Position statement on GDC registration requirements for oral and maxillofacial surgeons and other healthcare professionals regulated by statute

This webpage includes the GDC’s position statement on dual registration requirements.  

Introduction

1. This policy position explains when registration with both the General Dental Council (GDC) and General Medical Council (GMC) is required for oral and maxillofacial surgeons. It is also relevant to other professions regulated by statute where dual registration may be required. Its purpose is to ensure that the appropriate regulatory safeguards are in place to protect patient safety, support effective patient care, and reduce the risk of harm. 

The legal framework around exemption from the requirement for GDC registration

• The setting in which an activity is undertaken (e.g hospital department, private clinic) does not matter when considering whether it is a medical task.
• The inclusion of an activity within a non-dental professional’s curriculum or scope of practice does not in itself determine whether that activity is a medical task. 

Application of the framework to oral and maxillofacial surgeons

Education and training of dental students

Designated supervisor for dentists with temporary registration

CPD and revalidation requirements 

The following examples are designed to support professionals consider how they may apply their judgement to determine whether they could rely on the medical task exemption. In practice this will always depend on the particular scenario and case specific circumstances.

Please note that because care settings are not relevant to the requirement for dual registration, they have not been specified. The examples apply in any care setting and for any type of care (e.g. NHS or private care).

• As part of a wider course of medical clinical care, an oral and maxillofacial surgeon carries out an extraction on a patient. They do not need GDC registration as the extraction has been undertaken as a medical task.

• Unexpected medical complications arise whilst a dentist is undertaking an extraction on a patient, so the dentist hands over care to an oral and maxillofacial surgeon mid-procedure. The oral and maxillofacial surgeon does not need GDC registration as the ongoing clinical care is delivered as a medical task.

• An oral and maxillofacial surgeon operates an implant clinic. Dual registration will be required if implant procedures are not undertaken as part of wider medical clinical care.

• A dentist refers a patient to an oral and maxillofacial surgeon when specialist OMFS practice is needed for their care. The oral and maxillofacial surgeon does not require dual registration to manage the referred patient. 

• An oral and maxillofacial surgeon performs restorative dental procedures which are not part of wider medical clinical care. GDC registration is required.

• An unregistered dental student is observing an oral and maxillofacial surgeon as part of their training. The student does not need to be supervised in that setting by a registered dental professional, as they are not providing dental treatment to patients.

• An unregistered dental student is undertaking dental practice under the joint supervision of a GDC registered dental professional and a GMC registered oral and maxillofacial surgeon. The oral and maxillofacial surgeon does not need dual registration because the legal supervision requirement for the unregistered student has been met by the GDC registered supervisor.

• An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), plans a surgical procedure, assists with a surgical device in theatre, and makes or fits a facial prosthesis or obturator that may include artificial teeth. They do not need GDC registration as these activities are delivered as medical tasks.

• An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), makes dentures for a patient. If these dentures are not delivered as part of wider clinical care (e.g. as part of a multidisciplinary care plan), GDC registration will be required.

• An appropriately qualified clinical scientist, who is registered with HCPC (such as some maxillofacial prosthetists or some reconstructive scientists), is directed by an oral and maxillofacial surgeon to take an intra-oral impression for a maxillary obturator. They do not require GDC registration as the impression is delivered as part of wider medical clinical care.

• Am I registered with a statutory regulator?
• Am I appropriately qualified?
• Does the specific dental activity take place as part of the delivery of wider clinical care?

30 January 2023