Item 6 Council 18 June 2014

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1 Item 6 Council 18 June 2014 Report on the outcome of the consultation on the Annual Retention Fee Policy Purpose of paper To report on the outcome of the consultation on the Annual Retention Fee Policy. Action Corporate Strategy Business Plan 2014 For decision. Strategic Objective 5.0: Deliver cost effective regulation, ensuring maximum efficiency without loss of patient protection Develop a new annual retention fee policy. Decision Trail A review of the ARF Policy began in December 2012 The overall approach to the ARF policy was agreed by the Council at the meeting in December The Council approved the consultation document at the meeting in March Recommendations Authorship of paper and further information The Council is asked to: - note the themes and issues raised in the consultation - approve the policy approach to the setting of the Annual Retention Fee for Dentists and DCPs in the future and; - note that an Equality Impact Assessment has been conducted on this policy. David Rowland, Head of Corporate Policy, Nyree Connell, Corporate Policy Manager, Tim Whitaker, Director of Policy and Communications Page 1

2 Appendices Appendix 1: Risks and Considerations Appendix 2: Summary of results by questions Appendix 3: Respondents to the consultation Appendix 4: Equality Impact Assessment Page 2

3 Executive Summary 1. This paper sets out the results and key themes arising from the consultation on the Annual Retention Fee (ARF) policy which was open from 16 April until 4 June It also proposes some actions based on what we have heard from respondents. The Council is asked to approve the policy which was subject to consultation and to note the Equality Impact Assessment on the policy attached at Appendix 4. Background 2. The GDC is required under Section 19 of the Dentists Act 1984 to levy a charge on registrants in order to fund the delivery of our statutory functions. A review conducted in 2012/13 found that the GDC did not have a clear approach to determining fee levels for different registrant groups and that there was a lack of understanding amongst the professional associations about why a fee was charged, how the fee was set and the circumstances in which fee increases would occur The review looked at whether or not the GDC should take the individual income and circumstances of registrants into account when setting the fee level or whether the fee should be set on the basis of how much it costs the GDC to regulate each registrant group (Dentists and DCPs). 4. Because of our statutory duties to raise sufficient funds to protect the public and because of the fact that the GDC cannot be responsible for the amount earned by different registrant groups once it has issued a right to practise, the Council agreed that we should only charge each registrant group according to how much it costs us to regulate that group. This is in line with the expectations set out in the Treasury Guidance on regulatory fees However, we considered that it was important to seek registrants views on these principles and, in so doing, to also explain how any fee levels would be calculated in the future in line with these principles. We also set out to explain in the consultation document how the GDC spends the income it receives from fees and what the main cost drivers are. We considered this was important in order to aid scrutiny and transparency and improve our accountability to the profession. 6. We ed the consultation document to all GDC registrants and placed articles in the dental press and in our Gazette. We also notified the professional associations in advance of the consultation and sent reminder s throughout the consultation period. Respondents were given the opportunity to answer YES/NO questions as well as to provide answers in free-text. 1 Review of ARF Policy 2 HM Treasury Guidance on Managing Public Money Chapter 6 Page 3

4 What we heard 7. We received 1255 responses in total including responses from the following professional associations and organisations: - British Dental Association (BDA) - Medical and Dental Defence Union of Scotland (MDDUS) - British Society of Dental Hygiene and Therapy (BSDHT) - Dental Technologists Association (DTA) - British Orthodontic Society (BOS) - Royal College of Surgeons of Edinburgh - British Association of Oral and Maxillofacial Surgeons (BAOMS) - British Association of Dental Therapists (BADT) - British Association of Dental Nurses (BADN) 8. 57% of responses came from Dentists, 40% were from Dental Care professionals (DCPs) and 6% were from dental educators/trainers. Dental nurses accounted for 77% of DCP respondents. In general, the responses received were broadly representative of the demographic profile of the dental sector. More detail on the breakdown of who responded can be found at Appendix Overall, those who responded supported the approach to setting fees, with 65% agreeing with the idea that we should set the fee according to how much each registrant group (Dentists and DCPs) costs us and 90% of respondents supporting a different charge for Dentists and DCPs. 10. When it came to applying this principle to fee increases, there was less support with just over half (50.4%) supporting the proposal to calculate fee increases according to the additional costs of regulating each registrant group. Respondents were strongly against the idea of increasing fees each year in line with inflation with 84% stating opposition to this idea. 11. The support for the principle of charging each registrant group according to how much it costs us to regulate them (65%) seems to conflict with the fact that there was less support for the proposed approach to fee increases (50.4%), which is based on the same set of principles. This can, perhaps, be explained by the general concern expressed in the comments about the impact of possible fee increases on certain registrant groups and the resistance to any fee increase. More detail on the responses to individual questions can be found in Appendix Overall, the consultation responses demonstrated support for the policy approach to setting the fees according to how much we charge registrant groups but there were a number of issues which were raised in the free text comments which Council should be aware of. We have identified a number of actions to address these Page 4

