Closed consultation

Proposal for a ‘tie-in’ to NHS dentistry for graduate dentists

Published 23 May 2024

Applies to England

Ministerial foreword

I want to thank our excellent dental workforce for all their efforts, as we have seen real improvements over the past year. There has been a positive trend in the recovery of NHS dentistry following the pandemic thanks to the hard work of NHS dentists and their teams. As set out in our plan to recover and reform NHS dentistry, our ambition is to improve access to NHS dental care so that those who need to see a dentist are able to.

We are working on further reforms to the 2006 contract, in discussion with the profession, to properly reflect the care needed by different patients and more fairly remunerate practices. We are supporting our excellent dental staff to work at the top of their training, and encouraging more hard-working dentists to those areas of England that are currently underserved. And we are focusing on prevention by supporting families to ensure that every baby has the best start for life, and that our family hubs and settings that provide Start for Life services are promoting the importance of good oral hygiene for pregnant mums and babies.

To further support our ambitions on NHS dental care, we are proposing that graduate dentists spend at least some of their time delivering NHS care in the years following the completion of their training.

Dental students in England receive a fantastic deal, with access to high quality education and training supported by a significant investment by the taxpayer. Working in the NHS gives dental graduates the best start to their careers, by giving them the broadest range of experience, great support from strong teams of dental professionals and the most comprehensive training. Experience in NHS dentistry helps to produce well-rounded clinicians who can work alongside different professions and deliver high quality, safe patient care, and can be supplemented by additional work in private dentistry. This balance is better for our skilled dental workforce and better for the patients they treat.

We believe that it is right and fair that graduate dentists invest their skills and expertise in the NHS, much as the taxpayer invests in their education and training.

We want to ensure that all voices from professionals, organisations and members of the public can be heard and carefully considered as we take this important step to deliver our plan to make dental services faster, simpler and fairer.

The Rt Hon Andrea Leadsom MP
Minister for Public Health, Start for Life and Primary Care

Introduction

This consultation is part of the government’s plan to recover and reform NHS dentistry, and builds on the actions in the NHS Long Term Workforce Plan (LTWP).

Between 2020 and 2022, at least 7 million fewer patients saw an NHS dentist compared with pre-pandemic levels as a result of the pandemic (2022 data compared with 2019). Following the pandemic, patients seeking dental care have found it difficult to get the care they need.  

On 7 February 2024 we published Faster, simpler and fairer: our plan to recover and reform NHS dentistry (dentistry recovery plan), to help the sector to recover activity more quickly by addressing underlying issues and setting out the action needed for longer term reform of the system. Our commitment is to improve access to NHS dental care so that those who need to see a dentist are able to, especially in underserved parts of the country. 

Supporting our dedicated dental workforce is of utmost priority. The Department of Health and Social Care (DHSC) and NHS England will review what further actions can be taken to support professional development within NHS dentistry, to make NHS dental care an attractive career choice where all professionals can work to their full scope of practice.

Working in the NHS offers dental graduates the best start to their careers, by providing early career exposure to a diverse patient base, ensuring dentists develop a well-rounded skill set and can offer comprehensive dental care to a high standard.

The taxpayer makes a significant investment in the education and training of dentists in England. The government believes this investment should be reflected in the availability of NHS dentistry, especially given the current challenges around patient access to dental services.

This consultation seeks the views of interested parties on the proposal for a ‘tie-in’ to NHS dentistry for newly qualified dentists. This would ensure that graduate dentists spend at least some of their time delivering NHS care in the years following the completion of training.

This consultation is aimed at those who have an interest in the policy proposal, whether professionals, organisations or members of the public.

Background

NHS Long Term Workforce Plan

The first ever LTWP, published by NHS England on 30 June 2023, was commissioned by the government to set out a series of interventions to train, retain and reform the workforce, and put the NHS on a sustainable footing into the future. The government has backed the plan with over £2.4 billion to fund additional education and training places over 5 years on top of existing funding commitments.

As set out in the LTWP, we will grow the dental workforce in England by expanding dentistry training places to a record-breaking level. We will expand dentistry training places by 40% so that there are over 1,100 places by 2031 to 2032.

