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To First Minister of Scotland - Nicola Sturgeon and Joe FitzPatrick - MSP

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NHS Dentistry will collapse completely if we don't do something

Petition text

cc: Ms Nicola Sturgeon, First Minister, FirstMinister@gov.scot
cc: Mr Joe FitzPatrick, MSP, joe.fitzpatrick.msp@parliament.scot
cc: Mr Tom Ferris, SCDO, tom.ferris@gov.scot
cc: Mr Dave McColl, SDPC Chairman, d.mccoll@btinternet.com

19 June 2020

Dear First Minister,

I refer to the meeting of The Scottish Parliament that was held yesterday 19 June and your comments relating to the reopening of dental practices in Scotland.

It was expected that the Scottish Government would announce a transition from Phase 1 to Phase 2 as per the route map you have enforced. In the meeting of The Scottish Parliament you made some statements which will require clarity for the profession and indeed the public.

We as the dental profession have encountered poor communication and guidance with and from the Scottish Chief Dental Officer [SCDO], Tom Ferris and a degree of intransigence to engage.

Dental practices have been closed for thirteen weeks if we are to reopen on 22 June. The restrictions on clinical practice, namely the cap on patient numbers, shows a fundamental lack of understanding of the General Dental Practice business model. This amply demonstrates to everyone the Scottish Government’s chronic underfunding and reduced opinion of National Health Service (NHS) Dentistry in Scotland. As a profession we are an essential public health service that has been summarily dismissed. With little to no public sympathy, the dental profession is starting to become apathetic as morale deteriorates further.

During the meeting yesterday it was announced that:

“Dentists will be able to reopen from Monday, initially for urgent care.”

The Scottish Dental Practice Committee [SDPC] met with Scottish Government on 17 June [the day before the Scottish Parliament Meeting] to hold negotiations. Whilst we knew the remobilisation of NHS dental services would resume in Phase 2, it shows lack of professional courtesy and organisation to fail to inform dental practices in advance of the start date. This represents a disappointing level of engagement with the dental profession. For nearly thirteen weeks dental practices have been triaging all patients and referring them to Urgent Dental Care Centres (UDCCs) where there has been a patent lack of consistency regarding the clinical care between local health boards.

Forewarning the date of reopening would have enabled dental practices to schedule email, text alerts and social media posts to stem the tidal wave of enquiries we are going to receive. What you [meaning both you, the First Minister and SCDO] do not know is the volume of patients that have been managing and controlling odontogenic pain and infection for over three months because they don’t want to lose a tooth. These are potentially life-threatening conditions brought about by the waiving of antimicrobial stewardship with the increased risk of antimicrobial anaphylaxis and resistance. With further delay and inefficiency of urgent dental treatment there is a genuine risk of cellulitis, abscesses, sepsis and delayed diagnosis of oral cancers. The foregoing coupled with the neglect of paediatric dental care needs and the impact of postponement of child general anaesthetic services is unacceptable.

The route map created to guide us out of this global pandemic, whilst clear from you was further confused and contradicted by the SCDO’s plan that included 2(a) and 2(b) Phases. This plan lacked fundamental detail and I was disappointed with the additional guidance produced by the Scottish Dental Clinical Effectiveness Programme [SDCEP] COVID-19 Practice Recovery. This document combined with the remobilisation plan from the SCDO lacked evidence or even common sense. The communication and engagement level has been unsatisfactory from the SCDO. On reviewing the effectiveness of the SCDO and their management and performance during this crisis, I have made some notes below.

Under a Freedom of Information Act 2000 (FOIA) request the job description for the SCDO and was published on 18 June 2020. Essential criteria for the role of SCDO are:

a) Credibility. There is a failure on this criterion on the following grounds
o The confusion over the mixed NHS and non-NHS regulation.
o Unilateral and patently illegal withdrawal of our CPDA/Audit allowances which were subsequently re-instated.

b) Up to date. There is a failure on this criterion on the following grounds
o Does not cite evidence base or any justification.

c) Inspiring. There is a failure on this criterion on the following grounds
o The intransigence and poorly conceived plan do not incite much inspiration.

d) Empowering. There is a failure on this criterion on the following grounds
o Threatening police and GDC referrals do not encourage anyone.

e) Adaptive and Collaborative. There is a failure on this criterion on the following grounds
o Reviewing the communications from the SCDO and the stagnant negotiations with the SDPC shows lack of adaptability.
o Abundantly clear he does not collaborate with the profession at all.

f) Engaged and engaging. There is a failure on this criterion on the following grounds
o As demonstrated above, failure to engage.

The question was put to you [meaning the First Minister] by Miles Briggs MSP (Lothian) that the statement made by you on 18 June 2020 lacked any detail on the full restoration of dental services and that dentists feel there is a lack of transparency to which your reply was:

“I do not think that that is a fair characterisation. The chief dental officer has been working closely with the dental profession. The plan that he put together was subsequently shared among many other countries by the WHO, because it was seen as being a high-quality piece of work.

For obvious reasons, in the past few weeks dentists have been considered to be at high risk of transmitting the virus, but we are now able to move forward—thanks, in large part, to the work that the chief dental officer and the profession have been doing. Practices will be able to reopen on Monday—initially for urgent care, but we hope that they will be able to get back to normal soon afterwards. I know that, although they might not relish a visit to the dentist, many people will have plans to catch up on treatment that they have missed. Dentists will work hard to achieve that and, as they always do, they will have support from the Scottish Government to the extent that they need it in the weeks ahead.”