5 concerns and to take on board registrants views. These can be categorised under the following headings: A) Greater transparency in relation to the GDC s financial information, in particular Fitness to Practise Costs % of those who responded wanted more financial information than we had provided in the consultation document. In particular, concerns were raised about the costs of fitness to practise cases. Respondents wanted greater detail on why these were so high and more information on the figures provided in the consultation document. It was clear from the comments, that the high level figures that we did provide were not sufficient. For example, in the consultation document even though we highlight that the cost of investigating a complaint was 1100 and the cost of a hearing was 78, 000, respondents wanted much more detail on why a complaint and a hearing came to these amounts. Typical comments from respondents: I would like to understand the spiralling cost of holding fitness to practice hearings. Why are there so many more? Shocked by the amount a FTP hearing costs. I would like to see an itemised breakdown of these amounts The fee of 78,000 per case heard seems extremely high. What are the costs involved in these cases? What were highest costs and what were lowest? What has been done to keep costs low? 14. In addition, respondents wanted a more detailed financial breakdown overall than provided in the consultation document; in particular they wanted more information on the following: - staff costs - the cost of the Council - on GDC efficiency measures and how these have reduced costs. Proposed Action: In the consultation document on the Annual Retention Fee Level for 2015 we will provide more detail on the different aspects of the Fitness to Practise process, and will build this into our public reporting on how we spend the fee income. B) Differential fee levels for different DCP groups due to the lower salaries of dental nurses There was a strong call for the lower salaries of dental nurses, compared to other DCPs, to be taken into account when setting the ARF. Typical comments from respondents: I strongly believe that hygienists and dental nurses shouldn't pay the same amount. I think that for DCPs especially Dental Nurses the fee should be wage related. A huge proportion of Dental Nurses are on a low wage and can barely afford to pay Page 5

6 120 a year for the privilege of working especially when living costs are increasing all the time and wages are not. Dental nurses only earn a fraction of what other dental professions earn. 15. Some of the comments expressed the erroneous view that dental nurses account for fewer complaints than other DCPs and that therefore this group of registrants should be treated separately from other DCPs. Proposed Action: In order to ensure that the ARF policy is applied consistently across all registrant groups we will keep under review the costs of regulating different DCP groups and set the fee level accordingly. 16. If the Council agrees the policy approach to setting fee levels according to how much it costs us to regulate different groups (Dentists and DCPs) then we will not be able to take into account the individual circumstances of registrants, including Dental Nurses who are working part-time. However, we recognise that we need to be clearer about the reasons why DCPs are all charged the same amount and to keep this under regular review. 17. To this end, we have recently reviewed the DCP FTP cases by registrant type for 2013 and found that on the basis of these figures it costs the GDC roughly the same to regulate a dental nurse as it does to regulate a dental hygienist or therapist. In the last year, Dental Nurses made up 77% of the DCP group but incurred 50% of the DCP s overall FTP costs (as measured by the number of complaints received), whereas Dental Therapists, made up 3% of DCPs but incurred 4% of DCPs overall FTP costs, Hygienists made up 10% of the DCP group but incurred 12% of the DCPs FTP costs (See table 1 below). 18. However, it is important, that we keep under review the differential costs of regulating the various DCP groups. If the costs of regulating a particular group changes substantially overtime then we will consider the impact of this on the fee level for that group. Page 6

7 Table 1 - Breakdown of FTP complaints by DCP registrant type for 2013 Registrant title Dental Nurse Dental Technician Dental Therapist Dental Hygienist Clinical dental Technician Orthodontic Therapist Number of complaints received about DCPs Percentage of complaints received about DCPs % 77% 96 24% 9% 17 4% 3% 46 12% 9% 38 10% 0.4% 4 1% 0.5% Percentage of total number of DCP registrants 19. In addition, the number of comments about the salaries of dental professionals also demonstrates that we need to communicate more directly with registrants the fact that we cannot take into account the individual circumstances of registrants when setting the fee and the reasons behind this. Although respondents did not support a change in the title of the ARF to the right to practise fee it is important that we continue to stress that GDC registration is a legal requirement. Proposed Action: Ensure that our communications continue to be clear about the purpose of charging a fee and that we set the fee on the basis of how much it costs us to regulate each different group. C) Payment by instalment for DCPs 20. In addition, even though it was made clear that the fee consultation did not cover the method of payment, a significant number of respondents called for the option to pay by instalments in order to lessen the burden on them financially. However, whilst the GDC can legally do this for DCPs it cannot do this for Dentists due to the restrictions place on us by our legislation. Proposed Action: Further consideration should be given to the feasibility of collecting the ARF of DCPs by instalments. D) Other themes 21. In addition to the call for the annual retention fee to be calculated according to income levels, alternative methods of calculating the fee level were suggested in the following order: - Working hours e.g. part time and number of hours worked Page 7

