National Health Service (General Dental Services) (Scotland) Amendment Regulations 2025: final business and regulatory impact assessment

Introduction

This is a final BRIA for The National Health Service (General Dental Services) (Scotland) Amendment Regulations 2025. The SSI will amend the NHS (General Dental Services) (Scotland) Regulations 2010 in relation to two distinct aspects to make changes to:

• one of the bases on which prior approval of dental treatment is required; and
• the requirements around mandatory training for dentists who wish to provide NHS dental services in Scotland.

Prior Approval

Prior approval by the Scottish Dental Practice Board (SDPB) is a method of reviewing dentists’ treatment plans, as part of the clinical governance of NHS dentistry. Currently, dentists are required to submit for prior approval any course of treatment where the cost will exceed £660.

From 1 November 2023, the Scottish Government introduced significant reforms to the NHS dental payment system, moving to a high-trust, low bureaucracy model, which focuses on modernised service provision through clinical discretion and patient-centred care based on need. Within this we made substantial improvements to the fee structure, designed to incentivise dentists to provide more NHS care, and in turn improve patient access to services. As a result of the new payment system, there has been an increased volume of low clinical risk treatment plans being submitted for prior approval, which can result in delays to necessary treatment for patients due to a financial limit rather than for any clinical considerations. Therefore, this SSI will make changes to the prior approval system for dental treatment by changing the basis on which prior approval of treatment is required to ensure that clinical considerations are prioritised in the approval system for dental treatment.

Mandatory Training

At present dentists who wish to provide NHS dental services in Scotland for the first time, or after a break of 12 months or more (subject to some exceptions), have to complete a course of mandatory training and undertake a test of knowledge before they can join a dental list. The mandatory training courses are currently offered four times per year which can mean a dentist may have to wait for several months before they can undertake the mandatory training. This can result in dentists choosing not to work in Scotland at all or choosing to only provide private dental services. Therefore, in order to improve access to NHS dental services, whilst also maintaining appropriate oversight and governance of dentists joining a dental list in Scotland, this SSI will make changes to the requirements in place for mandatory training to allow a dentist to join a dental list on a provisional basis for a period of up to 6 months. At the end of the 6 months period, if the dentist has successfully completed mandatory training and the test of knowledge they will be able to remain on the dental list. If they have been unsuccessful they will be removed from the dental list and will be unable to reapply to join a list until they have successfully completed the required training.