The process for non-UK qualified dentists joining the NHS Dental Performers List in England has seen important changes and clarifications under updated NHS England guidance. These changes are particularly relevant to NHS dental providers and practice principals considering the recruitment of a non-UK qualified, General Dental Council (GDC)-registered dentist as an Agreed Term Dentist (ATD).
One of the key points highlighted in the latest guidance is the responsibility for checking Occupational Health (OH) and Basic Life Support (BLS) status. NHS England will not carry out these checks for an applicant ATD under the arrangements described by the client. Instead, the NHS provider or practice principal is responsible for checking the dentist’s suitability, including their clearance to undertake Exposure Prone Procedures (EPPs).
For dental practices planning recruitment, understanding these responsibilities is essential for maintaining appropriate clinical safety checks, supporting workforce planning and ensuring that the correct processes are followed before a dentist begins relevant clinical duties.
In this guide, we explain the key change, what it means for practice principals and NHS providers, and the checks that should be considered when recruiting a non-UK qualified dentist as an ATD.
What Has Changed for Non-UK Qualified Dentists Joining the NHS Performers List?
The main change highlighted in the client’s update concerns the responsibility for verifying an applicant ATD’s Occupational Health and Basic Life Support status.
Under the arrangements described, NHS England will not check the applicant’s OH or BLS status. The responsibility now sits with the NHS provider or practice principal considering the appointment.
This means that practices should not assume that these checks have been completed simply because a dentist is GDC registered or is progressing through the Performers List process.
The provider or principal must establish whether the applicant has the appropriate evidence and whether the dentist is suitable to undertake the duties expected of them.
The key responsibilities highlighted in the update are:
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Occupational Health (OH): The provider or practice principal is responsible for checking the applicant ATD’s relevant occupational health status.
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Basic Life Support (BLS): The provider or practice principal must check the applicant’s BLS status and relevant training evidence.
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Exposure Prone Procedures (EPPs): The provider or practice principal is responsible for ensuring that the dentist is appropriately cleared and suitable to undertake these procedures.
These checks form part of the practice’s recruitment and clinical governance considerations when accepting an ATD.
What Is an Agreed Term Dentist (ATD)?
An Agreed Term Dentist is a dentist accepted onto the relevant NHS Dental Performers List arrangements subject to agreed terms. These terms may set out specific requirements, support arrangements or actions that must be completed within an agreed period.
NHS England’s wider performers-list policy explains that some dental applicants who have not previously provided NHS primary dental services in the UK may need a structured conversation with a dental clinical adviser. This can help assess whether the applicant is up to date to provide NHS primary dental services and whether induction, educational support or a clinical support plan is needed.
The arrangements depend on the applicant’s circumstances and the applicable agreement. Practice principals should therefore establish the exact terms attached to an individual dentist’s inclusion and appointment rather than assuming that every ATD follows an identical process.
For practices recruiting overseas-trained dentists, understanding the distinction between GDC registration, inclusion on the Dental Performers List and the conditions attached to an ATD arrangement is important.
Occupational Health Checks: What Practice Principals Need to Know
Occupational Health checks are an important consideration when recruiting dentists for NHS primary care. They help establish whether the appropriate health clearance is in place for the clinical work the dentist will undertake.
Under the change highlighted in the client’s update, the provider or practice principal is responsible for checking the applicant ATD’s Occupational Health status rather than relying on NHS England to carry out that verification.
Practice principals should establish:
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Whether the applicant has the required occupational health assessment or clearance.
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Whether the evidence is current and relevant to the proposed clinical duties.
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Whether additional health clearance is required for Exposure Prone Procedures.
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Whether any outstanding requirements are specified in the dentist’s agreement terms.
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Whether the practice has documented the checks and any actions required before the dentist undertakes the relevant procedures.
NHS England’s published performers-list policy states that dental applicants require occupational health clearance appropriate to NHS work, including additional health clearance for Exposure Prone Procedures. It also explains that, in relevant circumstances, evidence may be provided later under agreement terms.
