Written evidence from the Chartered Society of Physiotherapy (HCP0009)

Introduction

The CSP welcomes the opportunity to provide evidence for the Health Select Committee Accountability Hearing with the Health and Care Professions Council (HCPC).

The Chartered Society of Physiotherapy (CSP) is the professional, educational and trade union body for the UK’s 52,000 qualified physiotherapists, physiotherapy students and support workers. 97% of qualified physiotherapists are CSP members.

We have drawn upon our experience in the evidence we submit. We would be pleased to supply additional information on any of the points raised in our evidence at a later stage.

Summary

• The CSP believes that the HCPC is an effective regulator, which takes a proportionate approach and provides a sound regulatory framework for physiotherapy and other Allied Health Professions (AHPs).
• The model of being a regulator of a large number of professions is one that works well, with distinct advantages, deriving from its cross-professional approach, which are strongly in the public interest.
• The CSP welcomes the strengthening of professional responsibility relating to candour for all health and social care professionals as an outcome of the Francis report of the Mid-Staffordshire NHS Trust public inquiry and the government’s response to this.
• We look forward to working with the HCPC to incorporate responsibility relating to candour into existing professional standards, and support the expectation that the strengthened responsibility is expressed and implemented consistently by all the regulators relating to the professions.
• The CSP strongly welcomes the proposal from the Government for a strengthened and more systematic relationship between professional bodies and regulators. The CSP supports this being applied to the HCPC, recognising the number and broad range of professional bodies with which it needs to have strengthened links.
• The CSP would like to see HCPC’s focus on protecting the public brought to the fore more through reflecting a patient-centred approach to its activity, such as strengthened requirements for user involvement in pre-registration education design, delivery and review.
• The CSP plays a key role in ensuring high professional standards within the UK physiotherapy profession, setting out clear expectations of members’ professionalism through our CSP Code of Professional Values and Behaviour and Quality Assurance Standards. We see these as complementing the regulatory requirements as set by the HCPC.
• The CSP also provides quality assurance and enhancement resources that the HCPC uses as curriculum guidance for pre-registration programmes in physiotherapy to inform implementation of its own standards of proficiency and of education and training. Again, we see these as strongly supporting the HCPC’s own standards and its enforcement of these.
• Responses that we have made to the 2012 Law Commission review of the regulation of the health care professions and the Professional Standards Authority call for ideas on strengthening the professional responsibility of candour are relevant to this submission. These can be accessed via the following links: http://www.csp.org.uk/documents/law-commission-review-regulation-healthcare-professionals-csp-response

http://www.csp.org.uk/documents/professional-standards-authority-call-information-about-encouraging-candour-csp-response

1.                The role of the CSP in upholding high professional standards

1.1              The CSP plays a key role in ensuring high professional standards, setting out clear expectations of members in our CSP Code of Professional Values and Behaviour[1] and Quality Assurance Standards[2]. We see these as strongly underpinning the role of the HCPC, including through advocating a patient-centred approach to professionalism.

1.2              These underline the importance of all members taking personal responsibility for their own practice and standards, and continuing professional development (CPD). They reflect the person-centred ethos of the profession. Physiotherapy as a discipline is centred on the person, taking into account the totality of an individual’s health and wellbeing, in hospital, home and work settings. In addition they emphasise the supervisory responsibilities of qualified physiotherapists.

1.3              The CSP Code of Professional Values and Behaviour and Quality Assurance Standards form part of core reference materials for the CSP’s team of professional advisers who support members in their practice.

1.4              More broadly, the CSP supports the development of the UK physiotherapy profession, in ways that meet changing population, patient, service and practice needs. In particular, we do this through delivering a quality assurance and enhancement role for pre-registration education, with our resources forming curriculum guidance on which the HCPC draws in enacting its programme approval role; leading and supporting the development of physiotherapy practice, including through the large network of CSP-accredited professional networks run by members with expertise in particular specialties and areas of practice; and leading and supporting the development of the profession’s evidence base.

1.5              The CSP would like to see the HCPC’s focus on protecting the public brought more to the fore through the implementation of a patient-centred approach across the HCPC’s activities. This could include, for example, requiring strengthened user involvement in the design, delivery and review of pre-registration education programmes.

2.              The regulatory framework for physiotherapy

2.1              The CSP welcomes the HCPC approach to the regulatory framework for physiotherapy and the other Allied Health Professions (AHPs). For example, we see re-registration requirements focused on CPD as being proportionate and appropriate, including the requirements’ strong focus on professionalism and the application of on-going learning to practice in the interests of safeguarding and enhancing patient care. We do not therefore believe that a system of revalidation, as being introduced for other professions by other regulators, is required. The low number of fitness to practice cases heard by HCPC is evidence of the effectiveness of current arrangements.

2.2              The CSP supports the introduction of a strengthened professional responsibility for candour for individual registrants, and the response that we have made to the 2012 Law Commission review is relevant to this submission[3].

2.3              We support the expectation of this being taken forward by professional regulators together, to ensure a consistent and clear approach is taken to how this responsibility is couched across all health and social care professions. This is in line with our response to the Professional Standard Authority’s consultation on the issue earlier this year[4].

2.4              The CSP has been proactive in updating web resources and support materials, including CPD support on issues of professionalism and regulatory professionals in light of Francis.

2.5              The CSP is well placed to play a lead role in ensuring that a strengthened responsibility for candour is fully incorporated into professional standards, and applied to practice and behaviour. We look forward to working with the HCPC to take this forward.

2.6              The CSP is aware of certain areas for improvement in how fitness to practice arrangements work. For example there is a need to bring down waiting times for hearings, both for the sake of the members of the public involved, and the registrants who may be unable to practice while they are waiting for a case to be heard.  Additionally there are concerns that the initial investigation process isn’t always sufficiently robust, leading to potential difficulties at fitness to practice hearings. The CSP would be keen to work with the HCPC to improve overall the fitness to practice arrangements to ensure they work better for the public and are fairer to registrants.

2.7              There were regular meetings between professional bodies, trade unions and the HCPC regarding fitness to practice arrangements in the past which provided an opportunity to explore any issues of concern or ways of improving the process for both the public and registrants. Returning to this approach would benefit all.

2.8              The model of the HCPC being a regulator of a range of professions works well, with advantages deriving from its cross-professional approach, which is strongly in the public interest.

3. How the HCPC works with professional bodies

3.1              Overall the CSP works well with the HCPC. However, engagement is inconsistent across the different parts of the HCPC.

3.2              In its final response to the Francis Inquiry the Government announced an intention that liaison should be strengthened between the royal colleges and the GMC. The CSP recommends that this should be applied in the same timeframe to the HCPC and all the bodies for the professions that it regulates.

3.3              Making the relationship more systematic could be helped by the development of a user forum. It would also be helpful to reinstate the previous use of professional liaison groups that the HCPC organised in the past, as a way of formalising appropriate input from professional bodies of other organisations to HCPC developmental and review work. We recommend that such approaches would make it possible for the HCPC to make better use of the expertise and experience of professional bodies.

December 2013