An overview of our fitness to practise activity undertaken in 2014-15

John Barwick, Acting Director of Fitness to Practise at HCPC, highlights the findings presented in our Fitness to practise annual report 2015 and discusses key areas of work and activities undertaken this last year.

This month we published our Fitness to practise (FtP) annual report, covering the period 1 April 2014 to 31 March 2015. The report provides information about the work we do in considering allegations about the fitness to practise of our registrants.

Here, we provide an overview of the statistics in terms of the cases progressed through our FtP process in 2014-15, as well as highlighting key activities undertaken to continually review and improve our procedures.

In 2014-15, the number of individuals on our Register increased by 2.7 per cent. The number of new concerns we received also increased from 2,069 to 2,170, a percentage rise of 4.8 from the year before. However, despite this increase, the proportion of the Register affected still remains low, with only 0.66 per cent of registrants (or 1 in 166) being subject to a new concern in 2014-15.

In 2014-15:

• 1,042 cases were closed before being considered by an Investigating Committee Panel (ICP) as they did not meet our Standard of acceptance.  
• 849 cases were considered by an ICP.
• 351 final hearings were concluded. Of these, 15 cases were discontinued, 76 were not well-founded, seven resulted in no further action, and one was removed. Imposed sanctions included 52 cautions, 39 conditions of practise orders, 69 suspensions and 62 strike-offs. 30 cases resulted in voluntary removal.
• 236 review hearings were held.

The number of cases considered by an ICP and the number of final hearings concluded increased significantly from 2013-14. We had anticipated these increases due to the high number of concerns we received in 2013-14 and the time it takes for those concerns to progress through the process.

Given the further increases in concerns received in 2014-15, we have planned our resources in 2015-16 to allow for additional ICP and hearing days if required. 

Key areas of work and activities undertaken in 2014-15

• Improving the experience individuals have when they’re involved in the FtP process, be it a complainant, registrant, employer or witness. This included reviewing the tone of our correspondence.
• New initiatives have included proactively seeking feedback from complainants and registrants at the conclusion of a case, and using the Patients Association peer review model to assess how we handle FtP concerns.
• Enhancing the information sources available to employers. Ongoing engagement with this group is important to ensure they understand what concerns to refer to us, at what time, and what information to provide.
• As part of our commitment to building an evidence base for the field of professional regulation, we published Preventing small problems from becoming big problems in health and care. This report provides an insight into the triggers of disengagement and explores ways in which preventative action might be implemented.
• We signed new Memoranda of Understanding with the Care Quality Commission and the Disclosure and Barring Service. These agreements set out how we will work together to achieve our separate statutory functions but also our joint objective of safeguarding the health and well-being of the public.

Future work

• We will continue to look at cost efficiency in our FtP process
• We have reviewed our Standard of acceptance policy to ensure it remains fit for purpose. This has involved taking into account the changing nature of the cases we receive, feedback from those involved, and feedback from our audit and complaints data.
• We will start work to further separate our investigation and adjudication functions to ensure enhanced independence in our FtP process.

The Fitness to practise annual report 2015 is available to download here.

What happens at a fitness to practise hearing?

Your six-point guide to the Health and Care Professions Council’s (HCPC) hearing process.

1. The panel

The three-strong panel considering the case will be led by a Chair. The Chair may be a lay person or from one of our professions. They will be joined by a lay person, who is not registered with us, plus a registrant from the same profession as the person being investigated.

Panels of the Conduct and Competence Committee consider allegations that a registrant’s fitness to practise is impaired by reason of misconduct, lack of competence, or a conviction or caution for a criminal offence. Panels of the Health Committee consider allegations that registrants’ fitness to practise is impaired by reason of their physical and/or mental health.

2. Public or private?

Hearings are usually held in public. This means that members of the public (including the press) can attend. Hearings may sometimes be held or part-held in private if there is confidential information involved. For example, if the panel thinks they need to protect service user confidentiality, the registrant’s private life or that of any witnesses.

Even if a hearing is held in private, any decisions the panel makes and the reasons for them, still need to be publically available.

3. Considered factors

In deciding whether a registrant’s fitness to practise is impaired, the panel will take into account factors including:

• Whether they have ignored previous warnings
• Whether they have taken action to correct their behaviour
• Whether they have insight (understanding of the harm caused)
• The link between their conduct and their profession
• Whether their behaviour has undermined public confidence
• Whether they have not met our standards of conduct, performance and ethics
• Whether they are likely to repeat the behaviour

4. Possible sanctions

If the panel finds the case against the registrant is well-founded, there are a number of actions they may take or sanctions which can apply:

• Take no further action or order mediation (a process where an independent person helps agree a solution to any issues)
• Caution order (place a warning on the Register for between one to five years)
• Conditions of practice order (setting conditions which must be met, e.g. working under supervision or further training)
• Suspension from practice (for no longer than one year)
• Striking-off order (registrant’s name will be struck from the Register which means they can no longer practice)

5. Timescales

The time a case takes to reach the end of the process can vary depending on the nature of the investigation, how complicated the issues are, and the availability of parties to give evidence to the panel. We understand that it can be stressful when an FtP concern is raised, and we will provide you with an idea of how long our enquiries will take at each stage of the process. 

In 2013-14 the length of time of cases referred for a hearing to conclude was an average of 17 and a median of 14 months from receipt of the allegation. Continuing to analyse the length of time cases take to conclude has enabled us to identify a number of early triggers that can be used to predict the impact on the lifetime of a single case, and the overall system.

6. Appealing a decision

Registrants can appeal against the panel’s decision if they consider it is wrong or the sanction is unfair. The appeal is heard by the High Court in England and Wales or Northern Ireland, or the Court of Session in Scotland. In 2013-14, seven registrants appealed the decisions made by the Conduct and Competence Committee. To date, two appeals were withdrawn by the registrant, three were dismissed by the court, one case had a substituted decision and one is ongoing.

