Changes to the General Dental Council and the Nursing and Midwifery Council's international registration legislation: government response
Updated 28 November 2022
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Executive summary
The Department of Health and Social Care (DHSC) consulted on proposed changes to the legislative framework governing the Nursing and Midwifery Council (NMC) and the General Dental Council (GDC) between 7 February and 6 May 2022.
The consultation document sought views on a number of changes which are intended to enable the GDC and the NMC to set out and change their processes for international registration more efficiently.
The department received 1,634 responses to the consultation from individuals and organisations, such as the UK health and care professional regulators, trade unions and professional bodies.
This document presents a summary of the views that were expressed and the response of the 4 UK health departments. As such, the 4 UK health departments will be referred to as ‘the government’ throughout the remainder of this report where collective responses or actions are referenced.
The changes will be made via a Section 60 Order which is a legislative vehicle used to amend legislation relating to regulated health professions.
The Order will amend the following legislation:
-
The General Dental Council (Overseas Registration Examination Regulations) Order of Council 2015 (the ‘2015 Order’)
The Order will also make consequential amendments to The Health Care and Associated Professions (Knowledge of English) Order 2015.
Registration of international dentists and dental care professionals
The government plans to take forward all of the proposals we consulted on to change the GDC’s legislative framework for registration of international dentists and dental care professionals (DCPs), as set out below:
- the GDC will have flexibility to apply a range of assessment options in determining whether international dentist and DCP applicants have the necessary knowledge, skills and experience for practice in the UK
- the requirement that an assessment for overseas dentists, such as the Overseas Registration Exam (ORE), must be provided by dental authorities, or a group of dental authorities, is removed
- registration routes for international dentists may include, but will not be limited to, recognition of overseas diplomas. This is distinct to mutual recognition of qualifications, whereby regulators may enter into regulator-to-regulator arrangements to recognise professional qualifications. The Professional Qualifications Act 2022 includes a regulation-making power to enable regulators to enter into Mutual Recognition Agreements (MRAs). Secondary legislation is required to give effect to that power and officials are currently considering how this legislation will be introduced
- the GDC will be able to charge fees for the purpose of meeting expenses incurred, or to be incurred, by the council in relation to international registration for dentists and DCPs. This will allow the GDC to cover the costs of recognising individual international qualifications which reflect UK standards. This may reduce the number of dentists required to sit an ‘ORE’ style assessment in future
- the GDC will be able to make rules to provide for the detail of its international registration processes for both dentists and DCPs, which will need to be consulted on, but will not require Privy Council approval. This will allow any necessary changes to be made in a timely and efficient manner
- the 2015 Order is revoked but its provisions will continue to apply until 12 months after the new Order comes into force. At this point the GDC will publish new rules on the detail of its international registration processes
- the saved provisions of the 2015 Order are amended to ensure that ORE candidates who were affected by the suspension of the exam due to the coronavirus (COVID-19) pandemic are provided with extra time to sit the exam
- the requirement in the GDC’s legislation that the overseas dentist assessment fee be contained within an Order approved by the Privy Council is removed, allowing the GDC to make fee changes more quickly
- the relevant qualification relied upon by an applicant to satisfy the registrar that they have the requisite knowledge, skills and experience to be registered under a particular title in the dental care professionals register can no longer be a diploma in dentistry. This change aligns international DCP registration requirements with requirements for DCPs registering with UK qualifications
Following the consultation, we have agreed with the GDC to make a minor amendment to the draft Order to allow the GDC to process DCP title applications received from internationally qualified dentists up until the day before the Order comes into force (currently planned for late 2022) and to deal with any resulting appeals and applications for restoration to the register from such registrants. This will mean that any dentist applicants with a ‘live’ DCP title application submitted before the legislation is passed are able to complete the registration process.
Registration of international nurses, midwives and nursing associates
The government plans to take forward all of the proposals we consulted on to change the NMC’s legislative framework for international registration, specifically:
- prescriptive detail on the process that the NMC must follow in relation to qualification comparability and the assessment of international applicants will be removed, providing the NMC with greater flexibility to change these processes in future
- the NMC’s international health and character declaration requirements will be required to clarify that separate declarations are required in support of both good health and good character and to specify what evidence of good character that applicants who are not currently registered with an overseas regulator must provide. The validity period of health declarations is also extended from 6 to 12 months. These changes will reduce unnecessary administrative delays in the application process
Next steps
We will continue to work with the regulatory bodies to understand what changes they plan to make following the introduction of the increased flexibility that the changes provide. In taking forward any changes to their international registration processes, the regulators will also need to have regard to commitments made within free trade agreements, such as commitments made in the EEA EFTA agreement on recognition of professional qualifications. At present we understand that:
- pending the agreement of its council, the GDC plans to publish draft rules for consultation on the future operation of the ORE which will enable it to increase the capacity of the assessment. The regulator will then introduce changes to the operation of the assessment after the 12 months during which the current legal framework will remain in place
- the GDC will be developing further proposals, using new flexibility arising from these changes to its legal framework, to make the routes to international registration as a dentist or DCP more effective while maintaining the necessary standards for public protection. All future proposals will be subject to approval from the GDC’s council and public consultation before they are implemented
- in addition, following the introduction of any future regulations under the Professional Qualifications Act, the GDC will be responding to any requirements for mutual recognition under UK trade deals, such as the EEA EFTA trade deal, and exploring if there are opportunities to enter into mutual recognition arrangements outside of trade deals where the public’s protection can be assured through comparable regulatory oversight of dental education
- the NMC will consider how the additional flexibility delivered by these changes can help it deliver an improved international registration process and will continue to look at ways to streamline its processes
Background
International joiners to the UK registers
International (including EU and EEA) staff make an important contribution to the delivery of healthcare in the UK and form a large proportion of joiners to the GDC and NMC registers. In 2021, 39% of new GDC dentist registrants qualified outside of the UK: 30% were either EU, European Economic Area (EEA) or Swiss-qualified, and 9% qualified in the rest of the world. In 2021 to 2022, 48% of joiners to the NMC’s register qualified outside of the UK: 1% were EU, EEA or Swiss-qualified and 47% qualified in the rest of the world.
At present, the GDC and NMC have different registration processes for international applicants for registration compared to UK-qualified applicants. Since the end of 2020, EU law relating to the recognition of EEA qualified healthcare professionals no longer applies in the UK. European qualifications in medicine, nursing, midwifery, pharmacy and dentistry will continue to be unilaterally recognised automatically under UK law, until the continued period of automatic recognition is ended. There is a regulatory duty on the Secretary of State for Health and Social Care to carry out a statutory review of these arrangements after a 24-month period and review will be conducted at the start of 2023. Automatic recognition of qualifications will continue unless and until further legislation is introduced to amend or end these arrangements.
The Professional Qualifications Act 2022 created a number of regulation-making powers designed to implement a new framework for the recognition of overseas professional qualifications in the UK replacing EU derived law. The Act applies to all regulated professions including health care professions. This includes a power to make regulations which can require specified regulators to have routes to consider applications from individuals with overseas gained qualifications or experience, which all of the healthcare regulators already have in place. Regulators will continue to be able to use their existing legislative powers to maintain and update international registration routes.
Trade deals with other countries also give opportunities to foster and improve international cooperation, and frameworks for how regulator-to-regulator recognition agreements might be agreed. In all trade negotiations, the government is keen to ensure regulator autonomy over UK standards, and decisions about who can practise a regulated profession. This includes ensuring patient safety by maintaining UK regulator autonomy over registration decisions for international applicants.
Proposed changes to the legislative framework
The government, on behalf of the 4 UK health departments, is in the process of reforming the legislative framework for the regulation of healthcare professionals. The existing UK model of regulation is rigid and complex and needs to be faster, fairer, more flexible and minimise its costs to registrants.
As part of the ongoing reforms to healthcare professional regulation, officials have identified prescriptive detail in both the Dentists Act 1984 and the Nursing and Midwifery Order 2001 which prevents the regulators from putting in place more flexible ways of assessing applicants’ knowledge, skills and experience. This may in turn deter safe and competent professionals from seeking registration to practise in the UK.
The government consulted on proposed changes which would:
- remove prescriptive detail from the GDC’s legislation on the operation of assessments for overseas registrants and the ways in which the GDC may assess whether international dentists meet its standards for registration
- provide the GDC with the ability to charge fees for the purpose of meeting expenses incurred, or to be incurred, by the Council in relation to international registration and to make rules on registration processes which will not require Privy Council approval
- revoke the 2015 Order, which sets out the ORE fee, structure and content, but save its provisions until 12 months after the new Order comes into force. At this point, the GDC will publish new rules on the detail of its international registration processes
- enable the NMC to explore alternative pathways to international registration alongside the test of competence, such as recognition of programmes of education delivered outside the UK, or registration based on recognition of the qualification held by an applicant, as it considers appropriate
- clarify the NMC’s requirements for good health and good character declarations provided by international applicants, as misinterpretation of these requirements can lead to confusion and unnecessary delays to the application process
The changes proposed by the draft legislation are consistent with the principles of the broader reform programme, in providing the GDC and the NMC with greater flexibility to amend international registration processes without the need for further legislative change.
