UK Wide

RCOT has responded to this consultation. 

RCOT and Specialist Section: Work responded to this consultation. The response can be found below.

The consultation document sets out:

•    why the HCPC is involved in this piece of work;
•    how registrants, employers and the wider health and care sector can work together to gain the benefits of effective preceptorship programmes;
•    how the principles have been developed leading up to this consultation;
•    how you can submit a response.

As part of this work, HCPC collaborated with Health Education England (HEE) and have engaged stakeholders across the 4 UK nations and 15 professions to build on existing examples of good practice in preceptorship. 
 

The HCPC are proposing a 20% increase in registrant fees starting in July 2023. This would impact occupational therapists from August 2023 when the next renewal period for the profession begins. 

Many RCOT members have contacted us to express their opposition to the proposed fees increase.  Although we understand some of the rationale for why HCPC are proposing 20%, we strongly oppose this double the rate of inflation change. 
 

March 2022

The Department of Health and Social Care (GOV.UK) launched a consultation on Healthcare regulation: deciding when statutory regulation is appropriate. This consultation considered how the powers to introduce and remove professions from regulation might be used in the future. It asked for views on:

• the proposed criteria to make decisions on which professions should be regulated
• whether there are regulated professions that no longer require statutory regulation
• whether there are unregulated professions that should be brought into statutory regulation

Link to the consultation

November 2021

The Medicines and Healthcare products Regulatory Agency (MHRA) invited members of the public to provide their views on possible changes to the regulatory framework for medical devices in the UK (this consultation is on a future UK-wide scheme for regulating medical devices).

They want to develop a future regime for medical devices which enables:

• Improved patient and public safety;
• Greater transparency of regulatory decision making and medical device information;
• Close alignment with international best practice, and;
• More flexible, responsive and proportionate regulation of medical devices.

They welcomed the views of patients, medical device researchers, developers, manufacturers and suppliers, clinicians, healthcare professionals and the wider public to help shape their future approach to regulating medical devices in the UK.

Link to consultation

RCOT RESPONSE: we responded to this consultation on 21 November 2021.  As it was an online consultation, our response is not available.

November 2021

The Health and Care Professions Council (HCPC) asked for views on their proposal to permanently amend their Rules to give them the express power to hold hearings remotely.

On 4 March 2020, the HCPC was granted an amendment to their existing Rules by the Department of Health and Social Care, which gave them the express provision to hold hearings remotely during an emergency. Currently, the Coronavirus emergency provisions are due to expire on 30 September 2021.  

They wanted to continue to hold hearings remotely once the emergency period ends, where it is fair and practical to do so. They therefore sought an amendment to their Rules to give them permanent powers to hold hearings remotely. 

Link to consultation

October 2021

The health and disability green paper set out how the welfare system can better meet the needs of disabled people and people with health conditions now and in the future, enabling people to live independently and move into work where possible.  

This green paper considered the options for addressing some of the short- to medium-term issues in health and disability benefits. It also started a discussion about the opportunities for wider change to deliver on the objectives of the health and disability benefit system.

The consultation concerned the following aspects of the Department for Work and Pensions’ support for disabled people and people with health conditions:
•    Ways to provide more support to help meet the needs of disabled people and people with health conditions and allow them to more easily access and use benefits and services.
•    Improve employment support for disabled people and people with health conditions, and how to encourage people to take up that support, where possible.
•    Short-term improvements to our current services such as improvements to assessments and decision making, to improve the experience of disabled people.
•    Changes to future assessments and alternative approaches.
•    Changes that could be made to the structure of the main benefits claimed by working-age disabled people and people with health conditions.

A copy of the Green paper can be found here.

This consultation by the Department of Work and Pensions (DWP) considered its plans to: work harder for disabled people to provide reasonable adjustments to DWP services; offer better and more tailored employment support to disabled people and rethink future benefit assessments.

June 2021

The UK model of regulation for healthcare professionals is rigid and complex and needs to change to better protect patients and service users, support our health services and to help the workforce meet future challenges. This consultation sought views on proposals to modernise the legislation of the healthcare professional regulators. The proposals were developed in partnership with the professional regulatory bodies, the Professional Standards Authority for Health and Social Care and tested with key stakeholders across the health and care system. The proposed reforms cover four key areas.

