The role we can play in preventing fitness to practise cases has continued to be a focus of our stakeholder engagement this year. In 2016, we commissioned a team led by the University of Surrey to better understand the reasons why we receive a large volume of fitness to practise cases about paramedics and social workers in England.
The findings, published this year, have been received positively, particularly by the paramedic profession and by stakeholders at our own events where the topic of prevention of fitness to practise has been discussed. The report’s recommendations will guide our work next year.
This includes raising awareness amongst registrants, employers, service users and complainants on when to refer; engagement with educators to develop teaching and learning materials; and exploring how employers can best use effective workplace supervision to prevent problems from occurring.
In last year’s report, we highlighted our efforts to reduce the number of older cases and ensure we made appropriate decisions about new cases in a timely manner. This year, the Professional Standards Authority, in their annual review of our performance, raised concerns about the application of our standard of acceptance, the quality of our investigations and the timely progression of cases. This is a strategic priority for us and we have developed a plan that identifies operational and strategic changes to further improve our performance in these areas.
During the year, the UK Department of Health and Social Care published their consultation on proposals to reform professional regulation. This gave us an opportunity to reinforce the urgent need for legislative reform to enable us to manage fitness to practise cases more flexibly and proportionately. In our response, we also set out our support for fewer regulators of the health and care professions. We believe this will extend our own successful model of multi-professional regulation with common standards and processes, economies of scale and equity amongst professionals. We will continue to work with Government to their timetable to secure these reforms and the legislative change needed to modernise and simplify professional health care regulation.
We are a regulator of health and care professionals in the UK. Our role is to protect the public.
We achieve this by:
- setting standards for the education and training, professional skills, conduct, performance and ethics required to practise in the professions we regulate;
- keeping a register of professionals who meet those standards (known as registrants);
- approving programmes which professionals must complete before they can register with us; and
- taking action when registrants do not meet our standards.
We are an independent, self-funding organisation and are regarded as a public body, but are not part of the Department of Health and Social Care or the NHS. Our costs are funded by fees from registrants.
As of 31 March 2018 we had 361,061 registrants on our Register from the 16 professions we regulate.
Professions we regulate
Chiropodists / Podiatrists
Hearing aid dispensers
Operating department practitioners
Prosthetists / orthotists
Social workers in England
Speech and language therapists
We set all our standards to be outcome-focused, flexible and at the threshold level to ensure safe and effective professional practice. To ensure they remain up to date, effective and fit for purpose for the modern health and social care environment, we regularly review them.
Revisions to the Standards of education and training (SETs)
This year, we published revised SETs and supporting guidance following engagement with a wide range of stakeholders. Changes included the addition of new standards requiring inter-professional education, learner involvement and supporting learners to raise concerns. We also strengthened the link between the SETs and the standards of conduct, performance and ethics (SCPEs). These revisions ensure the SETs reflect existing provision within the sector and continue to be appropriate and meaningful.
Threshold level of qualification for entry to the Register for paramedics
Following consultation, we changed the threshold level of qualification for entry to the Register for paramedics to degree level. We made this change because there is evidence that the role of the paramedic has changed over time and contemporary practice now requires increased depth of knowledge, understanding and clinical skills at entry to the profession. We are phasing this in and from 1 September 2021 new students will only be able to start degree level programmes. Existing registered paramedics who have not completed a degree level qualification will continue to be registered by us.
Disseminating key guidance
We have a statutory responsibility to inform and educate our stakeholders. One way we do this is to produce and disseminate guidance explaining our standards and processes. Over the year, we published several guidance documents, two of which are highlighted here:
Providing top tips on meeting our standards when using social media, we developed the guidance using a crowdsourcing tool, to ensure we included topics that were important to registrants. We produced case studies and a podcast to accompany the guidance. It has been downloaded 1,883 times.
What you should expect from your health and care professional
Following changes to the SCPEs, we produced this guidance by working with service users to understand their requirements. 112,000 copies of the leaflets are distributed to GP waiting rooms per quarter, with a pick up rate averaging at 96 per cent.