Consultation process and overview
The consultation ran from 7 February to 6 May 2022 and was undertaken on behalf of the government with the agreement of all UK health ministers.
The department received 1,634 consultation responses from both individuals and on behalf of organisations. Responses were submitted online and by email.
Consultees were asked to respond to a total of 21 consultation questions, which are considered in detail in the sections below. All of the questions provided the opportunity for respondents to give a justification for their answer or provide additional information in a free text box. All free text responses were read by DHSC officials and grouped into discrete themes to give an indication of respondents’ views on the questions.
Of those who responded, almost 97% identified themselves as individuals with only 3% responding on behalf of an organisation. A detailed breakdown of how respondents identified themselves can be seen below.
Table 1: responses by type
| Category | Number of respondents | Percentage |
|---|---|---|
| Individuals | 1584 | 97% |
| Organisation | 48 | 3% |
| Unknown | 2 | 0.1% |
| Total | 1634 | 100% |
Table 2: type of healthcare professional
| Category | Number of respondents | Percentage |
|---|---|---|
| Dentist | 839 | 51% |
| Dental hygienist | 151 | 9% |
| Dental therapist | 136 | 8% |
| Dental technician | 5 | 0.3% |
| Dental nurse | 56 | 3% |
| Internationally qualified dental professional (where specified) | 13 | 0.8% |
| Registered nurse | 38 | 2% |
| Midwife | 5 | 0.3% |
| Other regulated healthcare professional | 36 | 2% |
| Other unregulated healthcare professional | 9 | 0.5% |
| Other | 4 | 0.2% |
| No response provided | 342 | 20% |
| Total | 1634 | 100% |
Table 3: respondents by geographical location
| Location | Number of respondents | Percentage |
|---|---|---|
| Category | 1584 | 97% |
| England | 1211 | 74% |
| Scotland | 66 | 4% |
| Wales | 31 | 2% |
| Northern Ireland | 13 | 0.8% |
| Outside the UK | 172 | 10% |
| Other | 6 | 0.4% |
| No response provided | 135 | 8% |
| Total | 1634 | 100% |
The remaining sections of this document mirror the order of the questions as they were asked in the consultation. In each section we have provided background to the question, set out response data and given a summary of comments made by respondents and a selection of quotes. A number of responses to questions included comments that did not directly relate to the question being asked and in these instances we have considered these points under the most relevant question.
International registration legislation
Question 1
Do you agree or disagree with the department’s aim of ensuring that the GDC and NMC have flexibility to amend their processes for assessing international applications, in order to support the development of processes which are proportionate and streamlined, while protecting public safety?
Background
Aspects of the current legislative requirements for registering international dentists make it difficult and time-consuming for the GDC to make changes to its registration processes. Similarly, excessive detail on the process that the NMC must follow to assess international applicants also makes it difficult for the regulator to explore alternative registration routes to its test of competence.
Ahead of the broader reform of the GDC and NMC’s legislation, the government proposes amending the legislative framework underpinning these regulators’ international registration route. These changes are intended to support the regulators to put in place more flexible ways of assessing applicants’ knowledge, skills and experience. They are also consistent with the principles of the broader reform programme, in providing the GDC and the NMC with greater flexibility to amend international registration processes without the need for further legislative change.
Table 4: summary of responses to question 1
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 807 | 49% |
| Disagree | 669 | 41% |
| Don’t know | 35 | 2% |
| Neither agree nor disagree | 110 | 7% |
| Unknown | 13 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
A significant number of respondents who both agreed and disagreed with the government’s aim commented on the importance of maintaining high registration standards to protect public safety, cautioning that any changes to processes should not reduce standards.
Of those who agreed with the proposals many highlighted that the current GDC process for registering international professionals is too rigid or difficult because of the lack of availability of ORE places, resulting in unfairness to candidates; and that greater flexibility for both regulators will benefit both the public and professionals by improving registration processes and increasing the supply of healthcare professionals available to work in the NHS.
Quote from respondent in favour of this proposal:
The dental profession is hugely important to the UK and by allowing greater flexibility to the current processes we have a better opportunity to attract the best talent from overseas to come and live and work in the UK, and enrich the sector.
A wide range of reasons were provided by respondents for disagreeing. In addition to concerns about public safety, these included:
This change may result in more stringent and difficult registration processes which are not a proportionate means of assessing overseas-qualified dentists as they are as competent and well trained as UK-trained dentists.
Current international registration processes are sufficient to guarantee public safety and should not be amended.
The government should maintain the same, or greater control, over how the regulators operate rather than provide them with greater flexibility.
Quotes from respondents who disagreed with the proposal:
The whole point of the NMC is supposed to be patient safety, that’s why I am charged £120 a year. Why should I have to pay for this, when new recruits to the UK will only have their competency tested in retrospect, if they have failed their patients. This is not safe and not sensible. Believe me I understand that everywhere is understaffed, but waiving safety measures is not the answer.
This will put extra burden on international dentists and lead to extra scrutiny during examinations which is unfair. Dentists pay a huge fee to the GDC to go through the registration process and this ‘flexibility’ will only make situation harder for registration.
Government response
The government notes that many respondents were concerned that providing greater flexibility to the GDC and NMC might result in either lower registration standards, potentially endangering patient safety or, conversely, the introduction of more challenging processes that are not proportionate or fair to candidates. The primary purpose of professional regulation is to protect patients and the public from harm by ensuring those providing healthcare are doing so safely. Our view is that it is for the regulators as independent bodies to set the standards that registrants must meet to demonstrate that they are capable of practising safely and effectively. The proposals will provide the regulators with greater flexibility to amend the methods they use to assess these standards and support the government’s aim of ensuring that future registration processes for all professionals qualified outside the UK are proportionate and streamlined.
We also consider that the current level of detail within the GDC’s and NMC’s legislation regarding international registration processes is out of line with the wider reform principles which aim to enable regulators to set out their operational processes in rules and guidance rather than having these set out in legislation. The proposed changes will support the regulators to adapt registration processes to meet the needs of different professions and different requirements over time, in a more timely and efficient manner than the current legislation allows.
GDC’s framework for registration of international dentists
Question 2
Do you agree or disagree with providing the GDC with flexibility to apply a range of assessment options in determining whether international dentist applicants have the necessary knowledge, skills and experience for practice in the UK?
Background
Most international dentists sit the overseas registration exam (ORE) to gain registration with the GDC. These proposals support greater flexibility for the GDC to use additional assessment options in deciding whether to register international dentist applicants. The GDC is exploring how best to use this increased flexibility to take forward 2 international registration routes:
- an assessment of an individual applicant’s qualifications, skills and training, to be evidenced by their completion of an ORE style assessment, without the present restrictions on the exam’s delivery
- registration based on recognition of the qualification held by an applicant, where the GDC has assessed that qualification and considers that it provides applicants with the required knowledge, skills and experience
Table 5: summary of responses to question 2
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 684 | 42% |
| Disagree | 848 | 52% |
| Don’t know | 22 | 1% |
| Neither agree nor disagree | 64 | 4% |
| Unknown | 16 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
42% of respondents agreed with providing the GDC with the flexibility to apply a range of assessment options. Key arguments related to the need to maintain patient safety and registration standards and the potential for more efficient registration routes to those currently available. Common points made included that:
- existing routes to registration are overly long, complex and expensive, making it very difficult for competent international dentists to join the GDC’s register. Respondents believed that alternative routes, such as qualification recognition, could be quicker for applicants and more efficient to operate
- greater flexibility was welcomed by some respondents only on the basis that any new assessment routes should not lead to a drop in registration standards
Just over half of respondents (52%) disagreed. Many of these respondents stated that providing the GDC with greater flexibility would lead to a more difficult registration process, or to increased and unnecessary red tape being introduced. Some commented that overseas dentists are as competent as UK graduates and that registration processes should not be made more difficult. In addition, some respondents felt that the current process for international registration works well and does not require improvement, or that only one registration route should be applied to all international dentists, such as the ORE.
Government response
The government notes that many respondents who both agreed and disagreed with this proposal commented on the relative ease or difficulty of the GDC’s existing registration processes. Some people agreed because they believed it would lead to less onerous registration processes, and others disagreed because they were concerned that registration processes might become more difficult and burdensome to navigate. As set out in our response to question 1, it is for the regulators as independent bodies to set the standards that registrants must meet to demonstrate that they are capable of practising safely and effectively, while having regard to commitments made within free trade agreements. The draft legislation is intended to remove prescriptive detail on the operation of assessments for overseas registrants to enable the GDC, as the independent regulator, to decide how best to use this flexibility. We therefore plan to take forward the implementation of the changes which will support increased flexibility for the GDC to develop more proportionate and streamlined processes, as it considers appropriate.
The government and the GDC also recognise the frustration of those ORE candidates who have struggled to gain a place on the exam. The introduction of alternative registration routes, such as quality assurance of international education and training in addition to or in place of an assessment of an applicant, could reduce the time it takes for applicants to register and the burden of the application process on applicants.
Question 3
Do you agree or disagree with removing the requirement that Overseas Registration Exams or other assessments are held by a dental authority or a group of dental authorities from the GDC’s legislation?
