We want a relationship with our registrants that is based on trust, not checklists, says the Health and Care Professions Council’s Anna van der Gaag
The Health and Care Professions Council sets standards for 16 health, psychological and social work professions in the UK. Like the Nursing and Midwifery Council and other regulators, we have had to get to grips with the challenge of revalidation for the 320,000 people on our register.
Reassuring the public that health and care professionals have up-to-date know-ledge and skills and are fit to practise is part of a regulator’s role. There are different models of assurance, and we have looked at all the options. We do not use the term “revalidation”, preferring to talk about “continuing fitness to practise”, which describes the model to which we subscribe. This has been well researched in countries such as Canada, where regulators focus on the minority who give cause for concern, rather than audits or checks of everyone.
“Regulation exists to protect the public, maintain and uphold standards, and to maintain public confidence in the professions. The key principle in achieving this must be mutual trust”
Our system is based on certain assumptions. Registrants are autonomous professionals, who take responsibility for their learning. We want a relationship with them based on trust, not checklists. Part of this social contract is to act only when there is evidence that trust has broken down, then to act quickly and decisively to bring people to account.
In 2006, we introduced compulsory standards on continuing professional development and, two years later, we began random audits of registrants. The standards ask professionals to keep up to date in their scope of practice, keep a record of CPD activities, make sure these benefit service users and patients, and improve the quality of what they do. We do not ask for a minimum number of hours or points; we are interested in the impact of learning on practice and, in particular, the amount of reflection on practice. If selected for audit, professionals have to tell us what they have done in the previous two years, what they feel they have learnt, and the benefits of their activities for patients. International evidence indicates that systems based on points or hours have little or no influence on continuing competence. What makes a difference are regular self-assessment, personal development plans or appraisals and regular feedback from peers.
To date, we have undertaken 12,000 audits, and removed fewer than 0.5% from the register as a result. A further 4% have removed themselves voluntarily rather than go through the audit. These numbers support our assertion that few fail to engage, and that an approach that says “we trust you to undertake learning, to keep yourself up to date and fit to practise” is the right one. If non-compliance rises, we will increase the proportion of audits.
Our analysis of complaints to the HCPC shows the majority are about conduct, not technical incompetence. We commissioned work on this with students, educators and practitioners, and held debates and workshops to discuss the nature of complaints and how we could collectively address these. By informing registrants about trends in complaints and encouraging discourse, we hope to raise self-awareness of the importance of ethics and behaviour to good practice.
Self-directed learning and appraisals close the circle and allow professionals to take responsibility for keeping up to date and fit to practise. Regulation exists to protect the public, maintain and uphold standards, and to maintain public confidence in the professions. The key principle in achieving this must be mutual trust. Any model of assuring that someone continues to be fit to practise should reflect this, and invest resources accordingly.
- For more on HCPC’s approach to CPD and continuing fitness to practise, visit tinyurl.com/HCPC-revalidation and tinyurl.com/HCPC-guidance
Anna van der Gaag is chair of the Health and Care Professions Council