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

Executive summary

Issue and why it needs to be addressed

Prior Approval

Following the introduction of dental payment reform, the requirement for prior approval based on the cost of the course of treatment is not aligned with the new high-trust, low bureaucracy model, which focuses on modernised service provision through clinical discretion and patient-centred care based on need. Therefore, changes are required to ensure that clinical considerations are prioritised in the approval system for dental treatment and reduce delays for patients in accessing treatment.

Mandatory Training

At present some dentists require to complete mandatory training before they are able to join a dental list. Mandatory training courses are run four times per year which can mean a dentist may have to wait for several months before they can undertake the training. This can result in dentists choosing not to work in Scotland at all or choosing to only provide private dental services. As access to NHS dental services remains challenging in some areas of Scotland, allowing dentists to join a dental list on a provisional basis will be beneficial in improving access. 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.

Intended outcomes

The overall purpose of these policy proposals is to improve access to NHS dental services for patients.

Options

As the requirements for both prior approval and mandatory training are set out in the regulations, the only option for making changes/improvements is to take forward an amendment to the regulations.

Sectors affected

These changes will affect the dental sector, specifically dentists and dental practices.

Engagement completed, ongoing and planned

Engagement has been undertaken with relevant stakeholders and organisations involved in the administration and management of the proposed changes. Engagement will continue with these bodies throughout the implementation process.

Anticipated impacts (intended and unintended, positive and negative) and mitigating actions

We expect that these changes will be neutral or positive in impact.

Prior Approval

The changes to prior approval will prevent low clinical risk treatment plans requiring prior approval, enabling practices to have a more effective throughput of patients. It will also support dentists to use their clinical judgement in treatment planning whilst still ensuring an appropriate level of governance for high risk treatment plans.

Mandatory Training

The changes to mandatory training will not affect the majority of practices, but it may have some benefit in areas with lower level of recruitment, e.g. rural areas.

Enforcement/ compliance

Guidance regarding these changes will be issued to the dental sector in advance of the changes coming into force and the required updates to practice management software and processes will be put in place.

Recommendations/ implementation plans

Ministers have decided to bring forward an SSI which will amend The National Health Service (General Dental Services) (Scotland) Regulations 2010 to enable these changes.

Evaluation and monitoring of implementation/ review of BRIA

The outcome of the proposed changes will be measured through official statistics and relevant management information from NSS, who are responsible for administering prior approval on behalf of the Scottish Dental Practice Board.