GDC & GMC
This one page summary was written to reassure dentists working in medical specialties (such as OMFS, ENT or currently in COVID patient care) that they would not be at risk of 'scope of practice' litigation from their regulator - the General Dental Council.
Dental registration of OMFS Specialists
Do OMFS consultants need to be on the register to practice in the medical specialty of OMFS?
December 2019 update: GDC have now clarified their position
GDC confirms position on dual registration: from GDC website
The GDC is currently reviewing the need for dual registration with the GMC and GDC, including the need for oral and maxillofacial surgeons (OMFS) to maintain GDC registration. Pending the outcome of that review, we are issuing this statement in order to clarify the current position. This statement is not a new position. It simply restates the existing position as set out in 2008 and clarified in 2014. Neither does it indicate or in any way bind the outcome of the full review.
Tasks that constitute the practice of dentistry are in most circumstances only able to be lawfully performed by GDC registrants. There are certain limited circumstances in which a suitably qualified and registered medical practitioner may perform tasks which would otherwise require GDC registration. Those circumstances require the task in question to be performed as an essential part of a necessary medical or surgical procedure. This is in addition to medical tasks that can be undertaken by suitably qualified and registered healthcare professionals to deal with dental emergencies.
Pending its final position, to be announced in due course, the GDC will not require dual registration from an individual who is appropriately qualified and registered with the General Medical Council (GMC) and who is working or training as an OMFS, to perform tasks that would otherwise be the practice of dentistry, insofar as those tasks are being undertaken as part of their role within an oral and maxillofacial surgery setting. In all other circumstances, including the practice of dentistry outside their role as an OMFS and the supervision of registered dental students or temporary registrants, registration with the GDC will be required.
Dentists Act 1984, amended 2005 – Medical Task
“(1A) For the purposes of this Act, the practice of dentistry shall be deemed not to include the performance of any medical task by a person who:
- (a) is qualified to carry out such a task; and
- (b) is a member of a profession regulated by a regulatory body (other than the Council) listed in section 25(3) of the National Health Service Reform and Health Care Professions Act 2002.”
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Background: GDC & GMC - update from 2014
OMFS, as a dual degree specialty, must interact with both the medical (General Medical Council – GMC) and dental (General Dental Council – GDC) regulators.
The 2008 documents below were generated after trainee doctors working in and OMFS department were reported to the GDC for ‘illegal practice of dentistry’ because they were being trained in dentoalveolar surgery but were not yet dentists.
In 2014, after a meeting with the General Dental Council to discuss the issue of ‘double jeopardy’ for OMFS specialists – a short hand description of the fact that patient complaints about OMFS specialists would be processed separately and treated differently by both regulators – the GDC agreed that OMFS specialists could practice without dental regulation.
The 2014 notes (which are GDC notes of a meeting with BAOMS representatives) the GDC said that an OMFS consultant could work in hospital practice without dental registration and that it did not feel dual registration was necessary. Dental registration would be needed to ‘work in a dental practice or somewhere that looked like a dental practice’. BAOMS sought clarification on this but none has been forthcoming to date.
PMETB Review 2008
In June 2006, the Department of Health wrote to PMETB to request that the Board lead a review of the specialty training programme for Oral and Maxillofacial Surgery across the four nations of the UK.
The primary purpose of the review was to determine whether the current OMFS training programme was fit for purpose - the outcome was that it was, and the board made several recommendations as to how it could be streamlined.