The LTWP also committed to explore measures such as a tie-in period to encourage dentists to spend a minimum proportion of their time delivering NHS care in the years following graduation.

Faster, simpler and fairer: our plan to recover and reform NHS dentistry

The government’s dentistry recovery plan, published on 7 February 2024, will make dental services faster, simpler and fairer for patients and will fund up to 2.5 million additional appointments (or more than 1.5 million additional courses of dental treatment). 

The NHS in England invests £3 billion on dentistry every year and our plan to recover and reform NHS dentistry is a fully funded plan of £200 million. The plan sets out a number of actions which will improve access for patients, by helping the sector to recover activity more quickly, addressing underlying issues and setting out the action needed for longer term reform of the system. Longer term, we will grow the workforce and work with dentists and other dental care professionals so that more people will want to deliver valuable, high quality NHS dental care.

Actions include, but are not limited to:

• a new patient premium, which is supporting dentists to take on new patients, and a new marketing campaign, which is helping everyone who needs one to find an NHS dentist
• new dental vans, which will bring dental care to our most isolated communities
• ‘golden hello’ incentives, which will encourage dentists into underserved areas

We have further supported dentists by raising the minimum unit of dental activity (UDA) rate to £28 this year, making NHS work more attractive and sustainable.

The plan also sets out the government’s concern that a proportion of newly qualified dentists are opting to go straight into private practice after graduating, or are choosing to deliver little to no NHS work shortly after completing their foundation training. We are working on further reforms to the 2006 contract, in discussion with the profession, to properly reflect the care needed by different patients and more fairly remunerate practices. In addition to these changes, and building on the commitments in the LTWP, the government committed to launching a consultation on introducing a ‘tie-in’ for graduate dentists. For clarity, we define a ‘graduate dentist’ as an individual who has qualified as a dentist following completion of training at a university in England. We define ‘training’ in this context as an undergraduate or graduate-entry dental course at a university in England; postgraduate and/or other training is specified by name in this consultation.

Education and training pathway for dentists in England

To become a dentist in the UK an individual must complete a dental course approved by the General Dental Council (GDC), leading to a bachelor’s degree. This can be an undergraduate course, which usually lasts for 5 years, or a graduate-entry programme, which usually lasts for 4 years. Upon graduation, the individual is eligible for registration as a dentist with GDC. Once qualified and registered, a dentist can provide unsupervised dental care to private patients.

However, there is currently no requirement for dentists to work in the NHS following completion of funded training.

To work in NHS dentistry a dentist must subsequently complete postgraduate dental foundation training (DFT), working in an approved practice and receiving supervised training and assessment, which usually lasts for one year.

Upon completion of DFT, most dentists choose to work in a ‘high street’ primary care dental practice as an associate, where they can provide NHS dental care. Other career options for dentists include working in hospitals, community dentistry or dental public health.

Following completion of DFT, dentists can choose to take further optional postgraduate dental core training (DCT) in a secondary care or specialised primary care environment. This can last for up to 3 years, but applicants can also train for just 1 or 2 years.

After completion of the second year of DCT, dentists are eligible to apply to enter optional dental specialty training (for example, orthodontics, periodontics and oral surgery). This will run for between 3 and 5 years depending on the specialty.

Education and training funding

The government estimates that training an individual dentist from the beginning of dental school through to graduation can cost up to approximately £292,000.

Of this cost, up to approximately £94,000 in real terms is eligible to be repaid by the student to the Student Loans Company over a period of up to 40 years once the student becomes eligible to make repayments. As of the 2024 to 2025 academic year, dental students can apply for a tuition fee loan from Student Finance England for each of the first 4 years of study, which the student will start to repay following graduation. Students will also start to repay any maintenance loan for living costs paid by Student Finance England following graduation. From year 5 of an undergraduate course, and from year 2 of a graduate-entry course, dental students can access the NHS bursary. This is non-repayable and comprises payment for tuition fees and, where eligible, further grants and allowances.