8 - Levels of responsibility - Risk based - A no claims bonus for those registrants who do not receive a complaint - One fee for all of the dental team (i.e. Dentists and DCPs) 22. In answer to whether there were any other factors we should take into account when deciding whether to increase the ARF, the majority expressed the view that as salaries had been frozen across the healthcare sector, this should be considered in any ARF increase. 23. Respondents questioned why good practitioners were being penalised for poor performers and called for higher fees for poor performers. Summary of responses from the professional associations 24. The professional associations shared similar views to the majority of respondents but there were some differences and specific themes that emerged from their responses. 25. They all responded that the consultation clearly explained why we charge an annual fee, however unlike the responses from registrants and others the majority supported changing the name of the fee to practising fee. There was a strong understanding of how we outlined our spending on the fee income but more than half wanted more information on how we spend the ARF. The BDA wanted more detail on proposed cost efficiency measures and how our FTP function compared with other healthcare regulators in the UK and the EU. 26. In terms of the policy approach to setting the ARF, there was amongst the professional associations overall support for calculating the fee according to the cost of regulation and to setting the dentist/dcp fee according to what each registrant group costs us. However, there were some (BDA, BADN, BOS, BSDHT) that disagreed with this approach. The BADN echoed the views of registrants and suggested lower fees for part time workers and for dental nurses. 27. The BSDHT and the BDA also suggested that the fee for DCPs should be adjusted according to the scale of involvement in direct clinical procedures and that those with less clinical involvement and therefore less likelihood of facing FTP proceedings could be charged a lower fee. There was unanimous support for charging a different ARF to dentists and DCPs. Alternative suggestions for calculating the ARF included: Better identification of professionals at higher risk of being involved in a fitness to practise hearing. Reduced fee for trainees and part time workers Address risk of double jeopardy for dually-registered practitioners Page 8

9 28. There was overall support for applying the policy approach to any future fee increase which differed from the individuals who responded; however there was more support for increasing the ARF in line with the cost of inflation than expressed by registrants and others. Other points raised are highlighted below: The impact of direct access on complaints needs to be taken into account at an early stage In terms of dental education and training costs, it was suggested that as the cost of training programmes for clinical DCPs costs more than that of dental nurses this should be reflected in the ARF. Equality Impact Assessment 29. As part of our Public Sector Equality Duty under the Equalities Act 2010 we also sought views of registrants about the impact of the proposed policy on those with protected characteristics. We received a number of comments in response to the consultation relating to the impact of the policy on women and those who may be unable to work due to illness or maternity. 30. The GDC takes very seriously its duties under the Equality Act 2010 and we have previously sought external legal advice on this issue. We have also undertaken an Equality Impact Assessment which is included at Appendix 4. The impact assessment acknowledges the effect of the policy on those with shared characteristics but does not recommend that an alternative policy approach is taken. The current proposed approach is justified by our primary legislation and it can be demonstrated to be fair according to a set of principles. However, it is important that any calculation of the fee level for each registrant group is in strict accordance with the policy in order for us to be able to rely on this defence. Conclusion 31. The consultation exercise demonstrated broad support from respondents for the principles we apply to setting the ARF. It was clear however that there are a number of important areas that need to be kept under review, including ensuring that we are transparent in providing financial information, that we keep under review the differential costs of regulating DCPs, that we keep under review the method by which we collect payments. Risks and Considerations 32. Risks and considerations are set out in Appendix A. Recommendations 33. The Council is asked to: - note the themes and issues raised in the consultation - approve the policy approach to the setting of the Annual Retention Fee for Dentists and DCPs in the future and; - note that an Equality Impact Assessment has been conducted on this policy. Page 9

10 APPENDIX 1 : Risks and Considerations RISKS AND CONSIDERATIONS Risks and Considerations Public Protection The proposal is aimed at ensuring a proportionate and fair way of raising income from the profession in order to fund the GDC s primary duty of public protection. Policy The proposed policy approach to setting the ARF will allow the GDC to set out more clearly the basis on which it raises funds to carry out its statutory duties. This is an important consideration in the light of the recent PSA cost efficiency and effectiveness review. Communications This proposal will allow the GDC to be clear and transparent to registrants about why they pay an annual fee and how this is spent. There is currently a lack of understanding amongst our registrants on this issue. The consultation was aimed at increasing understanding and legitimacy of the GDC. Equality and Diversity Views were sought during the consultation on any Equality and Diversity implications associated with the principles underpinning the fee policy taking into account previous legal advice. An Equality Impact Assessment has been undertaken. Legal The power to prescribe a fee for retention on the register is given to the GDC in the Dentists Act The levels are set by the Rules made under the Act by the GDC. Legal advice will be obtained as Sign off Tim Whitaker Tim Whitaker Tim Whitaker Tim Whitaker Frances Low Page 10