For more information about fitness to practise hearings watch our YouTube video or visit www.hcpc-uk.org/complaints/hearings/atthehearing

5 things you should know about the HCPC’s annual monitoring process

Education Manager, Ben Potter, highlights what education providers need to be aware of when it comes to annual monitoring this year.

Programme leaders of our approved education and training programmes should have received correspondence in October about our annual monitoring process over the 2015-16 academic year.

Annual monitoring is a retrospective documentary process to consider whether a programme continues to meet our education standards, and that individuals who successfully complete the programme are able to meet the HCPC’s relevant Standards of proficiency (SOPs), standards for prescribers or standards for approved mental health professionals.

901 programmes – more than ever before – are being considered through annual monitoring in 2015-16. Here’s 5 things education providers can do to help ensure a straightforward and effective process:

1. Submit one of two types of monitoring submission: a declaration or an audit

Depending on whether you’re in Group A or Group B, you will need to submit an audit or a declaration. A declaration asks you to confirm that the programme continues to meet our education standards, and that recent and future changes have been reported to us. An audit asks you to submit a completed form and mapping document with several key pieces of your internal quality monitoring documentation. You can check if your education provider is in Group A or B here.

2. Evidence service user and carer involvement

Education providers who have not been visited since September 2014 will need to demonstrate how they are involving service users and carers in their approved programmes. This follows the introduction of SET 3.17 in 2014 and the prescribing standard B.15 in 2015. Guidance on how to evidence service user and carer involvement can be found here.

3. Demonstrate the integration of revised SOPs

With the exception of social worker and practitioner psychologist programmes, all pre-registration education and training programmes must declare that they have integrated the revised Standards of Proficiency (SOPs) for their profession into their teaching and learning. More information on our processes for assessing the revised SOPs is detailed here.

4. Send us your submission by the specified deadline

Your submission date is detailed in the correspondence emailed to you in October. This date will usually correspond with the end of any internal quality processes. You must complete the relevant form – declaration or audit – and submit it to us, along with the requested documentation, by the deadline stated in our correspondence to you. Failure to do so may result in your programme’s ongoing approval being considered by the HCPC’s Education and Training Committee.

5. Further guidance on the HCPC website

The Education section of the HCPC website provides detailed information and guidance about the annual monitoring process. You can also read and/or download our Annual monitoring – supplementary information for education providers publication. If you require any additional advice, you can contact the HCPC’s education department on 020 7840 9812 or email annualmonitoring@hcpc-uk.org

Health, disability and becoming a health and care professional

Our new guidance aims to encourage, enable and support disabled people who are considering or training to become HCPC-registered professionals. Policy Officer, Laura Coveney, tells us more.

We think that having a health condition or disability shouldn’t be seen as a barrier to becoming a health and care professional. Indeed, many people who have disabilities successfully complete our approved training programmes, go on to register with us and practise as health and care professionals.

We want to help people with disabilities overcome any perceived barriers to training and then becoming registered with us in their chosen profession. This was the primary reason for producing our updated guidance publication: Health, disability and becoming a health and care professional. It offers insight and advice for those with disabilities, as well as information for education providers about delivering support.

One of the key things the guide does is to break down the process of becoming a health and care professional; from choosing and applying for a course to registering with the HCPC and gaining employment. A brief summary is outlined below.

This four-step process is complemented by a series of case studies from students and staff who have shared their experiences of having a disability and training to become a health and care professional.

Step 1: choosing a course

Those with disabilities may find it helpful to speak to education providers, career advisors, etc., to find out about the support available during training and working in their chosen profession.

Step 2: applying and completing an approved programme

For students with disabilities, it’s important to have a realistic understanding of whether tasks can be carried out safely and effectively. The ability to do certain tasks, or the support needed to carry them out, may change over time. Education providers can assess applications and consider their responsibilities, including making reasonable adjustments if necessary.

Step 3: applying for registration

Part of the HCPC application requires prospective registrants to make a health declaration. We recognise that a disability may not be seen as a health condition.  And we do not need information about any health condition or disability unless it affects your fitness to practise.

Step 4: gaining employment

All professionals using one of our protected titles must be registered before they can begin practising. Similar to education providers, employers are also required to make reasonable adjustments in the workplace to ensure disabled employees are not seriously disadvantaged when doing their jobs.

Health, disability and becoming a health and care professional is available to download here. It is also available in a number of formats on request, including braille and large print.

For more information visit the dedicated health and disability section of the HCPC website: www.hcpc-uk.org/aboutregistration/healthanddisability

A reflection on my first 100 days with The Health and Care Professions Council (HCPC)

The HCPC's new Council Chair, Elaine Buckley, reflects on her first 100 days in office.

Following the 100th meeting of HCPC’s Council in my first 100 days it’s a good time to reflect on my experience of joining the organisation as Chair. I would therefore like to share with you some of the key elements of my reflections as I approach this key milestone.

In common with many colleagues, I have worked in both health and social care provider organisations and higher education institutions, one thing both sectors have in common is the unrelenting pace of change. I therefore took up the role of Chair of the HCPC wondering if it is possible for regulation to enable change rather than act as a barrier. The evidence I have gathered over my time at the HCPC is moving me towards a conclusion that it (regulation) can, and in fact should, enable change.

The rationale for my conclusion is multifaceted; as a regulator of 16 professions working across a range of sectors, the HCPC has an outcome model of regulation, using a framework of standards relevant to all. This enables registrants to apply them to their own context. Recent work carried out to evaluate our CPD standards provides robust evidence to support this theory. Our programme of education visits also demonstrates that innovative programme design and delivery is possible within the framework of our standards of education and training.

