IBMS response to HCPC registration fees consultation

To what extent do you agree or disagree that the rationale for our proposed fee increase is clear?

The Institute of Biomedical Science (IBMS) is the professional body for biomedical scientists and as such is well informed of the profound changes that have taken place within the profession in respect of service reconfigurations, efficiency savings and workforce reviews. While the IBMS recognises the business position of the HCPC, and the need for it to cover its running costs, the justifications and rationale for the proposed increases in fees is not perceived by our members as justifiable. The feedback we have received is that there has been no significant tangible benefit to the professions themselves.

Given the rationale set out, to what extent do you support the fee increase proposals?

It is recognised that a regular review of income takes place and increases in fees applied, when necessary, to meet increasing demands upon services. This is justified given that registrant fees are the only source of HCPC income. Notwithstanding this the IBMS has a significant level of discomfort that the unintended, or unforeseen, consequences of the proposed fee increases do not appear to have been modelled and would like to better understand the ‘prevention strategy’ to justify the proposed level of increase. In view of this the IBMS would favour a risk based approach to any resulting increase in fees rather than the application of an across the board increase. It is the view of the IBMS that this consultation should have provided an options appraisal and justification for the preferred model.

The IBMS wholly supports the need for protection of the public that all registrants serve, and while recognising the absolute need for the HCPC to raise sufficient income to cover running costs and to allow for a small reserve to be retained, we have difficulty in supporting a registrant fee increase of the magnitude proposed. It is accepted that fees cannot be maintained at the same level indefinitely as there comes a time when an increase is necessary, and that increase is likely to be larger than if there had been small but regular increases. In view of this an increase is supported but not at the proposed level.

Whilst fees have not significantly increased since 2015 (the delayed and reduced 2020 increase is recognised as an acknowledgement of the difficulties that were experienced by registrants during the pandemic) this proposal is for a 19% increase, which is significantly greater than inflation (by any of the current measures) and appears to use the reduction of financial reserves to support running costs as its justification.

The comparison with other regulators’ fees is not a helpful or relevant indicator as they are not like-for-like models. The HCPC is one of the largest regulators, which regulates the largest number of professions. Furthermore, this is not a competitive market as registrants cannot choose or change regulator based on cost. The medical profession has significantly greater risk to the public and the registrants have greater earning potential. Most of the HCPC registrants are in significantly lower paid posts than the medical profession and the proposed increase would have a disproportionate impact on lower banded staffs that form the greatest proportion of the workforce. It is felt that there needs to be more emphasis on cost reduction rather than income generation and feedback from our members requests greater transparency of the use of fees.

With respect to the scrutiny fee increases, it is felt that this is a significant increase although as it is a ‘one off’ payment it is an increase that can be supported.

With respect to restoration and readmission fees, this again represents a substantial increase although as it is a ‘one off’ payment it is an increase that can be supported. However, the IBMS recommend that the readmission fee is waivered for 3 months as 1 month is very short for genuine oversight.

To what extent do you agree or disagree that we should retain the 50% UK graduate discount for the first two years of registration?

Most new applicants are new graduates, many of whom will have student loans and will be employed on the lowest salary bands.

From the biomedical scientist perspective, a significant number of these graduates will not have had the practical training required to complete their Registration Training Portfolio, requiring them to work in a trainee position for up to 2 years before being eligible to apply for registration. The removal of the 50% discount would place an additional burden on registrants in the early years of their career and could contribute to the high attrition rate. Our view is that the 50% reduction should be retained.

In the consultation we set out two areas we would like to explore to mitigate the impact of the proposed fee rise. Please let us know the extent to which you support these. Please also tell us about any other mitigations you think we should explore’

a. Increasing our promotion of tax relief

This is a welcome suggestion although clear guidance on how this can be claimed will be required

b. Increasing the spread of direct debit payments

This is a welcome suggestion

c. Additional mitigations

Have I.T systems been reviewed recently with the purpose of improving processes and services and in the process, identifying savings that can be made through greater efficiencies and reduction in some costs? We are aware that the life expectancy of I.T systems is relatively short as new technologies and packages appear on the market; any proposals for new I.T should be accompanied with planned efficiency targets.

In the consultation we set out additional areas that we would like to prioritise, based on stakeholder feedback. Please let us know the extent to which you agree with these. Please also tell us about any other areas you think we should prioritise.

a.      Working with employers to secure better protected CPD time

There is widespread support for the HCPC to encourage employers to give some protected CPD time for registrants, and others have compared the HCPC registrants with other regulated professions whereby the employers pay the registration fees. However, there is a low level of confidence that employers would be receptive to the introduction of protected CPD time. Updates on efforts made regarding CPD time would be welcomed by registrants as evidence that their regulator is working on their behalf on this matter.

b.     Improving communications and engagement with registrants and stakeholders

From the perspective of the IBMS, as a professional body for one of the largest registrant groups and an HCPC approved education provider, we have recognised and appreciated the improved communications and significant investment in managing stakeholder relations that have already been made. We have found the HCPC to be both more supportive and more constructive in their manner of engagement. It takes time for perceptions to be altered in a positive manner so we would fully support the HCPC pursuing a strong communication strategy with its registrants.

c.      Developing further a compassionate approach to regulation

The IBMS supports the proposal for the HCPC to develop a more compassionate approach to regulation. The primary objective must always be the protection of the public, but the number of cases coming through to fitness to practice hearings remains high (more than 1,000 ftp concerns handled each year is a large and costly workload) and contributes significantly to the costs of regulation. As part of a more compassionate approach, we feel that there is potential for a model of partnership working with employers and professional bodies. With the exception of criminal activity, many “mistakes” are multi-factorial and a reflection of the system in which registrants operate, or where an employer has failed to implement human resources policies. However, should such a development be considered it would be essential that there is some form of audit to monitor effects if there is a consequential decrease in fitness to practice hearings. It is our view that it is a better strategy for a regulator to use remediation as the first approach to address issues with recourse to the hearing process seen as the last resort when intervention and remediation has failed.

In addition to those equality impacts set out in the consultation document, do you think there are any other positive or negative impacts on individuals or groups who share any of the protected characteristics

None of which we are aware.

Do you have any suggestions about how any negative equality impacts you have identified could be mitigated?

Not applicable in context of previous response.

Do you have any further comments to make about the proposals and information in the consultation?

1.      Dual registration

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. Perhaps this should have a 50% discount as it could present as a barrier to progression of the profession.

2.      Fees reflective of grade

The possibility of fees linked to grade or level of remuneration or linked to risk posed to the public is a matter that deserves consideration for the future. It would be administratively more complicated, we accept, but would demonstrate a better appreciation of fairness. Requiring a new registrant, who operates under a level of supervision and therefore is a reduced risk,  to pay the same as a very senior registrant with extensive autonomous practice, and therefore carrying a greater level of risk ,may be the simplest but not the fairest way to apply fees and manage fee increases.