11 necessary regarding any changes to the way the fee is calculated. Risks The risks associated with this proposal are not considered significant. It is possible that registrants may not have fully understood the purpose behind the consultation and the principles of the fee policy. This may also lead to false expectations about what level the fee will be set at in the future and what it should have been set at in the past. These risks will be mitigated through effective and ongoing engagement and clear communication with registrants and stakeholders. Resources None required Tim Whitaker Page 11

12 APPENDIX 2 Summary of results by each question asked. Question 1 Having read the information provided, do you think it is clear why we charge an Annual Retention Fee (ARF)? 90% of respondents stated they were clear about why we charge an ARF. Question 2 We currently call the annual fee the Annual Retention Fee. We are considering changing the name of the annual fee to Practising Fee. Do you think that this is a more appropriate name for the annual fee? There was no strong endorsement for a change in the name with 52% of respondents agreeing that practising fee would be a more appropriate name and 48% responding no. Question 3 Having read the breakdown of our spending, do you feel you understand how we spend the income we receive from the Annual Retention Fee? 86% of respondents said they understood how we spend the ARF from the information provided in the consultation. Question 4 Would you like us to provide any further information about how we spend the income from the Annual Retention Fee? 66% of respondents said no to further information and just over a third (34%) said yes to more information. Question 5 If yes, please tell us what information you would like There were over 300 comments provided. Key points: There was significant consternation expressed at the costs of Fitness to practice (FTP) cases and respondents demanded more information on the breakdown of these costs. Respondents wanted a more detailed financial breakdown overall than provided in the consultation document; in particular they wanted information on staff costs and the cost of Council. Page 12

13 Question 6 We have stated that the Annual Retention Fee should be calculated according to the cost to us of regulating dental professionals and that we should not take into account the income and circumstances of individual registrants. Do you feel that the information that we have provided clearly explains the reasons for this? 75% of respondents considered the information we provided clearly explained this. Question 7 Do you agree that we should set the Annual Retention Fee according to how much each registrant group (Dentists or DCPs) costs us? 65% of respondents agreed with this approach but 35% disagreed. Question 8 If not how do you think it should be calculated? Of the 35% who disagreed there was a strong call for the fee to be calculated according to income levels. Other alternative methods of calculating the fee level were suggested in the following order: - Working hours e.g. part time and number of hours worked - Levels of responsibility - Risk based - A no claims bonus for those registrants who do not receive a complaint - One fee for all of the dental team Question 9 Do you think that the GDC should charge a different Annual Retention Fee to Dentists and to Dental Care Professionals? There was strong support for charging a different fee to dentists and DCPs with 90% of respondents agreeing with this approach. Question 10 Do you have any other suggestions about how the GDC might calculate the Annual Retention Fee levels for dentists or DCPs? There were 700 comments. The vast majority said the fee should be calculated according to income earned. Other suggestions included: - Separating out DCPs this was a recurrent theme throughout the consultation responses Page 13

14 - Calculating fees according to risk levels of the different groups - Developing a charging system along insurance lines Question 11 Do you agree with the approach that we intend to take to any Annual Retention Fee (ARF) increase in the future? Just 51% of respondents agreed with the approach and 49 % did not. Question 12 Are there any other factors which we should take into account when deciding whether to increase the Annual Retention Fee (ARF)? There were close to 800 comments. The majority expressed the view that as salaries had been frozen across healthcare this should be considered in any ARF increase. The comments included appeals not to increase the fee. Respondents used the opportunity to repeat earlier concerns about the basis of the fee level calculation and called for hours worked to be considered when setting the fee level and to charge DCPs different amounts instead of treating them as one group. Other aspects: - Respondents questioned why good practitioners were being penalised for poor performers - There were a significant volume of comments on what GDC were doing to reduce costs and requests for more evidence of our efficiency savings and how this has had an impact on costs. Question 13 Do you think that we should increase the ARF in line with the cost of inflation each year? 84% of respondents said no to an increase linked to inflation. Question 14 Is this approach to calculating increases to the Annual Retention Fee (ARF) for Dentists and DCPs clear? 82% agreed that the approach was clear and 18% did not. Page 14

15 Question 15 Do you support this approach? 55% supported the approach and 45% did not Question 16 Is there a different approach that you would propose? There were approximately 500 comments, suggested approaches included: - Higher fees for poor performers - Take into consideration income, recent salary freezes and the impact of the recession - Treat and charge minimum wage part time nurses differently from other DCPs Question 17 Do you consider that the approach to setting the Annual Retention Fee described above is likely to cause disadvantage to registrants as a result of them having a protected characteristic? 29.4% of respondents said that our approach to setting the ARF was disadvantageous to particular groups. Question 18 In the free text response when we asked for more detail, the comments related predominantly to women who needed to take maternity leave and also to older and disabled workers who were only able to work part time hours. Page 15