Partnership is another key feature of how we work at the HCPC, whether that be with professional bodies, registrants, service users, employers or education providers. For example, we have recently worked with and launched a campaign to highlight the benefits of using arts therapists to employers. The organisation also has a broad programme of events and consultations, aimed at either gathering opinion or sharing evidence and good practice. We recently consulted on the revised standards of conduct, performance and ethics and guidance for disabled people wanting to become health and care professionals both which will be launched in the coming months. I am also very much looking forward to my first series of public events in Scotland next month. We are committed to being 'in touch' with the professions that we regulate and these events provide a vital opportunity to share and also hear what is happening.

Continuous quality improvement dominates the culture of the HCPC. That could be in response to stakeholder feedback through our regular research activities. It could also be through a cyclical programme of standards review, to ensure they remain relevant and current or our on-going work to further engage with members of the public, service users and patient safety groups. 

I have been fortunate to join a very effective and efficient organisation, but it’s by no means complacent. There is much work we need to do in order to ensure that the model of regulation we adopt delivers its ultimate objective; public protection, but in doing so enables our stakeholders to respond to the changing demands within their operating environment, whenever and wherever that might be.

Activity for the coming months includes refreshing the strategy for 2016 and beyond, publication of the new standards of conduct, performance and ethics and beginning work on reviewing the standards of education and training as well as improvements to our fitness to practise processes and our registration systems.

I look forward to working with my colleagues over the coming months and years to continue to strengthen the evidence base for regulation and build even stronger engagement among our stakeholders. 

Students: what you need to know about the HCPC

Welcome to all those embarking on one of our approved education and training courses this autumn. Here’s 11 things all new students should know about the Health and Care Professions Council (HCPC).  

1. We are a UK multi-profession regulator created to protect the public
The HCPC was created by legislation - the Health and Social Work Professions Order 2001 - and is independent of government, professional bodies and trade unions. We currently regulate 16 health and care professions.

2. We keep a Register of health and care professionals who meet our standards for their training, professional skills, behaviour and health
Those registered are called ‘registrants’. Registrants must be HCPC registered in order to use one of our legally protected titles, for example ‘Physiotherapist’, ‘Paramedic’ and ‘Social Worker’. This applies to those working in both public and private sectors.

3. In order to remain registered with us, registrants must continue to meet the standards that we set for your profession
There are four key sets of standards: Standards of conduct, performance and ethics; Standards of Proficiency; Standards of education and training; Standards of continuing professional development. These standards determine registrants’ ‘fitness to practise’.

4. Standards of conduct, performance and ethics set out the behaviour and conduct expected of our registrants
These standards apply to both registrants and prospective registrants. We have produced guidance on conduct and ethics for students based on these standards, which will enable you to familiarise yourself with them prior to registration with us.

5. Students’ behaviour whilst studying can impact on their ability to register with HCPC
While we do not register students or trainees, our Standards of conduct, performance and ethics apply to those studying to join a profession regulated by HCPC.

6. Every registrant must meet the Standards of proficiency for their profession
Meeting these standards is a requirement in order to become registered and to remain on the HCPC Register. Students must be able to meet these standards when they complete an approved programme.

7. Standards of education and training must be met by education providers
These standards ensure that all those completing an approved programme meet the standards of proficiency.

8. Standards of continuing professional development (CPD) must be met by all registrants
CPD is the way registrants continue to learn and develop throughout their careers so they keep their skills and knowledge up to date and are able to work safely, legally and effectively. Registrants must maintain a continuous and accurate record of their CPD activities.

9. The HCPC’s fitness to practise (FtP) process is designed to protect the public from those who are not fit to practise.
We can take action when there are concerns about a registrant’s conduct or competence. It is important to remember that only a very small percentage of registrants are ever subject to FtP concerns. Of the 322,021 registrants on the Register, just 0.64% were subject to FtP concerns last year.

10. Once you have successfully completed your training, you will need to register with HCPC before you are able to start work using a protected title
Your education provider will notify HCPC that you have successfully completed your programme. You can then apply to join the Register at www.hcpc-uk.org/apply. Your application must include: a character reference; certified copies of two forms of ID; the registration fee. Students currently receive a 50% discount on the first two years registration.

11. You must renew your HCPC registration every two years
We will notify you three months before your registration ends. The quickest and most convenient way to renew your registration is online.

Students can find out more about the HCPC via the website at www.hcpc-uk.org. Visit the ‘students and prospective registrants’ section for relevant information and guidance.

6 things you should know about the HCPC’s Education and Training Committee

Education Manager, Tracey Samuel-Smith, explains the key roles of our Education and Training Committee (ETC) and how their decisions can impact education providers.

The ETC is a statutory committee of the Council, and advises on matters relating to education, training and registration. Members of the Committee make up the Education and Training Panels who deal with visitor’s reports from the approval and monitoring processes. Their decisions directly impact education providers so it’s important to understand their role. 

Here’s six things that, as an education provider,
you should know about the ETC:

1. The Education and Training Committee consider recommendations from appointed visitors about whether a programme has met the appropriate standards.

2. The Education and Training Committee comprises six members of Council - three registrant and three lay members (in accordance with our Code of Corporate Governance). As such, not all of our regulated professions are represented on the Committee. Therefore they use visitor recommendations to make a final decision on programme approval and ongoing approval.

3. The Education and Training Committee will consider input from education providers, who have the opportunity to contribute to the decision-making process by submitting observations on any condition or recommendation in a visitors’ report. 

4. The Committee can vary any condition or recommendation in a visitors’ report. For example when they decide a condition exceeds threshold or is not relevant to a standard.

5. The Committee can withdraw approval from any education or training programme that closes or no longer meets our standards.