Background
The Dentists Act 1984 requires that the examination is provided by a dental authority, or a group of dental authorities (which in effect are a subset of UK dental schools). This results in a limited number of provider options and restricts the number of applicants who can take ORE and join the register. The draft Order removes the requirement that an assessment for overseas applicants, such as the ORE, must be provided by dental authorities, or a group of dental authorities from the Act. This will allow the GDC to explore using alternative providers for its assessment for overseas applicants, which could include private providers, or the GDC itself.
Table 6: summary of responses to question 3
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 746 | 46% |
| Disagree | 589 | 36% |
| Don’t know | 85 | 5% |
| Neither agree nor disagree | 194 | 12% |
| Unknown | 20 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
As shown in table 6, just under half of respondents (46%) who answered this question agreed with removing the requirement that the ORE or other assessments are held by a dental authority or a group of dental authorities from the GDC’s legislation. Many respondents who agreed argued that changes are required because the current ORE process is ineffective, restrictive and unfair. Some stated that the exam is expensive and difficult to access due to the small number of sittings that run each year. The use of alternative ORE providers could be beneficial to applicants, the NHS and patients if it results in increased exam places and increases the flexibility of the exam system, such as the introduction of alternative forms of assessment such as online testing. Other respondents .suggested that alternative routes to registration should be considered in place of the ORE, such as analysis of the syllabus and curricula of international qualifications or the introduction of supervised training schemes in universities and hospitals.
Quote from respondent who agreed with the proposal:
Booking for the exam is immensely difficult and if this action helps solve that problem then I agree.
Just over a third of respondents (36%) disagreed with the proposal. A number of these argued that dental authorities, or the GDC, should continue to run the ORE as those bodies with extensive knowledge and experience in assessing the knowledge and skill of dentists. Although there is no proposed change to the role of the GDC as the body which makes decisions on registration, some respondents commented that the GDC should continue to have oversight of the process regardless of any changes made. Some respondents felt that the introduction of alternative ORE suppliers could lead to unnecessary commercialisation of the registration process, or a potential drop in registration standards, or fraud in relation to the outcome of exam results. It was argued that any of these factors could also negatively affect patient safety.
Quote from respondent who disagreed with the proposal:
In depth knowledge and experience of what is to be assessed is crucial. All UK registrants have their examinations within the same environment. In the interest of maintaining standards, the ORE must also be assessed by those who assess our UK colleagues, for the benefit and safety of patients. The risks of fraudulent results and abuse of the ORE are potentially increased when the facilities providing them are not robustly regulated.
Government response
We note respondents’ concerns regarding standards dropping if alternative ORE suppliers are used. The GDC will continue to set the required knowledge and skill and other requirements for registration, and they will remain the same for both UK and internationally qualified applicants. The GDC will also continue to have oversight over all routes to international registration and its priority, as it is now, is to ensure that admission to the professional registers is only permitted for those applicants who meet the requirements for registration. The government is also aware of the difficulty that many ORE candidates have encountered in securing a place on the exam. This change will support the GDC to expand the number of exam places available and allow those international applicants on the waiting list to join the register more efficiently.
The government’s view is that the issue of who operates overseas registration assessments is an operational matter for the GDC which does not need to be set out in legislation and we plan to proceed with implementing this proposal. This is consistent with the level of detail in the legislative frameworks of the General Medical Council (GMC) and NMC, who already have the flexibility to decide which organisations run their overseas registration exams.
Question 4
Do you agree or disagree that any new dentist registration routes that the GDC develops may include, but will not be limited to, recognition of overseas diplomas?
Background
Under the Dentists Act 1984, the GDC can recognise international qualifications for the purpose of granting registration to internationally qualified dentists. Where applicants do not hold a recognised diploma, section 16 of the Act allows the GDC to require applicants to sit examinations, such as the ORE, to demonstrate that they have the required knowledge and skills for registration. In simplifying the GDC’s legislation, the draft Order removes the link between holding a recognised overseas diploma and eligibility for registration from the Dentists Act. This allows the GDC to explore alternative processes, such as quality assurance of international education and training, which is not expressly permitted in its current legislation.
Table 7: summary of responses to question 4
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 921 | 56% |
| Disagree | 450 | 28% |
| Don’t know | 98 | 6% |
| Neither agree nor disagree | 142 | 9% |
| Unknown | 23 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
Just over half of respondents (56%) agreed with the proposal. Many of those who agreed made the point that recognition of either an applicant’s diploma, or their experience, should always be based on these meeting the UK’s standards of training and education. Some respondents argued that alternative registration routes, such as a paper-based assessment of an applicant’s experience, competencies and skills, or of the university syllabus, would allow greater numbers of competent international dentists to register with the GDC. These routes were considered valuable alternatives to the ORE by a number of respondents. Another point made by a number of respondents was that overseas-qualified dentists are as competent as UK qualified graduates and the GDC’s registration routes should provide streamlined registration for such candidates, where appropriate.
Of those respondents who disagreed (28%), many commented that all international professionals should be required to demonstrate skills and knowledge which are equal to UK standards to register with the GDC. International qualifications should only be recognised where these are standards are met. A number of respondents also argued that an examination testing the practical skills and knowledge of applicants should remain a requirement and international registration should not be granted solely on the recognition of a qualification held, which could increase risks to patient safety.
Government response
The government plans to take forward this change, which will support improvements to the GDC’s registration processes by removing restrictive wording in the Dentists Act 1984 on how overseas qualifications are recognised. The government notes respondents’ concerns around how changes to registration processes may impact patient safety and the importance of ensuring that new entrants to the professional registers meet UK standards of education and training. It will be for the GDC, as an independent regulator, to decide how best to use the flexibility that the legislative changes allow while maintaining standards, and any changes to its current registration processes will be consulted on with stakeholders. As set out above, the GDC will continue to set the required knowledge and skill and other requirements for registration, and these will remain the same for both UK and internationally qualified applicants. The GDC will also continue to have oversight over all routes to international registration and its priority, as it is now, is to ensure that admission to the professional registers is only permitted for those applicants who meet the requirements for registration.
Question 5
Do you agree or disagree with providing the GDC with a power to charge fees on a cost recovery basis for activities that underpin routes to international registration, such as quality assuring, or accrediting international qualifications?
Background
The GDC wishes to explore granting registration to international dentists based on recognition of the qualification held by an applicant, where the GDC considers that it provides applicants with the required knowledge, skills and experience. The processes to deliver the accreditation of international qualifications will result in costs to the GDC which will need to either visit the relevant educational institution or remotely assess the learning outcomes a qualification provides. The regulator will also need to monitor the quality of the qualification on an ongoing basis for it to remain accredited. The GDC wishes to ensure that the costs of such activities are not funded, or cross-subsidised, by existing registrants.
Table 8: summary of responses to question 5
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 451 | 28% |
| Disagree | 964 | 59% |
| Don’t know | 51 | 3% |
| Neither agree nor disagree | 157 | 10% |
| Unknown | 11 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
As set out in table 8, nearly 60% of respondents who answered this question disagreed with the proposal. The majority of these respondents expressed concerns about cost to individual international applicants increasing. Many respondents argued that the GDC should ensure that costs to individual international dentists are reasonable, given that the ORE process is already expensive. Others expressed concern that any rise in registration fees may put international dentists off coming to the UK to work.
Quotes from respondents who disagreed with the proposal:
This may lead to unnecessary hiking of fees.
If it’s within current limits, that’s fine. But more than the current amount, then they’ll be clearly pushing it. How are candidate’s [sic] supposed to pay so much if they can’t even secure a job here in the UK? And that’s considering just one attempt, not multiple. Also, candidates shouldn’t be expected to sit the parts of exams that they have already cleared again and again. That’s just not fair. It’s the GDCs monopoly to make money.
Fees should be fixed and reasonable.
Many of those respondents who agreed with the proposal (28%) argued that the GDC should be able to charge individuals or organisations for any costs it incurs in assessing overseas qualifications. Some respondents also felt that the costs of quality assurance of international education and training should be recovered from individual international applicants, rather than from existing GDC registrants.
Government response
The aim of this proposal is to allow the GDC to charge fees for the purpose of meeting expenses incurred, or to be incurred, in assessing whether international applicants have the required knowledge and skill and in charging institutions for the cost of the process to recognise their qualifications. Without such a power, the regulator would not be able to develop new registration routes based on the qualification held by the applicant. The government recognises that more than half of respondents disagreed with the proposal, many of whom noted concern that registration costs to individuals may rise following the legislative amendment. However, the development of such routes, with associated fees charged to overseas institutions, rather than individual applicants, could potentially benefit all international applicants by reducing the number of dentists required to sit an ‘ORE’ style assessment. This would in turn decrease the pressure on the overseas exam system, which currently operates with a long waiting list.
Question 6
Do you agree or disagree with providing the GDC with greater flexibility to set out its registration requirements for international dentists in rules set by the regulator rather than in its legislation?
Background
The GDC has a power under Section 16(4) of the Dentists Act 1984 to make regulations as to the examinations required to be sat by international applicants. The resulting regulations, the General Dental Council (Overseas Registration Examination Regulations) Order of Council 2015/735 (the ‘2015 Order’) provide detail on the structure, content and fees for the overseas registration exam. Any changes to the 2015 Order require Privy Council approval. The draft Order provides the GDC with a power to put in place rules, which will need to be consulted on, but will not require Privy Council approval, on how it will satisfy itself that individuals with an overseas diploma have the required knowledge and skill and how the GDC will recognise overseas diplomas.