Approving and monitoring education programmes
Our approval and monitoring processes ensure that education and training programmes meet our standards of education and training (SETs). This important regulatory process ensures that when students gain a qualification they are able to practise their profession safely and effectively and are suitable to become health and social care professionals.
Meeting the service user and carer standard
One of our most important policy changes in recent years has been to ensure that education providers involve service users and carers in the development and delivery of their programmes. We introduced this change to ensure good practise in delivering education and training. We have now been assessing new programmes against this standard since 2014 and, during this year, completed the last wave of approved programmes through the annual monitoring process.
More professions able to prescribe
Legislation introduced in October 2016 enables appropriately trained dietitians and therapeutic radiographers to prescribe in order to provide a more efficient and convenient service for patients, while reducing demand on other services. As a result of these changes, we asked education providers to submit adjustments to their programmes for us to assess and approve before they could start. Those that did respond met our standards without any difficulty.
One of our key functions is to maintain and publish a register of health and care professionals who meet our standards. We do this so that members of the public can be assured that the person treating them meets national standards for their training, professional skills and behaviour.
As of 31 March 2018 we regulated 361,061 professionals, of whom 96,497 were social workers in England. The overall number of registrants has grown by approximately 10,000 or 3 per cent a year. Between 15,000 and 17,000 new UK graduates enter the professions each year, and between 2,000 and 4,000 professionals who qualified abroad also join the Register.
Revised registration renewal process
Following feedback from professionals on the Register, our focus this year has been on developing an improved renewal process, reducing the time it takes to send registration confirmation and increasing participation in online renewals. We have also introduced an online payment process for all international applicants, which has ensured more secure online payment by our registrants and reduced our potential exposure to credit card fraud.
Registration transformation and improvement project
Work has continued to revise business processes and create online channels that will improve the efficiency of the Registration Department and deliver an improved experience for professionals on the Register. Phase 1 of the project, to produce an online continuing professional development portal is underway and is expected to be completed in the summer of 2018.
Professionals on our Register 2017–18
Our fitness to practise (FTP) process is designed to protect the public from those who are not fit to practise. We will only take action where there are serious concerns about a professional’s ability to practise safely and effectively and when they have fallen below our standards.
Each year, only a very small percentage of our registrants are subject to allegations. The average percentage across all 16 of our professions  has remained almost constant over the past four years, at around 0.6 per cent, or six registrants in every 1,000. Therefore, the total number of allegations we receive has increased only proportionately to the overall growth in the Register.
Time taken to reach conclusion
The length of time cases take to reach a conclusion is a key performance measure for all health regulators, and is reflected in the Professional Standards Authority’s (PSA) standards of good regulation. Reducing the time taken to conclude cases is generally in all parties’ interests and this year we have put in place a series of measures to help us start to reduce the length of time for all cases, including those that are older than 18 months. Although our length of time has increased slightly this year, this is to be expected as we address the longer standing cases and bring them to a conclusion.
Improvements to the FTP process
The PSA’s Performance Review of the HCPC 2016–17 showed that we met most of their standards for good regulation. However, it identified some areas in FTP where further improvements still needed to be made. Since then, we have created a plan identifying operational and strategic changes to our FTP process. This includes reviewing resourcing levels and our quality assurance processes. It also includes reviewing our Standard of Acceptance, which is the level a concern about a registrant must meet before we will investigate it as an FTP allegation. We are also planning to develop key performance indicators, undertake a length of time review of cases that are older than 18 months and develop a process to prioritise and monitor high risk cases.
 The percentages of the Register subject to a complaint applicable to individual professions range from a tenth of 1 per cent to 1.3 per cent.
Allegations, hearings and days taken to complete hearings
We have a statutory responsibility to communicate with our stakeholders. This year, our priorities have been to engage with our wide range of stakeholders on our work to prevent fitness to practise (FTP) concerns arising and to communicate our revised guidance for continuing professional development (CPD).