6. The Education and Training Panel sits ten times per year. Dates of panel meetings are available on the HCPC website. These dates should be considered by education providers planning a visit or undertaking a significant change to a programme.

For more information about the HCPC’s Education and Training Committee, visit www.hcpc-uk.org/aboutus/committees

What happens if a concern is raised about me?

8 things you should know if a concern is raised about your fitness to practise.

1. The fitness to practise (FtP) process is not designed to punish registrants for past mistakes.

Rather, the process is designed to protect the public from those who are not fit to practise. Finding that a registrant’s fitness to practise is ‘impaired’ means that there are concerns about their ability to practise safely and effectively. In 2013-14, 1.2 per cent of social workers in England were subject to an FtP concern; a very small percentage, indicating that the vast majority of registrants are practising safely and effectively.

 

2. Your case will be allocated to a case manager.

If you find yourself the subject of a fitness to practise allegation, the case will be allocated to a case manager, who will remain neutral. They can explain how the FtP process works and what panels will consider when making their decisions. However they cannot advise you what to include in your response or how you should represent yourself.

3. We will give you an idea of how long our enquiries will take.

We understand that it can be stressful when an FtP concern is raised, and we will provide you with an idea of how long our enquiries will take at each stage of the process. In 2013-14 the length of time of cases referred for a hearing to conclude was an average of 17 and a median of 14 months from receipt of the allegation.

4. You can respond to the allegation in writing within 28 days. It is important to engage with the process so that you can give your side of events.

Once we have all the information we need, we will write to you with full details of the allegation that has been made plus copies of the documents we have collated. You are then invited to respond in writing within 28 days. If you need more time, your case manager can offer a 28-day extension, and if further time is required you can make a written application to the panel. 

5. You may find it helpful to get advice from your union, professional body or a solicitor at the earliest opportunity.

They will be able to provide advice on what to include in the response to the allegations which will be provided to the Investigating Committee Panel.

6. You are entitled to be represented throughout the process.

If the case is referred to a hearing, registrants are entitled to be represented, or can represent themselves, throughout the process. Information and guidance on the fitness to practise hearing process is available on our website, and explained in this useful YouTube video.

7. Cases are scheduled up to four months before the actual hearing.

We try to give registrants at least 60 days’ notice of the hearing date. We will also give you the material that we plan to rely on at the hearing 42 days beforehand. We ask registrants to provide their material 28 days before the hearing date.

8. Details of the hearing and allegations are published four weeks before the hearing is due to start.

We put this information on our website as the hearings are held in public. We do not put the information on the website more than four weeks before the hearing date to make sure we are acting fairly and balancing your rights with our role of protecting the public.

For more information download our brochure information ‘What happens if a concern is raised about me?’ or visit www.hcpc-uk.org/complaints/registrants

Applying for HCPC registration?

Registration Manager Dushyan Ashton highlights what you need to do to avoid having your application returned as incomplete.

Proud excited faces, mortar boards scattered against a sky-blue background, and groups of students posing in smart black gowns. The numerous photos posted on social media by newly qualified students - now graduating after successfully completing one of our approved programmes - are a happy reminder that graduation season is in full swing.

All those students completing an approved education and training programme are required to join our Register before they can practise using one of our legally protected titles.

During this current period our Registration Department will receive lots of new applications. We aim to process applications within ten working days of receipt of a complete application. This ensures that newly qualified professionals are added to our online Register as soon as possible.

It is important to make sure that your application is complete before submitting it to us. Common mistakes include failing to provide the appropriate documentation, or not including a fee with the application form. Incomplete applications will be returned for resubmission, which could potentially delay your entry to the HCPC Register.

To avoid this happening follow our checklist:

• Enclose two certified copies of documents to confirm your identity; one document should contain your photograph, one should provide your current address.
• All signatures must be original and dated within the last six months.
  
• Provide certified proof of any name changes; e.g. a certified photocopy of a relevant name change document such as a marriage certificate or deed poll.
• A fee must be submitted with your application form.  
• If you answered ‘yes’ to any question in section 3 (character and health self- declarations / vetting and barring schemes), you must provide additional information.

For further information about applying to join the HCPC Register
visit www.hcpc-uk.org/apply

Fitness to practise: advice for employers and managers

HCPC's Head of Fitness to Practise Service Improvement, Sarita Wilson, highlights 10 things you should know if you have concerns about an employee’s fitness to practise.

1. If a registrant is ‘fit to practise’ this means that they have the skills, knowledge and character to practise their profession safely and effectively.

Fitness to practise (FtP) isn’t just about professional performance; it also includes acts by a registrant which may affect public protection or confidence in the profession. For example, if a registrant has been cautioned or convicted for a criminal offence.

2. The Health and Care Professions Council (HCPC) will consider cases which question whether a registrant’s fitness to practise is ‘impaired’, or negatively affected.

This could be by misconduct, a lack of competence, a caution or conviction, the registrant’s physical or mental health, or a decision made by another regulator responsible for health and social care.

3. Incidents involving employment issues which don’t affect the safety or wellbeing of service users do not need to be referred to HCPC.

For example: lateness or poor time-keeping (unless it has a direct effect on service users); personality conflicts (as long as there is no evidence of bullying or harassment); sickness or other absence from work.

4. Concerns should be reported to the HCPC if…

…the behaviour or actions of a registrant have raised concerns about their fitness to practise; you have dismissed or suspended a registrant; you have taken the decision to downgrade the status of a registrant (for example, you place them under supervision).

5. Fitness to practise and employment processes are different and can result in different outcomes.

Issues that cause you as an employer or manager to take disciplinary action may not result in the HCPC placing any sanction on the registrant. In other cases, HCPC may take more serious action than you, which means that the registrant may not be able to work in their profession or has restrictions placed on their practice.

