The ADA represents both public and private sector dentists and dental students across Australia.

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1 Incorporated in the ACT ARBN Chandos Street St Leonards NSW 2065 All Correspondence to: PO Box 520 St Leonards NSW March 2014 The Hon. Christopher Pyne, MP Minister for Education Parliament House CANBERRA ACT Dear Minister, Following a meeting between representatives of the Australian Dental Association (ADA) and Dr Don Markwell, Senior Advisor on Higher Education, it was suggested that the ADA write to you again to outline some of the issues affecting the dental workforce, particularly in reference to your portfolio. The ADA represents both public and private sector dentists and dental students across Australia. As a result of increasing complaints from graduates in relation to the job market, the ADA has been monitoring dental workforce supply for some time. In its quest for data on the issue it retained the services of Insight Economics which completed three studies: 1. Review of Dental Workforce Supply to 2020, November 2012; 2. Productivity of Australian Dentists, April 2013; 3. Demand for Dental Services in Australia, August These are available to review at: The ADA is convinced that the dental workforce is saturated and the lack of availability of employment will only get worse. The issues This oversupply in the dental workforce is due to a number of factors: 1. Growth in the number of students graduating from Australian universities For decades Australia had five dental faculties. Since 2005, four new dental schools have been opened in Australia (Griffith, La Trobe, James Cook and Charles Sturt).

2 2 Over the same time period, existing dental schools increased the number of student places in dental programmes. The addition of new schools, increased places in existing schools and the removal of the cap on Commonwealth Supported Places have all resulted in a substantial growth in the number of students entering and subsequently graduating from Australian dental programmes. For example, in 2007 the number of new dentists graduating from Australian universities was 193. In 2014 it is anticipated that in excess of 620 students will graduate * >620* Table 1: Award Course Completions, Department of Innovation *Data from 2013 provided by Australasian Council of Dental Schools 2. Changes to international student visa conditions that allow students to remain and work in Australia The decision of the previous government to allow international students, holders of visa subclass 485, to obtain a visa and remain and work in Australia for between two and four years following completion of their degree has made it even more competitive for domestic graduates to obtain full-time work. The ADA is seeking to have this legislation repealed. 3. A significant increase in the number of dentists entering Australia through temporary and permanent migration pathways Compounding the oversupply of dentists is the significant increase in the number of overseas qualified dentists entering under temporary and permanent migration pathways. Australia is a popular destination for overseas qualified dentists. According to the Australian Workforce and Productivity Agency in around 307 dentists were granted visas to enter and work in Australia (137 permanent independent migrant and 170 temporary 457 employer-sponsored). Dentists from the UK, Ireland and Canada can enter the country and work without limitations. Dentists with qualifications gained elsewhere must be assessed by the Australian Dental Council (ADC). The number of overseas qualified dentists taking and passing the examinations and assessments of the ADC has grown significantly over the last decade. In the five years between 2000 and 2004 there were on average around 50 dentists per year who completed the ADC assessment process. In 2013 the number had increased to Table 2: ADC Completions

3 3 4. Ease of migration through the Trans-Tasman Mutual Recognition Agreement (TTMRA) The number of dentists entering the country under mutual recognition arrangements between Australia and New Zealand each year is unknown but may also be significantly contributing to the workforce oversupply. Overseas qualified dentists who have met registration requirements in New Zealand receive automatic recognition of their qualifications in Australia under these arrangements. Achieving registration in New Zealand is seen by many as a means of back door entry into Australia. For many years, there has been an exemption in the TTMRA that ensures that medical practitioners who did not complete their training in New Zealand do not receive automatic recognition of their qualifications in Australia. The ADA believes that a similar exemption should apply for dentistry. 5. The increase in training numbers of allied dental practitioners As well as increasing numbers of dentists, Australia now has a growing number of allied dental practitioners (dental hygienists, dental therapists and oral health therapists). Table 3 shows this growth over time. As allied dental practitioners work under the supervision of a dentist, it will also become increasingly difficult for these practitioners to obtain work if there are limited job opportunities available. Registration category Dec 2013* Dental hygienist Dental therapist Dental hygienist and dental therapist N/A N/A Oral health therapist Total Table 3: Allied dental practitioners registration data Source: AIHW Dental Workforce 2012 and *DBA Current position Between domestic graduates and migratory supply approximately 930 dentists are entering the workforce annually; the ADA believes that around 510 entrants are required to meet demand. This accounts for replacing retiring dentists and a population growth rate of 1.5%. With containment of the number of overseas qualified dentists at 50, then 460 graduates from Australian dental schools are required. The dental workforce has well and truly reached saturation level. Many graduates are unable to obtain employment and many of those who do find employment are only able to obtain part-time employment. Advertised vacant positions, even in rural locations, are attracting large numbers of applications. For example, a practice recently advertising for an Assistant Dentist in Mareeba on the Atherton Tablelands in Far North Queensland received 103 applications.

