The British Dental Association (BDA) wrote to the General Dental Council (GDC) to call on it to reject all three proposed options for a rise in the annual retention fee (ARF) ahead of its meeting last week.
It outlined six reasons for members to vote against the three tabled proposals, arguing that the GDC has repeatedly altered the methodology and justification for its proposals.
The BDA revealed the regulator had painted an alarmist and inaccurate picture of rapidly accelerating complaint levels. Documents published in June told consultees that it expected complaints to rise to 3,500 this year – however analysis of figures in a recent KPMG review saw that figure “adjusted downwards throughout the budget process”. The new figure is now 3,000 cases for 2014 – just ten more than the actual activity level for 2013.
The BDA revealed that the options facing council members are focusing entirely on the cash held in the regulator’s reserves – options that did not feature in the consultation. The Association is now awaiting a court date following an application for Judicial Review over the regulator’s handling of the fee rise.
Mick Armstrong, Chair of the British Dental Association’s Principal Executive Committee, said:
The GDC’s case for a fee hike is built on sand. It based its sums on historical trends that are indispensable one minute, ‘unreliable’ the next. It claims complaints are going through the roof, then suddenly we’re looking at levels identical to last year.
We’ve stepped into a twilight zone where zero growth in complaints warrants an unprecedented fee rise. Where at the eleventh hour it reveals that the final choice will hinge not on day-to-day operations, but on the cash it holds in its reserves.
We have seen our professional regulator busy peddling unreliable data, and forming even more unreliable conclusions. What we haven’t seen is anything resembling a credible argument for a fee rise.
So when GDC members gather this Thursday they can turn the page on this shameful chapter, by rejecting all three options that have emerged from this flawed consultation. Then they must look to the future. They have reserves to cope in 2015, and should take the opportunity to run a full, detailed and fair consultation in 2015.
Six reasons to reject the #ARFhike:
i. The GDC has shifted its position from one heavily reliant upon the extrapolation of supposed historic trends to one where historic trends are deemed to be unreliable as predictors. As a result, we believe that the central premise of the GDCs case as outlined in the consultation document for a fee rise has been shown to be fundamentally flawed.
ii. The GDC has now produced a completely different baseline to the one which consultees were asked to consider. Moreover consultees, despite timely requests for further information, have been denied the opportunity to comment on the actual data upon which the decision will be made.
iii. The GDC has now “scaled down” the estimated complaints level to a figure in line with the known figure for last year. If there is no growth there is no justification for a fee rise.
iv. The GDC has applied an unexplained growth level of 17 per cent to the number of complaints in 2015. The percentage increase remains unexplained and unevidenced, as is any asserted relationship between the number of complaints and the number of fitness to practise hearings. In fact, as the GDC’s own Director of Finance and Corporate Services appears to have acknowledged past complaint levels are not a reliable guide to future trends.
v. The GDC’s proposal in the consultation is a three year plan and there is no business case that justifies such a long term plan being made on such unreliable data. We remind the Council the GDC’s own policy is that so much and no more should be raised by way of ARF than is essential for the discharge of the GDCs statutory functions.
vi. The options proposed by GDC management to Council members focus solely on reserves policy rather than operational implications. To make a decision based upon the reserves of the GDC is totally at odds with the consultation process in that a change in the reserves policy was something that did not feature as an option put to consultees.
A copy of the letter sent to the GDC is available to download.