6. Letting HCPC know about your concerns does not necessarily mean that fitness to practise proceedings will begin immediately.

Neither does it mean you would have to suspend or end your own procedures. In many instances it will be more appropriate for HCPC to wait until you have finished your procedures. Even if HCPC does not immediately pursue an allegation, they are better placed to protect the public.

7. To raise a concern you should fill in an employer referral form.

This can be downloaded at www.hcpc-uk.org/complaints/
employers/raiseaconcern and emailed or posted to HCPC. Anything sent to HCPC will be copied to the registrant you are referring so that they can respond. If there is anything you would prefer not to be sent to the registrant, you should notify HCPC.

8. If you raise a concern with HCPC you can expect everyone involved to be treated fairly and be given an explanation as to what will happen at each stage.

You will also be given details of a case manager who you can contact should you have any questions.

9. You may be required to provide a witness statement or give evidence.

If the case is referred to a final hearing, you or members of your staff may need to meet with the HCPC’s solicitor to provide a witness statement. You may also be required to come to the hearing and give evidence. HCPC will organise your travel and accommodation if this is the case.

10. Employing a registrant who is the subject of a current FtP investigation.

Being the subject of an FtP investigation does not automatically make a registrant unsuitable for employment as they can continue to practise unless the HCPC has imposed an interim order preventing them from practising or placing restrictions on their practice. You can find out if a registrant has an interim order made against them by searching the HCPC Register.

For further information and advice for employers and managers visit
www.hcpc-uk.org/complaints/employers

Welcome from one Chair to another

I’m told, on the best authority (knowing nothing about football) that England has a reputation for keeping its goalkeepers until they are well past their best. As I stand down from my role as Chair of HCPC after nine years, I hope very much that I am not in that category. I have had a fascinating and privileged time at HCPC, and have been part of huge growth and change. I am grateful to my colleagues on the Council and to the employees of HCPC, many of whom I have worked with over many years. It gives me great pleasure to welcome Elaine Buckley, from Sheffield Hallam University, who will step into the role on the 1 July, and I can think of no-one who comes to the job with more enthusiasm, commitment and clear understanding of what regulation is for.

At its best, professional regulation exists for one purpose; to safeguard the public, to make sure professionals are doing their job to a consistent standard, so that the public know what to expect and get what they expect. Regulators are the gatekeepers, the patrols and the judges of the professions. It is for others to be the promoters, advocates and educators. Most of the time, this collaborative approach works well. It would be foolhardy to suggest that there are not many challenges along the way, and tensions will always arise between those who regulate and those who are regulated. For me, the essential components of success are embedded in values. Values define the personality of an organisation, and if people have clarity of purpose in what they do they are less likely to become distracted and pulled towards work that is best carried out by others.

And finally, I would want to add one more observation. I believe that the HCPC has never, and will never, settle for the status quo. It will always be changing, moving forward, recognising that whilst change is unsettling, it is part of the discomfort that goes with improvement.

Anna van der Gaag
Chair

AMHP training and education programmes: how can the conditions set during 2013/14 approval visits inform and guide education providers?

This was one of the key questions considered by our education team following the first year review of approval visits to AMHP programmes. Education Manager, Ben Potter, explains.

As part of the transfer of the General Social Care Council’s (GSCC) regulatory functions to the HCPC in August 2012, we became responsible for approving and monitoring AMHP education and training programmes in England.

All approved AMHP programmes are required to meet our criteria and conditions can be placed on programmes that do not. These conditions must be met before we can approve or continue to approve a programme.

During the 2013-14 academic year we considered 17 programmes at 11 education providers. We are scheduled to visit a further ten transitionally approved programmes at eight providers in 2014-15.

All AMHP education and training programmes visited in 2013/14 have now demonstrated how they have met any conditions placed on them – thus demonstrating how they meet our criteria – and are now approved.

To help, inform and guide education providers for the future, here we consider the two areas that incurred the highest number of conditions so that we can provide further understanding of certain aspects of our approval criteria. Our full report – Review of the Health and Care Professions Council (HCPC) approval visits to approved mental health professional (AMHP) education and training programmes in the 2013-14 academic year – is available to download.

Practice placements

As an education provider, you need to own and manage practice placements, including policies and procedures around approval and monitoring of placement settings; the staff in place; and ensuring that placement settings provide a safe and supportive environment.

When setting conditions in these areas, we often found that education providers would not own the policies, or would make assumptions that the placements were well-resourced in terms of staff, due to them being in statutory settings.

There were also assumptions by education providers that placements were providing a safe and supportive environment for students, due to the post registration nature of these programmes meaning that students were often employees of the organisation that provided their placements.

When we applied conditions in this area, education providers had often not considered that these employees / students need to be supported differently when undertaking activities to support their AMHP training in their place of work, when compared to how they need to be supported when carrying out their day to day role.

Documentation

Documentation underpins how programmes run in every area. We require documentation to communicate expectations about how a programme will interact with its stakeholders – including students, placement providers, and staff – and that it clearly defines the roles and responsibilities of all parties in the running of the programme.

As an education provider, if your documentation is of a poor standard, we are unable to make a well-informed judgement about whether particular criterion are met. When we are unable to fully assess and reach a decision, we need to apply a condition to ensure that the criterion is met.

How can understanding these key issues help to inform a future approval visit?

As an organisation, we have learnt a great deal from these visits and about how we will aim to help, inform and guide education providers participating in future visits.

You can find a range of guidance about our approval visits on the HCPC website. There are also online resources, featuring case studies and presentations from our seminars delivered to education providers in autumn 2014.

If your AMHP programme is being approved in 2015, or if you would like advice about the AMHP approval criteria, you can contact the member of our team allocated to manage your approval visit, or you can email education@hcpc-uk.org.