16 APPENDIX 3 - Respondents to the Consultation Characteristics of Respondents 1. We received responses to the consultation on the Annual Retention Fee policy, 98% of respondents were individuals and not part of an organisation. Respondents professional backgrounds are as follows 4 : Respondent type % Dentist 57% Dental Care Professional 40% Student (Dentist) 0.3% Student (DCP) 0.3% Dental educator/trainer 6% Other healthcare professional 1.4% 2. There was some variance with the GDC register of professional backgrounds, where 38% of registrants are dentists and 62% are DCPs. Respondents who categorised themselves as a DCP break down as follows: Respondent type % Dental Nurse 77.0 % Dental Hygienist 10% Dental Therapist 4.2% Orthodontic Therapist 1.9% Dental Technician 5.6% Clinical Dental Technician 0.8% 3. Dental nurses accounted for 77% of respondents who categorised themselves as DCPs; this is higher than the percentage of dental nurses on the GDC register which stands at 60%. 3 This was the total number received not all respondents answered every question. Page 16

17 Percent 4. The following shows the breakdown of respondents by gender, age and ethnicity where this information was provided. 62.8% of all respondents were female; this is lower than the 73.8% of all GDC registrants who are female. Respondent type % Male 37.2 Female 62.8% 5. Figure one below shows the age range of the respondents: 28% of respondents were aged between 45 and 54; 26.9% of respondents were aged between 35 and 44; 21% were aged between 24 and 34 and 18.7% between 55 and 64 years old. This roughly correlates with the GDC Register. The GDC register uses different age group bandings 23% of registrants are aged 41-50, 28.6% are aged 31-40; 26.9% are aged and 16% are aged Figure 1 What is your age? 100% 90% 80% 70% 60% 50% 40% 30% 20% 21.6% 26.9% 28.0% 18.7% 10% 0% 1.3% % Key 1- Under Ethnic origin 6. There was an error in the consultation document which was pointed out to us by a number of respondents which unfortunately meant that white British was not included in the options. We will rectify this issue in any subsequent GDC consultations. 60% of respondents selected the option any other white Page 17

18 background, 19 % selected Irish, 7% selected any other ethnic background ; 3.6% Indian, 2.5% White and Asian, 1.3% Chinese, 1.2% Black African and 1.2% Pakistani and 1.1% selected other Asian background. We are unable to identify whether the responses are representative of the GDC Register as not all GDC registrants have provided us with this information. 7. The majority of respondents (75.4%) practised in England, 12% in Scotland, 4.3% in Wales and 4.1% in Northern Ireland. Country % England 75.4.% Scotland 12% Wales 4.3% Northern Ireland 4.1% Other 4.0% Page 18

19 APPENDIX 4 Equality Impact Assessment Section 1 Overview of the legal framework for equality The Equality Act 2010 replaces the previous anti-discrimination laws with a single Act. The majority of the Act came into force on 1 October It covers employment, services and public functions. The Act protects people from discrimination on the basis of protected characteristics. These are: Age Disability Gender reassignment Marriage and civil partnership Pregnancy and maternity Race Religion or belief Sex Sexual orientation The Act provides protection against direct and indirect discrimination, harassment (including third party harassment) and victimisation in services and public functions, premises, education, associations and transport for all of the characteristics except marriage and civil partnership and age. Public bodies like the GDC must meet the public sector equality duty requirements. The equality duty is a duty on public bodies and others carrying out public functions. The equality duty consists of a general duty and specific duties. The general duty applies across Great Britain to public bodies listed in Schedule 19 to the Equality Act 2010 and it is this part of the Equality Duty that currently applies to the GDC. The aim of the equality duty is to embed equality considerations into the day to day work of public authorities so that they tackle discrimination and inequality and contribute to making society fairer. The general duty requires public bodies like the GDC to have due regard to the need to: eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010 advance equality of opportunity between people from different groups; and foster good relations between people from different groups. The duty applies before the GDC takes a decision. It is not sufficient for the GDC to take a decision and then review it for equality considerations. Equality considerations must, by law, be taken into account at the time a decision is made. The EIA template is designed to help staff, the Council and Committee members comply with the law by identifying and evaluating those consequences of a potential decision which impact on equality considerations. Page 19

20 Further information on the Act can be found on the Equality and Human Rights Commission and the Government Equalities Office websites and online resources to support EIAs can be found on the GDC intranet. Please liaise with the Legal Team in Governance when completing an EIA. Page 20

