The GDC’s updated response to COVID-19: providing treatment in uncertain times
This note updates and clarifies GDC guidance in three areas:
- Dental professionals working in non-dental setting
- Remote advice and prescribing
- Treatment in dental primary care settings
In all these areas, the GDC has no interest in second guessing clinical judgements which take account of this guidance and are based on an appropriate assessment of the risks involved.
Dental professionals working in non-dental settings:
The NHS is increasingly asking dental professionals to be ready to support the wider COVID-19 response by using their professional skills and experience outside the normal range of dental and oral health activities. As a regulator, we want to support that activity and our registrants taking part in it, while of course keeping to the fundamental need to do so in ways which support patient safety.
When a dental professional is providing support to the wider NHS, the same basic principles apply as in any other situation: the test is whether they are trained, competent and indemnified for the tasks they undertake.
There are many tasks in the wider health service which can be performed by dental professionals drawing on their existing professional skills and experience. Registrants should satisfy themselves that they are competent to perform the tasks being asked of them or are given the training necessary to equip them to do so. We understand that the health services are preparing guidance on the mapping between dental skills and wider medical tasks, which registrants will want to take into account.
We expect registrants to make a considered judgement about whether they are trained and competent; we do not expect them to limit themselves to the specific activities set out in their scope of practice. That doesn’t make scope of practice irrelevant: it will be a useful starting point for considering what wider tasks are appropriate, but it does not in itself constrain dental professionals’ ability to support the COVID-19 response.
Indemnity should not be an issue where support of this kind is being provided to the NHS, since the Coronavirus Act provides cover for any liabilities beyond the scope of existing cover. We understand that some indemnifiers may choose to offer extended cover; registrants should ensure that they check with their indemnity provider and, if appropriate, with the relevant NHS authority that coverage is in place by one route or the other.
Remote advice and prescribing:
Where patients cannot come to a dental surgery, dental professionals may be asked to provide advice remotely and to work with patients to defer the need for active treatment through the use of pain control and antimicrobial treatment. The basic principles of our guidance on remote consultation and prescribing continue to apply, but in the specific circumstances of COVID-19, the key requirement is to make an appropriate risk assessment. That risk assessment should be recorded and should take into account the infection risk of COVID-19, both from and to the patient, as well the apparent seriousness of the need for treatment and the extent to which it has been possible to make a clinical assessment. Where appropriate, it should also take account of NHS guidance on treatment which should and should not be offered in a primary care setting.
Treatment in dental primary care settings:
For the duration of the COVID-19 epidemic, infection control is of paramount importance and even greater than normal care will need to be taken to minimise the risk of infection to, from, or between patients and between members of the dental team. In many cases, the right approach will be to stop providing treatment altogether.
Practitioners providing NHS services will of course need to adhere to the directions given by their nation’s Chief Dental Officer; other practitioners will want to take that into account in making decisions. From a regulatory perspective, the central question is again whether an appropriate risk assessment has been made. If treatment is offered, it will be important to record the specific precautions in place to ensure that the risk is appropriately managed for the particular treatment envisaged.