Sir, this week CQC have commenced another consultation regarding fees for dental practices.

We recently had a visit by two members of the CQC to our LDC meeting. They stressed that CQC was not a 'tick box exercise' but outcome based. When asked about the outcome of CRB checks in dentistry they said that one person had been prevented from working since CRB checks had been instigated.

There were 22,920 dentists working in the NHS in 2011-2012 (www.ic.nhs.uk). Assuming they all work with a nurse and add on approximately 10,000 receptionists this equals 55,840 people requiring CRB checks. The cost is £44 for the CRB plus £20.83 to the post office to process the application. This is therefore at a total cost of £3.6 million in round figures. This doesn't include the cost of my CQC registration to pay for someone to check I have a CRB, or the cost of the time involved in getting it. When asked, the CQC representative said in reply, 'even if it prevents one person from abuse it is worth it'.

I work in a catchment area for deprived families and patients say, 'You've got to sort out this pain; I can't sleep or eat and I am taking it out on my partner/kids'. Evidence shows that the majority of abuse is carried out by family members. Preventing abuse by removing people from severe pain is the sort of real world evidence-based outcome our practice aims for and wants to spend money on.

In a system which has no additional funding for regulation, the cost of CRB checks is taken directly from patient care. If you are considering outcomes, surely the idealistic view of preventing one person from possibly reoffending at a cost of £3.6 million should be balanced against the benefit of treating 48,000 patients (cost £75/patient × 48,000 = £3.6 million) for dental pain. This has a much better evidence base for reducing abuse within the family and there are considerable spin offs such as fewer hospital admissions for acute care as well!

CRBs are just one small example of this lack of outcome-based thinking; space here limits us from looking at the others. I don't see much evidence for CQC analysing either their original justification or their own outcomes; just reducing dental care by diverting treatment funding. Is this really a good use and how much should we pay them?

1. Dewsbury