Department of Health and Social Care’s consultation on Regulating healthcare professionals

Yes, we agree. It will allow a more consistent and joined up approach covering workforce, employment, education and training, and health and care services provision.

In the eye health and care sector, multi-professional team working is becoming increasingly important as optometrists, dispensing opticians, ophthalmologists, orthoptists and ophthalmic nurses work more closely together to meet national eye health needs across primary and secondary care where issues raised may affect more than one regulator. A duty on regulators to co-operate with these organisations would improve the planning, provision and commissioning of services in the best interest of patients.

Yes, we agree. We would welcome more transparency in the regulators’ governance and processes when carrying out their functions and making decisions. Due to the complexity of some processes, it is important to ensure decisions are being made with the right level of independence, fairness and impartiality, and to ensure appropriate professional knowledge is utilised in the process so that sector specific needs and differences are taken into account.

Yes, we agree but we would welcome more details on how this assessment would be made: would that be through independent review or public consultation? As already mentioned in our response to question two above, more transparency when assessing the impact of proposed changes would ensure decisions are being made with the right level of independence, fairness and impartiality, and ensure appropriate professional knowledge informs the process so that sector specific needs and differences are taken into account.

We disagree with this proposal. It is not clear why two tier structures cannot support effective accountability on the grounds that it is the Councils which make decisions but the Executives which carry out work. The Council should set direction, in discussion with the Executive, and then hold the Executive to account for delivery. Parliament, or any oversight arrangements that are in place, should then hold the Councils to account for strategy, for the plans they have endorsed and how effectively they have held their Executives to account.

In addition, we disagree with the proposal to remove the requirement to appoint professional and lay members. The regulators’ ruling bodies must continue to include sufficient people with deep first-hand experience of the regulated professions. It is vital therefore in our view that any new system ensures regular and sufficient input from the professions regulated at all points. This input should reflect the skills, experiences and insights which the regulated professions can bring to the work of their regulators, which is very different to self-regulation.  It is also key that they appoint lay members, who represent the public and patients who are the ultimate benefactors of the regulators’ roles.

Yes, we agree that regulators should be able to set their own fees. These should be reflective of the costs involved in providing their regulatory function and the risk posed to the public by each profession, as they have the expertise to determine this value. Currently some regulatory bodies already set their fees without Parliamentary oversight.

Yes, we agree with this proposal, as it will help registrants better understand what they can expect.

The COVID-19 pandemic has heavily affected our sector and has shown why we must prepare better for an uncertain future.

Yes, we agree as this will allow each regulator enough flexibility to fulfil their functions and duties, and to adapt to the needs and specificities of each profession they are regulating.

Yes, we agree, but with caveats. Our view is that regulators should be appropriately resourced to carry out all their functions, including supporting professionalism, but the cost of regulation to optical registrants should be a fair reflection of the resources needed to regulate them effectively.

Since registrants fund the regulators, any potential savings should be passed back to registrants in the form of reduced fees.

In addition, any charges for services should be in line with the provider policy levels.

We disagree with this proposal. Regulators should not be able to delegate the following functions to other regulators.

• the holding of a register;
• determining standards of education and training for registration;
• providing advice about standards of conduct and performance; and
• administering procedures relating to misconduct and fitness to practise.

As mentioned in our responses to questions 2, 3, 4 and 6, the optical sector is structured differently from many other health and care professions. The regulators’ ruling bodies must continue to include sufficient people with deep first-hand experience of the regulated professions. It is vital therefore in our view that any new system ensures regular and sufficient input from the professions regulated at all points. This input should reflect the skills, experiences and insights which the regulated professions can bring to the work of their regulators, and this will not be possible if these functions are delegated to a third party or another regulator.

Yes, we agree, but with caveats. Data sharing can indeed be very useful but such requests should be proportionate to the need of fulfilling the regulators’ statutory objectives and functions. 

However, organisations required to share data should have the right to not disclose information, for example if there are data protection or confidentiality issues, and this should be added to the proposal.

Yes, we agree. Given the devolved nature of healthcare in the UK, it makes sense for the regulators to be more accountable to all the relevant governments. Sharing this responsibility across the devolved administrations would provide a useful expansion of public scrutiny capacity.

Yes, we agree that the Privy Council’s default powers should apply equally to all regulators to ensure consistency in the mechanism for protecting the public in circumstances where the regulator has failed to carry out its statutory functions. 