21 Section 2 : Initial EIA screening Please use the following template to help determine whether an equality impact assessment (EIA) is required. Name of the policy: Annual Retention Fee Policy Project Management Office reference: Business Plan reference: Directorate Policy and Communications Name of policy owner David Rowland Job title Head of Corporate Policy Date June 2014 Does the policy require an EIA? Please answer the following questions. 1. What are the main aims, purpose and outcomes of the policy? To determine how we set the annual retention fee level for our registrants in accordance with our statutory duties. To be clear and transparent to our registrants and the wider public about how we raise and spend money to deliver our statutory objectives. To provide clear reasons for the fee levels we set now and in the future. 2. Who is expected to benefit from the policy? Registrants, professional associations and wider stakeholders will benefit as they will gain a greater understanding of the GDC s approach to setting fees. 3. Who implements the policy and who is responsible for the policy? The Executive Management Team and Council will approve the policy and remain ultimately responsible for ensuring that it is sound, meets our corporate objectives and is consistent with our statutory duties. The Finance Directorate is responsible for implementing the policy. Corporate Policy along with Communications Team are responsible for ensuring clear communication of the policy with registrants, stakeholders and others. 4. Is it likely that the policy will have any relevance to our duty to: a. eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act b. advance equality of opportunity between people who share a protected characteristic and Page 21

22 those who do not c. foster good relations between people who share a protected characteristic and those who do not d. remove or minimise disadvantages suffered by people due to their protected characteristics e. take steps to meet the needs of people from protected groups where these are different from the needs of other people f. encourage people from protected groups to participate in public life or in other activities where there participation is disproportionately low? a) No b) No c) No d) Yes e) No f) No 5. What evidence do you have to come to this conclusion? The policy approach that we are proposing means the GDC will not take into account the individual circumstances of registrants when setting the ARF. Instead, we propose to set the fee according to how much it costs us to regulate each registrant group a flat fee. As a result, the policy will have a differential impact on registrants depending on how much they earn and their individual circumstances. We are aware for example that 50% of our registrants are dental nurses and 98% of them are women. Dental nurses are generally on low incomes and work part time. Concerns have been raised that our policy approach to setting the ARF is likely to discriminate indirectly against this group as the fee will be a greater financial burden for them compared to others who are able to earn a higher salary from practising the profession. 6. Are there any aspects of the policy, including how it is delivered or accessed, that could actively contribute to inequality? We recognise that charging registrants a flat fee rather than taking income and circumstances into account will not actively but indirectly contribute to inequality. 7. Do you consider that this is either a major policy or a minor policy with a major impact on equality? A minor impact because the fee level, currently 12 per month for DCPs, even if raised higher will have a minimal impact on the overall income distribution between different registrant groups and those with shared characteristics. If the policy is not relevant to an aspect of the organisation s activities or to its legal responsibilities, there is no need to conduct an EIA. If your answers to questions 4 or 6 above have identified potential effects and you have answered yes to question 7, then you should carry out a full EIA. Page 22

23 Before proceeding with the EIA you should consider the scope of the assessment and discuss this with colleagues if necessary. You should then move on to use the full EIA template to carry out the assessment. Is an EIA required? YES Initial screening has been checked by the Director or designated manager Name David Rowland Job title Head of Corporate Policy Date June 2014 Section 3 : Full equality impact assessment Step 1: Scoping the equality impact assessment (EIA) Begin the EIA by determining its scope. The EIA should consider the impact or likely impact of the policy in relation to all areas of our remit. It should be proportionate to the significance and coverage of the policy. Name of the policy: Annual Retention Fee Policy Project Management Office reference: Business Plan reference: Directorate Policy and Communications Name of Policy Owner David Rowland Job title Head of Corporate Policy Date June a. Is this a new or existing policy? An existing policy. 1b. What is the main aim, purpose and/or outcome of the policy? Page 23

24 To determine how we set the annual retention fee level for our registrants in accordance with our statutory duties. To be clear and transparent to our registrants and the wider public about how we raise and spend money to deliver our statutory objectives. To provide clear reasons for the fee levels we set now and in the future. We are also required by Parliament to charge registrants an Annual Retention Fee; this is set out in Regulation 19 of the Dentists Act The financial objective of the policy is to obtain full cost recovery for delivery of our statutory functions. This is in line with the expectation as set out in the Treasury Guidance on Managing Public Money Chapter 6 and Annex 6.1 that regulators charge according to the cost of regulation. 1.c Who is most likely to benefit from or be affected by the policy? Our data demonstrates that female dental nurses are most likely to be affected by the policy. The policy approach that we are proposing is that the GDC does not take into account the individual circumstances of registrants when setting the ARF. Instead we propose that we will set the fee according to how much it costs us to regulate each registrant group a flat fee. As a result, the policy will have a differential impact on registrants depending on how much they earn and their individual circumstances. We are aware for example that 50% of our registrants are dental nurses and 98% of them are women. Dental nurses are generally on low incomes and work part time. Concerns have been raised that our policy approach to setting the ARF is likely to discriminate indirectly against this group as the fee will be a greater financial burden for them compared to others who are able to earn a higher salary from practising the profession. Older and disabled people We are aware that the policy may impact older and disabled people who may also work part time, however, we do not have data on older or disabled people who may work part time as we have been unable to collect this information. It is generally accepted that more women than men work part time and we expect the policy to have a greater impact on women than men. Step 2 Involvement and consultation It may be helpful to the EIA to involve stakeholders in assessing the impact of the policy, such as registrants, individuals or organisations representing sections of the public or employees. When considering how you might involve other people in assessing the policy, think about internal and external audiences for it. Please consult the Research team on Step 2 and Step 3. 2a. If you have involved stakeholders, briefly describe what was done, with whom, when and where. Please provide a brief summary of the response gained and links to relevant documents, as well as any actions. Council reviewed the ARF Policy throughout 2013 including engagement with the Page 24

