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.

Its current membership includes the two scientist groups already within HPC regulations (Biomedical and Clinical Scientists), aspirant professions and those to be included within the proposed regulation framework for assistant and associate practitioners.

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 diverse forms within the health service.

The Federation’s response focuses on generic principles that have the support of all member organisations. Issues that may be relevant to specific professional groups will be dealt with as appropriate within responses from individual societies.

As requested, the Federations response is grouped around the key questions asked. The below response is supported by all 46 member professional bodies of the Federation. I would be pleased to elucidate further on any specific aspect of the response, should you feel this to be necessary.

Q1. How far should assistants and support staff be responsible for their own practice?

The terms “assistant” and “support” have unfortunate connotations that may unintentionally appear to diminish the contribution of groups within healthcare science that may traditionally be seen as supportive to another profession but in fact have intrinsic skills that should be recognised as belonging to that group and form an essential part of their training and competence. Most staff groups work within protocols and all groups whether or not they could be described as “support” have a responsibility to work within the protocols and systems agreed for their practice – even if supervised by another profession. It is important that “support” groups (however defined or described) should have the knowledge and responsibility to work only within the sphere of their defined competency. Clearly if an individual “support” profession is supervised through normal working practice by another profession then the supervising professional bears a responsibility (presumably to be expressed through their own registration regulations) to ensure that the supervised practitioner is appropriately trained, instructed and that work protocols are appropriate.

Q2. Should assistants and support staff set their own standards OR should those with overall responsibility for the work of these staff share in, or take, the lead in setting these standards.

This will vary from group to group. It is important to distinguish between groups who have their practice supervised and professions who may, often for reasons of management convenience, be traditionally managed by another regulated profession.
There are several examples of this within Healthcare Science. It is possible that all three models could be appropriate in some circumstances. The appropriate solution for each group would depend upon a pragmatic assessment of the involvement of the “supervising” profession in the formulation of the delivery in practical terms of the job function of the “support” group. In practical terms much will depend on whether or not a credible peer group professional voice exists for the “support” profession. All stake holders, appropriate for each group, would need to be represented within the regulation structure in some form.

Q3. Should regulatory arrangements be extended to healthcare assistants, therapy assistants, assistant practitioners, and others performing similar roles in routine care. If not, which groups of staff should be included and on what criteria?

The Federation supports the view that all NHS groups of staff involved in the clinical patient episode should have their sphere of practice regulated. Specifically, the Federation has not identified any professional practice group within healthcare science for whom regulation in some form would not be appropriate.

Q4. Is statutory regulation appropriate or should other approaches be taken?

A system of regulation not backed by statute would in essence by either a voluntary and recommended system, or a process of certification recommended for employment within identified work groups. Presumably employers and/or individuals could then opt out in circumstances that suited themselves without the “threat” of legal sanction. In either case, identified standards and certification would need to be nationally held by an appropriate body with the appropriate powers to administer them.

Q5. Should the Health Professions Council (HPC) regulate those groups of assistants and support staff identified for statutory regulation? Are other options preferable?

It would be sensible if the body of professional opinion and knowledge that relates to both practitioners and “support” practitioners could be held in the same system. There would need to be considerable duplication if both groups were regulated by completely separate and autonomous organisations.

Q6. If the HPC is the most appropriate body, should regulation be by way of a Statutory Health Occupations Committee or would other options be preferable?

The HPC is currently addressing ways in which it can cope in the future with the inevitable increase in professions that it regulates. Whether or not a separate “Council” within the HPC would work effectively would depend very much on the proposed structure and administration support. The suggestion of a statutory “Health Occupations Committee” could be a credible solution, however there is considerable scope for confusion of the public about exactly who is who. Perhaps this is inevitable, however as far as possible the names of the various professional groupings and the final adopted structure should minimise similarities in names particularly with the “assistant” groups.

Q7. Would regulation of assistants and support staff by the bodies responsible for regulating those whom they support lead to other problems such as “second class” workers?

The Federation for Healthcare Science does not see any “class” of member organisation. Each member organisation has equal rights and representation. This is achieved through a process of consensus and equal involvement. The Federation has within its membership organisations that represent professions that traditionally support other professions and others that are traditionally managed by members of other professions. This should not detract from the primacy of the full involvement of the appropriate professional society in the setting up of their standards and systems. There will need to be areas of co-operation with other professions and this is a complex situation for which there is no one simple answer. Within the area of Healthcare Science, the Federation would be pleased to work with the duly appointed authority in an attempt to minimise any perception of a “class” structure.

Q8. Are there other options for the structure of statutory self regulation we should consider?

The Federation for Healthcare Science supports the concept of statutory self regulation and has no alternative structure to suggest.

Q9. How can multi-disciplinary issues best be addressed? Should the regulators set common standards and /or recognise each other’s so that workers can move between different health and social care settings without the need for multiple registration? OR Could all assistants and support staff be regulated as a single framework including some shared standards and some discipline-specific standards?

The Federation would not wish to see a regulatory framework that was inflexible or made it unduly difficult for staff to move between occupations, particularly in the “support” grades, and this would also apply to some of the existing regulated professions. The model of identifying core skills to which specific professional practice was added as appropriate would seem to provide the most flexible system that would recognise the reality of current employment attitudes.

1 July 2004

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