GDC Consultation
Guidance on principles of management responsibility
By Richard Daniels
In reply to concerns that DLA consultation responses do not always reflect the needs of the membership, I am offering all DLJ readers the opportunity to read and respond to the recent GDC Consultation for the Guidance on Principles of Management Responsibilities.
This consultation will have an impact on all dental laboratory owners and dental laboratory managers, so it is important you take the time out to think about what the proposed guidance means to you and your working environment. There are 3 specific questions that require a response, which are listed in this article.
Draft guidance on the principles of management responsibility
One of the changes to the Dentists Act which came into force in July 2006 was to open up ‘the business of dentistry’ to dental care professionals(1) as well as dentists. This means that all members of the registered dental team can now receive payment for dental treatment, own dental practices and dental laboratories and employ other members of the dental team.
Another of the changes to the Act was to remove the limit on the number of Dental Bodies Corporate (DBCs) which can exist, meaning that any dental practice or group of practices can now become a corporate body.
In the light of these changes, the Council felt that it would be helpful to give guidance to registrants about their responsibilities when acting in a business capacity. The original intention was to produce guidance for registrants who are directors of DBCs. However the principles apply to any registrant who has a management role, whether that is in a DBC, a Primary Care Trust, a practice, a dental laboratory or elsewhere and the guidance has been widened to reflect that.
We would welcome your comments on the draft guidance, including:
- Whether you agree with the principles set out
- Whether you think that there is anything that should be added, and
- Whether you think that there is anything that should not be included
We look forward to hearing from you.
(1) ‘Dental Care Professionals’ means dental nurses, dental hygienists, dental therapists, orthodontic therapists, dental technicians and clinical dental technicians.
Guidance on principles of management responsibility
About this guidance
This guidance is for dental professionals who are in a position of management responsibility in dentistry. This includes those who are Directors of Dental Bodies Corporate (DBCs), those with a role in the management structure of dental health care organisations, and those who own or are responsible for running dental practices or dental laboratories. Management roles may involve responsibility for people and resources.
‘Standards for dental professionals’ sets out the six main principles which you should apply to your work as a dental professional. It is your responsibility to apply these principles to your daily work, using your judgement in the light of the principles.
‘Standards for dental professionals’ says: ‘Put patients’ interests first and act to protect them’
- Put patients’ interests before your own or those of any colleague, organisation or business
This guidance expands on how you should apply this principle to your daily work in your management role. It supports, and should be read in conjunction with, the other guidance in the ‘Standards for dental professionals’ series. As a GDC registrant, you are personally accountable to the GDC for your behaviour. This applies to any work you are involved in as a dental professional, including your behaviour as a director of a DBC, dental practice or dental laboratory owner or in a managerial role in a dental healthcare organisation or practice. This remains the case where a non-dental professional could perform your managerial role.
This means that you have a professional responsibility to be prepared to justify your actions in your managerial role in dentistry, as well as in any clinical role, and we may ask you to do so. You must be willing and able to show that:
- You are aware of ‘Standards for dental professionals’ and the guidance documents that support ‘Standards for dental professionals’, including this one; and
- You have followed the principles explained in the guidance documents
If you cannot give a satisfactory account of your behaviour or practice in line with the principles explained in the ‘Standards for dental professionals’ guidance, your registration will be at risk.
1. Your own behaviour
1.1 Put patients’ interests before your own or those of any colleague, organisation or business. If managerial concerns conflict with your primary duty to put patients’ interests first, raise your concerns formally, either with management colleagues, with external professional bodies, or with your defence organisation. If at any time you are not sure how to continue, contact us.
1.2 Make sure you work within your knowledge and competence as a director or manager. Keep up to date with and use guidance on the knowledge, skills and attitudes necessary to carry out your directorial or management responsibilities.
1.3 Be aware of your legal responsibilities as a director, owner or manager and make sure that you fulfil them.
1.4 Understand and fulfil your legal and ethical responsibilities in relation to equality and diversity.
1.5 As a director, owner or manager, justify the trust that your patients, the public, those you direct or manage and other colleagues have in you by always acting honestly and fairly.
1.6 Be open and honest in any financial and commercial dealings you are responsible for as a director, owner or manager.
1.7 Make sure that you do not compromise the interests of patients by allowing financial or other targets to have a negative influence on the quality of care which you or those you direct or manage provide.
1.8 If you delegate your managerial responsibilities, make sure that the person you delegate them to is competent to do what you are asking them to do. You will still be responsible and accountable to the GDC for the overall management of the tasks you have delegated.
1.9 Make sure that systems are in place in the organisation you work for to provide early warning of any concerns about the health, behaviour or professional performance of any staff you direct or manage, or of concerns about any aspect of the clinical environment, and that such concerns are addressed promptly and effectively.
1.10 If you have any concerns that an organisational decision, or any activity within the organisation would put patients at risk, make sure that you raise that concern with your colleagues. This includes any decisions or actions which would compromise patient safety, or the wider public interest (for example, dishonest behaviour). If your concern is ignored or inadequately dealt with, take advice, for example from external professional bodies. Follow our guidance ‘Principles of raising concerns’.
2. The behaviour of others within your organisation
2.1 As a director, owner or manager within an organisation, you are in a position to influence the way in which the organisation works and the way in which the people within it work. You have a responsibility not only to follow the principles in ‘Standards for dental professionals’ yourself, but to promote them to others within your organisation.
2.2 Make sure that people you direct or manage are familiar with ‘Standards for dental professionals’ and its supporting guidance.
2.3 All members of the dental team who have to register with us are individually responsible and accountable for their own actions and for the treatment or processes which they carry out. Make sure you do not take any action that may compromise the ability of any people over whom you have authority to follow the principles in ‘Standards for dental professionals’.
2.4 Follow the guidance on leadership of teams we have set out in ‘Principles of dental team working’.
2.5 Encourage staff you manage to raise any concerns they have about the activity of the organisation, including any risks that the health, behaviour or performance of colleagues may present to the safety of patients or the wider public interest. Follow our guidance ‘Principles of raising concerns’ and encourage others to do so.
Once you have collated your thoughts please either email them to info@dla.org.uk or simply post them to the DLA Chief Executive, Dental Laboratories Association., 44-46 Wollaton Road, Beeston, Nottingham NG9 2NR.