• standards for the outcomes of education and training which leads to registration or annotation of the register for individual learners;
• standards for providers who deliver courses or programmes of training which lead to registration;
• standards for specific courses or programmes of training which lead to registration;
• additional standards for providers who deliver post-registration courses of programmes of training which lead to annotation of the register; and
• additional standards for specific courses or programmes of training which lead to annotation of the register?

Please give a reason for your answer.

It is important for Regulators to have powers to set the standards for registration, in the form of outcomes of education and training, both for initial registration and for annotation on the register. 

However, the level of authority over the means by which those standards are met should be restricted to those aspects that are directly relevant to ensuring the registrant has been assessed with due rigour and fairness and will make a safe and effective practitioner, and that all potential registrants are provided with appropriate opportunities to meet those standards.  Responsibility for admissions, learning experience and resourcing should remain with the provider except where there is evidence of impact on the standard and equality of opportunity to achieve the outcomes.

All regulators should have the power to approve, refuse, re-approve and withdraw approval of education and training providers, qualifications, courses or programmes of training which lead to registration or annotation of the register? Please give a reason for your answer.

Within the boundaries of the answer to 13, it is implicit that approval be coupled with the capacity to withdraw approval.  However, the evidence bases for approval and withdrawal of approval must be a matter of record for accountability reasons, and should be subject to appeal processes.

It is essential that these functions are coupled to the powers discussed in 14 to support and ensure rectification of serious but not dangerous shortcomings. The regulators should also be required to commend providers and disseminate good practice where it is identified, to underpin future developments in education of the regulated professions.

The proposed “observation” process is insufficient to ensure that appropriate evidence is considered by the regulator, unless the regulator is required to respond to the additional evidence provided in a transparent fashion.

• education and training providers should have the right to appeal approval decisions;
• that this appeal right should not apply when conditions are attached to an approval;
• that regulators should be required to set out the grounds for appeals and appeals processes in rules?

Please provide a reason for your answer.

The reputational damage to the provider consequent on withdrawal of approval before appeal is allowed would be very significant. Appeal processes should also apply to conditions, as well as inaccuracies in reporting, to allow resolution before public confidence is damaged by threat of withdrawal of approval. Process and grounds for appeal should be clear, transparent and proportionate.

If powers are to change for any regulator, it is appropriate to allow a significant transition period in which to phase out or bring in additional powers. This should not be indefinite, unless there are clear differences in the sphere of practice that render consistency impossible. If the goal is consistency amongst regulators, retention of differential powers would therefore need a proper justification.

The power to set and administer assessments for entry onto the register should be separated in body from the oversight and maintenance of the standards being assessed. More widespread internalisation of assessment processes may undermine confidence in accountability activities of the regulators.

The regulators should not have the power to set the assessments that providers use to determine admission to the register. The regulators should set the standards, not the means by which they are met.

Variety of methods of assessment is appropriate in recognition of the diversity of activities and modes of learning underpinning the regulated profession. However, regulators should provide evidence based justification for the selection of the method(s) and evidence to be used in making judgement, and these should be clear, transparent and proportionate.

The case for removal of the duty to award CCTs is well argued and appropriate.

Maintenance of this function is appropriate, and necessary to ensure continued current safe and effective practice. All regulators should be required to have clarity in requirements and process for documenting and regular validation of CPD activities.

We agree with this proposal, but with caveats. This single register should not only be divided into parts for each profession but should also include parts for other aspects of each profession. As rightly mentioned in the document, the General Optical Council (GOC) holds an additional register for body corporates. This should be maintained and included in a single register.

Furthermore, the document points out that the GOC) regulates body corporates. This is only half true; GOC registration is voluntary for optical businesses unless they are using a protected professional title in their name. We consider that it is sensible that the GOC continues to regulate businesses in a proportionate and robust way, which balances the important duties of individual registrants and the duty of businesses to support their registrants. Indeed, we would suggest that, as part of any reforming legislation, the General Optical Council were given powers to regulate all optical businesses that carry out restricted functions.

• Name
• Profession
• Qualification (this will only be published if the regulator holds this information. For historical reasons not all regulators hold this information about all of their registrants)
• Registration number or personal identification number (PIN)
• Registration status (any measures in relation to fitness to practise on a registrant’s registration should be published in accordance with the rules/policy made by a regulator)
• Registration history

Please provide a reason for your answer.

We partly agree with this proposal. We do not see how the publication of the registration history will help protect the public and patients, who may only need to know if a practitioner is currently registered or not.

