Do we really need the GOsC?

OK.  Now I’ve got your attention, I can confess.  This is not going to be an entertaining post-Handoll diatribe against the GOsC, but my slightly nerdy effort to alert to you to the fact that the GOsC’s days could be numbered, and you, yes you!, can help decide the future of how we are regulated.

I think we have all known that there has been a possibility of the GOsC amalgamating with other regulators.  Regulation has just not felt that ‘fixed’ over the last 20 years, and whether we’d be better off as part of the HCPC, or even individually giving up our registration, is a question that regularly comes up amongst osteopaths.  But I’m  not sure how many of you know the Department of Health actually have a consultation document – Promoting Professionalism, Reforming Regulation – in which they are “looking at” reform.  For example, what it would be like if the number of regulators was reduced from 9 to, say, “3 or 4”?  Some of the language sounds quite tentative;  they are “looking” at what this might “look like”,  but some of it sounds pretty definite.  Phrases like:  “The four UK governments believe there is need for radical change”, and the even less ambiguous “this needs to change”   – mmm, sounds like something might be going to happen.  When?  I don’t know.  But this seems like an initial stage, so it’s a perfect time to express your opinion if you have one.

The document is 51 pages long, but quite a bit of that is annexed material, tables of contents, references etc. that you don’t have to read through.   And once you’ve picked up the main points you can have a say using their survey.  There are 24 questions, some of which we might not be well informed enough to answer, but some of which we might.  If you don’t like the questionnaire, feel free to send your views in any old form – essay, bullet points, novella, recorded rant – but preferably on a Word document.  They say they will take them all into consideration.  Now I guess that these views do get read, pertinent phrases might get quoted, you might actually have thought of something they haven’t, and if you think  you don’t have strong feelings about this now, there’s always a chance you’ll find you have strong feelings about it after the event, when it’s too late to have any influence over the initial direction of things any more.  Speak now or forever hold your peace.

The Deadline:  You need to fill in the survey or send your views by January 23rd 2018.

A few things in the document stood out for me:-

The regulators are described in exciting and rather martial-art–superhero terms as “gatekeepers to the professions” and even, (cue cinematic voiceover) “the guardians of the ethos and culture of each profession as a whole”.  And they are largely thought to be a good and necessary thing.  But someone, somewhere, thinks they need:

Greater consistency

Whoever wrote this document, and I couldn’t quite find an author, seems to think the professions might be a bit more consistent and streamlined, as they’ve all arisen and been legislated in a hotch potch manner over the last 150 years.

Better complaints processes

They also want to make the whole complaints bit better.  “All too often professionals encounter a culture of blame rather than learning”.  They want to shift the complaints process from a time consuming, adversarial, stressful and expensive process, to a quicker and more inquisitorial process.  Hard to argue with that bit, and that emphatic statement – “This needs to change” – suggests that this is one of the less tentative parts of the consultation.   The only question is, how?

Partly the drive is to shift things”upstream”, by which they mean do stuff earlier to stop complaints happening  i.e.  better training, dealing with badly behaving professionals before anyone has actually made a complaint about them, adding compulsory bits to CPD in problem areas  E.g. the way the GOsC is making us do consent and communication training, as they keep seeing complaints based on deficiencies in those areas coming up.  (By the way, our complaints process is the most expensive for some reason.  I believe it amazingly adds up to £15 384 per complaint, if I’ve read the slightly confusing table correctly, but I guess because we have a small number of complaints it is only 29% of total expenditure.  Compare that with nurses and midwives where the figure is 76% of their total.

More economical

I also now realise just how small the GOsC is compared to most of the other regulators.  We constitute only 0.3% of the total number of about 1.5 million regulated healthcare professionals, and are third from smallest, with only chiropractors and Northern Ireland pharmacists having fewer people.  Nurses and midwives are the largest group (a mammoth 692 550).  (NB all the figures in the document date from 2015/16)

The ideal size for a regulator, in efficiency terms, is over 100 000, and the larger they are the more financially efficient up to about 300 000 where it starts to plateau.  What it means for us is that a larger regulator should/could bring fees down.  If you want a peek at how large other professions are, and how much they pay, here is the list, from largest to smallest. This is from 2015/16 too.  (I notice today that the number of chiropractors is slightly up, to 3295  now, though.)  And if you’re wondering about physiotherapists, they’re part of the Health and Care Professions Council*, along with at least 15 other occupations, ranging from art therapist to social worker to paramedic to orthoptist.

Regulator                                                        Number of registrants                       Annual fee

Nursing and Midwifery Council                    692 550                                                   £120

Health and Care Professions Council*           341 745                                                   £90

General Medical Council                                  273 761                                                    £425

General Dental Council                                      108 209                                                 £116 – £890

General Pharmaceutical Council                        89 377                                                 £118 -£250

General Optical Council                                         29 136                                                 £320

General Osteopathic Council                                 5 102                                                     £570

General Chiropractic Council                                 3 109                                                   £800

Pharmaceutical Society of Northern Ireland      2 852                                                     £326

Fewer regulators

The Dept of Health are basically asking for opinions on whether this idea of fewer regulators is good or bad, and if good, which different professions to gather together under each regulator.  This is what they are asking:

Q5: Do you agree that there should be fewer regulatory bodies?
Q6:  What do you think would be the advantages and disadvantages of having fewer professional regulators?
Q7: Do you have views on how the regulators could be configured if they are reduced in number?
– in my opinion, these are the most crucial and lively questions of the whole thing.   I positively can’t wait for the social media entertainment to be had with this one.  I would think it obvious that physio would get bracketed with chiro and osteo, but let’s face it, that’s not going to go down too well with everyone.  I think they might want to bracket together different occupations which have a similar level of risk, and which require a similar level of oversight, and they provide a detailed explanation of their proposed 2-stage risk assessment. (You can comment on this, too).  I can’t help thinking the brackets will be perceived to represent similar status, not just similar risk.  (And as an aside, it says here that the government is very keen to raise the status of social workers, who are part of the HCPC).
More power to the PSA

The HCPC* already includes many different occupations, and decides which occupations need regulation.  There’s some idea here though, that they have a vested interest in recommending that professions are regulated, to boost their own size, and this decision-making power could be given over to the PSA, which is the body that oversees the whole lot of them, and which last year made quite a few proposals about how things might change.  Most of these involve standardising them, i.e. having a single register and single set of professional standards.  Some occupations could even be deregulated and others brought in to the fold.  They also want more co-operation and are even talking about a licensing system.

So if you care about this kind of thing, and it could have enormous ramifications for our profession, go and read the document and make your comment.  If not, it’s probably just as well you know that changes might be a-coming…

*For fellow stats fans, here’s the breakdown of numbers in the HCPC, from biggest to smallest.  These are current figures.

Social Workers (England)                                 95,388

Physiotherapists                                                 54,980

Occupational therapists                                    37,799

Radiographers                                                     33,638

Paramedics                                                           24,796

Biomedical scientists                                          23,142

Practising Psychologists                                     22,853

Speech and language therapists                       15,785

Operating Department Practitioners               13,595

Chiropodists/podiatrists                                     13,186

Dietitians                                                                9,556

Clinical Scientists                                                  5,675

Arts therapists                                                      4,273

Hearing aid dispensers                                       2,836

Orthoptists                                                             1,441

Prosthetists/orthotists                                          1,049





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