Top 10 tips for completing your CPD profile

Have you been selected for CPD audit? Here’s ten top tips for completing your profile.

1. Include a dated list of your professional development activities within the audit period - the last two years of registration. If you have any gaps of three months or more, they will need to be explained.

2. Don’t just describe your day-to-day work. Choose a range of different activities you have undertaken over the past two years (between four and six in total) and describe what you learned from each.

3. Provide good evidence for each of the activities. Reflective logs, case studies, presentations, certificates and feedback from your service users would all be relevant.

4. Remember, it is about quality not quantity - choose evidence which shows how you think you have met the standards.

5. Ensure confidentiality when including your evidence - make sure that none of your evidence or your statement includes references to named individuals.

6. Make sure that the evidence you send will back up the statements made in your profile. It should show that you have undertaken the activities you have referred to, and should also show how they have improved the quality of your work and benefited service users.

7. Be concise, but provide sufficient detail on how your learning activities had an impact on your service, and be clear about how each standard has been met.

8. Keep a personal log of your continuing professional development, so that if you move jobs or your circumstances change you will still have access to it.

9. Don’t forget that the summary of your practice history should help to show the assessors how your development activities are linked to your work.

10. The council’s approach to assessing professional development focuses on the outcome of your activities - how they have benefited you and your service users, not how many hours or points you have. It’s up to you, along with your manager, to think about what you need to do to keep up to date in your area of practice.

For more information and advice for completing your CPD profile, visit
www.hcpc-uk.org/registrants/cpd.
 

 

 

 

The 5 W’s of the amended approvals process for supplementary and independent prescribing programmes

Head of Educational Development, Brendon Edmonds, summarises the HCPC’s recent review of the amended approval process for supplementary and independent prescribing (SPIP) post-registration programmes.

An introduction to independent prescribing

Independent prescribing is prescribing by an appropriately qualified practitioner responsible for the assessment of patients with undiagnosed or diagnosed conditions, and for decisions about the clinical management. Independent prescribers can prescribe any medicine for any medical condition within their competence.

In 2009, the Department of Health (DH) published a report looking at the use of medicines by the allied health professions (AHPs). The report looked at whether prescribing and medicine supply mechanisms for AHPs should change to address patient and service needs. It found a strong case for extending independent prescribing to chiropodists/podiatrists and physiotherapists. In July 2012, the DH announced that legislation would be passed to allow appropriately trained chiropodists/podiatrists and physiotherapists to act, and be annotated on our Register, as independent prescribers.

As a result of this new legislation, the HCPC developed and published standalone standards for prescribing. We also amended the approval process for supplementary and independent prescribing (SPIP) post-registration programmes, which was reviewed in the 2013-14 academic year.

Here, we summarise the review and its key findings. The full report is available to download here.

WHEN…
 
When did the HCPC’s standards for prescribing come into effect following the revised legislation?

As part of the legislative change, we produced standards for prescribing. These came into effect from August 2013, following the legislation passing.

To develop these standards, we engaged with stakeholders and undertook a public consultation. The standards cover two areas: standards for education providers and standards of SPIP prescribers. The standards for education providers are based on our standards of education and training, whilst those for all prescribers are proficiency based, and expand upon the standards of proficiency required of chiropodists/podiatrists, physiotherapists and radiographers who undertake supplementary prescribing.

WHY...
 
Why does the HCPC have an amended approval process for SPIP post-registration education and training programmes?

The development of this amended approval process was a direct response to the DH changes to prescribing legislation in 2012.

It was already commonplace for education providers to deliver independent prescribing (IP) programmes for professions that we don’t regulate (pharmacists and nurses) and supplementary prescribing (SP) for ones that we do (physiotherapists, radiographers and chiropodists/podiatrists).

However, we needed to be sure that independent prescribing could be supported for our professions and in relation to our prescribing standards.  As we already approve SP programmes, we were satisfied that new independent prescribing programmes would already meet some of the standards for prescribing. We were also satisfied we didn’t need to conduct a full approval visit to assess them - hence the need for an amended approval process.

This gave eligible education providers the opportunity to gain approval for prescribing programmes in a significantly shorter timeframe than our standard approval process. In fact on average, programmes were approved ten weeks after their documentary submission – less than half the average time taken for programmes via the full process (22 weeks).

This really demonstrates how we’re able to amend our processes to support the work and initiatives of health and care providers.

WHO…
 
Who did the legislative changes affect and how did this impact education providers?

The changes to prescribing legislation meant that our chiropodist/podiatrist and physiotherapist registrants could act as independent prescribers once appropriately trained and annotated on our Register.

Prior to, and soon after, the legislation being passed, we wrote to education providers which delivered approved supplementary prescribing (SP) programmes to let them know how the amended approval process would work. We also advised them we would assess their programmes against the newly published standards for prescribing.  

Our process reduced the burden of work required for education providers to evidence how they met the required standards when compared to the full approval process. This was because they were only required to focus on the standards which were directly impacted by the introduction of independent prescribing. 

WHERE…  
 
Where did the HCPC find its visitors for the approvals and monitoring work?

We work with visitors who make the assessments of programmes to ensure they meet our standards. For prescribing, we set rules about selecting visitors for this specific area of approvals and monitoring work.

Our visitors work together in pairs to make an assessment.  At least one of the visitors had to be from a non-medical prescribing profession which was entitled to undertake independent prescribing training (a nurse or pharmacist). This visitor was required to be registered, with the entitlement recorded on their respective register.

We also recruited independent prescribing visitors to competencies that were based on the competencies for the visitors of our 16 professions.

WHAT…

What were the key outcomes of the amended approval process?

We reviewed 100 prescribing programmes at the assessment days in November 2013.