Working together to prevent fitness to practise concerns
Our Meet the HCPC and Employer events provide us with the opportunity to hear directly from hundreds of our registrants and employers across the UK. As well as presenting on our role, we used our UK-wide events series to discuss and identify examples of good practice, and share ideas of how employers and registrants can work with us to prevent FTP concerns. This engagement has been particularly important as there is increasing recognition within the sector that regulators, working with others, can play an important role in this area.
Understanding our CPD requirements
We expect professionals to continue to develop their knowledge and skills while they are registered with us so we can be confident they are able to practise safely and effectively. Meeting our standards for CPD is, therefore, a requirement of registration. During 2017–18 we ran 15 workshops across the UK to support registrants in understanding the revised guidance around our CPD standards and the audit process itself. We met almost 1,000 registrants face to face and provided a range of new materials to support increased understanding of our CPD requirements. In our consultation, 79 per cent of respondents felt the guidance is now clearer and easier to understand.
Meeting with professional organisations, government ministers and civil servants
Over the year, our Chair of Council and Chief Executive met with over 90 representatives from different regulatory organisations, professional bodies and charities, as well as various government ministers and civil servants across the UK. These meetings are an important way in which we build effective relationships to ensure that we are able to influence the wider policy agenda on key issues like reforming professional healthcare regulation and the potential regulation of medical associate professionals.
“I gained ideas from people from different professions on what could be used for CPD that I hadn’t thought of before. How to more efficiently keep track of my CPD, be prepared for an audit and feel more relaxed about the process.”
Registrant at the CPD workshop
The tables below show the key operating and financial statistics for the five years to 31 March 2018. These statistics among others are captured on a monthly basis by our management information systems and reported to Council four times a year in the Chief Executive’s report. Council meeting papers are available on our website at www.hcpc-uk.org/aboutus/council/councilmeetings
Our renewal fee at £90 per year (discounted by 50 per cent for graduates of approved UK programmes for their first two full years on the register) is the lowest of all the nine UK statutory regulators overseen by the Professional Standards Authority (PSA).
In 2017–18, our fee income increased by £2m or six per cent on the prior year. This was the product of a three per cent growth in the size of the Register, together with all professions now paying the £90 registration fee that first took effect in 2015.
Expenditure increased by £2.8m or nine per cent and our result for the year was an operating deficit of £0.7m.
Factors contributing to the increase
Two non-recurrent factors contributed to the increase in costs and the deficit.
- The restructuring of the Executive Management Team. Although the restructuring was not completed until May 2018, it began before the year end so the redundancy and other costs, which totalled £0.4m, were charged in 2017–18.
- The refurbishment of 186 Kennington Park Road, which completed in June 2018. The total costs of the project in 2017–18 were £2.4m, of which £1.2m were capitalised and £1.2m were charged to operating costs, seen within the major projects line in the table above. The capitalised costs increased the book value of our freehold property before revaluation, and therefore contributed to the £0.8m revaluation loss and the £1.4m total comprehensive net expenditure.
The third main factor in the increase in our expenditure is fitness to practice costs. The action plan in response to the PSA’s report described on requires increased resources, which have pushed up costs further in 2017–18, in addition to the increase in the previous year resulting from the increasing complexity of cases referred to above. To complete the action plan, we have budgeted for a further increase in the department’s budget in 2018–19.
The increase in our costs over the longer term includes the cost of our dedicated tribunal suites in 405 Kennington Road since December 2015, and the levy we pay to the PSA since August 2015.
As a result of the requirement for registrants to pay their fees in advance, we hold relatively large cash balances. The aggregate of cash at bank and short term deposits was £18.9m at 31 March 2018 (2017, £19.5m). These are not surpluses or profits: the element of fees received in advance is reflected in the deferred income balance of £21.3m (2017, £20.7m), and fee income is recognised evenly through the renewal cycle.
Our total accumulated reserves are £3.6m at 31 March 2018, which represents approximately £10 per registrant. The decline in total reserves and free reserves in 2017–18 is the consequence of our deficit for the year and (in relation to the free reserves) our capital expenditure. Our reserves policy, set out below, explains the importance of free reserves.
