change the band not the tune...
So, after much speculation the CQC have finally issued the annual registration fees that they are proposing to charge dental practices. For sure, they are only in the consultation stage but still worthy of examination and for the uninitiated they are as follows:| Lower range number of locations | 0 | 2 | 4 | 11 | 51 | 101 |
| Upper range number of locations | 1 | 3 | 10 | 50 | 100 | |
| Proposed fee | £1,500 | £3,000 | £6,000 | £12,000 | £24,000 | £48,000 |
I am not quite sure of the logic or reasoning behind this proposed schedule but it is clearly profoundly flawed and unfair as my following table shows.
| Number of locations | 1 | 2 | 3 | 4 | 7 | 10 | 11 | 35 | 50 | 51 | 75 | 100 | 101 | 350 |
| Fee per location | £1,500 | £1,500 | £1,000 | £1,500 | £857 | £600 | £1,091 | £343 | £240 | £471 | £320 | £240 | £475 | £137 |
The questions and anomalies that flow from the analysis are endless; why does a provider with 3 practices pay £1,000 per site when if you have either 2 or 4 practices you have to pay 50% more. If you have 7 practices then you end up paying £244 per location p.a. less than if you have 11 at £1,091. Why not have 35 practices at £343 p.a. each or even better 50 practices at a snip of just £240 each rather than 101 sites at £475? Meanwhile, if you grow to 350 practices it’s just £137 each, less than 10% of what a single owner would have to pay?
Surely, we have all seen more than enough of the deeply flawed 3 band UDA system that haunts the current NHS contract; that’s had to be reviewed and a new contract is to be outlined in December, so please let’s not make the same mistake again!
However, it is all too easy just to criticise what is proposed and not to be constructive and offer an alternative, so here goes. I believe that there should be perhaps 3 bands but based on the number of active surgery/consulting rooms and that each location should pay the same irrespective of the number of practices in the group. So, to give a precise example, and I do not know if the maths work for the CQC, it might look as follows:
| Number of active surgery/consulting rooms at the location | 1 - 3 | 4 - 6 | 7 or more |
| Proposed fee | £600 | £900 | £1,200 |
Of course, no system is perfect, but this fee schedule is simple and based on the explicit assumption that if a practice is larger than there is more regulated activity being performed. Therefore, the CQC’s task is more time consuming and should be reflected in the fee level.
Well, whatever happens, there has got to be a fee structure and when it is finalised let’s hope that it is fair, logical and not punitive to smaller practices; if that is to be achieved then the band as well as the tune has got to change.
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