Visitors were able to request further documentation if they were not satisfied that a standard was met following their review of the documentation. Visitors could also recommend a full approval visit if there were issues remaining following their assessment of a programme. 62 per cent of the programmes assessed met the standards for education providers without the need for additional documentation, as demonstrated in the graph below. This outcome contrasts with the full approval process, where only three per cent of programmes visited in 2012/13 were approved following our first assessment.

So why was this?

There are a number of reasons:

• Education providers were not fundamentally altering their existing prescribing provision to incorporate independent prescribing.
• All of the education providers that engaged with this process ran existing HCPC approved SP programmes, and many ran IP programmes for nurses and pharmacists.  
• The education providers were already familiar with our standards and processes.

Programmes required to submit further documentation were able to evidence how they met our standards, and all 100 prescribing programmes were approved by February 2014. None of the programmes required a follow up approval visit. Therefore, we have granted open-ended approval to these programmes and it will remain in place, subject to meeting our ongoing monitoring requirements.

The outcome of approving these programmes is that individuals from the relevant professions can have their registration record annotated as an independent prescriber, once they complete the relevant training. To date, we have updated the records of 150 registrants with the independent prescribing annotation. 

Preventing small problems from becoming big problems in health and care

I recently attended the 26th conference of the US Institute of Health Improvement, and had the privilege of hearing Don Berwick and Atul Gawande amongst many others sharing their reflections on the changing landscape of health and care. I was struck by the strong focus on looking for new ways to reduce staff burnout and to invest more in the human aspects of care. Having strong and resilient relationships at work was seen as key to providing sustainable care. Kindness and compassion were just as important to good care as technical skills and knowledge. Addressing these aspects of care, both for service users, patients and for professionals, was given great emphasis. Gerald Hickson spoke about the "power of an honest conversation" as an important part of this process.

Our work on professionalism reflects this pursuit of greater awareness and understanding of the interpersonal aspects of care. I am very pleased that our latest research in this area continues this exploration, and reflects the mood and direction of thinking in a wider arena. Preventing small problems becoming big problems in health and care explores the reasons behind incremental disengagement, where challenging circumstances appear to lead to concerns about practise, and eventually to a complaint. Patients and service users in the study recognised the pressures and challenges of delivering high quality care, and the need to ensure professionals were supported to do their jobs well.  They said they wanted to be seen by professionals who were compassionate, communicative, and consistent in the care they provided.

Feedback from professionals in the study highlight the links between poor supervisory structures, lack of peer support, professional isolation and disengagement from practise. Disengagement was characterised as a symptom of underlying, often longstanding issues in the workplace which could be addressed and might be resolved before complaints arose. Not rocket science to anyone working in health and care services, but nevertheless important to the debate about what needs to change.

I was struck by words from Atul Gawande who spoke about ways in which services and professionals must evolve in response to the changing needs and expectations of society. A strong advocate for team based care, and the need to break down hierarchies amongst professionals.

Gawande suggested that "The relationship between clinicians and institutions has been like a tenant and landlord relationship. Clinicians expected to be left alone by their landlords to do what they did. But now, it has changed. Thinking about what happens in hospitals and clinics, and allowing others in, has become crucial."

This notion of "allowing others in" is enormously complex. At one end of the spectrum, this means allowing reflection and self awareness to generate those honest conversations with trusted colleagues at an early stage, as a means of addressing problems early on. At the other end of the spectrum, it can mean investigation by a regulator. Between the two ends lie conversations and interventions by managers, educators, and professional associations. My hope is that our work with Zubin Austin, Carole Chistensen-Moore and Joan Walsh will help to generate more activities at the reflective end of the spectrum, and reduce the activities at the regulatory end. It is in everyone's interest to prevent harm, to reduce complaints, and to see more emphasis on support, kindness and compassion in health and care.

Anna van der Gaag

Time for a new Chair at HCPC

 Public appointments, quite rightly, require those who hold office to stand down after two terms. This is to safeguard against office holders becoming too stale, or too close to the organisation they are charged with governing. Although I feel great personal sadness that I stand down from my role as Chair in June 2015, I believe wholeheartedly that this principle is the right one.

The role of the Chair is to provide clear strategic leadership, working closely with the Council and the Executive to keep the objective of the organisation - that of public protection - at the heart of all decision making. On a day to day basis, financial and operational oversight are also key aspects of the work, but it is maintaining this clarity of purpose around what regulation is for, that is most central to the job. This manifests itself in many different ways, working closely with the Council and the Executive team and engaging with the very many stakeholders who have an interest in the work of the regulator.

The HCPC is unique amongst regulators. Set up in 2002, the organisation has established itself as a multi professional regulator with a worldwide reputation. In the last eight years, it has doubled in size, taken on four additional professions, and been proactive in its pursuit of delivering transparent and proportionate regulation. Amongst its defining characteristics lies a single governing Council, one set of standards and processes for all 16 professions, and a commitment to treating all professions as equal, regardless of size or perceived status. This sense of equality extends throughout the organisation - the Council members and the Executive team work as equals around the table, valuing diversity of opinion and experience, with a shared committed to continuous change and improvement. Dialogue with our colleagues in health and social care, in the four governments of the UK, in education, professional trade unions and associations, and other regulators is an important part of the day to day work.

Looking back over the years, there are a number of developments that illustrate the culture of the HCPC. I am proud of the way in which the organisation has pioneered an evidence based approach, arguing that if health and care professionals are being asked to be evidence informed, so should the regulator. We have focused our research efforts on many areas, notably on professionalism, and on creating a better understanding of the experience of regulation from different perspectives  - complainants, professionals, students, employers, educators and the perceptions of a wide range of patients, service users and the public. We have been fiercely defensive of using evidence to inform our decision making, even when those decisions were not in line with wider views and opinions of the day.