Important: The precise requirements should be checked against the current NHS England guidance and the individual dentist’s agreement. Practices should not interpret the change as meaning that occupational health clearance is unnecessary.
Basic Life Support (BLS): Responsibility for Verification
Basic Life Support training is another key consideration when appointing a dentist to an NHS primary care role.
The client’s update makes clear that NHS England will not check the applicant ATD’s BLS status under the arrangements described. The responsibility for checking the applicant’s status therefore rests with the NHS provider or practice principal.
Before the dentist undertakes clinical duties, the practice should establish what evidence is required and whether the applicant meets the relevant requirements.
Points to consider include:
- Evidence of recent, hands-on Basic or Advanced Life Support training, as applicable.
- The date the training was completed and whether it meets the relevant guidance.
- Any outstanding BLS requirement included in the applicant’s agreement terms.
- A record of the evidence checked and any follow-up action required.
PCSE’s published guidance for the English Dental Performers List states that evidence of recent hands-on BLS training may be provided later under agreement terms where it cannot be supplied with the initial application.
This does not mean that practices should disregard BLS requirements. Instead, practice principals should confirm the applicable arrangements for the individual applicant and ensure that responsibilities and outstanding requirements are clearly understood.
What Are Exposure Prone Procedures (EPPs) in Dentistry?
Exposure Prone Procedures are clinical procedures in which an injury to a healthcare worker could result in the worker’s blood contaminating a patient’s open tissues.
The UK guidance on general dentistry categorises procedures according to the risk of bleed-back. Examples of dental procedures that may be exposure-prone include certain extractions, periodontal surgery, root canal treatment and dental implant placement.
The exact classification depends on the procedure and how it is performed. Practices should refer to the relevant guidance rather than relying on a general list alone.
For practice principals, the important point is that a dentist’s suitability to undertake EPPs must be appropriately established. The client’s update places responsibility for checking this suitability on the provider or practice principal when considering an applicant ATD.
Relevant considerations include:
- Whether the dentist has the required additional occupational health clearance.
- Whether the available evidence is appropriate for the clinical work they will undertake.
- Whether any restrictions or outstanding requirements apply.
- Whether the practice has documented its checks and resolved relevant issues before the dentist undertakes EPPs.
A dentist being GDC registered does not, by itself, demonstrate that all occupational health requirements for a particular clinical role have been met.
NHS Dental Recruitment: A Practical Checklist for Practice Principals
The updated arrangements make it particularly important for dental practices to have a clear process for assessing applicants and documenting the checks completed.
The following checklist can help NHS providers and practice principals organise their recruitment process when considering a non-UK qualified, GDC-registered dentist as an ATD.
| Check | What the practice should establish |
|---|---|
| GDC registration | Verify the dentist’s current registration and relevant registration details. |
| Performers List status | Confirm the applicant’s position in the NHS Dental Performers List process and the applicable arrangements. |
| Agreement terms | Understand the specific conditions, support requirements and outstanding actions attached to the ATD arrangement. |
| Occupational Health | Check the relevant occupational health evidence and any additional clearance required. |
| Basic Life Support | Check the applicable BLS training requirements and evidence. |
| EPP suitability | Establish whether the dentist is appropriately cleared for the exposure-prone procedures they will undertake. |
| Clinical support | Consider whether induction, supervision or a clinical support plan is required under the applicable arrangements. |
| Record keeping | Keep appropriate records of checks, decisions and follow-up actions. |
This checklist is a practical aid, not a substitute for the current NHS England policy, the relevant regulations or the applicant’s individual agreement terms.
How These Changes Affect NHS Dental Providers and Practice Principals
1. Recruitment processes need clear ownership
Practices should identify who is responsible for checking occupational health and BLS evidence. These responsibilities should be built into the recruitment process rather than left until the dentist is due to start work.
2. Documentation becomes particularly important
A clear record of the evidence reviewed, any outstanding requirements and the actions taken can help practices demonstrate that they have considered the relevant checks.
3. Workforce planning should account for outstanding requirements
Recruitment timelines may be affected if evidence, assessments or training remain outstanding. Practices should establish the position early and confirm what can be completed under the individual agreement terms.