Table 9: summary of responses to question 6
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 626 | 38% |
| Disagree | 849 | 52% |
| Don’t know | 50 | 3% |
| Neither agree nor disagree | 99 | 6% |
| Unknown | 10 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
Of those who agreed with this proposal (38%), the most common reason given for doing so was that it will make it easier for the GDC to modify its registration requirements and process as it considers appropriate, without needing to pursue time-consuming legislative changes. Some respondents agreed on the basis that the GDC should consult on any changes or allow for regular peer review of its processes. Others also wanted to see registration processes shortened or made simpler or highlighted the importance of maintaining high registration standards.
Quote from an individual who agreed with the proposal:
Yes, by including the flexibility in regulations rather than legislation there is more opportunity to carry out evaluation and modify accordingly for improvements and effectiveness.
Of those who disagreed (52%), many felt that parliamentary oversight of the GDC’s international registration processes was being reduced by too great a measure and that Parliament should continue to have a role in scrutinising changes to the GDC’s approach to international registration. Some respondents voiced concern that registration processes may become more difficult in future as a result of the GDC having more flexibility to change them, while others were concerned about registration standards dropping.
Quote from organisation who disagreed with the proposal:
We have concerns about the lack of oversight and scrutiny inherent in this proposal. Whilst we agree that the use of primary legislation is too cumbersome to be effective, we believe there still needs to be some Parliamentary scrutiny of the GDC’s actions on this. We would propose, for example, amending the Dentists Act to allow the use of Statutory Instruments to achieve this effect, allowing for greater flexibility than at present whilst maintaining overview and scrutiny.
Government response
The government intends to move forward with the proposal to provide the GDC with greater flexibility to set out its registration requirements for international dentists in rules set by the regulator rather than in its legislation.
The approach taken under this proposal is consistent with the principles of the broader reform programme for professional regulation, in providing the GDC with greater flexibility to amend international registration processes without the need for further legislative change. It is right that the GDC, as an independent regulator, has flexibility to amend its international processes, including publishing rules on these, without requiring ongoing legislative intervention by Parliament. The proposals do not change the way in which the GDC’s knowledge and skills requirements for international applicants are set, or the GDC’s role in ensuring that admission to the registers is only permitted for those who meet the necessary requirements but provide the regulator with greater flexibility to change the assessment methods it uses. It will be for the GDC to decide how best to use the flexibility that the legislative changes allow, and stakeholders will have the opportunity to provide their views on any changes to its current registration processes as these will be subject to public consultation. This will allow necessary changes to be made in a timely and efficient way, reducing the parliamentary and departmental time and resource required to make such changes.
Question 7
Do you agree or disagree with The General Dental Council (Overseas Registration Examinations Regulations) Order of Council 2015 remaining in force for 12 months after the draft international registration Order comes into force?
Background
The provisions of the 2015 Order, which sets out the ORE fee, structure and content and is revoked by the draft Order, are saved until 12 months after the new Order comes into force. At this point, the GDC will publish new rules on the detail of its international registration processes as detailed under the response to question 6.
Table 10: summary of responses to question 7
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 532 | 33% |
| Disagree | 543 | 33% |
| Don’t know | 245 | 15% |
| Neither agree nor disagree | 285 | 17% |
| Unknown | 29 | 2% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
As the table shows, a third of those who responded to this question agreed (33%) and a third disagreed (33%) with the proposal. Those respondents who didn’t know whether they agreed or disagreed (15%) or neither agreed nor disagreed (17%) made up a significant proportion of the remaining responses.
Many respondents who agreed indicated that a transition period was needed during which the old rules continued to be in force, whether to allow current applicants to progress their application under the existing system or to allow the regulator time to prepare for the changes it plans to make to the registration process.
Most of the comments from those respondents who disagreed indicated that they considered that 12 months was too long. The arguments for making improvements to the registration process more quickly included that this would help tackle the long waiting times for candidates to take the ORE, which have been compounded by the suspension of the exam due to the coronavirus (COVID-19) pandemic, and that changes would support patient safety. Other respondents suggested that changes to the current registration process were not required, or that those candidates on the ORE waiting list should be able to complete the ORE under the current rules.
Government response
The aim of the proposal is to ensure that the GDC has sufficient time to prepare to implement the changes it wishes to make to the operation of the ORE when the current rules fall away. The new rules will be subject to public consultation and the 12-month period during which the provisions of the 2015 Order continue to apply. This will allow time for the GDC to run a consultation and finalise its approach in response to feedback from stakeholders.
The GDC has indicated, pending approval of its Council, that the new rules will include limited information on the operation of the ORE, in contrast to the existing 2015 Order, with the regulator setting out the content and fee for the ORE in policy documents. The GDC plans, pending approval of its Council, to make modest changes to the structure of the delivery of the ORE, while keeping the components the same. In addition, it plans to provide more information to candidates to help them understand what is required of them to pass. These measures will support increases to the capacity of the Part 2 exam by removing restrictions on the number of candidates that can sit the exam at any one time. They will also reduce the number of candidates who re-sit the whole assessment, either by making it more likely a candidate will pass first time or by removing the requirement to re-sit some components that have already been passed.
Suspension of ORE due to the COVID-19 pandemic
Question 8
Do you agree or disagree with extending the 5-year period during which ORE candidates must pass Part 2 of the ORE following their first attempt at Part 1, where restrictions from COVID-19 have prevented them from taking the exam?
Question 9
Do you agree or disagree with providing those candidates whose 5 year period was due to end within 3 months of April 2020 and who had secured a place on that month’s ORE sitting with an extension of 12 months to provide them with sufficient time to secure a place on a subsequent ORE sitting?
Background
We have grouped these questions together as they are on closely related proposals to protect candidates whose opportunity to sit Part 2 of the ORE within 5 years of first attempting Part 1 (as required by GDC regulations) was lost following restrictions on the operation of the exam resulting from the coronavirus (COVID-19) pandemic. While the 2015 Order requires that applicants must pass Part 2 of the ORE within 5 years of first attempting Part 1, the draft Order specifies that in calculating this, no account should be taken of the period between 2 April 2020 (when the ORE was suspended) and the day after the new Order comes into force. In addition, those people whose 5-year period was due to end within 3 months of April 2020 and who had secured a place on that month’s cancelled ORE sitting are provided with an additional extension of 12 months, to provide them with sufficient time to secure a place on an ORE exam. Without the extension, these candidates would only have one month remaining within their 5-year period to sit the ORE at the point that this legislation comes into force.
Table 11: summary of responses to question 8
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 1245 | 76% |
| Disagree | 266 | 16% |
| Don’t know | 43 | 3% |
| Neither agree nor disagree | 61 | 4% |
| Unknown | 19 | 2% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Table 12: summary of responses to question 9
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 1245 | 76% |
| Disagree | 215 | 13% |
| Don’t know | 56 | 3% |
| Neither agree nor disagree | 89 | 5% |
| Unknown | 29 | 2% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
The majority of people who responded to question 8 (76%) agreed with the proposal to extend the 5-year period where COVID-19 restrictions had prevented candidates from taking the exam. Most respondents felt that this proposal was fair and that candidates should not be penalised for having been on the ORE waiting list during the period of the pandemic, which led to the suspension of the exam. Some respondents also argued that the 5-year period should be removed altogether. Some of those respondents who disagreed (16%) commented that 5 years was a sufficient period during which candidates have the opportunity to take the exam and that it does not need to be extended, while others thought 5 years was too long.
Comment from respondent who agreed with the proposal:
Yes this is sensible and fair as through no fault of their own some candidates have not been able to pass Part 2 ORE in the prescribed time limit due to COVID.
The same proportion of respondents (76%) who answered question 9 agreed with the proposal to provide those candidates who had secured a place on the April 2020 sitting of the ORE with an extension of 12 months to provide them with sufficient time to secure a place on a future ORE sitting. Most people who commented considered that the proposal was fair to candidates, while a few argued that the extension provided to this group should be longer than 12 months. Of those who disagreed (13%), the most common argument was that this approach was unfair on newer candidates waiting to take the ORE or that the extension provided should be longer than 12 months.
Government response
The pandemic restrictions meant that there were no sittings of the ORE between April 2020 and January 2022 and some candidates on the ORE Part 1 and Part 2 waiting lists lost nearly 2 years of the 5-year period available to them to pass both parts of the ORE. The government notes that some respondents who disagreed with these proposals did so on the basis that they thought a 5-year period is either already a sufficient period of time during which candidates can sit the ORE exam, or that the 5-year period requirement should be abandoned altogether.
Owing to the suspension period, the time-limit has expired so far for 191 candidates who have not had a full 5 years of opportunity to sit and the GDC is not able to offer these candidates a place on upcoming ORE sittings until its legislation is amended. The government and the GDC consider that in the interest of fairness, these candidates should be given the same time period and realistic opportunity to apply for a place on either Part 1 or Part 2 of the exam as they would have had if the exam had not been suspended as a result of the pandemic. Therefore, we will proceed with the two proposals outlined above. The GDC will contact candidates affected directly to inform them of the length of time they have available to sit the ORE once this legislation comes into force.