We agree with this proposal. The collection of this information is usually already requested when all registrants have to renew their registration each year or in the context of a Fitness to Practise (FtP) or equivalent procedure.

However, we would disagree with this proposal if the collection of data is unrelated to the registration process or FtP process, as we do not see how this would improve the safety of the public.

We would recommend adding more clarity on why and when regulators should collect and process data and what the data would include.

We disagree with this proposal. The publication of specific data about registrants should be limited to what is required to register or stay registered, and only if this is in the public protection interest, in which case we would recommend adding a limited and agreed list of specific data to be included on the register.

We agree with this proposal, but with caveats. Annotations should be limited to indicate where registrants hold specialist qualifications and regulators should only be able to charge a fee for making annotations at the registrant’s request.

The proposal states that annotation could also reflect a decision to restrict a registrant’s scope of practice or registration which is unlikely to be at the registrant’s request, so it seems unfair to charge a fee in these cases. We would recommend clarifying this point and allow regulators to charge a fee only when annotations are at the registrant’s request.

We partly agree with this proposal. This emergency power should not go beyond registration. Regulators should be given emergency power to remove any unnecessary regulatory barriers that may prevent registrants to deliver effective care during an emergency situation. During the COVID-19 situation, registrants have had to vary their practice for extended periods of time and in challenging circumstances by providing more care remotely. Emergency power should enable registrants to continue to provide safe and effective care as soon as an emergency starts.

This emergency power should also cover training and education to allow education providers to adapt to the emergency and understand the changes needed in education delivery, and what the changes regulators are making to quality assurance activities of regulator-approved education during an emergency.

Finally, it may be helpful to include the possibility for regulators to allow registrants to work in different settings, outside their usual scope of practice. For example, during the COVID-19 emergency, the NHS invited optometrists, dispensing opticians or students to support the wider COVID-19 response by using their professional skills and experience in different settings, back-filling other roles in the health and care sector to fill workforce gaps. This could include clinical roles outside of eye healthcare (e.g. in a pharmacy or in a hospital, such as monitoring blood pressure); or non-clinical roles (e.g. carrying out non-clinical tasks, such as porter duties or delivering food or medicines).

We disagree with this proposal. We strongly recommend maintaining the protection of function alongside the protection of title, in the best interest of patients’ safety.

Furthermore, it is not clear how the protection of functions currently described by the Opticians Act would be applied and regulated. This currently includes areas such as the required components of a sight test, ability to supervise or delegate certain functions as part of a sight test or contact lens fitting, the supply of spectacles and the supply and verification of contact lenses. The regulated nature of these functions serve to protect the public and form the basis of how clinicians and providers deliver eye care and supply optical appliances. Moving away from the protection of these functions would have a negative impact on patient’s safety. This would be in contradiction with the overall objective of these proposed regulatory changes, which is to improve patient’s safety.

(these are offences where an intent to commit the offence does not have to be proven or demonstrated)

We think that some offences should be non-intent offences. Whether it is intended or not, such offenses not only pose a risk to patient’s safety, but also would have a damaging impact on a whole profession and affect the trust and confidence of the public and patients towards health and care professionals.

We agree with this proposal, as it will ensure a continuity of the statutory duties of regulators.

However, we would recommend adding a requirement when regulators appoint a deputy registrar and/or assistant registrar to ensure a consistency of positions when decisions are made. It would seem unfair for registrants to potentially receive a different decision whether this decision is being taken by the registrar or the deputy registrar/assistant registrar. Consistency of opinions and decisions should be maintained, and supported by transparent and robust governance mechanisms.

We agree in principle. Regulators are the experts and gatekeepers to each regulated profession, and are therefore best placed to set out their detailed requirements for registration. However, we would recommend adding a requirement for regulators to consult with the relevant stakeholders before making any significant change to their registration processes and to give enough notice before implementing any potential changes to allow all relevant stakeholders to adapt to the new processes.

Applicants should only be turned down because they have failed to meet the new criteria for registration for consistency and equality of access to the register. As mentioned above, regulators are the experts and gatekeepers to each regulated profession, and are therefore best placed to set out their detailed requirements for registration from the outset. Giving a discretion to turn down an applicant for registration may have a negative impact on the regulator’s capacity to assess an application through a solid process and may therefore have a negative impact on the public’s trust towards the whole profession.

