since the article was written which may affect the information and advice given therein.