I am also proud of the way that HCPC has developed its engagement with service users and patients. Conscious of the trap of tokenism, we have worked hard to create authentic and meaningful forms of engagement, to listen and work closely with users in many different settings. Regulation is there for the public, and it must be intelligible, accessible, responsive, and visible for those who need it. We have worked hard over the years to improve our communications, so that individuals know where to find us, and judge us to be trustworthy to act when standards are not being met.

My final observation, for those who might be considering applying for this role is that the HCPC is quite simply a great place to work. It has a strong "can do" culture running through it. The people who work here are highly committed, hard working, and open to change and improvement. The Council work well as a team, clear about their role and of the territory best left to the Executive.

It was John Carver who observed that the role of a Chair is to protect and further the integrity of governance, as a servant of the Board and the organisation. I can think of no better place to pursue this goal, and no better team to work with.


  

5 key findings from social work programme approvals

Jamie Hunt, Education Manager at the HCPC, talks through some of the observations and trends following the second year of social work programme approval visits.

The 2013-14 academic year saw the Education team complete the second year of approval visits to social work programmes. In total we visited 113 programmes at 43 education providers, 16 of which were new programmes.

The purpose of the process is to ensure an education provider:

• has a robust framework to manage all aspects of their programme effectively;
• holds responsibility for all aspects of their programme, including placement environments;
• has curriculum and assessment which support the delivery of our standards of proficiency for social workers in England, and;
• can make good decisions about those individuals who receive the final approved award.

If we find areas which do not meet our standards following an approval visit, we will set conditions which must be met before it can be approved.

With other professions previously new to HCPC regulation, we’ve found that education providers better understand our quality assurance approach over time, and therefore work effectively to align their programmes to our standards. This usually means that as the series of approval visits progresses, the fewer issues we identify. This was certainly true of our approval visits to social work programmes in the 2013-14 academic year, in comparison to the previous year.

Here, we have summarised some of the key observations and trends. Our full report – Review of the Health and Care Professions Council (HCPC) approval visits to social work pre-registration education and training programmes in the 2013-14 academic year – is available to download on our website.

Social work programme approval visits 2013-14: 5 key findings

1. On average, we applied 1.8 fewer conditions per social work programme in the 2013-14 academic year compared to the previous year. 

This result suggests social work education providers are becoming more familiar with our regulatory requirements. They are successfully providing the evidence to meet our standards prior to and at the visit itself.

2. Education providers are more aware of the importance of managing issues regarding student consent.

SET 3.14 requires education providers to ensure that: “where students participate as service users in practical and clinical teaching, appropriate protocols must be used to obtain their consent”.

Last year, we found we applied conditions to 56% of programmes but this has dropped to 33% in year two. This suggests there is greater understanding amongst programme teams regarding getting informed consent from students where they are involved in role play or are sharing personal information. 

3. Many of the conditions we placed on programmes were linked to:

• Inadequate programme documentation

One way to demonstrate a robust framework is in place to manage a programme is ensuring all areas are clearly documented. This is why we ask education providers to submit copies of key programme documents (e.g. programme and placement handbooks). We commonly set conditions where we find inconsistency, or an absence of information, in these documents which could affect a stakeholder’s engagement with a programme.

• A lack of documented policies and systems, used to manage a range of programme areas

To approve a programme, policies and systems must be in place, written down and appropriately applied. As a regulator, we do not solely rely on the establishment of good will and long-standing relationships between various stakeholders to support a programme’s delivery. We need to be satisfied an education provider can effectively identify, manage, mitigate and learn from issues and risks and in doing so, maintain the level of quality that our standards require of them.

• Clarity regarding how the programme meets Standards of Education and Training (SETs) and supports individuals meeting our Standards of Proficiency (SOPs)

Education providers need to clearly identify how their programme aligns to our standards. This can take time and this is one of the reasons we provide education providers with a six month lead in time to the visit itself. Careful thought is needed to consider how the programme meets our SETs and SOPs and it is important that this is mapped clearly for the benefit of our visitors who will assess the programme. This process of mapping should also allow an education provider to identify any potential gaps in how they meet our standards prior to the visit.

4. A shift in the split between undergraduate and postgraduate programmes sees more social work programmes being delivered at postgraduate level.

At the point of transfer in August 2012, 47% per cent of programmes were delivered at postgraduate level. At the end of the 2013-14 academic year, 54% of programmes were delivered at postgraduate level.

5. All social work programmes visited in the 2013-14 academic year have now successfully completed the approval process.

This means that programmes with conditions placed on them have now evidenced that all conditions have been met. Once a programme has met all our standards through an approval visit it receives what is called 'open-ended' approval. This does not mean these programmes are approved indefinitely. They will need to continue meeting our standards through mandatory engagement year to year with our monitoring processes.

We prefer to keep regular engagement with the programmes we approve, rather than running a re-approval cycle. It allows us to assess incremental changes to programmes largely as and when they occur. Importantly, where significant changes are identified in our monitoring processes, we have mechanisms in place to enable a new approval visit to be initiated if required.

In conclusion

We are pleased to see that the work we have carried out with education providers is proving effective. Over the past two years we have delivered seminars aimed at those providers who were yet to undertake an approval visit, and have supported providers with guidance literature and through our newsletter, Education Update. We were also able to directly address any issues with members of programme teams before their visit. We also widely publicised the findings of our first year review and we’ll be doing the same this year, so have a read and share our findings.

Our second year report is not intended to be a comprehensive review of social worker education in England. We are still part way through our three year programme of visiting transitionally approved social work programmes, and it is too early to draw full conclusions about the impact of the standards of education and training (SETs) in assuring, and driving improvements in, social work education. We intend to begin a more comprehensive review at the end of the 2014-15 academic year.