The licence to practise should be removed from primary legislation and that any requirements to hold a licence to practise and the procedure for granting or refusing a licence to practise should instead be set out in rules and guidance.

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We agree with this proposal. Although it is important to ensure that registrants comply with their administrative duties, failure to do so may sometimes go beyond the direct control of registrants for various reasons. A suspension from the register seems proportionate and gives a chance to registrants acting with honesty and integrity to comply with their administrative duties, without creating unnecessary stress. It would also limit the number of restoration procedures, costing more time and money for both the registrant and the regulator.

We agree in principle. We would recommend that these processes should be clear, that any changes to these rules should be consulted on, communicated and implemented with enough notice. As a minimum, these processes should include the right to appeal any decision to remove a registrant from the register for one of the reasons listed in the document.

We disagree with this proposal as it adds an unfair disadvantage for the registrant. This document recommends that the regulators should be able to set out their removal and suspension processes to the register in rules; the right to appeal decisions affecting registrants’ registration should be part of these processes and therefore should also be set out in rules and not in legislation.

We partly agree with the proposal that regulators should set out their registration appeals procedures in rules, as mentioned in our response to question 38 above. However, we are of the opinion that all decisions, including those listed in paragraph 216, should be subject to appeal. A decision to suspend or remove a registrant from the register should only be definitive after a registrant has had the opportunity to explain why they failed to comply with their duties and how they plan to comply with these again.

We agree with this proposal. In the eye care sector, student optometrists are working with patients and the public throughout their course of study, under the supervision of a registered optometrist or registered medical practitioner who will be accountable. The patient will continue to be protected as all patient episodes will be under the supervision of a registered professional.

We partly disagree with this proposal. The purpose of registration is to provide assurance that professionals are safe to practise. However, we would not suggest removing this discretionary power, but instead the power to establish non-practising registers should be part of the permanent emergency registration power as set out in paragraphs 165-169.

We agree with this proposal. It is consistent with the proposal allowing regulators to set out their registration processes in rules and guidance.

1. initial assessment
2. case examiner stage
3. fitness to practise panel stage?

 Please give a reason for your answer.

Yes, we agree with this proposal. Regulators should be able to resolve fitness to practise concerns in a way that is fair to all parties, proportionate and as swift as possible. Furthermore, this three-step fitness to practise process would lead to fewer cases proceeding to full hearings, saving time and money for all parties.

• All regulators should be provided with two grounds for action – lack of competence, and misconduct?

We agree with this proposal. We agree that the grounds for action should be consistent across all regulators in order to clarify to the public, registrants and the regulators the circumstances in which action can be taken. However, we would suggest adding a clear definition for each ground for action or a list of examples of what each ground for action would cover. Indeed, “misconduct” could cover very different situations ranging from a single and minor incident with no aggravating features and no ongoing risk to patient safety, to public confidence in the profession, and to a registrant failing to comply with a professional standard, or is subject to a criminal conviction.

• Lack of competence and misconduct are the most appropriate terminology for these grounds for action?

We do not agree nor disagree. Any terminology would be deemed appropriate as long as it is clear enough for the public and registrants to understand what each terminology would cover. However, it would be helpful to have consistency in terms used across the regulators.

• Any separate grounds for action relating to health and English language should be removed from the legislation, and concerns of this kind investigated under the ground of lack of competence?

We partly agree with this proposal. Removing separate grounds will add consistency across all regulators in order to clarify to the public, registrants and the regulators the circumstances in which action can be taken. However, concerns related to health cannot be considered as a lack of competence, although registrants must declare any physical and mental health conditions when registering. As mentioned in our response above, the terminology should be clear enough for the public and registrants to understand what it covers. In this case, we would suggest adding a term related to the inability to practice due to health reasons, as separate terms will best indicate whether the grounds relate to lack of competences (including English language), or health considerations.

• This proposal provides sufficient scope for regulators to investigate concerns about registrants and ensure public protection?

We partly agree. This proposal would indeed provide sufficient scope for regulators to investigate concerns about registrants and ensure public protection, but as mentioned in our response above, this proposal may not provide sufficient clarity to the public as to when and on which ground a complaint could be raised.