These are:

• Governance and Operating Framework
• Education and Training
• Registration
• Fitness to practise

 The consultation also sought views on the proposed approach to introducing statutory regulation for physician associates and anaesthesia associates.

November 2020

This consultation sought the views of stakeholders on the Health and Care Professions Council’s (HCPC’s) draft Corporate Strategy 2021-2026.

October 2020

The Health and Care Professions Council (HCPC) launched a consultation regarding its proposed changes to the Standards of proficiency for each of the 15 professions it regulates, including occupational therapists. These standards, which set out what the HCPC consider necessary for safe and effective practice, describe what professionals must know, understand and be able to do at the time they apply to join the Register.

The HCPC proposed changes to both the generic and profession-specific standards, following engagement and feedback from stakeholders last year.  The purpose of the generic standards is to recognise commonality across all the professions that they regulate. The profession-specific standards set out the threshold requirements that are relevant to each specific profession.

 September 2020

June 2020

Housing for those living with dementia was the subject of a new Inquiry launched by the All-Party Parliamentary Group (APPG) on Housing and Care for Older People.

Supported by Anchor Hanover, the Inquiry will hear evidence over the coming months and make recommendations to Government early next year on how to ensure housing policy reflects the needs of the rapidly rising number of people with dementia. There are currently around 850,000 people with dementia in the UK, according to the Alzheimer’s Society. This is projected to rise to 1.6 million by 2040. Two thirds of these are not living in residential care but in their own accommodation, and our study will consider the policies and practices that can enhance independence and quality of life.

The APPG sought evidence covering:

• The links between housing, health and social care to improve the journey of people affected by dementia;
• The design of new homes;
• Ways to increase supply of specialist dementia-friendly properties;
• Changes and adaptations to existing properties to enable people to live well with dementia at home; and
• The role of innovative technology to improve the delivery of better care and support.

It also sought written submissions to inform its report, which will make recommendations to central and local government and provide guidance for housing providers. These were collated by the Housing LIN, Secretariat to this APPG inquiry.

Link to consultation

January 2020

The Faculty of Clinical Informatics (FCI) has completed the first phase of their Core Competencies Project.  The Core Competencies Project (CCP) is a key project that the Faculty is undertaking to develop a methodology for the development of core knowledge and skills-based competencies for Clinical Informaticians (CIs) and the mechanism by which these competencies can be mapped to educational and professional developmental initiatives for accreditation.  The FCI project is made up of three stages, with phase 1 being to: develop, test and define the output core competences required of a professional clinical informatician.  The FCI asked for feedback on Phase 1 in a consultation exercise.
 

September 2019

In June 2019, the government commissioned the Migration Advisory Committee (MAC) to carry out an in depth analysis of potential future salary thresholds and the range at which they could be set.  This salary threshold refers to a key component of the UK’s immigration system.  In addition to the salary thresholds, the MAC was also asked to look into an ‘Australian-style’ points-based system and how this might work in the UK.

The call for evidence identified the sort of information that the MAC will find most helpful to receive during the initial phase of its consideration of the government’s commission.

Link to consultation

October 2019

This consultation sought views on how employers can best support disabled people and people with long-term health conditions to stay in work. It contained 56 questions listed at the back of the document but some of the key questions regarding occupational health are summarised below. The proposals set out in the consultation included:

· Amending the legal framework to encourage workplace modifications and early action to support individuals on sickness absence leave;

· Reforming Statutory Sick Pay so that it is better enforced, more flexible and covers the lowest paid and potentially, rewards effective action with a new rebate;

· Improving access to occupational health services with additional support for small employers including a potential subsidy;

· Government to provide best practice advice and support for employers on managing health and disability in the workplace.

Chapter Three (page 36) considers how to stimulate and improve the occupational health market and relevant questions for occupational therapists working in OH include:

• Would targeted subsidies or vouchers be effective in supporting SMEs and the self-employed to overcome the barriers they face in accessing OH?
• Would potentially giving the smallest SMEs or self-employed people the largest subsidy per employee be the fairest way of ensuring OH is affordable for all?
• What type of support should be prioritised by any potential, targeted OH subsidy for SMEs and/or self-employed people?
• How could the government ensure that the OH services purchased using a subsidy are of sufficient quality?
• If you are an OH provider, would you be willing to submit information about the make-up of your workforce to a coordinating body?

