The Council fully understands the hardship and anxiety many oral health practitioners have experienced as a result of necessary restrictions on your practice due to COVID-19.
A national emergency and response to a global pandemic creates extraordinary and challenging circumstances. In response to the COVID-19 crisis, the New Zealand government has put in place unprecedented public health and social measures that have significantly impacted on individuals, their health, and the economic future of our country. The Prime Minister has indicated a move slowly and cautiously to safely return New Zealanders to work.
We have now moved to alert level 3 and we know that practitioners are urgently seeking clarity about the extent of any restrictions and guidelines that will apply under alert levels 2 and 1 so you can plan for future care.
Many practitioners have questioned the Dental Council’s role and the actions of Council during the COVID-19 crisis. To assist and answer your questions, this update provides the following information:
In a public health crisis, the government is responsible for putting in place public health and social measures to respond to the threat of community infection. Our government has developed an alert system setting out restrictions, including restrictions on the delivery of oral health services, that apply under each alert level.
The relevant government departments provide their sector with further detail about what can and cannot be done at each level. We have seen this with the Ministry of Health’s active role in determining ‘essential’ health services at level 4 and ‘safe’ health services at level 3.
The regulatory authorities, which includes the Dental Council, can then provide further, more tailored direction or guidance to their professions, as necessary.
During the COVID-19 response, the Council’s authority to regulate key aspects of professional practice continues to operate within the provisions of the Health Practitioners Competence Assurance Act (the Act). Our key responsibility is to protect the public by ensuring practitioners deliver safe oral health care within the COVID-19 restrictions that apply.
The role of individual health providers including employers, professional associations, educational institutions and, ultimately, individual oral health practitioners, is to operationalise the guidelines issued by the Ministry and the regulator, and support each other to institute practices that fall within this framework and suit their work environment based on their clinical judgement.
To meet our key responsibility to ensure public safety, Council has taken a lead role liaising closely with the Ministry of Health (the Ministry) to prepare and provide guidance to ensure practitioners deliver safe oral health treatment to their patients. The guidelines we have developed to date have stood up well and have been recognised internationally.
Immediately after the government announced alert levels and initial measures, the Council reached out to key associations and we were able to issue early communications to practitioners with the support of these groups. Professional associations including NZDA joined with the Council and the Ministry in issuing a joint statement on 23 March 2020 requiring all non-essential and elective dental services to be suspended.
The guidelines for the move to level 4 were developed under extreme time pressure that limited the opportunity to seek wider feedback. We worked directly with the Ministry and our professional advisors to issue these guidelines within 20 minutes of level 4 coming into effect.
For the most recent alert level 3 guidelines the Council formed a clinical advisory group to provide advice and to develop draft guidelines for oral health practitioners during the COVID-19 response. These guidelines were developed based on the assumptions about the possible restrictions the Government and Ministry would put in place for alert level 3.
Professional associations and the two educational institutions were given an opportunity to provide feedback on the draft guidelines. Following feedback, the Council and Ministry finalised the guidelines prior to approval by the National Health Coordination Centre (NHCC) which includes infectious diseases specialists. This takes considerable time but once approved, the guidelines were issued to practitioners on the same day.
We have begun developing the level 2 guidelines and will follow a similar process as we did for level 3. Our objective is to work as quickly as possible to complete drafting the guidelines, gather feedback, finalise and obtain sign off before issuing these to practitioners.
Last week, comparisons were made to Australia and some practitioners asked why the same level 2 treatment guidelines that have been announced there cannot apply in New Zealand also.
The primary reason we have not followed the Australian guidelines is that our two governments are making different decisions and we are required to follow the decisions of the New Zealand government for the New Zealand situation.
As you will be aware, the New Zealand government has decided we will be at alert level 3 for at least two weeks before it reviews the next steps on 11 May 2020. We are developing the guidelines for level 2 according to our government’s requirements for health service delivery at this level.
At all times, the Council aims to work positively and constructively in the best interests of not only the public but practitioners and sector groups as well. Our preference is always to work with associations and we fully support them in their role.
As a regulatory authority, the Dental Council’s role is quite different and distinct from the roles of associations who represent the interests of their members and take actions on their behalf.
We have proactively tried to engage with associations throughout the COVID-19 response and have sought their feedback and contribution wherever possible.
Although the constantly evolving and developing nature of the COVID-19 response has meant our usual wider consultation processes are not possible, the Council has invited key associations to communicate jointly and contribute to the process of developing guidelines.
We have continued to engage with key associations, gain input to guidelines and seek feedback within very short timeframes. This has been difficult and we have and will continue to endeavour to issue guidelines to you all as soon as possible in what is a complex New Zealand health system over this time.
The most significant government decision made during the COVID-19 response for dental services has been the requirement to suspend non-essential and elective dental treatment. Recognising the huge impact this decision would have on each oral health practitioner, the Council issued a joint statement with the Ministry and associations on 23 March 2020 to this effect.
We know that many practitioners have found it difficult to source PPE supplies and these concerns have been relayed to the Ministry through many channels. As we have previously noted, sourcing PPE is not the role of the regulator.
We encourage and support practitioners to continue working together within their personal and professional networks, with their associations, dental suppliers and local DHBs to source necessary PPE supplies.
Many comments have been made about annual practising certificate (APC) fees during this crisis. The Council does understand the financial strain many are under and has worked within its constraints to relieve such pressure where possible with the removal of late penalties for APC applications.
Some practitioners have asked for APC fees to be refunded or waived this year.
The Dental Council is a regulatory body and is in a different position to voluntary membership associations who do have the ability to waive membership fees which some have done. The Council does not receive “membership” fees. After consultation with practitioners and associations, annual fees payable are gazetted through a parliamentary process.
We understand that many practitioners are currently unable to work. But, holding a current APC is a legal requirement under the Health Practitioners Competence Assurance Act for all practitioners to practise, and we are unable to change this.
Understandably, practitioners have many concerns and questions during this difficult time.
The Council takes on board the criticism and dissatisfaction with communication from us over this crisis. The Council has had a significant increase in direct inquiries from practitioners and we are attempting to respond individually as quickly as possible. This is proving difficult due the sheer number of inquiries and the detailed and specific questions in each one.
We will aim to provide more frequent general updates to all practitioners on progress over this difficult time for you all.
Communications with associations from the guideline development process for the de-escalation to level 3 are also available on our website including feedback received and our replies which include Council’s consideration. We will also publish this information when guidelines are developed for levels 2 and 1.
We are aware that many practitioners are currently facing severe impacts on your businesses, livelihoods and personal wellbeing. We encourage you to seek help and support from those close to you, your own doctor, and other organisations able to assist.
To everyone who has supported the Ministry, the Council members and staff, as well as all those of you who have continued to make significant sacrifices and support the nation through this crisis, we would like to personally say thank you.
This is a difficult time for everyone as we each face personal challenges of our own. Throughout these challenges, we will continue to try to work with you all in a professional, constructive, timely way to achieve the government’s objectives and support the national COVID-19 response.
We will continue to provide advice and issue joint Ministry and Council guidelines with input from associations and key sector groups as quickly as we possibly can in these unprecedented times.
Andrew Gray & Marie Warner
Chair & Chief Executive