Prescription of ORE exam fees
Question 10
Do you agree or disagree with the removal of the ORE exam fee from the GDC’s legislation, enabling the GDC to set any overseas assessment fees on a cost recovery basis?
Background
Allowing the GDC to set international registration exam fees within rules, by removing the requirement that the overseas assessment fee is contained within an Order approved by the Privy Council from its legislation, will allow fee changes to be made more quickly and efficiently. The Order requires that any fees imposed must only meet expenses incurred, or to be incurred by the GDC, so that they may cover the costs of carrying out the assessment but will not generate extra revenue for the GDC.
The GDC has advised that initially, costs to applicants are likely to increase to ensure that the overseas assessment is run in a cost-neutral way. There are currently a limited number of potential providers for the ORE exam, which leads to limited competition between providers for contracts. While the GDC expects that costs to overseas assessment applicants will increase in the short-term to cover the current costs of providing the assessment, savings are likely to be achieved over time as additional providers of the assessment are identified. This may in future allow for reduced fees. Exam place capacity will also be increased to address demand and reduce waiting times.
Table 13: summary of responses to question 10
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 776 | 47% |
| Disagree | 528 | 32% |
| Don’t know | 94 | 6% |
| Neither agree nor disagree | 209 | 13% |
| Unknown | 27 | 2% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
As set out in table 13, just under half of respondents who answered this question (47%) agreed with the proposal. A number of respondents caveated their support for greater flexibility for the GDC by emphasising that fees must be affordable, with some respondents suggesting that they should be lowered. Many respondents argued that the GDC should be able to cover the cost of running the exam by recouping this from international applicants in full, which the current fee level does not allow for, and therefore supported greater flexibility for the regulator. Some respondents argued that the system must be fair, while others wanted to see costs spread equally across applicants with different types of qualification.
Just under a third of respondents (32%) who answered this question disagreed with the proposal. The majority of these respondents indicated that they believe that the ORE exam fees are already too high, and many individual applicants were concerned that the change would lead to rising fee levels. The issue of fairness to individual candidates was also a common theme in the comments provided from those who disagreed.
Government response
The current fee charged to individual applicants to sit the ORE Part 2, which was set in Privy Council-approved legislation in 2015, does not cover the cost to the GDC of running the exam. As a result, losses must be cross subsidised from the annual retention fee paid by registrants. This is not consistent with the GDC’s wider fee setting policy and it wishes to ensure that the operation of the exam is cost neutral and is not subsidised by existing registrants. The ORE fees are currently not included under the GDC’s fee setting policy because the fees are set in the 2015 Order but will brought under this policy in future.
While we recognise the concerns of ORE applicants about these fees rising in future, the government’s view is that the GDC should have the flexibility to amend the detail of its international processes. This includes the GDC being able to set the fees for any overseas assessment on a cost-recovery basis and in a more responsive way than is currently possible. As set out above, while the GDC expects that costs to overseas assessment applicants will increase in the short-term, savings are likely to be achieved over time. The GDC’s new registration routes may also result in fewer applicants needing to sit an assessment, mitigating the risk of future applicants being discouraged by increased fees. We therefore plan to proceed with the legislative proposal which will allow the GDC greater flexibility to update the ORE fee, without requiring ongoing legislative intervention by Parliament.
GDC’s framework for registration of international dental care professionals
Question 11
Do you agree or disagree with providing the GDC with flexibility to apply a range of assessment options in determining whether international DCP applicants have the necessary knowledge, skills and experience for practice in the UK?
Background
The GDC’s legislation requires it to conduct an individual assessment of the knowledge and skills of each international DCP applicant. The consultation proposed that the GDC should have consistent powers of assessment in relation to all of the professions it regulates. The Order provides the GDC with the same flexibility in relation to setting and amending processes for international DCP applicants as for international dentists.
Table 14: summary of responses to question 11
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 651 | 40% |
| Disagree | 887 | 54% |
| Don’t know | 23 | 1% |
| Neither agree nor disagree | 60 | 4% |
| Unknown | 13 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
An analysis of the responses received reveals that many respondents interpreted the proposal to mean that greater flexibility would result in a more difficult registration process, while others thought that it would result in simplified processes. A significant number of respondents who both agreed (40%) and disagreed (54%) were in favour of an easier, more streamlined international DCP registration process.
Some respondents who agreed argued that international dentist applicants to the DCP register were either over-qualified or already had the required knowledge and skills for registration. Other reasons provided were that alternative registration routes could help applicants demonstrate that they have the required knowledge and skills via alternative methods such as via workplace or practical scenario-based assessments, resulting in more streamlined, robust and fair processes and increasing the number of DCPs registered. Some respondents suggested change was needed because the current system did not include a practical assessment. Others agreed on the basis that registration standards are maintained and equal to those in the UK.
Comments from respondents who agreed with the proposal:
Different overseas DCPs have different abilities and should have different assessments.
Important applicants skill set is assessed, especially as the scope of a dental hygienist or dental therapist is different across the world.
Some of those who disagreed considered that the proposal would lead to a more complex international DCP registration process, with others commenting that overseas dentists should gain automatic DCP registration because they hold a dentistry degree.
Comment from respondent who disagreed with the proposal:
International DCP applicants have already gone through vigorous assessment to be able to consider applying overseas and adding more would only hinder their chances or make their chances more difficult.
The most common argument provided by those who disagreed with the proposal was that there was nothing wrong with the current registration process, which many felt provides sufficient assessment options for applicants to demonstrate the required knowledge, skills and experience. Some respondents suggested that changes might impact patient safety negatively. The importance of maintaining UK standards was raised and some respondents argued that everyone should go through the same process in the interest of fairness.
Government response
While we recognise that more than half of respondents disagreed with the proposal, a significant number were in favour of a more streamlined international DCP registration process. It is the government’s view that this can be achieved by providing the GDC with sufficient flexibility to amend the detail of its international DCP processes as it considers appropriate. In making any future changes to these, the GDC will consult with stakeholders with the aim to ensuring that its processes are both fair and proportionate, while protecting public safety by maintaining standards of registration. On this basis, we plan to take forward the proposal to provide the GDC with flexibility to apply a range of assessment options in determining whether international DCP applicants have the necessary knowledge, skills and experience for practice in the UK.
The government understand that the GDC, pending approval of its Council, plans to continue to apply the current assessment process for DCPs qualified outside the UK in the short term but will use the flexibility that these changes provide to explore the use of alternative methods. This may include competence testing or the application of different assessment methods for different protected titles.
Question 12
Do you agree or disagree with providing the GDC with a power to charge fees on a cost recovery basis for activities that underpin routes to international DCP registration, such as quality assuring, or accrediting international DCP qualifications?
Background
The Order provides the GDC with flexibility to apply a range of assessment options in determining whether an international DCP applicant has the necessary knowledge, skills and experience for practice in the UK. To support this, the GDC will be able to charge fees to cover the cost of expenses incurred, or to be incurred by the GDC in relation to international DCP registration. This will allow the GDC to cover the costs of recognising individual international qualifications which reflect UK standards.
Table 15: summary of responses to question 12
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 475 | 29% |
| Disagree | 958 | 58% |
| Don’t know | 66 | 4% |
| Neither agree nor disagree | 123 | 8% |
| Unknown | 12 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
Just over half of respondents disagreed (58%) with the proposal to provide GDC with the power to charge fees on a cost recovery basis for activities that underpin routes to international DCP registration. Many respondents commented that international registration fees were already too high and should be lowered or removed altogether. It was argued that increasing applicant fees could make registration unaffordable for some individuals, resulting in unfairness for international applicants. Others felt that the proposed change would make the application process more complex and have a negative impact on the flow of DCPs into the workforce.
Comments from respondents who disagreed with the proposal:
The cost may become a huge burden on candidates.
An independent body should not have complete authority to frame the rules and processes autonomously as it could potentially lead to exploitation of applicants.
Among those who agreed with the proposal (29%), many felt fees should reflect expenses incurred by the GDC. Some respondents agreed with the proposal but felt costs to individuals should be reasonable. Others agreed because they felt existing registrants should not have to subsidise the costs of international registration and that costs should be recovered by charging international applicants.
Comments from respondents who agreed with the proposal:
Quality assurance and accreditation processes are expensive so it is only right that the organisation requesting accreditation should be required to fund the process. Current registrants should not accommodate the financial burden of activities that underpin the routes to international registration, and fees should be charged for activities such as quality assurance and accrediting international qualifications.
Government response
As with the equivalent proposal for dentist registration under question 5, this proposal is intended to allow the GDC to cover any expenses incurred, or to be incurred, in assessing whether international DCP applicants have the required knowledge and skill and in charging institutions for the cost of recognising their qualifications. Without such a power, the regulator would not be able to develop new registration routes based on the qualification held by the applicant.
The government recognises that many respondents are concerned about costs to individual applicants rising. However, the development of such routes, with associated fees charged to overseas institutions, rather than individual applicants, could benefit DCP international applicants whose qualifications have been recognised by the GDC by streamlining the amount the evidence they need to provide in order to register.
Question 13
Do you agree or disagree with the requirement that international applicants to the dental care professionals register must hold a DCP, rather than a dentist, qualification.
