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Anna van der Gaag: 'Focus on continuing fitness to practise, not revalidation'


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.

Anna van der Gaag is chair of the Health and Care Professions Council


Readers' comments (3)

  • Agree with all of the above. The problem really isn't revalidation or whatever it's going to be called, the problem is the NMC. I have no confidence in its ability to keep patients safe from harm and I don't know anyone else who does. Similarly, It's almost a given that they'll balls-up revalidation.

    Why not save all of the money needed to fund these 16 separate professional councils and just have one large body? It'll help keep costs down by sharing back office costs and these savings could be passed on to registrants?

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  • I still don't believe the NMC is fit for purpose. This bloated organisation still pursues too many nurses who are referred maliciously by employers they have whistleblown against. The CHRE needs to set down some time limits for it's next review of the NMC- it's not uncommon for good nurses to be kept dangling ( and sometimes jobless) for two years and more.

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  • I agree with this article and think there should be emphasis on those that have been identified within their employment structure as not fit to practice. I therefore think that there should be in house protocol within organisations that have been laid down by the NMC and that these could be included within the annual development review that we are all supposed to have. This would ensure that the reviews happen as they should also! The process of re validation is almost an insult against the high fees that we pay to maintain our registration and I include union fees in that. It roughly costs me £328 per year just to stay legally registered and insured and yet in 9 years I've had 2 annual development reviews! It would feel more like a fair partnership if we were reviewed in totality of our role. After all it's one thing to look good on paper but the academic side of our role is not what has let us down as a profession of late. I feel very strongly about this. I also feel very strongly that the appalling staffing situation makes it difficult to be released to complete additional or extended training and it is difficult to maintain continued professional development at times and more problematic for some than others. The whole governence thing is like a knotty mess and in times of ongoing pay freeze etc I really don't know how an organisation that is support to be a supporting element to the nursing profession can justify increasing its fees because it wants to play a new game!

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