Consultation on the revised Indicative Sanctions Policy

Policy officer Olivia Bird discusses our consultation on revising the current Indicative Sanction Policy, what may change and why it’s important to have your say. 

We are currently consulting on a proposed revised version of our Indicative Sanctions Policy, which sets out the principles that our Fitness to Practice (FtP) panels should consider when deciding what, if any, sanction should be applied in FtP cases.

The policy is an important one, as it aims to ensure that all FtP decisions are fair, consistent and transparent. The current policy has been kept up to date when required, for example to take account of any changes in case law. However we are now taking this opportunity to undertake a thorough review of the existing Policy and are seeking the views of our stakeholders on a revised version.

We have used market research, input from professional bodies and unions and a review of similar documents produced by other health regulators in order to put together a number of proposed changes to allow the policy to adapt to an increasingly challenging regulatory landscape.

With this in mind some proposed changes to the document include:

• Providing clarity on what mitigation means. Following feedback from the independent market research we commissioned, we have outlined the differences between insight, remorse and apology, the relationship between these factors, and how their presence is likely to reduce the risk of harm to public and public confidence in the profession.
• The new policy seeks to provide further clarity and detail to panels in relation to aggravating factors. We have been clearer about what aggravating factors are, providing detail on the key types and the reasons why they increase the risk to the public and public confidence in the profession.
• The revised policy seeks to provide clarity on the differences between the sanctions available to the panel.
• The revised policy introduces guidance on the approach panels should take at review hearings; including the purpose of those review hearings, and the factors the panel should take into account when deciding the outcome.

These are not the only changes, and we encourage registrants and other HCPC stakeholders to read the full document and respond. It is important that those who are interested in, or could be affected by, these changes take part to ensure that the policy is useful, clear and fit for purpose. 

You can respond to this consultation in one of the following ways:

By completing our easy-to-use online survey. 

By emailing us at: consultation@hcpc-uk.org

By writing to us at:
Consultation on revised Indicative Sanctions Policy
Policy and Standards Department
The Health and Care Professions Council
Park House
184 Kennington Park Road
London
SE11 4BU