Background
The Order specifies that the qualification relied upon by an international applicant to be registered under a particular title in the Dental Care Professionals register cannot be a diploma in dentistry. This change aligns international DCP registration requirements with requirements for DCPs registering with UK qualifications, as under the Dentists Act 1984, UK-qualified dentists are unable to register as DCPs.
Table 16: summary of responses to question 13
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 271 | 17% |
| Disagree | 1142 | 70% |
| Don’t know | 84 | 5% |
| Neither agree nor disagree | 127 | 8% |
| Unknown | 10 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
The majority of respondents disagreed with this proposal (70%), with many respondents arguing that international dentists are already qualified or have enough clinical experience to work as a DCP. Others felt that this was a valuable route for international dentists to practice in the UK while waiting to take the ORE and practise as dentists.
Another common theme among those who disagreed was that the current ORE process poses difficulties for overseas dentists and therefore DCP registration should be permitted to allow these dentists to work in the UK. Others commented that the current DCP registration framework was valuable for the workforce and the public, and therefore should not be closed. Some respondents who disagreed also raised concerns that DCP titles are not as common, or non-existent in other countries.
Comments from respondents who disagreed with the proposal:
Enabling dentists to register as DCP will provide the necessary manpower to ease the backlog of the healthcare system and the shortage of DCP.
Offers valuable experience of UK dentistry before full route to registration.
This is in the public interest, since overseas dentists have demonstrated their ability to work well as DCPs, and it also prevents deskilling while waiting (sometimes for years) for registration.
The majority of those who agreed (17%) felt that a dentist’s qualifications differ from those of a DCP and therefore separate registration pathways are required. Another common theme highlighted was the importance of transparency. Respondents felt that allowing international dentists to register as DCPs was misleading to patients. Others raised patient safety concerns and felt the current system is unfair as it allowed a ‘backdoor’ into the profession with no requirement to prove the clinical skills specific to that of a DCP.
Comment from respondent who agreed with the proposal:
The GDC standards are clear in that patients and the public should not be misled and an overseas dentist registering as a DCP is misleading to patients and the general public as their training and qualification is that of a dentist and not of a hygienist or therapist.
Some respondents felt the change would bring the GDC’s registration requirements in line with other regulators and bring consistency between its UK and international registration requirements. Other respondents agreed with the proposal only if its introduction is delayed until the GDC introduces improvements to the ORE process.
Government response
We note that most respondents to this question did not agree with the proposal. While many respondents felt that holding a dentistry qualification means that an individual is suitably qualified to practise as a DCP, the government and GDC recognise dentists and DCPs as distinct professions. The GDC considers the effect of the wording of its current legislation as an anomaly and wishes to bring consistency between its UK and international requirements for DCP registration. On the basis of fairness and consistency between the UK and international routes, we plan to take forward the proposal.
We note that many respondents with dentistry degrees argued that the difficulty of gaining dentistry registration via the current ORE process means that the DCP route should remain open to applicants who can contribute positively to the dentistry workforce while waiting to pass the ORE. Others requested that the route remains open to dentists for a grace period, given that the GDC’s process to improve the ORE will not be in place until one year after the Order is in force.
The GDC is currently processing a high volume of DCP applications from dentists and has advised that it will need more than 12 months after the Order comes into force to process those applications received up until the day before the Order comes into force and to deal with any resulting appeals. The government has therefore agreed to amend the Order to allow the GDC to continue to process such applications after the Order is in force, so that current applicants are not unfairly prevented from completing the registration process. The additional drafting within the Order can be seen at paragraph 2 of Schedule 5 to the Order, which is published alongside this document.
Following this period of ongoing application processing, the GDC is planning to introduce improvements to the ORE which will support increased capacity of the examinations. This will help those dentists who may have previously sought to use the DCP registration route, as increased ORE exam capacity will help them to complete the GDC registration process more quickly.
Question 14
Do you agree or disagree with providing the GDC with greater flexibility to set out its registration requirements for international dental care professionals in rules set by the regulator rather than in its legislation?
Background
In the same way as described for dentists at question 6, the Order will allow the GDC to make rules setting out the detail of its DCP international registration process. These rules will need to be consulted on but will not require Privy Council approval.
Table 17: summary of responses to question 14
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 563 | 34% |
| Disagree | 857 | 52% |
| Don’t know | 92 | 6% |
| Neither agree nor disagree | 103 | 6% |
| Unknown | 19 | 1% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
Most respondents who agreed with the proposal (34%) were in favour of the GDC having more autonomy in this regard, on the basis that changes will be subject to consultation and that registration standards must be maintained. Others commented that greater flexibility would provide more opportunity to evaluate international DCP applicants and modify the registration process. A few respondents commented that they agreed if the change resulted in a shortened, improved process for applicants and others felt that some level of parliamentary scrutiny should be retained.
Comment from respondent who agreed with the proposal:
Agree, subject to proper oversight and Consultation. Removing privy council approval reduces accountability and removes scrutiny of decisions which could adversely impact on workforce retention and supply.
Of those who disagreed (52%) the most common points raised were concerns that flexibility would lead to a more difficult registration process and that the current system works well and should not be changed. In addition, many respondents felt it was necessary that the rules remain in legislation to maintain standards and prevent the GDC from having full autonomy to change its processes.
Comment from respondent who disagreed with the proposal:
It is important the registration requirements for internationally qualified DCPs remain set out in legislation rather than by the GDC, in order to ensure that there is no conflict of interest and consequent drop in standard of the test for registration.
Government response
We plan to proceed with this legislative proposal which will allow GDC greater flexibility to set out its registration requirements in its rules rather than its legislation. As described under the response to question 6 which provides the GDC with equivalent powers in relation to international dentist registration, the approach taken under this proposal is consistent with the principles of the broader reform programme for professional regulation, in that the GDC, as an independent regulator, should have flexibility to amend its international processes, including publishing rules on these, without requiring ongoing legislative intervention by Parliament.
The proposals do not change the way in which the GDC’s knowledge and skills requirements for international applicants are set, or the GDC’s role in ensuring that admission to the registers is only permitted for those who meet the necessary requirements. However, they will provide the regulator with greater flexibility to change the assessment methods it uses. It will be for the GDC to decide how best to use the flexibility that the legislative changes allow, and stakeholders will have the opportunity to provide their views on any changes to its current registration processes as these will be subject to public consultation. This will allow necessary changes to be made in a timely and efficient way, reducing both the parliamentary and departmental time and resource required to make such changes.
NMC’s framework for registration of international nurses, midwives and nursing associates
Question 15
Do you agree or disagree with amending the Nursing and Midwifery Order to encompass a range of international registration routes, such as quality assurance of international qualifications, to be used in addition to the NMC’s test of competence?
Background
Article 13(1)(d)(ii) of the Nursing and Midwifery Order 2001 requires the NMC to consider whether a person’s qualification is of a comparable standard to a UK qualification before the regulator may require an applicant to sit a test of competence. The draft Order amends the wording to encompass a range of international testing routes.
Table 18: summary of responses to question 15
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 436 | 27% |
| Disagree | 479 | 29% |
| Don’t know | 414 | 25% |
| Neither agree nor disagree | 231 | 14% |
| Unknown | 74 | 5% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
27% of respondents agreed with the proposal to amend the Nursing and Midwifery Order to encompass a range of international registration routes in addition to the NMC’s test of competence. Many commented that this would be beneficial because alternative registration routes may increase the number of international professionals who register with the NMC and could potentially help address staff shortages in NHS services. A number of respondents felt that the proposed change would result in a streamlined application process and could increase public safety and quality assurance of professionals. Others commented that they agreed only if international registration standards remain equal to UK standards and alternative registration routes did not replace the NMC’s test of competence, which was considered a robust test of applicants’ knowledge and skills.
Comment from a respondent who agreed with the proposal:
As long as the system implemented for verifying the standards of qualifications are consistent then a range of routes should be possible. Standards must equate to the existing UK levels of training or above that level.
Just under a third of respondents (29%) disagreed with the proposal, with many citing concerns around the use of qualification comparison as an alternative to a test of competence in assessing professionals’ skills and training. Some respondents expressed concern that this would lead to low quality of care and international qualifications would not be equivalent to UK standards. A number of respondents interpreted the proposal to mean that additional testing would be introduced and disagreed on the basis that the proposed change would make the application process more difficult.
While the proportion of respondents who agreed and disagreed was similar, a large proportion of respondents said that they either didn’t know (25%) or neither agreed nor disagreed (14%). Over 70% of respondents to the consultation overall were dental care professionals and therefore many felt that they could not comment on NMC issues. Some respondents also felt that more information was needed on the NMC’s future plans in order to provide a view.
Government response
The government notes that some respondents disagreed with this proposal because they were concerned that the change may result in reduced registration standards. The primary purpose of professional regulation is to protect patients and the public from harm by ensuring those providing healthcare are doing so safely. Any new registration routes introduced by the NMC, such as qualification comparison, will be based around ensuring that international applicants meet the UK standards of training and knowledge required to join the register.
We also recognise that some respondents were concerned that international registration processes would become more difficult. It is our view that it is for the NMC, as an independent regulator, to decide how its international processes should change, with input from stakeholders, but without requiring ongoing legislative intervention by Parliament. The aim of these changes is to provide this flexibility and it will be for the NMC to decide how to use it.
