organisation. If concerns persist then, ideally, this matter should be discussed with the underperforming dentist. The truth is that very few of us welcome criticism, however constructive and well-intentioned. If barriers are met, the concerned dentist may wish to approach, for example, the NHS Board, area team or the CQC with an impartial and accurate account of the situation. Having done so, the matter can be left in the capable hands of the relevant agency. However, there may be some


circumstances in which it is deemed that these measures are insufficient and that referral to the GDC is required. This is a big step. Aside from taking advice, prospective informants should examine their own motives – the GDC has in the past been used as a sword and a shield. Consideration should also be given to the GDC’s guidance in this regard. Direct referral to the regulator may well


be appropriate where there are serious risks to patient safety arising out of, for example, systemic cross-infection failures or drug abuse. However, lesser problems may well be manageable in a more discrete, proportionate (and, some might argue, efficient) manner, utilising the options set out above. In other words, GDC referral should be normally considered in extremis or where all else has failed.


TO CONCLUDE Now more than ever, there is the possibility that a GDC investigation will consider whether registrants have discharged their duty of candour. It is also conceivable that, where a registrant’s failings are serious or recurrent, other professionals may be asked why they did not protect patients by raising concerns at an earlier stage. Although these concepts can have commonality, their pathways are distinct. Duty of candour is patient-facing: treating clinicians must be open and honest about adverse outcomes. Raising concerns involves different processes. If patients are deemed to be at risk, registrants must not turn a blind eye. However, concerns should be raised in good faith, at an appropriate level and should be voiced within a professional rather than a public setting.


Mr Doug Hamilton is a dental adviser at MDDUS MDDUS INSIGHT / 15


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