IBMS response to HCPC fees consultation

The below response captures the views expressed by our members:

Consultation questions

1. To what extent do you agree or disagree with the rationale we have set out for increasing our fees by the minimum necessary amount?
   
   Agree
   
   The majority of views expressed recognise the financial position and accept the rationale for increasing the fees to cover its running costs. However, there is concern at the large increase in the number of Fitness to Practice cases (FTP) raised compared with previous years, which has consequently placed a higher economic burden on the HCPC than had been anticipated. There is also concern that an FTP case could potentially be brought without due diligence by the accusing authority.
   
   In view of this the Institute, while appreciating the work that goes into reviewing and assessing allegations to ensure there is a valid case to take to a full FTP investigation, would urge that all efforts are made to achieve a resolution wherever possible without the need for a full FTP investigation and hearing.
   
   
2. Given the rationale, to what extent do you support the fee increase proposal?
   
   Agree
   

   It is welcomed that a regular review of income is now taking place with regular but small increases in fees applied to meet increasing costs and the increasing demands upon services. This is justified given that registrant fees are the only source of HCPC income. It is noted and welcomed that the HCPC has implemented savings measures that include a 50% reduction in estate size that has generated a saving of £1 million.
   
   The IBMS wholly supports the need for protection of the public that all registrants serve and recognises the need for the HCPC to raise sufficient income to cover running costs and to allow for a small reserve to be retained. While responses received are being broadly accepting of the proposed fee increases there is a number of points that the Institute would wish to make on its members’ behalf.
   
   The comparison with other regulators’ fees cannot be taken at face value as they are not like-for-like models, and this is not a competitive market whereby registrants can choose or change regulator based on cost. The medical and professions pose a significantly greater risk to the public and the registrants have significantly greater earning potential than most HCPC registrants.
   
   With respect to the previous fee increases, there was a five-month delay from July to November in the implementation of the 2023 increase, which had an impact on the HCPC financial projections. There is concern that this delay has impacted on the original financial projections, resulting in increased costs for the HCPC, which are having to be covered by the subsequent planned fee increases. Furthermore, there was also a commitment to increase the spread of direct debit payments; this has still not been implemented although it is noted that this will take place from April next year. This does not sit comfortably with registrants.
   
   A number of individuals hold dual registration as both biomedical and clinical scientists. These are usually individuals employed in Advanced Clinical Practice roles and have chosen to hold dual registration due to uncertainty about how future posts will be advertised. This is likely to affect only a small number of individuals, but the fairness of being required to pay for listing on both registers should be considered. It is suggested that in the next review of fees consideration should be given to a discount to those registrants who are on more than one register as this could present as a barrier to progression of the profession.
   
   A view that is repeatedly expressed is the relative unfairness of a single registration fee, regardless of grade or level of remuneration of the registrants or the risk posed to the public. The reduced fee for new registrants is welcomed but many remain in a low employment grade and do not progress to roles that carry a higher rate of remuneration. It has also not gone unnoticed that although biomedical scientists comprise one of the largest registrant groups, they represent one of the lowest number of fitness to practice cases. While this is not relevant to this current consultation it is a matter that deserves consideration for the future as FTP hearings accounts for the single largest costs to the HCPC. It would be administratively more complicated, we accept, but would demonstrate a better appreciation of fairness.

3. In addition to the equality impacts set out in the Equality Impact Assessment, can you identify any further impacts relating to protected characteristics that we should consider?
   
   Protected characteristics consist of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, ethnicity, religion or belief, sex, sexual orientation.
   
   If you would like to make any suggestions about how any negative equality impacts you have identified could be mitigated, you may do so here.
   
   
   The IBMS has no further comments to make