We understand that the NMC plans to continue to apply its test of competence as the primary assessment route for international applicants, but it will explore using its powers to recognise programmes of education delivered outside the UK or to undertake a qualification comparison exercise to ascertain whether an applicant’s qualification gained outside of the UK is of a comparable standard to a UK qualification approved by the NMC. The NMC does not plan to introduce these routes as additional steps in the registration process, but to use them as alternatives to its test of competence. The regulator will also need to have regard to commitments made within free trade agreements, such as commitments made in the EEA EFTA agreement on recognition of professional qualifications. We plan to proceed with amending the Nursing and Midwifery Order to encompass a range of international registration routes, such as quality assurance of international qualifications, to be used in addition to the NMC’s test of competence.
Question 16
Do you agree or disagree with removing the duty on the NMC to determine procedures to assess whether a qualification is of a comparable standard and publish a list of such qualifications from the Nursing and Midwifery Order?
Table 19: summary of responses to question 16
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 358 | 22% |
| Disagree | 471 | 29% |
| Don’t know | 448 | 27% |
| Neither agree nor disagree | 280 | 17% |
| Unknown | 77 | 5% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
A significant proportion of people who responded to this question stated that they either didn’t know (27%), or neither agreed nor disagreed (17%) with the proposal. Some respondents felt that there was not enough information available on the NMC’s plans for them to provide a view on the proposal while others commented that issues relating to NMC registration were outside their area of knowledge.
Of the remaining respondents, just under a quarter (22%) agreed. Some felt that greater flexibility would lead to positive changes and/or was the logical next step needed to improve and expand registration routes open to international applicants. A slightly higher proportion (29%) disagreed with the proposal. Many respondents felt that the duty to publish a list of approved qualifications is key to providing transparency on how the NMC’s international registration processes operate. Some respondents interpreted the proposal as meaning that the NMC would no longer have a power to assess international qualifications, which they considered to be part of the NMC’s role. Others were concerned that, following the change, professionals may enter the register who do not meet UK standards of training and education and that patient safety may be compromised as a result.
Comment from an individual who disagreed with the proposal:
It is unclear why removing the NMC’s duty to publish a list of comparable qualifications will result in greater flexibility. Stakeholders and the wider public would benefit knowing which qualifications the NMC considers to be of a comparable standard. If an alternative NMC source is agreed for publishing the list this may be acceptable.
Government response
We note that a number of respondents to this question were concerned that the proposal may reduce the transparency of the NMC’s international registration processes by removing the duty on it to publish a list of comparable qualifications. We also note that some respondents argued that the NMC should hold a power to recognise qualifications. However, the proposal does not stop the NMC from recognising or publishing a list of recognised qualifications but removes prescriptive detail from its legislation about how the NMC should operate these qualification comparison processes. The NMC has advised that it will publish a list of any qualifications approved in future.
Further, as set out in the response to question 15, any new registration routes introduced by the NMC, such as qualification comparison, will be based around ensuring that international applicants meet UK standards of training and knowledge. The regulator will also need to have regard to commitments made within free trade agreements, such as commitments made in the EEA EFTA agreement on recognition of professional qualifications. We therefore plan to proceed with this legislative proposal.
Question 17
Do you agree or disagree with amending rule 6 of the Nursing and Midwifery Council (Education, Registration and Registration Appeals) Rules 2004 to change the NMC’s requirements in relation to third party declarations in support of good health and good character?
Background
The draft Order makes the following changes to rule 6 of the Nursing and Midwifery Council (Education, Registration and Registration Appeals) Rules Order of Council 2004:
- clarification that the applicant is required to provide separate third-party declarations in support of both good health and good character. The current wording can be interpreted as requiring only one such declaration from applicants which leads to delays in some applications being processed
- extension of the validity time period for health declarations submitted by applicants from 6 months to 12 months, reflecting the length of time it can take for a final decision to be made after the submission of the declaration at the start of the application process. This will reduce the likelihood that an applicant is asked to provide a second declaration confirmation of the types of evidence of good character that would satisfy the registrar of the applicant’s good character where they are not currently registered with a regulator or licensing body which can provide a declaration on their behalf
Table 20: summary of responses to question 17
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 342 | 21% |
| Disagree | 388 | 24% |
| Don’t know | 519 | 32% |
| Neither agree nor disagree | 297 | 18% |
| Unknown | 88 | 5% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
A significant number of respondents who both agreed and disagreed with the proposal commented that there is potential for declarations of health and character to be forged. They felt that such documentation needed to be assessed carefully by the regulator to avoid risks to public safety of low quality of care provided by registrants who had relied on false documentation.
Of those who responded that they agreed (21%), some respondents felt that the proposal would benefit public safety by reducing the risk of forgery. Others asserted that the changes would help provide clarity to applicants on the NMC’s registration requirements and avoid unnecessary delays in the registration process.
Comment from an individual who agreed with the proposal:
Misinterpretation of these requirements can lead to confusion and unnecessary delays to the applications process. Clarity of requirements regarding good health and good character declarations will support applicants in the process and reduce chances of delays and misinterpretation.
Just under a quarter of respondents (24%) disagreed with the proposal, with many commenting that the current system should be kept the same. Some respondents felt that the changes to the NMC’s requirements could lower registrations standards and/or invite abuse of the registration system.
Again, a significant proportion of respondents responded either with “don’t know” (32%) or “neither agree nor disagree” (18%). Many felt they were either unable to comment or they were unsure what the issue is with the current framework. Others reiterated concern that third party references can be unreliable.
Government response
We plan to proceed with this legislative proposal which will clarify the NMC’s requirements for good health and good character declarations provided by international applicants. Misinterpretation of these requirements can lead to confusion and unnecessary delays to the application process. We note that some respondents were concerned that any changes to the NMC’s requirements could invite abuse of the registration system. The NMC uses a secure portal to send and receive information direct from third parties which includes any declarations in support of health and character. The proposed changes maintain the same high standard of safety and clarify the requirements while offering some degree of flexibility for international applicants.
Costs and benefits and equalities considerations
During the development of our proposals the government considered the costs and benefits of these changes and how they might impact on people with protected characteristics.
Analysis of consultation responses – costs and benefits
Question 18
Do you agree or disagree with the potential costs and benefits of these proposals detailed in the ‘Costs and benefits’ section?
Table 21: summary of responses to question 18
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 435 | 27% |
| Disagree | 500 | 31% |
| Don’t know | 307 | 19% |
| Neither agree nor disagree | 331 | 20% |
| Unknown | 61 | 4% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
As the figures in the table illustrate, just over a quarter of respondents (27%) agreed with the potential costs and benefits detailed in the consultation document. A number of these respondents accepted that increased costs, whether to individual applicants or to the regulators, were an inevitable consequence of registration processes being improved. Some commented that the benefits of the changes, such as increased supply of dentists and nurses to work in the NHS, would outweigh the potential costs. A number of respondents also suggested that any increased registration costs should fall to individual applicants rather than the regulator.
Quotes from respondents who agreed:
Costs will inevitably increase in order to streamline processes. As long as the costs are not prohibitive and reflect the amount of work taken to simplify applications.
Increased flexibility for the NMC to develop additional international registration routes may benefit future international applicants by providing them with simpler and less time-consuming routes to registration, while still upholding standards and protecting the public.
A similar number of respondents (31%) disagreed with potential costs and benefits detailed, though only a small number provided a reason for doing so. Some of these respondents referenced their concern that costs to individual internationals applicants could rise unfairly as a result of the changes. Others commented that rather than focussing on the costs and benefits of its proposals, the government should aim to ensure that the changes uphold patient safety and high registration standards as a priority.
The remaining responses were fairly evenly split between those who didn’t know (19%), or neither agreed nor disagreed (20%). Some respondents felt that there was not enough information provided in this section to provide a view on the costs and benefits.
Quote from respondent who disagreed:
Costs and benefits are irrelevant when considering the potential impact on patient safety should there be a drop in standards in the test for registration. Any costs associated with registering internationally qualified dentists or DCPs should passed on to these individuals. A robust standardised system of objective knowledge and skills assessment should continue for all potential registrants.
Government response
The additional comments we received as part of the consultation, which mainly focussed on potential costs to individuals, were fed into further considerations on the impact of the changes. As set out in the consultation document, the proposed changes to the GDC and NMC’s registration processes will not have quantifiable costs or benefits but will provide the regulators with greater flexibility to make future changes to these processes without Parliamentary approval.
Our assessment remains that increased flexibility for both the GDC and NMC to develop additional international registration routes may benefit future international applicants by providing them with simpler and less time-consuming routes to registration, while still upholding standards and protecting the public. The new registration routes that the GDC is planning for international dentist and DCP applicants may result in an increase in applications from these groups, resulting in increased potential capacity to provide dental services. In addition, streamlining the NMC’s health and character requirements will potentially reduce the cost to some international applicants and improve the accessibility of the registration process. We will also continue to work with the GDC and the NMC to understand their plans for using these flexibilities in future.
