Continuing dental education- will be it another avenue for profiteering by institutions??
In 2007, the Dental Council of India came out with an ambitious but poorly drafted, half hearted and ambiguous attempt to make continuing education compulsory for practising dentistry. In 2011, a new regime, struck it down as non implementable due to several reasons. Five years later it has now emerged again as a rehashed version of the original regulation, by the same dispensation that struck down the earlier version.
There are two things that strike me.
1. Why is it that the already beleaguered and over produced specialty of dentistry alone require such compulsory updation as a pre requisite for renewal of registration when critical health bodies like MCI, AYUSH and other bodies have not imposed such compulsions?
2. Why has the onus of providing such updation been placed almost exclusively with Dental Colleges which have been variously described as ranging from very good to very bad. In other words, why are other private organisations and skill providers been excluded from accreditation?
Before anybody gets me wrong, let me explain that I am in full support of doctors and dentists being fully updated on advancement in their science as a matter of public safety and quality treatment. However, there are too many glaring holes in the structure of the current regulation, though most of us will concede that it is a significant improvement over the last attempt, a decade ago. My position on the matter is simple. Make learning a more open process where people can gain knowledge in less expensive ways provided by modern communication technology. We do not need another regulatory body breathing down the backs of the poor struggling dentist who has to reckon with one more 'bully' in the form of the state dental council. Here are some of the objections
1. The primary task of providing continuing education has been offered to the teaching institutions. Are we looking at a bail out package for Dental Colleges that are sinking for want of students taking up dentistry? Going by the new regulation, it seems that the statutory bodies are providing them with another opportunity to make money. It is completely presumptuous to think that teachers in dental colleges are better placed to provide skills and knowledge. On the other hand the need for continuing education and updation is precisely because many of the sub standard colleges have failed to provide good training in the first place.
2. Even more presumptuous is the fact that teachers do not need continuing education. They are exempt!! This could be true, if they were pure teachers who did not do private practice and their work is restricted to the dental colleges. Let me give you an example. How can a teacher in Oral Pathology, who neither sees nor treats dental patients in a dental college be allowed to practice dentistry after college hours without the mandated CDE points? Does teaching Oral Pathology give the person knowledge about Infection control, Ethics, Crown and Bridge preparation or Oral Surgery. Absolutely not!!! The only way that this major anomaly can be addressed is by preventing dental college staff from private practice or by making it compulsory for them to undergo CDE like every body else, if they wish to practice after their working hours.
3. By introducing a self assessment protocol we are giving too much of discretionary powers to the regulators. They can pick and choose their victims. Most of us see the enormous possibility of some of these powerful persons venting animosity by targeting those they have professional or personal rivalry with. If made compulsory, CDE as a compulsory requirement, should be used universally against all those who do not comply by a process of due diligence exercised by the regulatory bodies. Any attempt by regulators to exempt anybody from statutory action for non compliance, should be considered as a corrupt practice and criminal action should be initiated against the regulators. This is the only way to prevent selective harassment.
4. There is a discord in the rules for obtaining CDE points. It says one should have 100 points in 5 years but not less than 20 points in a single year. Going by this rule, a person who gets less than 20 points in the first year, already faces disqualification. Why wait for 5 years to take action? Another clause also says ' not more than 25 points in a year'. What will the DCI do? Punish those who learn more? We will ignore that as oversight or stupidity!!
5. The notification says it comes into effect immediately. Does this mean that a dentist cannot register on the 1st January 2019, if they do not have 20 points? Are all the oversight mechanisms in place or is it going to be arbitrary. Is my next CDE programme this weekend valid? Is the next National Conference of my specialty valid? Too many gaps, if you ask me.
There are several more vacuous discrepancies in this incomplete regulation.
My bottom line is that while the DCI has the powers to make sub ordinate legislations, it cannot legally refuse re -registration on the grounds of this new regulation. The Dentist Act only requires a recognised qualification and a prescribed fee for registration. In any conflict between the Act and regulation, the Act will prevail. I hope the DCI is prepared for litigation, unless they amend the Act and even then it cannot be used retrospectively. It cannot be used for those who are already registered.
The DCI should remove draconian consequences for not updating and encourage CDE as a positive way to remain relevant in the profession. In as much as that is concerned, I appreciate the provision in the new regulation for certifying those who achieve the recommended CDE points. That alone should be an incentive. Not punitive action!
George Paul
Oral and Maxillofacial Surgeon
Salem
