The regulations relating to submission of FP17s or FP17Os relates to both general and orthodontic courses of treatment, but NHS Business Services Authority (NHSBSA) were only asked to enforce the rule for general courses of treatment.
Our systems do check and report on any forms that breach the rule, but in the case of orthodontic courses we simply create the comment code which is included on the pay statement. This has been the case since the late submission rule was introduced in June 2014.