• all measures (warnings, conditions, suspension orders and removal orders) should be made available to both Case Examiners and Fitness to Practise panels;

We agree, with caveats. While we agree that making all these measures available to both Case Examiners and Fitness to Practise has the potential to make the throughput of complaints faster and more efficient, we would welcome more information on the roles of Case Examiners and Fitness to Practise panel members and how decisions would be made. For example, we believe that it is important that clinical complaints should be considered by a Case Examiner with the same title as that of the registrant. A complaint concerning an optometrist should be considered by a registered optometrist, a complaint concerning a dispensing optician or contact lens optician by a registered dispensing optician or contact lens optician and a complaint concerning an enrolled body corporate by a professional with relevant and senior-level experience in body corporate management. This would be the appropriate way to proceed both in terms of efficiency and fairness to the registrant.

• automatic removal orders should be made available to a regulator following conviction for a listed offence?

Whilst we agree in general terms that such a power is appropriate, we consider that a distinction should be drawn between immediate and suspended custodial sentences. Automatic removal orders are appropriate when a registrant has received an immediate custodial sentence; however, we are less certain that this is an appropriate decision in terms of a suspended custodial sentence. A suspended custodial sentence for a registrant may be the result of significant mitigating circumstances, which should be appropriately considered during the regulator’s investigation. Regulators should have the power to invoke an Interim Order if considered necessary in such circumstances.

We agree with this proposal, as this would best protect patients. If additional information was to become known, that would raise a more serious issue; regulators should then be able to review their decision and measures, and put in place stronger measures.

Yes, we agree with this proposal. Regulators must be more transparent about how they conduct Fitness to Practise processes if trust in their ability to protect the public is to be maintained. This would also be the appropriate way to proceed both in terms of efficiency and fairness to the registrant.

In addition, we recommend that notifications to registrants be made in a reasonable time allowing them to properly respond, to be represented and to make a written submission. This would ensure a fair and proportionate process for all parties.

We disagree with this proposal. This discretionary power is not consistent with paragraph 247 “Cases that do not meet the criteria for onward referral in the fitness to practise process will be closed at this [Initial Assessment] stage”. Having a clear list of criteria to decide whether to investigate or not will increase the trust and confidence of the fitness to practise process by the public, employers and registrants. This would also ensure a fair and proportionate process for all parties.

We agree with this proposal. If regulators have delays in investigating and completing fitness to practise cases, then a case could go beyond 5 years and regulators would need to be in a position to complete their investigation. This 5 year restriction should be removed, and older cases looked into when they come to light, as the practitioner may still be providing poor quality or unsafe care to patients.

However, this should not be an incentive for regulators to take longer in investigating and completing fitness to practise cases.

We understand the need to have a separate power to ensure that regulators are not impeded from assessing fitness to practise, but any such power should only be used as a last resort. Regulators should first assess whether this non-compliance by registrants is intentional, through appropriate communication channels. We are of the opinion that addressing non-compliance should be a key aim of the initial assessment stage.

We agree with this proposal, with caveats. Regulators should give enough notice to registrants when amending the grounds for action and provide enough time to registrants to make written submissions. These should be explicitly set out in the rules.

(in line with the powers set out in the Social Workers Regulations)

We agree with this proposal, with caveats. We agree that regulators should be able to automatically remove a registrant from the Register, if they have been convicted of a listed offence, in the interest of public’s safety and the reputation of the whole profession. However, this power should only be enacted when the conviction is definitive and not subject to appeal. We would recommend a suspension from the Register until the final confirmation of the conviction, as mentioned in our response to question 45 above.

• have the full suite of measures available to them, including removal from the register?

Yes, we agree as the accepted outcome process would be less adversarial, and would enable cases to be concluded more quickly. It would also reduce the burden on those who would have been required to attend a hearing - including the registrant, the person(s) who raised the concern, and other witnesses and experts.

• make final decisions on impairment if they have sufficient written evidence and the registrant has had the opportunity to make representations?

Yes, we agree. See our response above.

• be able to conclude such a case through an accepted outcome, where the registrant must accept both the finding of impairment and the proposed measure?

Yes, we agree. See our response above.

• be able to impose a decision if a registrant does not respond to an accepted outcomes proposal within 28 days?

We agree, with caveats. Regulators should first ensure that a registrant’s failure to respond to accepted outcomes is intentional only, for example by requesting an acknowledgment of the receipt of the decision by the registrant.

We agree, with caveats:

• Regulators should assess the effect which any interim measures might have on the registrant to ensure that the consequences are not disproportionate to the risk to the public.
• The primary purpose of an interim order should be to protect the public from a demonstrable present or likely future risk, and not only on the ground that it is in the public interest (for example, to maintain public confidence in the profession).