Analysis of consultation responses – equalities analysis
Question 19
Do you think any of the proposals in this consultation could impact (positively or negatively) on any persons with protected characteristics covered by the public sector equality duty that is set out in the Equality Act 2010 or by Section 75 of the Northern Ireland Act 1998 or on family formation, family life and relationships?
In addition to considering the costs and benefits of the proposals, we have considered them in relation to the Equality Act 2010, specifically the Public Sector Equality Duty (‘the Duty’), and also Section 75 of the Northern Ireland Act 1998. The Duty requires public bodies to consider, in their day to day work, the needs of people who share the following protected characteristics: age, disability, gender reassignment, pregnancy and maternity, race (includes ethnic or national origins, colour or nationality), religion or belief (includes lack of belief), sex and sexual orientation. In parallel with the equality impact assessment, the department is assessing the potential impact of these proposals on family relationships and functions.
Table 22: Summary of responses to question 19
| Category | Number of responses | Percentage |
|---|---|---|
| Yes | 675 | 41% |
| No | 244 | 15% |
| Don’t Know | 652 | 40% |
| Unknown | 63 | 4% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
A significant proportion of respondents (41%) thought that the proposals could positively or negatively impact people with protected characteristics. About half of these respondents thought the impact would be positive. Some respondents felt the proposals could increase the number of nursing and dental healthcare professionals working in the NHS which would in turn increase patient safety and positively impact patients who will hold protected characteristics. Some respondents also suggested that measures which lead to the introduction of a broader range of registration routes for international professionals would be beneficial for international applicants with protected characteristics and result in increased diversity in the workforce.
Quote from respondent who felt the proposals would have a positive impact:
It may encourage people from diverse communities, those with disabilities and ethnic minority [sic] heritage into the field of work, which can only enrich society.
People within the following groups who hold protected characteristics were identified as potentially being negatively impacted as a result of these changes:
- patients, impacted by reduced patient safety resulting from changes to registration processes
- existing NMC and GDC registrants who may face increased competition for jobs following any increase in the number of international professionals registered
- international applicants who may face increased barriers to entering the NMC and GDC’s registers, particularly in relation to the proposal to prevent international dentists registering as DCPs. It was argued that this could reduce the number of qualified overseas DCPs registering to practise in the UK.
Comments from respondents who felt proposals would invite negative impact:
People from different ethnicities will find it more difficult to get through changes brought within the selection system.
If overseas dentists are not allowed to register as DCPs, this would definitely go against the Equality Act 2010.
15% of respondents disagreed that the proposals would have a positive or negative impact on people with protected characteristics, with the majority of those respondents stating that the proposals would have no equality impact.
A significant number of respondents (40%) responded “don’t know” to this question, with many commenting that their view would depend on the results of the consultation and how the GDC uses the increased flexibility provided by these legislative changes in future.
Government response
The government has considered the impact the proposals may have on the equality principles. As set out in the consultation document, we have identified that the policy changes which we expect to follow these legislative changes may potentially impact international applicants and existing registrants with different protected characteristics, particularly with regards to age, sex and race. However, we have not identified any evidence which suggests these changes will directly have a significant impact on individuals, or between communities, with protected characteristics, or on family relationships and functions.
We have also identified that future changes may contribute to the elimination of discrimination and advancement of equality of opportunity between people who hold protected characteristics and those who do not, as we understand that both regulators may develop additional registration pathways.
The draft regulations
Question 20
Do you agree or disagree that the legislative amendments set out in the draft Dentists, Dental Care Professionals, Nurses, Nursing Associates and Midwives (International Registrations) Order 2022 support streamlined and proportionate international registration processes for the GDC and the NMC?
Background
The consultation document set out the effect of each provision of the draft Order, which was published alongside the consultation, on the GDC and NMC’s legislation.
Table 23: summary of responses to question 20
| Category | Number of responses | Percentage |
|---|---|---|
| Agree | 546 | 33% |
| Disagree | 515 | 32% |
| Don’t know | 289 | 18% |
| Neither agree nor disagree | 222 | 14% |
| Unknown | 62 | 4% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
Of the respondents who agreed (33%) that the legislative amendments support the regulators to develop streamlined and proportionate international registration processes, a number commented that the amendments would support the regulators to make necessary changes to their legislation which would lead to improvements for international applicants, such as a simpler or shorter registration process. Some respondents cautioned that patient safety must be protected and that any process changes must be undertaken with this in mind.
Quote from respondent who agreed:
Any improvements or streamlining of the process while maintaining high clinical and patient safety standards is essential for effective management and recruitment processes.
A similar proportion of respondents disagreed (32%). Some were concerned that the changes could result in overly complex registration processes, or that the ORE should remain in place as the main route for international dentists to gain registration. Others commented that any increase in costs to individual applicants could put professionals off applying to register in the UK.
Quote from respondent who disagreed:
This is not a streamlined process, in fact it just adds confusion and delays to the already existing labyrinthine assessment procedure.
A further third of respondents neither agreed nor disagreed (14%), or that they didn’t know (18%). Some of these respondents stated that they needed more information to understand what the implications of the legislative changes would be, and others thought that the impact would depend on how the regulators implemented policy changes, making it difficult to comment.
Government response
The government notes that a number of respondents felt that they did not have enough information to comment on whether the changes in the draft Order support streamlined and proportionate international registration processes for the GDC and the NMC. This may also be why this question attracted proportionately less comments than many of the others in the consultation document.
We recognise the concerns of those respondents who wish to avoid the international registration processes becoming more complex for individuals professionals to navigate. Our view is that, in reducing prescriptive detail on the ways in which the regulators assess whether international applicants meet their standards for registration, these changes will support the GDC and NMC to introduce processes which are more streamlined for applicants, rather than less so. However, it will be for the regulators as independent bodies to decide how best to use this flexibility and what processes they need to put in place to be assured that international entrants to their registers have the required knowledge, skills and experience.
Question 21
Do you have any further comments on the Draft Order itself?
Table 24: summary of responses to question 21
| Category | Number of responses | Percentage |
|---|---|---|
| Yes | 168 | 10% |
| No | 1361 | 83% |
| Unknown | 105 | 6% |
| Total | 1634 | 100% |
Note: percentage figures have been rounded and therefore may not total 100%.
Analysis
The majority of respondents (83%) did not have any further comments on the Draft Order. An analysis of those who commented (10%) revealed that the ORE exam process was a concern to many respondents. Many respondents felt that the exam needed to be improved. Suggestions included the provision of more sittings, the removal of the 5-year rule and an increase in the number of ORE part 2 exam re-sits candidates are allowed to take (which is currently limited to 4). Some respondents also commented that extra time should be provided to candidates who were affected by the suspension of the exam due to the coronavirus (COVID-19) pandemic.
A number of respondents stated that they did not want the legislative changes to result in more complex registration processes or higher applicant fees, particularly for dentists. Many people also reiterated their concerns about the proposal to prevent international dentists registering under DCP titles in future. A few respondents highlighted their concern for the mental health and wellbeing of international applicants subject to current processes as a further reason for simplifying these. Others argued that simplified registration processes would also support the increased supply of competent healthcare professionals into the NHS workforce.
Some respondents commented that greater clarification and detail is needed about the resulting policy GDC and NMC changes that may follow the legislative changes.
Government response
Since the draft Order was published as part of the consultation, an amendment has been made to allow the GDC to continue to process DCP registration applications from international applicants holding a diploma in dentistry. This will mean that any dentist applicants with a ‘live’ DCP title application submitted before the legislation is passed are able to complete the registration process. The additional drafting can be seen at paragraph 2 of Schedule 5 to the Order, which is published alongside this document.
As set out in the introduction, the government intends to move forward with all the proposals we consulted on to change the GDC’s and the NMC’s legislation for international registration.
Conclusion and next steps
The government is grateful to those who responded by taking the time to provide wide ranging comments on this consultation.
After consideration of the responses received as part of this consultation the government plans to move forward with the proposals and lay the Order published alongside this report in Parliament for debate in late 2022.
The changes will be made via a Section 60 Order which is a legislative vehicle used to amend legislation relating to regulated health professions under the affirmative resolution procedure.
We will continue to work with the regulatory bodies to understand what changes they plan to make following the introduction of the increased flexibility that the changes provide. In taking forward any changes to their international registration processes, the regulators will also need to have regard to commitments made within free trade agreements, such as commitments made in the EEA EFTA agreement on recognition of professional qualifications. At present we understand that:
- pending the agreement of its Council, the GDC plans to publish draft rules for consultation on the future operation of the ORE which will enable it to increase the capacity of the assessment. The regulator will then introduce changes to the operation of the assessment after the 12 months during which the current legal framework will remain in place
- the GDC will be developing further proposals, using new flexibility arising from these changes to its legal framework, to make the routes to international registration as a dentist or DCP more effective while maintaining the necessary standards for public protection. All future proposals will be subject to approval from the Council and public consultation before they are implemented
- in addition, following the introduction of any future regulations under the Professional Qualifications Act, the GDC will be responding to any requirements for mutual recognition under UK trade deals, such as the EEA EFTA trade deal, and exploring if there are opportunities to enter into mutual recognition arrangements outside of trade deals where the public’s protection can be assured through comparable regulatory oversight of dental education
- the NMC will consider how the additional flexibility delivered by these changes can help it deliver an improved international registration process and will continue to look at ways to streamline its processes