Undergraduate dentistry is an expensive course to deliver. The fees paid by dental students do not cover the full cost of providing dental education and training. Funding is given to universities in recognition of these additional costs for specialist staff, equipment and facilities. Dental students also spend a significant amount of time undertaking clinical placements with healthcare providers, which receive funding for delivering placements. Approximately, the taxpayer invests in the region of £200,000 in the education and training of each individual dentist, excluding those costs eligible for repayment by the student.

An approximate breakdown of the maximum cost of training an individual dentist from the beginning of an undergraduate course at dental school through to graduation is included in the table below. These costs are based on the latest published figures and assume a student is eligible for the maximum level of support.

Table: the cost of undergraduate dental training in England [note 1]

Type of undergraduate training cost [note 2]	Approximate maximum cost	Repayable status
Tuition fee loan (years 1 to 4) [note 3]	£37,000	Repayable by student
Maintenance loan (years 1 to 4) [note 3]	£53,392	Repayable by student
Strategic priorities grant (year 1 to 5) [note 4], [note 5]	£46,854	Non-repayable
Clinical placement costs (years 2 to 5) [note 6]	£136,596	Non-repayable
NHS bursary tuition (year 5) [note 7]	£9,250	Non-repayable
NHS bursary maintenance (year 5) [note 7]	£5,487	Non-repayable
Reduced rate maintenance loan (year 5) [note 8]	£3,658	Repayable by student
Total	£292,237	Not applicable

Note 1: the table does not include funding that could be made available for a student for an intercalation year.

Note 2: assumes no uprating applied to loan amounts over time, and maximum loan value for maintenance as the London rate.   

Note 3: source: Student finance for undergraduates: new full-time students (GOV.UK)

Note 4: strategic priorities grant (SPG) costs referenced above represent the grant funding to providers for the high-cost subjects element of the SPG for the dental provisions. Excluded from this amount are all other SPG grants funding to providers associated with student costs.

Note 5: source: Funding for academic year 2023 to 2024 (Office for Students)

Note 6: source: Healthcare education and training tariff: 2023 to 2024 (DHSC)

Note 7: source: NHS bursary students (NHS Business Services Authority)

Note 8: source: NHS bursaries: what you’ll get (GOV.UK)

Summary of proposal

The need for an NHS ‘tie-in’

The NHS LTWP commits the government to grow the dental workforce in England by expanding training places to a record-breaking level. From 2031 we will be training more than 1,100 dentists each year, compared with approximately 810 dentists each year currently.

However, having more dentists is not the sole solution to current workforce challenges in NHS dentistry.

More than 35,000 dentists are registered with GDC in England as of 15 May 2024. However, only 24,151 dentists delivered at least some NHS care in England in 2022 to 2023. This means that nearly one-third of registered dentists are not contributing to NHS dentistry and may be exclusively working in private practice. Of the approximately two-thirds that are delivering NHS dental activity (see Regional performer by UDA delivery for financial year (FY) 2016 to 2017 to FY 2022 to 2023), many are doing so on a less than full time equivalent (FTE) basis and some are making only a token commitment to NHS dentistry.

While there is certainly a role for private dentistry, we need dentists to do more NHS work alongside, or instead of, their private work. In July 2022 we announced a package of reforms to improve access to NHS dentistry as detailed in Our plan for patients. We have already made changes to tackle some of the problems identified with the current contract and have committed to further reform.

Most newly qualified dentists develop their career in the NHS by taking up postgraduate DFT. DHSC is concerned that a growing proportion are opting to go straight into private practice after graduating, or are choosing to deliver little to no NHS work shortly after completing DFT.

As set out in detail above, the government estimates that training an individual dentist from the beginning of dental school through to graduation can cost up to approximately £292,000, of which costs in the region of £200,000 are not repayable by the student. The government believes it is right and fair to seek better value for the significant investment that the taxpayer makes in the education and training of the dental workforce. That’s why the government’s dentistry recovery plan committed to launch a consultation on introducing a ‘tie-in’ for graduate dentists.