We recommend adding these two requirements to the proposal.

We agree with this proposal, as long as key principles ensuring a fair, transparent and equitable process for all parties are set out in the legislation.

We agree with this proposal. It is vital for a registrant to have the right of appeal to ensure, as far as possible, that a case examiner, Fitness to Practise panel or Interim Measures panel have arrived at an appropriate decision and have not made an error of law or fact.

We agree with this proposal. In this way, the registrant is able to have the decision reviewed by another independent body. This right of appeal will enable errors to be corrected and will maintain and enhance the confidence of the public and registrants in the Fitness to Practise process.

Yes, we agree. This is consistent with the proposal that regulators should be able to set out their registration processes in rules and guidance. However, as mentioned in our response to question 33 above, regulators should be required to consult with the relevant stakeholders before making any significant change to their registration (including restoration to the register) processes and to give enough notice before implementing any potential changes to allow all relevant stakeholders to adapt to the new processes.

Yes, we agree with this proposal. As mentioned in our response to question 37 above, these processes should include the right to appeal any decision to remove a registrant from the register. Therefore, it seems fair and logical to include also a right of appeal against a decision not to permit restoration to the register.

As mentioned in our response to question 57 above, we agree with this proposal as it will give the registrant a fair and equitable opportunity to have a decision reviewed by another independent body. This right of appeal will enable errors to be corrected and will maintain and enhance the confidence of the public and registrants in Fitness to Practise processes.

We disagree with the proposal. This review mechanism is the equivalent of a right to appeal and should therefore follow the same fair and impartial process as the right of appeal conferred to the registrant.

"Under our proposals, the PSA will not have a right to refer decisions made by case examiners (including accepted outcome decisions) to court, but they will have the right to request a registrar review as detailed above."

We disagree with this proposal. As mentioned in our response to questions 56, 57, 59, 60 and 61 above, any review of any decision, including by a third party as the PSA, should be treated as an appeal and should therefore follow the same fair and impartial process as the right of appeal conferred to the registrant in paragraphs 217, 319 and 350.Q63. Do you have any further comments on our proposed model for fitness to practise?

We would recommend regulators to be required to consult with all relevant stakeholders when developing their fitness to practise processes in rules, and in any case before these processes have been finalised and approved by regulators.

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We agree with the following benefits:

More efficient governance

Greater transparency of processes

Greater autonomy to amend own procedures

Opportunity for more economic use of resources e.g. moving away from focusing on Fitness to Practise and moving towards preventative regulation.

We disagree with the following benefits:

Improved patient safety: Delays in completing a Fitness to Practise process may put patients at risk. The suggested revision to the Fitness to Practise process could lengthen this process (as it includes three stages, with right of appeals and various reviews at each stage). If we can reduce delays, that would improve patient safety.

Faster resolution of concerns: While we mainly agree with the new process suggested, the revisions to the Fitness to Practise process could lengthen the process (as it includes three stages, with right of appeals and various reviews at each stage). This may improve process and transparency, and speed up some cases, but may not speed up resolution of cases that have to progress through all stages.

Improved cooperation between regulators: Consistency of governance and processes between regulators will not automatically lead to improved cooperation between them.  We would like to see more detail on how this could be achieved.

Lower central administrative costs of maintaining the legislation: This reform may lead to lower central administrative costs but it will lead to an increase administrative costs for the regulators as more responsibilities - and therefore costs - are transferred to them. We are concerned as this may lead to an increase of registrants’ fees.

We do not know about the impact of following suggested benefits:

Registrants better supported through improved standards/CPD: as mentioned in our response to question 23 above, while regulators should continue to be able to set out in their CPD and revalidation requirements to ensure continued current safe and effective practice, all regulators should provide clarity of requirements and process for documenting and regular validation of CPD activities. In addition, it is not clear if this reform will be aligned with the current GOC Education Strategic Review.

Improved public perception of regulated professionals: public perception depends on how regulators communicate and their ultimate decisions, rather than how they work.

Cost savings from ability to be more flexible in functions e.g. registration, fitness to practise: No evidence that giving more flexibility will save costs.

We partly disagree with the transitional costs involved in implementing changes. As mentioned in our response to question 68 above, lower central administrative costs will lead to an increase of administrative costs for the regulators as more responsibilities - and therefore costs - are transferred to them. We are concerned as this may lead to a permanent increase of registrants’ fees, and not only for transitional costs.

 We do not have the necessary data to inform a view.