Out of total fixed assets of £7.2m (2017, £6.9m) £5.0m is our freehold offices in Kennington, London. In June 2018, we completed the refurbishment of the 186 Kennington Park Road building that was purchased in 2013 in a dilapidated condition. The refurbishment provides a modern and efficient working environment in the 186 building, to the same standard as the 184 building, and joins the 184 and 186 buildings together. We carry our land and buildings on our balance sheet at valuation, and because the increase in the value of the property during the year is less than the capital cost of the refurbishment, there has been an impairment charge.
Impact of the creation of new regulator for social workers
The Children and Social Work Act 2017 established a new body, Social Work England (SWE), which will regulate social workers in England. The government’s target date for SWE to take over regulation of social workers from HCPC is spring 2019.
During 2017–18, we continued to liaise with colleagues in the Department for Health and Social Care and the Department for Education on the establishment of the new regulator. In 2018-19 we will begin closer working with the departments and SWE on the practicalities of the transfer of data and regulatory responsibilities and functions. In April 2018, we signed a grant agreement with the Department for Education under which the department will fund the costs we incur on the transfer, so that those costs are not borne by our remaining registrants.
The transfer of regulation of social workers in England to SWE will have a significant impact on our operations, income and expenditure from 2019–20 onwards. Social workers represent over a quarter of our total registrants; income from social workers was £8.6m in 2017–18 and is budgeted to be £8.9m in 2018–19.
The loss of income will be partly offset by a reduction in our direct, variable costs, including the fees and travel costs of the members of FTP panels hearing social workers’ cases, and related legal costs. However, the reduction in direct variable costs will be significantly less than the reduction in income, so the key financial impact of the transfer of regulation of social workers to SWE is a loss of contribution to our fixed costs.
Now that the timetable for the transfer has been established, we are undertaking further analysis to determine the extent to which the lost contribution can be covered by cost reductions, and whether a fee increase may be necessary. Any increase in our fees would be subject to public consultation and approval by the Privy Council and the Scottish and Westminster parliaments.
Principal risks and uncertainties
- Transfer of regulation of social workers in England to SWE.
A project has been established to manage the transfer, with its own risk register, and progress is being reviewed by the Audit Committee on a regular basis.
- Other legislative changes affecting the scope of our work.
- Poor operational performance with associated reputational damage. For example the risk of inability to meet call handling standards in our Registration Department.
- Rapid increase in FTP allegations and resulting legal costs.
- Rapid increase in education programme approvals. Due to legislative, service, commissioning or funding changes.
- Failure to complete of major projects. For example the delivery of new IT systems.
- Business continuity risks. For example interruption to the electricity supply to our offices or a postal strike.
- Financial risks. Such as budgetary overspends or errors leading to a shortage of funding, or the financial failure of a key supplier.
The full Risk Register is presented to Audit Committee and Council and is available on our website within the papers for Audit Committee and Council meetings.
The following matters are covered in the next section headed “Accountability report: Council’s report”.
- Health and safety, including the number of reported incidents and statistics on employee sickness.
- Corporate, social and environmental responsibility.
- Equality and diversity, including statistics on the gender of Council members and employees.
- Employee involvement.
In March 2018, Council approved the corporate plan for 2018–20, which identifies four strategic priorities.
Improve our performance to achieve the Professional Standards Authority’s Standards of Good Regulation
This priority will be delivered through the fitness to practise improvement project, started before the year end and continuing through 2018–19.
Ensure the organisation is fit for the future and is agile in anticipating and adapting to changes in the external environment
This includes the review of our cost base and financial sustainability noted above; continuing investment in people, processes and systems; and continuing to prepare for the transfer of regulation of social workers in England to Social Work England, working with the Government.
Ensure our communication and engagement activities are proactive, effective and informed by the views and expectations of our stakeholders
We intend to be more proactive in influencing the regulatory policy agenda. We will commission research to better understand the views and expectations of our stakeholders. We will put in place an action plan as a result of the findings, and a new plan to guide our engagement with stakeholders across the four countries.
Make better use of data, intelligence and research evidence to drive improvement and engagement
To deliver this priority we will develop a classification system for capturing the characteristics of fitness to practise cases and deliver further research on this topic.