25 professional associations and we collected and analysed information about income and earnings. The link to the policy review is below: We conduct and annual survey of registrants; the 2012 survey revealed there were significant concerns about the level at which the ARF is currently set. We issued a call for evidence to professional associations about our approach to setting the fee level in February Following the call for evidence and the initial review. We consulted on the policy in April The link to the consultation is below: Annual-Retention-Fee-Policy-Consultation.aspx The consultation was sent to all registrants and key stakeholders and we wrote articles and press releases to publicise the consultation exercise ahead of its launch date (16 April). Step 3 Data collection and evidence 3a. What evidence or information do you already have about how this policy might affect equality (for people protected by the Equality Act)? Please cite any quantitative (such as statistical data) and qualitative (such as survey data, complaints, focus groups, meeting notes or interviews) relating to these groups. Describe briefly what evidence you have used. The below sets out the evidence we have used to assess the impact of the policy on our registrants: In February 2013 a call for evidence on the ARF policy was sent to the professional associations seeking views on a number of issues related to the way in which the GDC sets the fees. The specific issue of the ARF policy was discussed with registrants in the registrant survey. In the feedback from both of these exercises there was a view from the hygienists and therapists in particular; that the low rates of pay of dental nurses meant that it was unfair that they should have to pay the same regulatory fee as hygienists and therapist. Representative groups for dental nurses have repeatedly argued that the lower income of dental nurses should mean that they pay less than other groups. This point was made again in our recent consultation exercise. In the ARF Policy consultation, 28% of respondents considered that our approach to setting the ARF would be disadvantageous to particular groups; namely women who needed to take maternity leave and also to older and disabled people who worked part time. We conducted research into the income levels of GDC registrants; this highlighted the range of incomes within the dental care professional registrant group. For example, dental nurses on a full time salary might earn in the region of 15-20k 5 approximately and we are aware that a significant number of dental nurses work part time. This 5 The BADN s recent salary survey for found that a majority of respondents earned between 10, 000 and 20,000 accessed 27 May A qualified dental nurse with more than 10 years experience and working more than 35 hours per week is likely to be earning between and per annum. Page 25

26 contrasts with hygienists and therapists who are also classified as dental care professionals and can earn between 30-60k. (See Annex B) 3. b What additional research or data is required to fill any gaps in your understanding of the potential or known effects of the policy? Have you considered commissioning new data or research? No we have not considered commissioning new data or research at this time. Step 4 Assessing impact and strengthening the policy 4.a What impact does, or could, the policy have on: a. eliminating unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act b. advancing equality of opportunity between people who share a protected characteristic and those who do not c. fostering good relations between people who share a protect characteristic and those who do not d. removing or minimising disadvantages suffered by people due to their protected characteristics e. taking steps to meet the needs of people from protected groups where these are different from the needs of other people f. encouraging people from protected groups to participate in public life or in other activities where there participation is disproportionately low? 4.b If the policy is likely to have a negative effect on equality, what are the reasons for this? Our flat fee policy means that the same fee will apply to full and part time workers. A higher proportion of dental nurses are women on a lower income who generally work part time. Concerns have been raised that our policy approach to setting the ARF is likely to discriminate indirectly against this group as the fee will be a greater financial burden for them compared to others who can earn a higher salary from practising the profession. 4. c What practical changes will help to reduce any negative impact on particular Page 26

27 groups? See response to 4.d 4. d What could be done to improve the promotion of equality within the policy? The nature of the policy is such that it will be difficult to mitigate the negative effects on equality which have been identified. However, we are committed to being transparent about how the fee level is set and to ensuring that registrant groups are only charged according to how much it costs us to regulate them and that their fee income does not avoidably cross subsidise the regulation of other registrant groups. We will therefore keep the fee level under annual review and determine whether fee levels for different groups are set appropriately in line with this principle. Step 5 Procurement and partnerships 5a. Is this project due to be carried out wholly or partly by contractors? Please summarise the equality issues. You will need to ensure that any partner you work with complies with all relevant legislation. GDC tendering and specifications, awards processes, contract clauses, performance measures and monitoring are/will be standardised with reference to the Equality Act. Please consult the Procurement Manager. The project is not carried out by contractors. Step 6 Making a decision 6a. Summarise your findings and give an overview of whether the policy will meet the organisation s responsibilities in relation to equality. The below summarises what we have set out in this document namely: What the policy is and how it relates to our statutory functions What the effects of the policy are on different groups and how these are the results of the policy The range of evidence that we have collected about the registrant groups which we consider are likely to be impacted by the policy How the policy can be justified even though we recognise that it has certain impacts on certain groups. What the policy is and how it relates to our statutory functions The aim of the policy is to determine how we set the annual retention fee level for our registrants in accordance with our statutory duties. We are also seeking to be clear and transparent to our registrants and the wider public about how we raise and spend money Page 27