• What are your views on private OH providers’ involvement in the training of the clinical workforce?
• If providers should be more involved but will need support, what additional support would be needed?
• What changes to the training and development of the OH workforce could support the delivery of quality and cost-effective services?
• Should there be a single body to coordinate the development of the OH workforce in the commercial market? If yes, what should its role be?
• What would encourage providers, particularly smaller providers, to invest in research and innovation in OH service delivery?

• What approaches do you think would be most effective in terms of increasing access to OH services for self-employed people and small employers through the market?
• What more could be done to increase the pace of innovation in the market?
• What methods would you find most helpful for finding out about new evidence and approaches that could improve your service?
• What indicators of quality could help improve the standard of services in the OH market?
• Do you have suggestions for other actions which could improve capacity, quality and cost effectiveness in the OH market?

Link to consultation

March 2019

Many people are living in unsafe, unsuitable and unhealthy accommodation, with little hope of being able to move or improve their homes.  For many older people right now this is having a detrimental impact on their physical, mental and social wellbeing. 

The UK has 1.4 million people over the age of 65 with unmet care needs, many needing help with essential everyday tasks, like getting out of bed, going to the toilet or getting dressed.  These everyday tasks are inextricably linked to their living circumstances and are often made worse by poor housing conditions.  There are also links between living in unsuitable accommodation and increased feelings of social isolation and loneliness among older people.

This shows just how vital it is that we find long-term solutions for decent and accessible homes that can meet the needs of an ageing population.  For an older person, living with poor housing conditions can also have a huge impact on their physical and mental health. 

This might be because they don’t have the right facilities in their homes for a carer to be able to cook, clean or help with their healthcare.  They might also struggle to get the right adaptations for their needs or to give them the independence for them to be able to look after themselves, like having handrails in the shower, wider internal doors or motion sensor lights.

All of which is increasing the strain on the social care system and the NHS.  The cost to the NHS of delayed discharge from hospital is a staggering £500 a minute.  This is in part due to people not having suitable accommodation to return home to.  This situation is untenable and is only going to get worse as winter approaches and the NHS struggles to cope with increased demand.

This is why the APPG for Ageing and Older People decided to launch an inquiry in Parliament into decent and accessible housing standards for older people.  The main aim of the inquiry was to understand the detrimental impact of poor housing on older people’s physical, mental and social wellbeing and to find solutions that can be presented to the government.  During the inquiry, the APPG heard evidence from key industry figures and Parliamentarians on the older people’s housing.

The APPG will look at where poor housing is located and between different housing tenures; the cost of this to the NHS and social care; the conditions for older people in supported housing; and what happens to older people in the private rented sector.  The aim of the inquiry is to look at measures we could take to improve the situation and find solutions to older people’s housing needs that have cross-party support.  There are a growing number of older renters and a lack of suitable supported and social housing. There are also increasing numbers of older homeowners unable to maintain or adapt their homes to a decent standard.  Many of these older people have unmet care needs and are affected by the crisis in social care.

Unless sustainable solutions are found, older people and the most vulnerable in society will continue living in substandard and unsuitable accommodation, the implications of which could be devastating to their physical, mental and social wellbeing.  The government has to look at building homes that are suitable and adaptable, and to find solutions to improve the conditions of current housing stock so that they work for those that call them home.

This APPG for Ageing and Older People’s inquiry into decent and accessible housing standards was the housing sector’s chance to engage with the political and legislative housing issues before Parliament and actively help to positively shape the future of housing for older people.

Read the consultation

January 2019

In June 2018, the government commissioned the Migration Advisory Committee (MAC) to carry out a full review of the composition of the shortage occupation list (SOL), to report in spring 2019. The MAC was asked to start the review of the SOL in the autumn.  The evidence provided by stakeholders will allow the MAC to assess and analyse the information in a structured and methodological way, assessing all information using the same criteria. 

RCOT responded to the consultation and provided evidence on the shortage of occupational therapists in the UK using the online form.   It must be noted that that we were restricted by the word count for the RCOT response.

Thank you to all those who sent in information to support the RCOT response. 

• Read the consultation at the gov.uk site

December 2018

The HCPC launched a consultation on proposals to increase registration fees.  The HCPC stated on their website:

• We are consulting on proposals to increase our registration fees. If adopted, the changes would be effective from 1 October 2019 and existing registrants would pay the new renewal fee when their profession next renews its registration.
• The increases are needed to support our new strategic focus of promoting professionalism and preventing fitness to practise issues from arising. We also need to continue to invest in the services we offer to registrants. The consultation takes place in the context of keeping pace with the cost of inflation and the impact on our operations and income when social workers in England transfer to Social Work England in 2019.

