Regulation of Health Care Staff in England and Wales – A Consultation Document
A response from the British Psychological Society
The British Psychological Society is pleased to have the opportunity to comment on the above proposals. Overall we support the need for an extension of regulation to assistant and support staff.
We are, however, surprised that we were not among the people consulted listed at Annex C as the proposals contained in the consultation are closely linked to our current status as an aspirant profession to the Health Professions Council (HPC). In particular they impact on the position of Psychology Assistants and discussions that are currently taking place in both England and Scotland regarding the potential for developing a new level of psychological support worker or “Associate”.
Drawing on the issues highlighted in the consultation document, it may be that the position of PsychologyAssistants and Associates should be considered in the context of the regulation of Applied Psychologists rather than as part of the Health Occupations proposals. We would be happy to engage in such a discussion as a matter of urgency.
We were concerned to note the content of the third bullet point in Annex B 2 that refers to:
“numerous complaints about sexual and psychological abuse and exploitation of patients by psychologists and psychotherapists…”
With respect to psychologists, including those on our recently opened register of Chartered Psychologists specialising in Psychotherapy, our disciplinary and investigatory records show that only a very small number of complaints have been received in this category. While it is regrettable that any such complaints are felt necessary, we feel that the use of the term “numerous” is completely misleading and can only serve to cause unnecessary and unwarranted alarm in members of the public. It serves to undermine the basis of trust that is the foundation for successful intervention and is damaging to the reputation for high ethical standards that has been gained by Applied Psychologists working under our Society’s Code of Conduct.
In response to the specific questions raised in the consultation, we would respond as follows:
Q1How far should assistants and support staff be accountable for their own practice?
The British Psychological Society believes that it is essential to draw a clear distinction between those staff who have completed a training to a full, professional standard and those who have not, in a manner that does not risk misleading the public about the scope of their competence. While those who operate at assistant and support levels play an important role in the delivery of health care, we believe that their training does not equip them to take full, competent and independent responsibility for assessment, formulation, intervention and review as these are properly the focus of the occupational standards underpinning full professional training.
It is therefore our view that assistants and support staff should be accountable through supervised practice overseen by an appropriate professional who is fully qualified in the relevant discipline. This provides the optimum arrangement for quality of service and protection of the public.
Q2Should assistants and support staff set their own standards OR should those with responsibility for the work of these staff share in, or take, the lead in setting these standards?
It follows from our answer to Q1 that the British Psychological Society believes it is essential that the work of assistants and support staff should be to the standards set and monitored by those with overall responsibility for the work in which those staff share. It is essential to avoid any implication, either to staff or patients, that the work of assistants or support workers might be to a lower standard or “second class”.
Q3Should regulatory arrangements be extended to healthcare assistants, therapy assistants, assistant practitioners, and others performing similar roles in routine care? If not, which staff should be included and on what criteria?
The British Psychological Society recommends that regulatory arrangements should be extended to cover all the groups indicated.
Q4Is statutory regulation appropriate or should other approaches be taken?
The British Psychological Society believes that statutory regulation will be the most appropriate route in most cases. However, where such staff already have an integral and unique relationship with one particular discipline or profession it may be useful to consider the overall regulation of that discipline or profession including the assistant or support roles.
Q5Should the Health Professions Council (HPC) regulate those groups of assistants and support workers identified for statutory regulation? Are other options preferable?
In some cases, including our own, The British Psychological Society believes that it may be appropriate for assistant and support staff to be regulatedwithin the structures of the profession with whom they are primarily identified. We also believe that,for those who do not have an integral affiliation with a specific discipline or profession; who cannot be accommodated in existing systems; or who work in a cross disciplinary manner, HPC would be an appropriate body to provide additional regulatory structures.
Q6If the HPC is the most appropriate body, should regulation be by way of a statutory Health Occupations Committee or would other options be preferable?
Where there is an integral affiliation with a profession or discipline already subject to statutory regulation, the British Psychological Society believes that it may be both confusing and problematic to separate entirely the regulation of the main professional role from that of the assistant or support worker.
Specifically in relation to assistants and support workers in Psychology, we believe that it would be appropriate for them to be regulated within the general structures for Applied Psychologists. Assistants and support workers in Psychology will have at least a first degree in Psychology to honours standard and many will have a postgraduate qualification to Master’s level(with the exception of a very few working in Prison services). They are thus in a different position to assistant or support staff in most other professions where graduate (or equivalent) qualifications are the level of full professional entry.
We would therefore propose that the work that Psychology assistants and support workers will undertake is distinctly and specifically psychological and must be undertaken at all times under the close supervision of a fully qualified and registered Applied Psychologist.
We are currently engaged in a review of how staff at assistant or support levels might access the “skills escalator” and have the option of progressing in accredited ways to full professional qualification as they are drawn from a similar pool of undergraduates to those who currently enter approved training routes.
We believe that there are opportunities for innovation in extending access to training, new routes through training, and levels of practice in relation to stages of training that we would wish to explore collaboratively with respect to the workforce requirements of the NHS.
Q7Would the 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 British Psychological Society suggest that any notion of “second class” workers should be avoided by ensuring that routes remain available to assistant and support staff to work towards the achievement of a full professional qualification with appropriate accreditation of prior experience and learning. Thus, although they might “step off the skills escalator” at a number of pre-determined points, they would continue to be seen as having the potential to progress, with their work at each stage being undertaken to the same standards as those whom they support.
We are currently exploring the potential for such developments with the Modernisation Agency in relation to Psychology Associates. A prerequisite will be clear, agreedstandards for training at all levels of assistant and support work that are assessable, quality assured and linked to progress towards accreditation within the framework of the National Occupational Standards for Applied Psychology. We are also working with both the Department of Health and the Quality Assurance Agency in developing benchmarks for professional training in the Applied Psychologies.
Q8Are there options for the structure of statutory self regulation we should consider?
In our answer to Q6 the British Psychological Society has suggested, specifically for psychology assistant and support staff but potentially for others, that statutory self regulation may be an option where the regulation of such staff can be integrated into innovative schemes incorporating flexible approaches to extended training under supervision.
In the case of Psychology it may be possible to draw some parallels with the conditional Chartered status that is available to Society members who are on an approved training route. The Society is currently reviewing both Chartering and Membership with a view to meeting developing training and regulatory needs in a flexible manner while retaining Chartered status as the recognition that psychologists have achieved the benchmark set by our Occupational Standards through an accredited and assessed route. We would be pleased to explore how this might be helpful in relation to managing complex issues of regulation for Applied Psychologists and psychology assistants and support staff.
Q9How 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 group within a single framework including some shared standards and some discipline-specific standards?
Where the nature of the assistant or support role is inherently and genuinely cross disciplinary, the British Psychological Societybelieves that there should be a single set of standards agreed among the relevant disciplines that may be contextualised for a specific discipline or setting where appropriate.
Where staff have been regulated on the basis of an integral relationship with a specific discipline, there should be an agreed mapping of competencies among disciplines that would allow staff to “top up” and re-contextualise existing accredited knowledge and skills in order to facilitate workforce flexibility and mobility.
We note again our collaboration with the Department of Health and the Quality Assurance Agency in their work of developing overarching benchmarks for health professions and suggest that this will be an important contribution to addressing these issues. It may be desirable in the future to work towards a single regulatory framework for all health professionals, including those currently covered by the Nursing and Midwifery Council and the General Medical Council, as we see increasing development in the delivery of knowledge and skills within a multi professional, competence based context.
We hope you will find these comments constructive and we should be pleased to have further discussions on the specific implications for Applied Psychology at an early date.
Yours faithfully,
BPS - June 2004Page 1