For clarification Miles Briggs’s observation is an entirely fair characterisation of the current situation. As a member of the dental profession and community I can assure you that the SCDO has not been working closely with the dental profession. The SCDO communicates via Twitter infrequently and has not engaged with me or replied to any of my correspondence. And in what context has the WHO shared your plan, [referenced by you subjectively ‘as a high-quality piece of work’]? Was this as an example of how to remobilise public dental services? To my knowledge we are one of the few countries to adopt a total risk avoidance strategy when it comes to primary dental care. Another example: it seems as though we [meaning the UK] are the only country that requires face fit testing for enhanced Personal Protective Equipment [PPE].

Please clarify your statement and provide evidence that “dentists” have been considered high risk of transmitting the virus. Firstly, the dentist is a person, I think it should be made clear you mean the dental environment from an aerosol perspective. Secondly this is a sweeping generalisation that is counterproductive when we should be advocating the public to attend dental practice regularly to maintain the oral and dental health rather creating fear. We are particularly sensitive to the misuse of “dentists” in that context because on a regular basis patient’s visit us and say, “I hate the dentist”. This insensitivity was echoed by your further comments that the public might not “relish” a visit to see us despite having thirteen weeks of cumulative dental pain and infection or the indignity and despair of having lost a tooth that could otherwise have been easily treated.

As I mentioned earlier the intransigence of the Scottish Government and the SCDO has made it clear to the dental profession that there is not any “forthcoming support” like you say. The SCDO has said the funding for the Phase 2 is “adequate”. The PPE supplied by the Scottish Government is basic at best and our routine minimum standard. They have provided single use PPE to be used on up to ten patients per day which is not enough to:

a) satisfy the urgent clinical needs of our patients and
b) to survive financially as a viable business.

Additionally, not enough PPE is being provided beyond two weeks’ worth, with some health boards advocating reuse.

Another area of contention surrounds the regulatory aspect of NHS and non-NHS [meaning independent and private] dentistry in Scotland. The SCDO does not have any regulatory remit over non-NHS Dentistry in Scotland and neither do the local health boards to their embarrassment. The local health boards had to seek advice from the Central Legal Office [CLO]. I sought further clarity from my health boards’ Chief of Dentistry [CoD] and the CLO who clarified that there is no remit. It was also said that whilst they have no regulatory powers they can report us to the Police under a violation of the “Health Protection (Coronavirus) (Restrictions) (Scotland) Regulations 2020, dental services can take place but that this does not automatically override the requirement to take all reasonable measures to maintain a 2m distance (Reg 4(1)(a))”.

And that they can report us to the General Dental Council [GDC] for any actions they deem to be putting patients at risk. There is absolutely no doubt that the passive-aggressive rhetoric and the underlying tone of the message is threatening. It is widely known and accepted that our regulator [based in England] is:

a) expensive,
b) overbearing and
c) heavy handed.

Referral to the GDC is literally a dentist’s worst nightmare.

To summarise.
a) A “mandatory” thirteen-week dental practice business closure under the SCDO’s instruction was later found to be inaccurate

b) A sustainability package that is limited and only sustains predominantly NHS majority practices.

c) A Phased return to dentistry that does not support most dental practices which will lead to financial hardship or bankruptcy and closure of NHS practices.

d) No financial support for dental practices from local council or Her Majesties Revenue and Customs [no grants, no rates relief]

e) No support for self-employed practitioners just over the Chancellor’s £50,000 threshold.
a. Please explain to me how one can qualify for SEISS if they earn £49,999 [average 16/17, 17/18, 18/19] but if they earn £50,001 then then can survive on your own for over three months with no income?

f) SCDO has been ineffective in communicate and engaging with the profession. I believe the job description for the office is to be a respected and professional leader. I have attempted to engage via Twitter, email, and open letters to Tom Ferris to no avail.

So far, the SCDO and the Scottish Government have not accepted or acknowledged that extreme deterioration of Scottish dental and oral public health needs. The demand for urgent dental treatment now and for the foreseeable future will be extraordinarily high, delivered slowly and ineffectively. The UDCCs were not suitable to cope with capacity or to satisfy the variety of urgent treatment needs of the public. Mandatory nominated dentists as required to work in the UDCCs whilst their [dentists, technicians, therapists, hygienists, nurses, assistants, receptionists, managers] livelihoods and businesses are on the brink of financial ruin.

During a pandemic and whilst trying to avoid person to person transmission of a contagious virus, could you [First Minster or SCDO] please explain the rationale and why it was advisable for large hubs to be commissioned at additional cost, time, resources, administration rather than small local dental practices?

If it is of the view that no more can be done to support the provision of NHS Dentistry in Scotland, then it would be wise for the Scottish Government to admit that. Otherwise appropriate funding is required and required now. Further protracted delays will force dental practices to make the decision to withdraw NHS dental services and act in our patient’s best interest.

I would sincerely be grateful for the courtesy of a response to my concerns and further support for our profession.

Yours sincerely,

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The Scottish Government's Abandonment of NHS Dentistry

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