Link to consultation

UK

The All Party Parliamentary Group (APPG) on Mental Health is a group of MPs and Peers from all political parties who are interested in mental health.  They held an inquiry into the implementation of the Five Year Forward View for Mental Health.

We are now halfway through the first ever five-year plan to improve the nation’s mental health and this is an opportunity to assess where progress has been made and which areas need much more work.

The APPG wanted to understand what impact the Five Year Forward View for Mental Health has had so far and what should be included in any strategy after 2021.

Read the consultation.

Read the RCOT response.

June 2018

In 2014, the Government introduced wide-reaching changes to the SEND system, with the intention of offering simpler, improved and consistent help for children and young people with SEND. The Government claimed these changes would give families greater choice in decisions. The Committee’s new inquiry is intended to review the success of these reforms, how they have been implemented, and what impact they are having in meeting the challenges faced by children and young people with special educational needs and disabilities.

• Read the consultation

The current Teaching Excellence and Student Outcomes Framework (TEF) assesses ‘provider-level’ undergraduate provision. The Department for Education intends to extend this to a disciplinary (subject) level from 2020.

They looked for comments from all stakeholders, including:

• students
• providers
• employers
• sector bodies

In section 11, RCOT’s online responses was:

Do you:

a) Agree that QAA Subject Level Benchmark Statements and PSRB accreditation or recognition should remain as a voluntary declaration, if not, why? NO - as outlined in the RCOT response.

b) Think there are any subjects where mandatory declaration should apply? YES - particularly in relation to pre-registration education for professions in health and social care.

The findings from this consultation will ensure the proposed design is informed by thorough evidence.

Read the consultation

RCOT Response

March 2018

According to NHS England, an emergency admission to hospital is “when admission is unpredictable and at short notice because of clinical need”.  From 2007 to 2017, emergency admissions have increased by 24%.

A recent National Audit Report examined the reasons for admissions growth, and how much it costs. It found that in 2016–17, there were 5.8 million emergency admissions, costing a total of £13.7bn.

The increase in cost has been slower than the increase in overall admissions, suggesting that NHS England has become more cost-effective at handling emergency admissions to hospital. However, where the rate of growth in admissions has also slowed, the NAO did not find compelling evidence that NHS England’s programmes were the reason for this. For example, only 32% of local areas reported meeting their Better Care Fund targets to reduce emergency admissions.

The committee will ask NHS England, NHS Improvement and the Department for Health and Social Care how they can ensure that emergency admissions are put on a long-term sustainable trajectory.

Before this, the committee will ask NHS England about progress with handling clinical correspondence. The committee examined some aspects of this issue in November, but is concerned to ensure the NHS makes progress in solving the problem fully.

Read the consultation

Download the RCOT Response

March 2018

Social care provision and funding has been the subject of numerous reports, commissions and Government papers over many years. Despite agreement on the urgent need for reform, this has not translated into action or consensus on how it should be achieved. 

Ahead of the Government’s Green Paper, the Communities and Local Government Committee and the Health Committee held a short inquiry to identify funding reforms which will command broad consensus, and which will enable the Government to make swift and tangible progress in this area. Bearing this in mind, submissions were invited from organisations and individuals on the following terms:

• How to fund social care sustainably for the long term (beyond 2020), bearing in mind in particular the interdependence of the health and social care systems; and
• The mechanism for reaching political and public consensus on a solution.

Read the consultation

Download the RCOT response

March 2018

The Government published a green paper on children and young people’s mental health. It set out specific proposals that represent a fundamental shift in how the Government will support all children and young people with their mental health and ensure  that they are always able to access the right help, in the right setting, when they need it. One objective was to put schools and colleges at the heart of efforts to intervene early and prevent problems escalating. There were three key elements to this:

• Incentivise every school and college to identify a Designated Senior Lead for Mental Health to oversee the approach to mental health and wellbeing.
• Funding new Mental Health Support Teams, supervised by NHS children and young people’s mental health staff to provide specific extra capacity for early intervention and ongoing help.
• Trialling a four-week waiting time for access to specialist services.