28 to deliver our statutory objectives as well as provide clear reasons for the fee levels we set now and in the future. What the effects of the policy are on different groups and how these are the results of the policy We are proposing to charge registrants what it costs us to regulate each registrant group; this means that we do not take into account the individual circumstances of registrants when setting the annual retention fee (ARF). As a result, the policy will have a different impact on registrants depending on how much they earn and their individual circumstances. We are aware for example that 50% of our registrants are dental nurses and 98% of them are women. Dental nurses are generally on low incomes and work part time. Concerns have been raised that our policy approach to setting the ARF is likely to discriminate indirectly against this group as the fee will be a greater financial burden for them compared to others who can earn a higher salary from practising the profession. The range of evidence that we have collected about the registrant groups which we consider are likely to be impacted by the policy. We have a good understanding of the registrant groups that will be affected through analysis of our register and the demographic data we have gathered through our register and our consultation exercise. In addition we have gathered information on the salary levels of all registrants which from the data available indicate that the annual incomes which could be earned by GDC registrants may range from 300k for some dentists to 10k for dental nurses. Hygienists and therapists may earn between 30-60k. How the policy can be justified even though we recognise that it has certain impacts on certain groups. Parliament requires that the General Dental Council is funded by the dental profession and that it should not receive funding from the taxpayer. As a result, we are legally required to charge registrants in order to deliver our statutory functions. We work on the principle that we charge registrant groups what it costs us to regulate them. The fee we charge reflects the costs of regulation for the two distinct groups of registrants (Dentists and DCPs). This approach to setting fee levels is in line with the expectation as set out in the Treasury Guidance on Managing Public Money - that we charge according to the cost of regulation. In addition, in our recent consultation exercise on the fee policy, 66% of respondents agreed with our approach to setting the fee and 90% agreed that dentists and DCPs should be charged different fees. We have considered other approaches to setting the fee including dividing the total costs of regulation equally amongst all registrants or introducing a low income discount. We found that the former option would increase fees significantly for dental nurses and other DCPs and the latter could result in lower paid registrant groups contributing less than is required to regulate them. This would then require a subsidy from one registrant group to another which would in itself be unfair. In the recent consultation exercise, respondents questioned why DCPs are treated as one registrant group and there were calls for dental nurses to be separated out from other DCPs. We have sound evidence, gathered from reviewing the DCP Fitness to Practise cases by Page 28

29 registrant type for 2013, that it currently costs the GDC the same to regulate a dental nurse as it does to regulate a dental hygienist or therapist. In the last year, Dental Nurses made up 60% of the DCP group but incurred 50% of the DCP s overall FTP costs (as measured by the number of complaints received), whereas Dental Therapists, made up 3% of the DCP but incurred 4% of DCPs overall FTP costs, Hygienists made up 10% of the DCP group but incurred 11% of the DCPs FTP costs. (See table below) Breakdown of FTP Cases by registrant type for 2013 Registrant title Number of complaints received about DCPs Percentage of complaints received about DCPs Dental Nurse % 60% Percentage of total number of DCP registrants Dental Technician % 10.5% Dental Therapist % 3% Dental Hygienist % 10% Clinical dental Technician Orthodontic Therapist % 0.3% % 0.4% Concluding points: The GDC, by registering individual professionals is in effect issuing a licence to practice, which provides registrants with the right to practise their profession in the UK. The GDC would contend that although there are legitimate concerns about the low pay received by some registrant groups, the income levels of dental professionals are beyond the control of the GDC and outside its remit as a regulator. It costs the same to take an individual earning a low income through Fitness to Practise as it does someone earning a high income. If registrant groups are charged according to how much they earn rather than how much it costs to regulate them then this raises the possibility that certain low paid registrant groups may end up contributing less than is required to regulate them. This would go against the proposed policy approach to setting the fee and could require a subsidy from one registrant group to another. In addition, Parliament has stated that we must be able to pay for our statutory functions through charging registrants enough to cover our costs; if we link our fees to earnings and the earnings of the dental profession went down then this would mean that we might not have enough income to regulate the profession. We will ensure registrants are clear about our charging policy and that we continue to be transparent about setting fees. We will keep the fee level and the policy under annual review and will ensure that different registrant groups are not charged more than the cost Page 29

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