A ‘tie-in’ policy had previously been considered for medical students and was consulted on by government in 2017. There was some agreement from organisations that responded on the principle that the taxpayer should expect to see a return on the investment it has made in medical education, but from individual respondents, the majority disagreed. Given responses to the consultation, and that the vast majority of doctors practise in the NHS following graduation, the proposal was not pursued further. General Medical Council data shows that approximately 7% of doctors do not hold a licence to practice 5 years after foundation year 2 (equivalent to approximately 450 doctors) – a relatively small number. A graduate medic in the UK must undertake one year of foundation training to register as a doctor, followed by an additional year of foundation training and at least 3 years of general practice specialty training to become a GP. By comparison, a graduate dentist is immediately able to register as a dentist and practice dentistry unsupervised, including in private practice, with no requirement to work in NHS dental services.

Proposal to mandate NHS service for graduate dentists

The introduction of a minimum NHS service requirement, or ‘tie-in’, for graduate dentists would aim to ensure that newly qualified dentists spend at least some of their time delivering NHS dental care in the years following the completion of training.

The proposal is envisaged for the NHS to retain dentists who otherwise may have only delivered private practice, or very little NHS practice, in the years following graduation.

DHSC considers a minimum commitment as a period of time in which graduate dentists should be expected to deliver NHS dental care as a minimum proportion of their time or activity, alongside or instead of private dental care. NHS dental care may include working in a ‘high street’ primary care dental practice, secondary care, community dentistry or dental public health.

DHSC seeks views on whether the taxpayer believes that it should see a return on its investment in the education and training of dentists, what form this may take, and the length of time this could apply for. For example:

• newly qualified dentists should commit to delivering at least a minimum amount of NHS dental care, for a minimum number of years after graduating
• newly qualified dentists should repay some of the public funding invested in their education and training if they do not deliver a minimum amount of NHS dental care

Subject to the results of this consultation, DHSC will consider the impact of these proposals and explore the proposed policy further. For the avoidance of doubt, any future minimum NHS service requirement for graduate dentists would not apply to those currently undertaking a dental course of study, and any changes would be advertised to prospective students in advance of applications to study dentistry. Additionally, DHSC will consider how such a system can be flexible to consider individuals’ unique working patterns and circumstances.

The morale and wellbeing of our dental workforce is of utmost priority. DHSC and NHS England will review what further actions can be taken to support professional development within NHS dentistry, to make NHS dental care an attractive career choice where all professionals can work to their full scope of practice.

We also recognise that circumstances may exist where a graduate dentist may be unable to fulfil a minimum service requirement due to unforeseen or exceptional circumstances and this will be considered as part of policy development.

Consultation questions

Question

Do you agree or disagree that dentists should make a minimum commitment to NHS dentistry, in return for the taxpayer’s investment in their education and training?

• Strongly agree
• Agree
• Neither agree or disagree
• Disagree
• Strongly disagree

Question

Do you agree or disagree that graduate dentists should spend a proportion of their time working in NHS dentistry in the years after completing training?

• Strongly agree
• Agree
• Neither agree or disagree
• Disagree
• Strongly disagree

Please explain your answer. (Maximum 500 words)

Question

For how many years do you think that graduate dentists should make a minimum commitment to work in NHS dentistry?

• I do not think that any minimum commitment should be required
• 2 years or fewer
• 3 or 4 years
• 5 or 6 years
• More than 6 years

Question

If a graduate dentist chooses not to make a minimum commitment to work in NHS dentistry, do you agree or disagree that they should be required to repay some or all of the public funding invested in their education and training?

• Strongly agree
• Agree
• Neither agree or disagree
• Disagree
• Strongly disagree

Please explain your answer. (Maximum 500 words)

Question

Please share any further comments on how the government can ensure better value for the taxpayer’s investment in the education and training of dentists. (Maximum 500 words)

How to respond

Please respond using the online survey. We welcome responses from any interested person or organisation.

The consultation is open for 8 weeks and will close at 11:59pm on 18 July 2024. If you respond after this date, your response may not be considered.

If you have any queries on this consultation, please contact [email protected]. Do not send your consultation answers or any personal information to this email address.