There will be a number of trailblazer areas which will be operational from 2019. The new approach is then to be rolled out to at least one fifth to one quarter of the country by the end of 2022/23, subject to the success of the trailblazers and securing funding.

Link to consultation: https://www.gov.uk/government/consultations/transforming-children-and-young-peoples-mental-health-provision-a-green-paper

January 2018

On 31 October 2017, Philip Dunne, Minister of State for Health, announced the Department of Health’s consultation on the reform of the regulation of healthcare professionals in the UK. This will take forward the manifesto commitment to legislate to reform and rationalise the current outdated system of professional regulation of healthcare professions, based on the advice of professional regulators.

The proposed model of professional regulation aimed to:

• secure public trust
• improve clinical practice
• adapt to developments in healthcare

This consultation sought views on what DH need to do to protect the public as much as possible and at the same time support the development of the workforce.

More on the consultation at the Gov.uk website.

August 2017

The APPG launched a ground-breaking inquiry looking at mental health support for people with Parkinson’s who experience anxiety or depression.  The inquiry will make recommendations to Government and other relevant authorities that could improve mental health services and make it easier for people with Parkinson’s to access them.  The RCOT Specialist Section Neurological Practice made a submission on behalf of RCOT. 

Link to consultation: https://www.parkinsons.org.uk/content/all-party-parliamentary-group-parkinsons

Download the response.

This consultation sets out proposals of the four UK higher education funding bodies for the second Research Excellence Framework (REF) for the assessment of research in UK higher education institutions. The proposals seek to build on the first REF conducted in 2014, and to incorporate the principles identified in Lord Stern’s Independent Review of the REF.

An overall approach based on REF 2014 is proposed, incorporating the principles of Lord Stern’s Independent Review, and subject to changes that may be made in responses to this consultation. Views are sought on aspects of the following features of the assessment framework: overall approach, Unit of Assessment structure, expert panels, staff, collaboration, outputs, impact, environment, institutional-level assessment, outcomes and weighting, and proposed timetable.

This Green paper asked “What will it take to transform the employment prospects of disabled people and people with long term conditions?”. It proposed a spectrum of initiatives including:

• Improving employment support by expanding employment advisers trained in talking therapies and introducing a new Personal Support Package
• Working with professional bodies to embed evidence into clinical practice and support training of the NHS workforce
• Investing £115 million into new models if support –rapidly scaling up those that make a difference and weeding out less promising approaches
• Strengthening the business case for inclusive practice by employers • Using work coaches to pay a more active role for disabled people
• Improving the welfare system particularly ESA
• Promote timely access to musculoskeletal and mental health services to ensure people can stay in employment
• Improve occupational health support
• Reinforce work as health outcome in commissioning decisions and clinical practice (Note COT/PHE Health and Work Champion pilot project page 77)
• Encourage, harness and spread innovation about what works best
• Create a culture of high hoper and expectations from people with disabilities and long term conditions so they can achieve their employment aspirations.  

The consultations covered topics such as how to tackle inequality; how to support people into work; assessments for benefits; supporting employers to recruit with confidence; supporting employment through health services (particularly musculoskeletal and mental health services) and how to build a movement for change. Such was the volume of comment and case examples submitted by occupational therapists that the COT response was separated into two documents; the first is the main response and the second is the appendices which provide more detailed information about COT members excellent work and expert opinion.

November 2016

HCPC consulted on proposed changes to the standards of education and training (SETs) and supporting guidance. The SETs describe the policies, processes and arrangements that each education and training programme must have in place in order to gain approval from HCPC. They ensure that all learners meet the HCPC standards of proficiency when they complete an approved programme and are eligible to apply for registration with HCPC.

Download the response.

October 2016

The Health and Care Professions Council (HCPC) sought views on draft revised guidance on their requirements for returning to practice.

The HCPC returning to practice requirements help to ensure that registrants who have been out of practice for more than two years, and wish to return, update their knowledge and skills in order to resume safe and effective practice. HCPC produces guidance to help people who have taken a break from practising, or are considering doing so, to understand requirements.

The guidance was last published in 2006 and HCPC has proposed changes to make sure it is up to date and continues to be clear and helpful. They did not propose to change the requirements themselves at this point. This consultation was of particular interest to registrants who have or are considering taking a break from practising, as well as those who employ or supervise professionals who have recently returned to practice.