4. Clinical duties should reflect the dentist’s clearance and arrangements
Providers should confirm that the dentist is appropriately cleared and meets the applicable requirements for the procedures they are expected to undertake. They should not assume that every clinical duty is automatically authorised by GDC registration or Performers List progress.
5. The individual agreement still matters
The arrangements for an ATD can depend on the applicant’s circumstances and the terms agreed with NHS England. Practice principals should check the individual requirements rather than applying a single process to every applicant.
Does GDC Registration Mean a Dentist Can Start NHS Primary Care Work?
No. GDC registration and eligibility to provide NHS primary dental services are separate considerations.
In England, dentists providing NHS primary care generally need to be included on the Dental Performers List, subject to the applicable rules and exceptions. The relevant application process, agreement terms and clinical requirements must also be considered.
Practice principals should verify the dentist’s status and confirm that the arrangements permit the proposed work. They should also establish whether any outstanding requirements or restrictions affect the duties the dentist can undertake.
For the official process, refer to NHS England’s Performers Lists guidance and PCSE’s Performers Lists service.
Frequently Asked Questions (FAQs)
1. What has changed for non-UK qualified dentists joining the NHS Performers List?
The client’s update highlights a change in responsibility for checking the Occupational Health and Basic Life Support status of an applicant Agreed Term Dentist. Under the arrangements described, NHS England will not carry out these checks for the applicant ATD; the provider or practice principal is responsible for checking the relevant status and suitability for Exposure Prone Procedures.
2. Who is responsible for checking the Occupational Health status of an ATD?
The NHS provider or practice principal considering the appointment is responsible for checking the applicant ATD’s relevant Occupational Health status under the arrangements described in the client’s update.
3. Who checks Basic Life Support training for an applicant ATD?
The NHS provider or practice principal is responsible for checking the applicant’s BLS status under the arrangements described. The practice should confirm the applicable training requirements and review the relevant evidence.
4. What are Exposure Prone Procedures in dentistry?
Exposure Prone Procedures are procedures in which an injury to a healthcare worker could result in their blood contaminating a patient’s open tissues. Certain dental surgical and other clinical procedures may fall into this category. Practices should use the relevant UK guidance to assess individual procedures.
5. Does GDC registration automatically allow a dentist to provide NHS primary care?
No. GDC registration does not automatically mean that a dentist can begin providing NHS primary dental services. The relevant Dental Performers List requirements and any applicable agreement terms must also be satisfied.
6. Can an applicant provide Occupational Health or BLS evidence after joining the Dental Performers List?
NHS England and PCSE guidance allows certain evidence to be provided later under agreement terms in relevant circumstances. Whether this applies to a particular applicant depends on the applicable arrangements and requirements. Practices should confirm the individual position before the dentist undertakes relevant duties.
7. What should a practice principal check before accepting an ATD?
The practice should verify the dentist’s registration and Performers List position, review the applicable agreement terms, check the relevant Occupational Health and BLS evidence, establish suitability for the proposed clinical duties and document outstanding requirements and follow-up actions.
Conclusion
The updated guidance on non-UK qualified dentists joining the NHS Dental Performers List highlights an important responsibility for NHS dental providers and practice principals considering an Agreed Term Dentist.
The key point is that, under the arrangements described in the client’s update, NHS England will not check the applicant ATD’s Occupational Health or Basic Life Support status. The provider or practice principal must establish the relevant status and ensure that the dentist is suitably cleared for Exposure Prone Procedures.
For dental practices, the practical response is to review recruitment procedures, assign responsibility for checking the relevant evidence, understand the individual agreement terms and maintain appropriate records.
As NHS dental recruitment requirements can vary according to the applicant’s circumstances, practices should consult the latest NHS England and PCSE guidance before making recruitment or clinical deployment decisions.
Editorial note: This article provides general information for dental recruitment and workforce planning. It is not a substitute for the current NHS England policy, applicable regulations or individual agreement terms. Practices should verify the requirements that apply to each applicant before making clinical deployment decisions.