Privacy notice

Summary of initiative or policy

DHSC is seeking the views of interested parties on the proposal for a ‘tie-in’ to NHS dentistry for newly qualified dentists. This would ensure that dentistry graduates spend at least some of their time delivering NHS care in the years following the completion of undergraduate training.

Data controller

DHSC is the data controller.

What personal data we collect

We will collect data on:

• whether you are responding as an individual member of the public, an individual sharing your professional views, or on behalf of an organisation
• the name of your organisation, where your organisation operates or provides services
• the sector of your organisation, if responding on behalf of an organisation
• the country you live in
• your internet protocol (IP) address (this is for security purposes and will not be attached to your survey response)

If volunteered by you, we will also collect data on:

• your personal characteristics (including your age, sex, ethnicity and whether you consider yourself to have a physical or mental health condition)
• your email address
• any other personal data you may provide in response to open-ended questions in the survey

How we use your data (purposes)

Your data will be treated in the strictest of confidence.

We collect your personal data as part of the consultation process:

• for statistical purposes - for example, to understand how representative the results are and whether views and experiences vary across demographics
• if you need to contact DHSC about amending or deleting your response, the only way DHSC can verify that it is your response is via your email address
• if you didn’t have time to finish the survey, we can send you a reminder before it closes

Legal basis for processing personal data

Under Article 6 of the United Kingdom General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this personal data is:

• public task: the processing is necessary to perform a task in the public interest or for our official functions

In addition, we are also processing special category data under the following condition as per Article 9 of the UK GDPR:

• health or social care

Data processors and other recipients of personal data

Responses to the online consultation may be seen by:

• data analysts and officials in DHSC supporting dental workforce policy
• DHSC’s third-party supplier (SocialOptic), who is responsible for running and hosting the online survey

International data transfers and storage locations

Storage of data by DHSC is provided via secure computing infrastructure on servers located in the European Economic Area (EEA). Our platforms are subject to extensive security protections and encryption measures.

Storage of data by SocialOptic is provided via secure servers located in the United Kingdom (UK).

Retention and disposal policy

DHSC will only retain your personal data for up to one year.

SocialOptic will securely erase the data held on their system 6 months after the online consultation closes, or when instructed to do so by DHSC if the data has served its intended purpose (whichever happens earlier).

Data retention will be reviewed on an annual basis. Anonymised data will be kept indefinitely.

How we keep your data secure

DHSC uses appropriate technical, organisational and administrative security measures to protect any information we hold in our records from loss, misuse, unauthorised access, disclosure, alteration and destruction. We have written procedures and policies which are regularly audited and reviewed at a senior level.

SocialOptic is Cyber Essentials certified.

Your rights as a data subject

By law, data subjects have a number of rights, and this processing does not take away or reduce these rights under the EU General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018 applies.

These rights are:

• the right to get copies of information - individuals have the right to ask for a copy of any information about them that is used
• the right to get information corrected - individuals have the right to ask for any information held about them that they think is inaccurate to be corrected
• the right to limit how the information is used - individuals have the right to ask for any of the information held about them to be restricted - for example, if they think inaccurate information is being used
• the right to object to the information being used - individuals can ask for any information held about them to not be used. However, this is not an absolute right, and continued use of the information may be necessary, with individuals being advised if this is the case
• the right to get information deleted - this is not an absolute right, and continued use of the information may be necessary, with individuals being advised if this is the case

Comments or complaints

Anyone unhappy or wishing to complain about how personal data is used as part of this programme should contact [email protected] in the first instance or write to:

Data Protection Officer
1st Floor North
39 Victoria Street
London
SW1H 0EU

Anyone who is still not satisfied can complain to the Information Commissioner’s Office.

Their postal address is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Automated decision making or profiling

No decision will be made about individuals solely based on automated decision making (where a decision is taken about them using an electronic system without human involvement) which has a significant impact on them.

Changes to this policy

We keep this privacy notice under regular review, and we will update it if necessary. All updated versions will be marked by a change note on the consultation page. This privacy notice was last updated on 23 May 2024.