The Federation for Healthcare Science consists of 46 member professional bodies, associations and societies that represent the 50,000 workforce that covers healthcare science in the health service. The major role of the Federation is to articulate the collective views of its member organisations on matters that are significant for the practice of healthcare science in all its many and diverse forms within the health service.

The Federation welcomes the opportunity to comment on this most important part of the Health Professions Council systems development. It is encouraging to see that considerable attention that has been given to this initiative and there appears to be a widely held view that the time spent in the presentations organised throughout the UK has assisted significantly in achieving a better understanding of the objectives of the CPD aspects of regulation. No doubt others will have mentioned that unfortunately the HPC documentation does on occasion use gender specifying terminology when this could be avoided.

Specific comments relating to the questions raised in the consultation paper are listed below. Clearly the requirement for all registrants to be able to demonstrate on request compliance with the CPD standards is a significant additional responsibility for which detailed guidance will need to be made available in order to generate consistency of approach. The emphasis on self-commitment and self-regulation is supported. Nevertheless a robust, fair and consistent audit process must be established quickly in order to provide a credible and therefore effective process.

Time spent in providing examples that indicate the level, volume and standard of the evidence required will assist considerably in this respect, bearing in mind that many professional bodies already have mature CPD schemes that may have been established for differing purposes to those required of a system for regulation. This will inevitably lead to differing opinions about the interpretation of the needs and type of evidence required for the HPC program.

Q1. What are your views of the HPC’s proposed Rules?

It would be advisable to indicate over what period the evidence for any particular period of CPD relating to regulation would need to be kept. It is unclear whether a registrant selected for audit would need to provide evidence of satisfactory CPD for the period relating to the current registration renewal or whether the opportunity would be taken to review the totality of the registrants’ professional activity.

The rules also suggest that the only sanction available for unsatisfactory compliance would be removal from the register. Bearing in mind the implication of this on employment, the HPC would presumably require additional and lesser sanctions that could be applied on a preliminary basis for those who fall short of the standard in some respects, but for whom deregistration would not seem appropriate in the first instance. A pragmatic and realistic approach will be needed particularly during the early stages of implementation.

The rules also imply that appeal against failure to achieve an adequate standard of CPD for renewal of registration would be by a written process only. This is appropriate in the first instance, but in view of the implications of removal from the register, representation in person should be allowed before that final sanction is taken.

Q2. Are there any additional activities which you believe should be included in Appendix 1?

Bearing in mind that a section entitled – ‘Other activities’ – is already proposed it should be sufficient to allow any evidence or information that would support a registrant’s application to be included here. For example, this would include membership of expert or advisory committees developing or applying guidelines, policies or standards, which can be at local, area, national or international level. The principle to be followed is that the registrant can illustrate the value of these activities for their CPD.

Q3. Do you agree with this approach for CPD?

The HPC regulates a large number of registrants, all of whom are from mature and established professions, and a system based on self commitment and self regulation reflects this. Nevertheless the process of audit must be perceived as real and significant in order to ensure that apathy does not develop over time, if individuals who appear not to keep updated records do so with apparent impunity. It is a question of adequate balance in this respect.

It is essential that the adopted process recognises that individual registrants’ scope of practice may evolve to be fundamentally different from that used for initial registration. This has been proposed and is supported.

However a pedantic interpretation of the sentence (sic) “..registrants must choose to engage in CPD within their evolving or current scope of practice…” implies that it would be in order for CPD evidence to concentrate on a future potential role rather than the significant part of current practice. Evidence should appropriately reflect the actual mix of current and evolving practice for the period that it covers.

Q4. What are your views of the HPC’s proposed standards for CPD?

The proposed standards establish the context and also the emphasis of this part of regulation requirements. Minor, although significant editing is suggested:
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Q5. Are there any other Standards for the CPD that should be included.

The standards satisfactorily establish the concept and to a degree the process. However the success of the implementation of the CPD program of regulation will depend very much on the interpretation of individuals about what exactly is required. Guidance notes with good examples will be essential. It would be sensible to involve the professional bodies in this respect at an early stage, as inevitably members will look to these as well as the HPC for peer group support. There has to be a degree of uniformity of the interpretation of the type and style of evidence required to avoid what could easily become chaos without due leadership.

Doubtless the HPC will reflect on the fact that registrants already have significant pressures on their time for professional practice and will therefore need clear guidance in order to satisfactorily assimilate another responsibility.

Q6.What are your views of the HPC’s proposed CPD standards process?

The CPD Standards process appears appropriate. Its success will be dependent on the ability and skill of the appointed partners, and it is essential that each profession has confidence in those chosen, with a consistency of approach between the professions.
Evidently both the HPC and the registrants will be “feeling their way” for some time as the process beds in. A pragmatic and realistic attitude with an emphasis on advice and assistance rather than sanction will be required, particularly in the early stages.

Q7. Have you any views on the proposed audit process as set out?

The time period allowed for presentation of evidence should be extended, particularly for a “bedding-in period”. The literal approach would take the view that registrants, if complying with the requirement to maintain a portfolio of CPD evidence, should have no difficulty in making this available. However the pressures of modern professional life will mean that well meaning and competent practitioners will inevitably “get behind”. The primary objective must be to ensure satisfactory compliance, not to establish a culture “catching out”. In particular, the three-month limit for meeting any conditions imposed for remedial action may be too short, particularly for smaller professions where courses or updates may only be presented on an annual basis. The HPC would have grave difficulty should it adopt a process that produced a significant number of “failures”. The concept in some cases will be a significant and challenging addition to individual responsibilities and the audit process should be implemented in a way to challenge only those whose continued registration could pose a threat to public (patient) safety.

Q8. Is any further information required for the profile?

The required profile appears clear, except that some terminology appears better suited to the therapy professions rather than healthcare scientists – for example “practice history”; perhaps “professional activity” would have a wider meaning. In order to achieve consistency of approach a “model” summary would prove invaluable if not essential.

Perhaps a very short summary of CPD outcomes for the period could also be included.

Q9. What do you think of the proposed size of the audit sample?

The size of the audit sample is a balance between adequate “policing”, cost and the ability to process the work involved effectively and efficiently. The sample sizes shown are the recommendation of informed and experienced statisticians. These may need to be adjusted to take into account the attitudes of registrants to the process. Credibility will be central to its success.

Q10. Do you believe that the summary of practice (work) history should contain anything else and if so what?

A very brief summary of CPD outcomes during the period is a possible addition.

Q11. Are there any additional activities which you believe should be included in Appendix 2?

Appendix 2 represents a very far reaching list. However it would be impossible to attempt to include all possible examples. Registrants should be given the option to include any type of evidence that they believe would support their claim for continued registration. Since testimonies and letters from carers, student and colleagues are unlikely to be included in a portfolio if they are negative, more objective evidence such as survey reports originating from a third party would be more appropriate..

Q12. Do you believe that requirements should be set for the number of pieces of evidence to be submitted?

Guidance only should be given. Typical examples will become available as the system becomes established and these should be made available as representing an appropriate response without being overly prescriptive.

Q13. How can the assessors satisfy themselves that all documentary evidence is verifiable as either an original piece of work or, where claimed, that the registrant has actually contributed to the work?

Considerable responsibility for this will rest with the assessors who will need to be experienced enough to make such judgments. Assessors should be allowed in certain circumstances to seek clarification or further information from registrants when they have reasonable doubt. The evidence could be countersigned by professional line managers to add credence, although this would not be possible in all cases.

Q14. Are the prompt questions adequate?

The prompt questions are particularly useful, but would benefit considerably from some examples.

6 December 2004

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