4 4 Up until 2011, it was reported through the Graduate Careers Survey that almost 95% of newly qualified dentists were in full-time employment four months after graduation. In 2012, this figure fell to less than 84% and continued to drop in the 2013 survey. The Graduate Careers Survey findings support the views of the ADA and its members. A recent survey undertaken by the ADA showed that 61% of graduating dentists encountered difficulty in obtaining work. Twenty-eight per cent were working less than 24 hours per week because they were unable to obtain any additional hours. The ADA hosts a free job posting portal for its members. Analysis of the jobs advertised over the last few years indicate a growing increase in the number of part-time positions in favour of full-time opportunities. Comments provided by representatives of Health Workforce Australia, which is in the final stages of their assessment of the dental workforce, believe that Australia has a surplus supply of dentists and this will continue until at least They have not made any projections beyond The ADA believes there are more than sufficient numbers of Australian dental graduates currently entering the workforce and urges the Australian Government to put in place a number of initiatives to bring this workforce back into balance. Solutions In relation to the education portfolio, the ADA is urgently seeking: the discontinuation of a demand model for student places in dental programmes; the repeal of the legislation allowing international students to remain and work in Australia following completion of their course; and limitations on immigration pathways. The demand driven funding model The ADA recognises the current demand driven model underpinning Commonwealth funding to universities has merit. However, supporting unlimited places in dental programmes when there is no pathway to gainful utilisation of the training through employment is a waste of resources and taxpayers monies. It is also unfair to students. In an economic climate where efficiencies and economies are being sought to bring the Federal Budget into balance, the wasted investment into training university students when no employment path follows has to be stopped or redirected to other areas of education. The ADA notes from media reports that the government has commissioned a report to examine if the shift from a capped system to a demand-driven one was an effective model to adopt. Adoption of the demand driven model in tertiary education has resulted in a significant increase in the number of students seeking higher education, particularly in fields of study with known workforce shortages. Where shortages exist the demand model meets the desires of students and the market. However, when there is no workforce shortage the utilisation of the free demand model is inappropriate as it is wasteful. Adverse impacts of the demand driven model are:

5 5 1. Skilled graduates with limited employment outcomes A dentist qualification may take from between five to seven years to achieve, depending upon the type of programme undertaken. Obtaining a dentist qualification provides the graduate with a well-defined skill set. These skills do not translate to any other sphere of employment opportunity. A graduate either seeks to practise dentistry or seeks to embark on a whole new career most likely requiring another 3 4 year minimum course of study. There are no options that the ADA can identify that provide any alternate employment pathway to another career for the dentist graduate. 2. Attracting the brightest and smartest Currently dentist courses attract a high calibre candidate for enrolment. If a dentist course, through the continued use of the demand model, created a situation where dentist supply grossly exceeds demand then that high calibre candidate is likely to avoid pursuit of that degree due to poor employment prospects. This would result in a lower calibre candidate entering the course and graduating. In all spheres of professional practice, it is the leaders that dictate the level of performance of the profession. High calibre graduates will enhance the development and research of the profession. If they are not part of the profession, research and development will suffer as will the high skill levels that currently exist. The community will suffer as a result. 3. Use of taxpayers monies Undoubtedly, the demand driven model has provided greater development opportunities for students. However, it has also resulted in substantial increases in government expenditure in higher education which will continue to grow under such a scheme. In their submission to the Higher Education Base Funding Review (the Review) in 2011, the Australasian Council of Dental Schools (ACODS) indicated that the average annual cost to deliver a dentist programme was $36,536 per (EFTSL). Dental programmes are categorised within Funding Cluster 8 which attracts the highest annual contribution from both the Commonwealth, at $21,273 per equivalent full-time student load, and from students at $10,085 each (2014 amounts). Assuming the cost of delivering programmes has increased by at least CPI each year since 2011, there is a significant gap between the cost of delivering dental programmes and the funding provided by the Commonwealth when combined with the student contribution. This gap was recognised in the Review Panel s findings and the Review Panel recommended that dentistry, along with other programmes, receive additional funding for teaching and learning. Despite any perceived gap between cost of delivery and funding available, this is a substantial investment by the Commonwealth and the student. Full fee paying students contribute in the order of $250,000 to $300,000 to undertake the five-year course. With an expected demand for 460 new dentists per year and with graduating classes annually of more than 600, at best it means a minimum wasted investment of $5.1 million per annum. The opportunity cost of having capital infrastructure and academic staff engaged in the education of students unable to gain meaningful employment is a waste of taxpayers money

