Teledentistry in NHS Practice: What You Are Allowed to Do

Every teledentistry pitch deck contains a slide about reducing failed appointments and freeing chair time. Almost none of them contains a slide about the FP17. That absence is the whole story, because the NHS teledentistry rules in England are set not by what is clinically sensible but by Schedule 4 of the NHS (General Dental Services Contracts) Regulations 2005 and by what NHS Business Services Authority will pay a claim on. Remote assessment is permitted. It is claimable in a much narrower set of circumstances than the sales conversation implies, and the gap between those two facts is where practices lose money.

If you are about to sign a two-year contract for a triage platform, read the next section before you do.

No clinical examination, no Band 1

Here is the rule that settles most arguments. A Band 1 course of treatment is defined around clinical examination, case assessment and report. NHS England’s position, consistent since the 2020 standard operating procedures and never subsequently relaxed in the regulations, is that a clinical examination cannot be conducted over video. A video call where you look at a patient’s swollen cheek, take a history and advise them is a legitimate clinical activity, properly recorded, entirely defensible to the GDC. It is not a Band 1. It generates no UDA and no £27.40 patient charge.

So a “remote check-up” is not a thing that exists inside the NHS contract, whatever the platform’s marketing copy says about digital-first assessment. Practices that built recall pathways on the assumption it did have ended up delivering care they cannot claim for.

What is claimable, when a remote contact genuinely produces one of these outcomes:

Notice what the table does not contain: any row where the remote contact itself is the billable event, other than the prescription-only claim. The remote call is administrative overhead attached to a course of treatment that still has to happen in your surgery. Your contract pays for the treatment, not the triage.

The maths on an advice-only triage clinic

Take a practice on a 14,000 UDA contract at £31 per UDA. It buys a triage platform and runs a daily 45-minute remote slot, about 30 contacts a week.

Of those 30, roughly 18 convert to an in-practice appointment. Those claims would mostly have happened anyway; the patient rang, they were in pain, they were going to be seen. Four end in a prescription: 4 × 0.75 = 3 UDAs, worth £93. The remaining eight are advice, analgesia and reassurance. Zero UDAs.

Annualised, the advice-only cohort is roughly 380 contacts. At 12 minutes of associate time each, that is 76 hours a year of clinician time producing no contract credit and no private fee. On a 50/50 associate split with the associate paid per UDA, the associate carries that loss personally, which is how these workflows quietly become an associate recruitment problem eighteen months in.

The prescription-only claims, meanwhile, are the ones most likely to attract attention. Remote antimicrobial prescribing is where teledentistry and the GDC’s joint High Level Principles for Good Practice in Remote Consultations and Prescribing collide hardest. Irreversible pulpitis needs operative intervention, not amoxicillin. A pattern of 0.75 UDA prescription-only claims in an NHSBSA data set looks like antibiotic prescribing without examination, because frequently that is exactly what it is.

The premises question nobody raises

GDS services are commissioned to be delivered at the premises named in your contract. Domiciliary care requires a specific contractual provision. Out-of-hours is separately commissioned. There is no line in the 2005 Regulations that contemplates a dentist at their kitchen table assessing a patient at theirs.

In practice, commissioners have tolerated remote contacts as part of a course of treatment delivered at the practice. Tolerance is not entitlement. If you are designing a model where an associate does two remote sessions a week from home, raise it with your commissioner in writing and keep the reply. The cost of asking is one email. The cost of not asking surfaces at a mid-contract review, applied retrospectively.

Charging an NHS patient a private fee for a remote consultation about a problem that falls within NHS scope is a separate and more serious issue. Do not build that into a pricing page.

Radiograph AI does not change who justifies the exposure

Pearl’s Second Opinion, Overjet and VideaHealth are all real, and the caries and bone-level detection is genuinely useful. None of them moves a single IR(ME)R 2017 duty.

The employer holds the framework. The referrer refers. The practitioner justifies each individual exposure, and the practitioner is a registered person, never a piece of software. A tool that suggests bitewings are due is a prompt to a referrer, not a referrer. A nurse with a post-registration certificate in dental radiography can act as operator and take the images while you read them remotely, and that arrangement is fine. It still is not a Band 1, because nobody examined the patient.

The medico-legal exposure runs the other way from what people expect. When Pearl flags proximal caries on the 36 and you decide to monitor, the software has created a timestamped record of a flag you overrode. That is discoverable. Your notes now need to say why you monitored, with reference to what you could see clinically that the algorithm could not. Practices adopting these tools should update their note templates in the same week they switch the AI on, not six months later.

Before you buy, ask for the UKCA or CE certificate and the device class. Software that outputs diagnostic findings is generally Class IIa under the UK Medical Devices Regulations 2002. If the answer you get back is “FDA 510(k) cleared,” you have been answered about a different jurisdiction. MHRA registration is what matters for a patient sitting in Bolton.

Where remote assessment actually pays

Orthodontics is the honest success case. A completed GDS orthodontic course pays 21 UOAs, claimed on completion, with 1 UOA for assess-and-review or assess-and-refuse. Because the payment sits at the ends and not in the middle, DentalMonitoring or Invisalign Virtual Care during active treatment converts directly into recovered chair time without touching the claim at all. A practice reviewing 60 active cases can realistically drop two of every five in-person adjustment visits. That is pure capacity.

Front-desk and admin AI is the other genuine win, precisely because it never touches a claim. Kiroku for clinical notes, automated recall sequencing inside Dentally or Software of Excellence Exact, call-handling that captures the pain history before the patient reaches a nurse: none of it is a claimable activity, so none of it creates FP17 risk. It creates time. Time is the thing you are actually short of.

Triage sorting also works, as long as you are honest that it is a routing function rather than a revenue function. Deciding which of Monday’s 14 emergency callers needs the 9am slot is worth doing well. We go into the detail of pathway design, urgency scoring and what to record at each step in Triage and Remote Assessment.

The paperwork your vendor’s slide deck skipped

Four items, all real, all routinely omitted:

1. DSPT. Your Data Security and Protection Toolkit submission is due by 30 June each year and must reflect the systems you are actually running. New clinical software mid-year means the submission changes.
2. DCB0160. When a practice deploys clinical software into NHS care, the practice is the health organisation under the clinical risk management standard, which expects a clinical safety case and a named Clinical Safety Officer with appropriate training. Vendors will show you their DCB0129 evidence. That is their half, not yours.
3. DPIA. Article 35 UK GDPR, and unavoidable for AI processing of special category health data at scale. Read the data processing agreement for anything permitting use of your patient data for “service improvement.” That phrase means model training.
4. Indemnity confirmation in writing. Dental Protection, MDDUS and MPS all cover remote consultation, with conditions. Get the conditions.

One last practical point on scope: this is England. Wales measures activity through ACORN and patient numbers rather than UDAs, which makes the remote-contact question genuinely different there, and Scotland’s Statement of Dental Remuneration operates on items of service. Do not read an English blog post, including this one, as guidance for a Cardiff or Dundee practice.

The next commissioner conversation you have about this will go better if you bring the FP17 categories with you and ask which of them your proposed workflow lands in. Make them name the row.