6 6 4. Impact on fees for dental services The ADA recognises that in a balanced perfect economy, where demand for dental services exists with shortages in supply of dentists, the impact would be to increase the price of dental services. If supply of dentists exceeds demand for services then economic theory suggests prices will decrease in the market. Having excess supply will have a favourable outcome for consumers. However, dentistry is not performed in such an economic market setting. Factors such as the role of private health insurers and government schemes, which help fund dental services, create an economic environment that causes the standard supply and demand theory to no longer work in this pure fashion. These contributors in themselves significantly influence the price of services regardless of supply of dentists or demand for services. It is the ADA s opinion this impact on prices will be lost where supply exceeds demand by more than 15%. When supply exceeds demand by more than this amount, in the case of dental services and most capital intensive professional labour service delivery models, the tendency will be for prices to increase. This is because the provider has a level of overhead that will need to be covered. The supplier of the services will seek to meet the cost of the overhead and achieve resultant profit by either providing services that may exceed real need or alternatively (and more likely) increase prices for the services provided. The ADA hopes professional ethics will limit the first but the second is not so constrained. Allowing the demand driven model to produce an oversupply of dentist graduates that flood the market, creates a market not in equilibrium and one that will have an adverse impact on consumers through increased prices. The demand model must cease to operate in the education of dentists. In conjunction with a review by Health Workforce Australia and input from the profession, a cap on the number of student places needs to be introduced. The introduction of a suitable cap of 460 graduates will allow for the requisite market forces to continue containing prices. More importantly, it will create efficiencies in the education sector where resources are redirected to where they are most needed to professional sectors where increased supply is required. The approximate minimum annual expenditure of $5 million would be avoided and saved. Limitation on immigration pathways The ADA has also written to the Hon. Scott Morrison MP, Minister for Immigration seeking removal of the profession of dentist from the Skilled Occupations List and the Consolidated Sponsored Occupation List until further notice. While it is still unclear who has responsibility for Mutual Recognition Arrangements, the ADA is also seeking an exemption for the occupation of dentist under the TTMRA, similar to the arrangements in place for medical practitioners.

7 7 Conclusions The ADA believes the combined strategies of ceasing the demand driven model for student places in dentistry; placing a cap on domestic student numbers and repealing the legislation that allows international students to remain and work in Australia following completion of their programme of study; and removal of the occupation of dentists from the Skilled Occupations List would improve graduates employment prospects. The ADA has previously written to Ministers under the Gillard and Rudd Governments who had responsibility for education and immigration matters. However, these concerns have not resulted in any meaningful action. In your capacity as Minister for Education, the ADA seeks your support of these concerns and respectfully requests that you seek to discuss this matter with Minister Morrison to ensure that these proposals will be given due consideration. We would welcome the opportunity to meet with you to further discuss this pressing issue facing the dental profession in Australia. Yours sincerely Dr Karin Alexander Federal President cc: Dr Don Markwell